Digests

The case involves the statutory construction of PD No. 1638, as amended by PD No. 1650, which governs the retirement system for military personnel. The controversy centers on the interaction between Section 3 (defining “active service” to include prior civilian government service) and Section 5(a) (setting compulsory retirement at age 56 or upon accumulation of 30 years of active service, whichever is later), and how the inclusion of civilian service affects the computation of benefits versus the determination of the retirement date.

Decisions of the Commission on Audit are reviewable by the SC only through a special civil action for certiorari under Rule 64 in relation to Rule 65, not via an appeal by certiorari under Rule 45; consequently, review is limited to errors of jurisdiction or grave abuse of discretion. Furthermore, under Presidential Decree No. 1638, as amended, when prior civilian government service is included in “active service” under Section 3 for computing retirement benefits, that same total active service must be used to determine the compulsory retirement date under Section 5(a), which may result in an earlier retirement date and potential overpayment of benefits.

Romeo G. Jalosjos was convicted by final judgment on November 16, 2001, of two counts of statutory rape and six counts of acts of lasciviousness under Republic Act No. 7610, for which he was sentenced to reclusion perpetua and reclusion temporal. These principal penalties carried the accessory penalty of perpetual absolute disqualification under Article 41 of the Revised Penal Code. On April 30, 2007, then-President Gloria Macapagal Arroyo commuted his prison term, and he was discharged from prison on March 18, 2009. In April 2012, Jalosjos applied for voter registration in Zamboanga City but was denied by the Election Registration Board due to his prior conviction. He nevertheless filed a …

The Commission on Elections may motu proprio cancel a certificate of candidacy without prior quasi-judicial proceedings when the ground therefor is a candidate's perpetual absolute disqualification based on a final judgment of conviction, as this constitutes an administrative function of enforcing election laws; and Section 40(a) of the Local Government Code is a general provision that does not supersede the specific penalty of perpetual absolute disqualification under the Revised Penal Code.

Ariel R. Marquez and Ireneo M. Verdillo were employed as dealers at the Casino Filipino Heritage operated by the Philippine Amusement and Gaming Corporation (PAGCOR). In the game of Craps, a "stickman" validates throws by ensuring at least one die hits the rubber wall at the table's end; invalid throws must be declared "no dice." On November 26, 2006, while Verdillo served as stickman and Marquez as pay-off dealer at Table No. 30, an Acting Pit Supervisor observed that Verdillo repeatedly declared throws by patron Johnny Cheng as "good dice" despite the dice failing to hit the rubber wall, with Marquez subsequently paying out winnings on these void transactions. An Internal Security Investi…

The designation of the offense in an administrative charge is not controlling; what matters is that the respondent is sufficiently informed of the nature and cause of the accusation through a clear statement of the acts complained of, and conspiracy to commit administrative offenses may be established by substantial circumstantial evidence showing a common design to defraud, even without direct proof of an explicit agreement.

In 1998, Darma Maslag filed a complaint for reconveyance of real property with declaration of nullity of an original certificate of title against Elizabeth Monzon, William Geston, and the Registry of Deeds of La Trinidad, Benguet before the Municipal Trial Court (MTC) of La Trinidad, Benguet. Maslag claimed that Monzon fraudulently included a portion of her property in Monzon's title despite Maslag's open, continuous, and exclusive possession since the 1940s.

The proper mode of appeal from an RTC decision depends on the jurisdiction actually exercised by the RTC: an ordinary appeal under Rule 41 applies when the RTC exercised original jurisdiction, while a petition for review under Rule 42 applies when the RTC exercised appellate jurisdiction. An RTC order declaring it has original jurisdiction when the law confers only appellate jurisdiction is void and produces no effect; parties cannot by agreement or estoppel confer jurisdiction where none exists.

Spouses Marcelino and Myra Collado operated an electronics and appliance repair shop annexed to their residence at No. 32 R. Hernandez St., Barangay San Joaquin, Pasig City. Police received information that the couple sold shabu and maintained their residence as a drug den where users, including out-of-school youth, congregated for drug sessions.

A warrantless arrest is lawful as in flagrante delicto when the arresting officer personally observes the overt act indicating the commission of a crime, such as a buy-bust operation where the accused sells dangerous drugs to a poseur-buyer; objections to the arrest are waived if not raised before arraignment or via motion to quash.

Non-compliance with the inventory and photographing requirements of Section 21 of RA 9165 does not invalidate the seizure or custody of dangerous drugs provided the integrity and evidentiary value of the seized items are properly preserved by the apprehending officer.

**Violation of Section 14 of RA 9165 (possession of drug paraphernalia) is malum proh…

LPG dealers associations reported to the National Bureau of Investigation (NBI) that certain entities were engaged in the unauthorized refilling, sale, and distribution of LPG cylinders bearing the registered trademarks of Petron Corporation (GASUL) and Pilipinas Shell Petroleum Corporation (SHELLANE). Acting on the complaint, the NBI conducted surveillance and a test-buy operation at the Republic Gas Corporation (REGASCO) refilling plant in Malabon. NBI operatives brought four empty branded cylinders and had them refilled by REGASCO employees alongside a regular customer’s purchase. Search warrants were subsequently issued, and a criminal complaint for trademark infringement and unfair com…

The unauthorized use of a container bearing a registered trademark in connection with the sale, distribution, or advertising of goods or services, which is likely to cause confusion, mistake, or deception among buyers, constitutes trademark infringement under Section 155 of the Intellectual Property Code (R.A. No. 8293), and giving one’s goods the general appearance of those of another manufacturer through the use of such containers amounts to unfair competition under Section 168. Corporate officers who knowingly and intentionally cause the corporation to commit these acts are individually liable for the crime and cannot shield themselves behind the corporate entity.

The case involves a dispute between Mitsubishi Motors Philippines Salaried Employees Union (MMPSEU) and Mitsubishi Motors Philippines Corporation (MMPC) regarding the interpretation of a Collective Bargaining Agreement (CBA) provision on dependents' group hospitalization insurance. Under the CBA, employees contributed ₱100 monthly via salary deduction, with the balance paid by the company, to fund hospitalization insurance for their dependents up to a maximum amount per confinement.

A CBA provision requiring direct payment to the hospital and doctor based on actual bills limits the employer's liability to actual hospitalization expenses incurred, excluding amounts already paid by other health insurance providers.

The petitioner, Lucille Domingo, was charged before the Municipal Trial Court in Cities (MTCC) of Davao City with violation of Batas Pambansa Bilang 22 for issuing a UCPB Check in the amount of ₱175,000.00 in favor of the respondent, Merlinda Colina, which was dishonored for the reason "ACCOUNT CLOSED." The case involved the interplay between the criminal and civil aspects of a single act, governed by the Revised Rules on Criminal Procedure, specifically Section 2, Rule 111, which addresses the extinction of the civil action when the penal action is extinguished.

The dismissal of a criminal action based on the prosecution's failure to prove the accused's guilt beyond reasonable doubt does not automatically extinguish the civil action based on delict, unless there is a categorical finding in a final judgment that the act or omission from which the civil liability may arise did not exist. The civil aspect survives such an acquittal and may be appealed separately, with the civil liability proven by mere preponderance of evidence.

The case arises from the common practice in the transportation industry of hiring employees through manpower agencies to avoid direct employer liability. The dispute centers on the termination of a bus conductor for alleged irregularities in the collection of fares, and the subsequent question of whether the bus company (operating as a sole proprietorship) or the manpower agency bears liability for the illegal dismissal.

In cases of illegal dismissal where the employer is a sole proprietorship, the owner is personally and directly liable for the payment of backwages and other monetary awards, since a sole proprietorship does not possess a juridical personality separate and distinct from its owner, who has unlimited personal liability for all the debts and obligations of the business.

Thirteen non-licensee teachers employed by St. Joseph Academy of Valenzuela (SJAV) faced dismissal after failing to secure professional teaching licenses required under Republic Act No. 7836, the Philippine Teachers Professionalization Act. These teachers, members of the St. Joseph Academy of Valenzuela Faculty Association-FUR Chapter-TUCP, had served SJAV for periods ranging from five to nine years with satisfactory performance records. The dispute escalated when the union filed a notice of strike alleging illegal termination and union busting, leading to voluntary arbitration before the Secretary of Labor and Employment.

Financial assistance equivalent to one-half month's pay for every year of service may be granted to legally dismissed employees as a measure of social justice and equity, provided the dismissal is not for serious misconduct, does not reflect on the employee's moral character, or involve moral turpitude, and the employee has rendered substantial years of satisfactory service.

Petitioner Jaime Gapayao owned agricultural landholdings and various business establishments in San Julian, Irosin, Sorsogon. From 1983 until his death on November 4, 1997, Jaime Fulo performed work for Gapayao as a farm laborer harvesting abaca and coconut, processing copra, and clearing weeds. Fulo also occasionally performed repairs and worked in Gapayao's bakery, grocery, hardware store, and piggery. Following Fulo's death from electrocution while doing repairs at Gapayao's residence, Gapayao provided financial assistance to Fulo's widow, Rosario, who executed an Affidavit of Desistance and entered into a Compromise Agreement wherein Gapayao expressly acknowledged Fulo as his "employee."

An employer-employee relationship exists where a farm worker continuously renders services for the employer's business over multiple seasons, and the employer exercises the right to control the worker's performance, either directly or through an overseer; such relationship is binding upon the employer who expressly admits it in a compromise agreement voluntarily executed with full knowledge of its implications.

The intestate estate of the late Don Filemon Y. Sotto included four real properties. Respondent Matilde S. Palicte, one of four declared heirs, redeemed the properties. In a first case decided by the Supreme Court in 1987, her redemption was upheld, and she was declared entitled to have title transferred to her name, subject to the other three heirs’ right to join the redemption within six months. Over the following decades, several other heirs or their successors brought separate actions to undo Palicte’s exclusive right: a civil case to annul a waiver of rights (decided adversely in 1998), an incident in the intestate proceeding wherein the heirs of Miguel Barcelona sought belatedly to be…

A lawyer who files multiple actions founded on the same essential facts and seeking substantially the same reliefs, after a final judgment on the merits, commits willful and deliberate forum shopping punishable by fine for direct contempt; the alleged “hypothetical admission” of facts by a defendant in a motion to dismiss for failure to state a cause of action does not constitute a binding admission for any purpose beyond resolving the motion and cannot be used to evade the preclusive effect of prior judgments.

The Monetary Board of the Bangko Sentral ng Pilipinas (BSP) prohibited the Rural Bank of Tuba (Benguet), Inc. (RBTI) from doing business, placed it under receivership, and designated the Philippine Deposit Insurance Corporation (PDIC) as receiver. After determining RBTI's insolvency, the Monetary Board directed PDIC to proceed with the liquidation of RBTI under Section 30 of the New Central Bank Act. PDIC accordingly filed a petition for assistance in the liquidation of RBTI before the Regional Trial Court (RTC) of La Trinidad, Benguet.

Section 52(C) of the Tax Code of 1997, requiring a certificate of tax clearance from the BIR before the SEC issues a Certificate of Dissolution, does not apply to banks ordered placed under liquidation by the Monetary Board under Section 30 of the New Central Bank Act.

This case involves the dismissal of janitorial and maintenance personnel (janitors, janitresses, and supervisors) of Philippine College of Criminology Inc. (PCCr), a non-stock educational institution. The employees were made to understand that they were employed by Metropolitan Building Maintenance Services, Inc. (MBMSI), a corporation providing janitorial services, despite working directly under the supervision of PCCr's Senior Vice President for Administration, who was also the President of MBMSI. The controversy arose when PCCr discovered that MBMSI's Certificate of Incorporation had been revoked as early as July 2, 2003, prompting PCCr to terminate its contractual relationship with MBMS…

A labor-only contractor is solidarily liable with the principal employer for the rightful claims of the employees under Article 106 of the Labor Code; consequently, a valid release, waiver, or quitclaim executed in favor of the labor-only contractor extinguishes the solidary obligation of the principal employer pursuant to Article 1217 of the Civil Code. Furthermore, a corporation whose charter has been revoked may validly enter into agreements to settle its affairs and liabilities beyond the three-year winding up period under Section 122 of the Corporation Code, as the corporation continues as a body corporate for liquidation purposes, and Section 145 preserves all rights and remedies notw…

Respondent Evelyn A. Monilla served as Court Stenographer III at the Regional Trial Court (RTC), Branch 4 of Legazpi City. Complainant Leticia A. Arienda, a neighbor and relative of Monilla, sought respondent's assistance in settling the estate of her deceased mother, which involved partitioning several lots located in Bigaa, Legazpi City. Monilla's husband, Atty. Zaldy Monilla, was employed at the Department of Agrarian Reform, while her brother, Engineer Matias A. Arquero, was a geodetic engineer who conducted surveys of the properties.

A court employee who is not a lawyer but prepares and finalizes an extrajudicial settlement of estate—a document requiring legal knowledge and skill—and receives compensation therefor, commits simple misconduct punishable under Section 52(B)(2) of the Revised Uniform Rules on Administrative Cases in the Civil Service.

Christian Caballo, a 23-year-old dancer, met 17-year-old AAA (the victim) in Surigao City where AAA's uncle served as a choreographer and Caballo was one of his dancers. They became sweethearts after Caballo visited AAA in Cebu City during the Sinulog Festival in January 1998. Between March and November 1998, Caballo engaged in multiple sexual acts with AAA, resulting in her pregnancy in June 1998 and the birth of their child in March 1999. Caballo had assured AAA she would not become pregnant due to the "withdrawal method" and promised marriage to induce her consent. When confronted by AAA's mother, Caballo initially promised to marry AAA but later rejected her after her parents allegedly …

In cases involving violation of Section 5(b), Article III of RA 7610, consent is immaterial and the "sweetheart defense" is unacceptable; a child is deemed subjected to other sexual abuse when induced to engage in sexual intercourse due to the "coercion or influence" of an adult, which includes persuasion, inducement, and enticement through promises and assurances that overcome the child's free will by improperly using power or trust to deprive the child of rational choice.

On July 23, 2004, appellant Ibañez visited Weapons System Corporation (WSC), inquiring about the firing range schedule, gun club membership fees, days with many patrons, and whether Henessy Auron was the only female employee. Three days later, WSC was robbed of 53 firearms and ammunition valued at approximately ₱1.48 million. WSC gunsmith Rex Dorimon was found dead inside the firing range with multiple gunshot wounds from a .45 pistol. Another employee, Zaldy Gabao, was found handcuffed to the company vault. Days after the robbery, the NBI conducted entrapment operations that led to the arrest of Cachuela and Ibañez, who were caught separately attempting to sell firearms reported stolen fro…

Conviction for robbery with homicide may rest solely on circumstantial evidence if the established circumstances constitute an unbroken chain leading to a fair and reasonable conclusion that the accused committed the crime to the exclusion of all others, provided there is more than one circumstance, the facts from which the inferences are derived are established, and the combination of all circumstances unavoidably leads to a finding of guilt beyond reasonable doubt. An extrajudicial confession made without the assistance of competent and independent counsel is inadmissible, as is an out-of-court identification where the procedure's suggestiveness cannot be evaluated. The disputable pre…

FEGDI is a stock corporation primarily engaged in golf course development, while FELI is a stock corporation engaged in real estate development. FEGDI developed Forest Hills Golf and Country Club and, in consideration for its financing support and construction efforts, was issued several shares of stock of Forest Hills. The transfer of shares of stock in the Philippines is governed by Section 63 of the Corporation Code, which requires delivery of the stock certificate indorsed by the owner for a valid transfer, and by Article 1191 of the Civil Code, which governs the rescission of obligations for breach of contract.

Physical delivery of a stock certificate is an essential requisite for the transfer of ownership of shares of stock, and the seller's prolonged failure to deliver it constitutes a substantial breach warranting rescission of the sale under Article 1191 of the Civil Code.

The appellants were charged with illegal recruitment in large scale under Republic Act No. 8042, the Migrant Workers and Overseas Filipinos Act of 1995, for recruiting and promising employment abroad to seven named private complainants without the required license and authority from the Department of Labor and Employment. The offense was alleged to have been committed by a syndicate or in large scale, as it was carried out by more than three persons acting in conspiracy and against more than three victims. The case involved a scheme wherein complainants were promised employment in London, United Kingdom as caregivers and general services workers, but were instead sent to Thailand and Malays…

Illegal recruitment in large scale is committed upon concurrence of three elements: (1) the offenders undertake any activity within the meaning of recruitment and placement defined in Article 13(b) or any prohibited practices enumerated in Article 34 of the Labor Code; (2) the offenders have no valid license or authority required by law to enable them to lawfully engage in the recruitment and placement of workers; and (3) the offenders commit the acts against three or more persons, individually or as a group. The prosecution's evidence satisfied all three elements, and conspiracy was properly inferred from the mode and manner in which the offense was perpetrated.

Dr. Teresita Lee was a client of Atty. Amador L. Simando, who served as her retained counsel from November 2004 until January 8, 2008, with a monthly retainer fee of Three Thousand Pesos (Php3,000.00). Atty. Simando also represented Felicito M. Mejorado in a claim for informer's reward against the Bureau of Customs. The case is an administrative disciplinary proceeding arising from the respondent's conduct in facilitating a financial transaction between his two clients.

A lawyer is prohibited from representing conflicting interests, and this proscription applies even where the conflicting interests arise with respect to the same general matter, however slight the adverse interest may be, and even if the conflict pertains to the lawyer's private activity or performance of a function in a non-professional capacity. The test is whether the lawyer would be called upon to use against a former client any confidential information acquired through their connection or previous employment, and the termination of the attorney-client relationship does not justify representing an interest adverse to the former client.

The dispute originates from the status of land within the Fort Bonifacio military reservation. In 1957, President Carlos P. Garcia reserved the area for military use through Proclamation No. 423. Over the years, subsequent proclamations excluded certain portions for other purposes. In 1986, President Ferdinand E. Marcos issued Proclamation No. 2476, declaring specific barangays within the reservation as alienable and disposable. The core of the controversy is a handwritten note he allegedly added to this proclamation to include Western Bicutan, which was omitted from the official publication, leading petitioners to claim rights over the land they occupy therein.

An unpublished portion of a law, such as a handwritten addendum to a presidential proclamation, has no legal force or effect; publication in full is an indispensable condition for the effectivity of all laws to ensure the public is duly informed of their contents and to comply with the due process requirement.

The Local Government of Quezon City sought to expropriate a 1,000 square meter parcel of land registered under the name of Henry L. Sy, located in Barangay Balingasa, Balintawak, Quezon City. The intended use was for a multi-purpose barangay hall, day-care center, playground, and community activity center. Although the City enacted the authorizing ordinance in 1994 and filed the expropriation complaint in 1996, it had actually taken possession of the property and utilized it as a barangay day care and office as early as 1986 without initiating formal expropriation proceedings or paying compensation.

In expropriation proceedings, just compensation must be determined based on the fair market value of the property at the time of the actual taking, and legal interest accrues at twelve percent (12%) per annum from the time of taking until full payment, as the government's obligation to pay constitutes an effective forbearance.

Retired police officer Francisco R. Co, Jr. filed a civil suit for damages against Abante Tonite, a daily tabloid, and its officers and editorial staff, alleging that an article published in the June 6, 2000 issue was libelous. The defendants included Allen A. Macasaet (Publisher), Nicolas V. Quijano, Jr. (Managing Director), Isaias Albano (Circulation Manager), and editors Janet Bay, Jesus R. Galang, Randy Hagos, and columnist Lily Reyes. The complaint was filed before the Regional Trial Court (RTC) of Manila and raffled to Branch 51.

Substituted service of summons is valid only after a bona fide attempt at personal service has proven futile or impossible within a reasonable time, with the serving officer required to state in the return the efforts made to locate the defendant and the reasons for their failure; where the defendant's work necessarily requires absence from the office, two attempts on the same day may satisfy this requirement, and subsequent voluntary appearance by filing pleadings waives any defect in service.

Petitioner Susan Lim-Lua instituted an action for declaration of nullity of marriage against respondent Danilo Y. Lua before the Regional Trial Court (RTC) of Cebu City, Branch 14. In the course of proceedings, the trial court granted support pendente lite, which the Court of Appeals subsequently reduced to ₱115,000.00 monthly for petitioner and the two minor children. Following the finality of this award, respondent sought to deduct substantial advances—including the purchase of two automobiles, credit card expenditures for non-essential items, travel expenses, and cash gifts—from the accumulated support arrears, precipitating the dispute over the proper construction of the executory judgm…

Expenses incurred by a supporting spouse for luxury items and voluntary expenditures beyond the scope of the judicially determined support award cannot be deducted from accrued support arrears owed to the custodial spouse absent special equitable considerations or consent; only payments directly related to the necessities covered by the support decree—such as food, household maintenance, medical attendance, and essential clothing—may be credited against arrears, consistent with the principle that support comprises only what is indispensable for sustenance in keeping with the family's financial capacity.

Victoria Cabral originally owned a parcel of land in Meycauayan, Bulacan covered by Transfer Certificate of Title No. T-73737. The land was placed under the coverage of Presidential Decree No. 27, and in 1993, Emancipation Patents were issued to Spouses Enrique and Victoria Moraga covering portions thereof. Cabral contested the issuance of these patents before the Provincial Agrarian Reform Adjudicator (PARAD) in 1994, alleging fraud and non-agricultural classification. While her appeal was pending before the Department of Agrarian Reform Adjudication Board (DARAB), the Spouses Moraga subdivided the land, obtained new titles, and sold the subdivided lots to Filcon Ready Mixed, Inc. in 1996.…

A final judgment of an administrative quasi-judicial body does not bind a purchaser of property who was not impleaded in the proceedings and had no notice of the pending litigation, and such judgment constitutes a "cloud on title" removable through an action for quieting of title where it is apparently valid but unenforceable against the purchaser who holds valid Torrens titles acquired in good faith and for value.

Renaud Cointreau & Cie, a partnership registered under French law, has operated the renowned Le Cordon Bleu culinary school in Paris since 1895, establishing worldwide recognition in classical French cuisine and pastry making. Ecole De Cuisine Manille, Inc., a Philippine corporation engaged in culinary education and restaurant operations, began using the designation "LE CORDON BLEU" in the Philippines in 1948, with its directress and foundress having trained at Cointreau's Paris institution in 1977.

Prior use of a trademark abroad, coupled with bad faith appropriation by a domestic user who had knowledge of such foreign use, establishes the foreign user's ownership under Section 2-A of the Trademark Law (R.A. No. 166), notwithstanding the domestic user's earlier actual use in the Philippines.

The accused-appellant, Moises Caoile, was a neighbor of the victim, AAA, in Alipang, Rosario, La Union. AAA had been left in the care of her grandmother and aunt when her mother went abroad to work. Caoile's daughter, Marivic, was AAA's playmate, and AAA was a frequent visitor at the Caoile residence. The case was prosecuted under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353 (the Anti-Rape Law of 1997), which defines rape committed by carnal knowledge of a woman who is deprived of reason, unconscious, or demented. The informations specifically charged Caoile under paragraph 1(d) — rape of a demented person — alleging that AAA was "a demented person with a men…

Carnal knowledge of a woman who is a mental retardate constitutes rape under Article 266-A, paragraph 1(b) of the Revised Penal Code, as amended, because a mentally deficient person is automatically considered incapable of giving consent to a sexual act; the perpetrator's lack of awareness of the victim's mental disability does not exempt him from liability, but knowledge of the disability at the time of the commission qualifies the crime and elevates the penalty.

Petitioner is the Department of Agriculture–Regional Field Unit XII (DA-RFU XII), a government office mandated to implement the laws, policies, and programs of the Department of Agriculture in its regional area, while respondents are officials and employees of the same office. On March 30, 2004, Executive Order No. 304 was issued designating Koronadal City as the regional center and seat of SOCCSKSARGEN Region, directing all departments, bureaus, and offices of the national government in the region to transfer their regional seat of operations to Koronadal City. The dispute arose from the employees' opposition to the implementation of this executive order.

A motion for reconsideration is dispensed with as a prerequisite to a Rule 65 petition where the questions raised in the certiorari proceedings have already been duly raised and passed upon by the lower court, and the judiciary cannot enjoin the transfer of a regional office mandated by executive order because such transfer is an executive function whose wisdom is beyond judicial inquiry.

The case involves a 1.1057 hectare agricultural parcel in Barangay Magsaysay, Naguilian, Isabela, designated as Lot No. 5378, covered by TCT No. EP-43526, registered in respondent's name based on Emancipation Patent No. 393178 issued by the DAR on May 2, 1990. The property fell under the coverage of PD 27, which decreed the emancipation of tenants from the bondage of the soil and transferred to them ownership of the land they tilled. The previous owner, Serafin M. Garcia, was identified as a "perennial PD 27 landowner."

A sale of agricultural land covered by PD 27 after October 21, 1972 is null and void unless made in favor of the actual tenant-tiller thereon. Because petitioner's ownership claim derived from a void contract, he could not assert any right over the subject landholding, including a claim for exemption from OLT coverage.

The accused-appellant Guillermo Lomaque was the stepfather of the victim "AAA," who was born on September 15, 1985 to her mother "BBB." Lomaque began living with "BBB" in 1993, bringing with him his own children from a previous marriage. The charges arose from a series of sexual abuse incidents allegedly committed by Lomaque against "AAA" over a period spanning from 1993 to 1999, when "AAA" was a minor. The case was prosecuted under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, in relation to Section 5 of Republic Act No. 7610 (the Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act).

The qualifying circumstance of relationship in rape must be proven by competent evidence — the marriage contract is the best evidence of the fact of marriage — and cannot be established by mere testimony or by the accused's own admission; absent such proof, the accused may only be convicted of simple rape. The Court further held that a variance between the mode of commission of rape alleged in the Information and that proven during trial is binding upon the accused if he fails to object to the evidence showing a different manner of commission.

Petitioners Spouses Delfin and Aurora Tumibay owned a parcel of land in Sumpong, Malaybalay, Bukidnon covered by Transfer Certificate of Title (TCT) No. T-25334 registered in the name of Aurora. Petitioner Delfin acquired American citizenship while Aurora remained a Filipino citizen. Aurora's sister, Reynalda Visitacion, resided in the Philippines and acted as the couple's representative regarding the property. Sometime in 1994, respondent Rowena Gay T. Visitacion Lopez (Reynalda's daughter) and petitioners entered into negotiations regarding the sale of the subject land.

In a contract to sell, the seller retains ownership of the property until the buyer has paid the price in full, and a buyer who covertly usurps the seller's ownership prior to full payment commits a substantial and fundamental breach that defeats the very object of the contract, entitling the seller to rescission under Article 1191 of the Civil Code.

Spouses Deo Agner and Maricon Agner obtained financing for the purchase of a 2001 Mitsubishi Adventure Super Sport from Citimotors, Inc., executing a Promissory Note with Chattel Mortgage on February 15, 2001. Citimotors assigned its rights under the promissory note to ABN AMRO Savings Bank, Inc., which in turn assigned the same to BPI Family Savings Bank, Inc. on May 31, 2002. The promissory note stipulated monthly installments of ₱17,391.00 and contained a waiver of notice or demand clause, as well as a provision deeming the mere sending of correspondence to the mortgagor's address as valid notice. The legal framework governing the dispute includes Article 1484 of the Civil Code, which pr…

The remedies under Article 1484 of the Civil Code are alternative and not cumulative, but where a writ of replevin is issued but the vehicle is never actually seized, the mortgagee is not deemed to have exercised the remedy of foreclosure and may validly pursue the alternative remedy of exacting fulfillment of the obligation. Additionally, stipulated interest rates of 6% per month (72% per annum) are excessive, iniquitous, unconscionable, and exorbitant, and may be equitably reduced to 1% per month (12% per annum) even absent a finding of usury, as Central Bank Circular No. 905-82 did not grant lenders carte blanche authority to impose interest rates that would enslave borrowers.

Philippine Journalists, Inc. (PJI) and the Journal Employees Union (JEU) were parties to a collective bargaining agreement covering PJI’s regular employees, including Michael Alfante. Section 4, Article XIII of the CBA granted funeral or bereavement aid for the death of a regular employee in line of duty, for the death of a regular employee not in line of duty, and for the death of a legal dependent of a regular employee, but the CBA did not define the term legal dependent. Contemporaneous social legislation—the Social Security Law, the National Health Insurance Act, and the GSIS Law—defined dependents by reference to actual dependency for support. Article 100 of the Labor Code prohibited t…

Where a CBA grants funeral or bereavement aid for the death of a “legal dependent” of a regular employee but does not define the term, the term is construed consistently with contemporaneous social legislation, which focuses on actual dependency for support rather than the employee’s civil status; the employer’s continuous grant of such benefit may ripen into a company policy that cannot be unilaterally diminished under Article 100 of the Labor Code. The concurrence of a legitimate spouse does not disqualify a child or parent from being a legal dependent provided actual dependency is substantially proved.

The case involves a 152-square meter parcel of land located at Cuadra-Smith Streets, Downtown, Bacolod, erected with a building leased to various tenants. Spouses Rodolfo and Emilie Montealegre mortgaged the subject lot to petitioner Philippine National Bank (PNB) as security for a loan, using Transfer Certificate of Title (TCT) No. T-156512 purportedly registered in the name of Emilie Montealegre. Respondents Spouses Bernard and Cresencia Marañon claimed to be the true registered owners of the subject lot by virtue of TCT No. T-129577, which they alleged was illegally cancelled by TCT No. T-156512 through a falsified Deed of Sale bearing their forged signatures.

A mortgagee in good faith's lien attaches only to the property actually owned by the mortgagor; where the mortgagor is later declared not to be the true owner, Article 2127 of the Civil Code does not operate to include the improvements and their fruits in the mortgage. The doctrine of immutability of judgments bars any court, including the court that rendered the judgment, from modifying a final and executory judgment, even to correct alleged errors of fact or law.

The case arose from the Municipality of Agoo’s multi-phased Redevelopment Plan for the Agoo Public Plaza, a historical and public park containing the Imelda Garden and Jose Rizal Monument. To finance the plan, the Municipality obtained two loans from Land Bank, using a portion of the plaza as collateral and assigning part of its IRA as security. Residents led by Cacayuran opposed the conversion of the plaza into a commercial center, leading to a taxpayer suit that eventually reached the SC.

A municipal loan is void as an ultra vires act in the primary sense when it is contracted pursuant to mere resolutions rather than a law or ordinance and its purpose is to commercialize a public plaza, which is property of public dominion outside the commerce of man; a resident-taxpayer has standing to challenge such a loan when public funds are involved or the act affects a public property.

The Department of Public Works and Highways (DPWH) initiated expropriation proceedings for the construction of the EDSA-Quezon Avenue Flyover, naming several property owners as defendants, including Spouses William and Rebecca Genato who claimed ownership of a 460-square-meter parcel of land covered by Transfer Certificate of Title No. RT-11603 (383648). During the pendency of the proceedings, the DPWH received information suggesting that the subject property was actually government land and that the respondents' title was of dubious origin and fabricated.

Section 9, Rule 67 of the Rules of Court authorizes the court in expropriation proceedings to determine issues of uncertain ownership or conflicting claims for the sole purpose of identifying who is entitled to just compensation, without violating the prohibition against collateral attacks on Torrens titles under Section 48 of P.D. 1529.

Leovegildo R. Ruzol, Mayor of General Nakar, Quezon from 2001 to 2004, convened a Multi-Sectoral Consultative Assembly to regulate and monitor the transportation of salvaged forest products. Participants, including a DENR Provincial Environment and Natural Resources Officer (PENRO) and NGO representatives, agreed that the Office of the Mayor would issue permits to transport upon payment of fees to the municipal treasurer. From 2001 to 2004, 221 permits were issued, 43 signed by Ruzol and 178 by co-accused Municipal Administrator Guillermo T. Sabiduria.

A local government unit possesses shared authority to issue permits regulating salvaged forest products to complement DENR-issued permits, provided the issuance is pursuant to a valid municipal ordinance; however, a mayor who issues such permits without an enabling ordinance but in good faith and without pretense of supplanting DENR authority is not guilty of usurpation of official functions under Article 177 of the Revised Penal Code.

Rosario Berenguer-Landers and Pablo Berenguer, together with other Berenguers, were registered owners of a 58.0649-hectare landholding in Bibingcahan, Sorsogon, Sorsogon. The Department of Agrarian Reform issued a notice of coverage over the land under Republic Act No. 6657, the Comprehensive Agrarian Reform Program, while the Berenguers sought exclusion on the ground that the land was used exclusively for livestock pursuant to DAR Administrative Order No. 09. Respondent Isabel E. Florin was the Regional Agrarian Reform Adjudicator; Marcelino Jornales was Assistant Regional Director for DAR; and Pedro Vega was DAR Legal Officer V. The controversy concerns disciplinary liability of lawyers s…

A lawyer who holds a quasi-judicial office may be disciplined as a member of the Bar when misconduct in the discharge of official duties also violates the lawyer’s oath; issuing a writ of execution or possession before the order has become final and executory, and despite a pending appeal, constitutes ignorance of the law and an obstinate disregard of applicable rules warranting suspension. A judge or quasi-judicial officer may not be disciplined for a mere error of judgment absent conscious and deliberate intent to cause injustice, but such protection does not cover obstinate disregard of the law.

Flora Makapugay owned a 2.5-hectare farm in Barangay Lugam, Malolos, Bulacan, covered by Transfer Certificate of Title No. RT-65932 (T-25198), and Eugenio Caparas tilled it as agricultural lessee under a leasehold agreement. After Makapugay's death, her nephews and niece Amanda dela Paz-Perlas, Justo dela Paz, and Augusto dela Paz succeeded her, with Amanda acting as Makapugay's attorney-in-fact; after Eugenio's death, his children Modesta Garcia, Cristina Salamat, and Pedro Caparas survived him. The governing statute is Republic Act No. 3844, which provides for succession to the leasehold upon the lessee's death, security of tenure, modification of lease terms, and limitations on causes of…

The Dead Man's Statute bars an assignor's affidavit or testimony recounting a deceased adverse party's alleged admission when offered against the deceased's surviving spouse or successor-in-interest, who cannot contradict or disprove it; absent other evidence, the claimed alternate farming agreement cannot establish co-lessee status or defeat the lawful successor-tenant's security of tenure under Republic Act No. 3844.

The controversy arose following the impeachment and departure of Chief Justice Renato C. Corona in May 2012. Petitioner Francisco I. Chavez, nominated as a candidate for Chief Justice, questioned the composition of the JBC, which at the time included eight members: two representatives from Congress (one Senator and one House Representative), each exercising one full vote. The constitutional provision was crafted to insulate judicial appointments from political pressure, creating a body representative of stakeholders in the judicial appointment process.

Section 8(1), Article VIII of the 1987 Constitution mandates that Congress is entitled to only one (1) representative in the Judicial and Bar Council, and such representative must exercise one (1) full vote; the practice of having two representatives from the Senate and the House of Representatives sitting simultaneously is unconstitutional.

Rommel Arnado is a natural-born Filipino who lost his Philippine citizenship upon naturalization as a United States citizen. On July 10, 2008, he took his Oath of Allegiance to the Republic of the Philippines under Republic Act No. 9225, re-acquiring Philippine citizenship and effectively becoming a dual citizen. To qualify for elective office, Arnado executed an Affidavit of Renunciation of his U.S. citizenship on April 3, 2009. Despite this renunciation, Bureau of Immigration records showed that he used his U.S. passport four times to travel in and out of the Philippines between April 14, 2009, and November 24, 2009. On November 30, 2009, Arnado filed his COC for Mayor of Kauswagan, Lanao…

The use of a foreign passport after executing an oath of renunciation of foreign citizenship recants the oath, reverts the candidate to dual citizen status, and disqualifies them from running for any elective local position.

President Gloria Macapagal Arroyo appointed petitioner Emmanuel A. de Castro as Assistant General Manager for Operations (AGMO) of the Metropolitan Manila Development Authority (MMDA) on 29 July 2009. The appointment was concurred in by the Metro Manila Council, and petitioner assumed office. Following the change in administration, on 29 July 2010, Executive Secretary Paquito Ochoa issued Office of the President (OP) Memorandum Circular No. 2, which allowed non-Career Executive Service Officials (non-CESOs) occupying CES positions to remain in office temporarily until 31 October 2010 or until replaced. Shortly thereafter, the MMDA Chairperson reassigned petitioner, designated another office…

A person appointed to a Career Executive Service position who lacks the requisite CES eligibility holds only a temporary appointment and enjoys no security of tenure; his employment may be terminated at the pleasure of the appointing authority, and he cannot maintain a quo warranto action to oust a subsequent appointee. The position of Assistant General Manager for Operations of the MMDA is a CES position because it is a career position above division chief level that requires the performance of executive and managerial functions.

Abakada Guro Party List is a registered sectoral party-list group that won a seat in the May 2007 elections, with respondent Jonathan de la Cruz as its first nominee and sole representative in Congress. Petitioners Samson S. Alcantara, Romeo R. Robiso, Pedro T. Dabu, Jr., Lope E. Feble, Noel T. Tiampong, and Jose Floro Crisologo were officials and members of ABAKADA, while respondents included Jonathan de la Cruz, Ed Vincent Albano, and Benedict Kato. ABAKADA’s constitution and by-laws required a Supreme Assembly to be convened at least once every three years to elect officers and amend the party’s CBL.

Political parties, including registered party-list groups, are generally free to conduct their internal affairs under their constitution and by-laws pursuant to the right to free association; the COMELEC may resolve party leadership disputes, and its factual findings are binding absent grave abuse of discretion or lack of substantial evidence.

The dispute arose from a unilateral change in working conditions at CCBPI’s Cebu bottling plant. For decades, male bottling operators had used chairs while monitoring production lines. In 2008, management implemented a national efficiency program requiring constant mobility, resulting in the removal of chairs. The Union contested this through the CBA grievance machinery, leading to voluntary arbitration and conflicting decisions by the Arbitration Committee (pro-Union) and the CA (pro-management).

The removal of non-monetary workplace amenities (chairs), when undertaken as a bona fide efficiency measure accompanied by compensatory adjustments to working hours and rest periods, is a valid exercise of management prerogative that does not violate Article 100 of the Labor Code, which strictly applies only to monetary benefits or privileges with monetary equivalents.

Oscar Cacayorin, a member of respondent Armed Forces and Police Mutual Benefit Association, Inc. (AFPMBAI), applied to purchase a subdivision lot through a Pag-IBIG loan facility. On July 4, 1994, petitioners executed a Loan and Mortgage Agreement with the Rural Bank of San Teodoro (RBST). RBST issued a letter of guaranty to AFPMBAI, prompting AFPMBAI to execute a Deed of Absolute Sale in petitioners' favor and for a new title to be issued in their names with the corresponding mortgage annotation. Subsequently, the Pag-IBIG loan did not materialize, RBST closed and was placed under PDIC receivership, and AFPMBAI took possession of the loan documents and petitioners' title. AFPMBAI then made…

Consignation is necessarily judicial and falls within the exclusive jurisdiction of the regular courts, not the HLURB, even if the underlying transaction involves the sale of a subdivision lot.

Lorenza Lizada owned Lot 183 in Lambunao, Iloilo. Upon her death, the lot passed to her sole heir Jesusa Lizada Losañes, married to Hilarion Castigador. Their daughter Lilia Castigador inherited a portion, Lot No. 5, but predeceased her parents. Lilia's heirs—her husband Maximo Catedrilla and their children, including petitioner Rey Castigador Catedrilla—agreed to subdivide the property. In 1980, respondents Mario and Margie Lauron constructed a residential building on a 100-square-meter portion of Lot No. 5 with the tolerance of Lilia's heirs. Demands to vacate were made, but respondents refused.

A co-owner may bring an ejectment suit without joining all other co-owners as co-plaintiffs because the suit is deemed instituted for the benefit of all. Additionally, the owner of a house built on the subject lot is not an indispensable party in an ejectment suit against the actual occupants, as the only issue is physical possession, and a breached compromise agreement may be regarded as rescinded under Article 2041 of the Civil Code, reviving the original demand.

Martino Dandan was the registered owner of a 28,214-square-meter parcel of land in Kananga, Leyte, covered by Original Certificate of Title No. P-429, issued pursuant to Homestead Patent No. V-21513 in 1953. In 1960, he sold a portion of the land to Purificacion Cerna and delivered the owner’s duplicate certificate of title, but the sale was never registered. Purificacion later sold that portion to Marianito Pono in 1973, again without registration. Martino eventually left Leyte for Cavite. In 1990, he sold the entire land to his grandson, petitioner Esmeraldo Vallido. At the time of that sale, Martino did not have the owner’s duplicate certificate of title because it had been delivered to …

In a double sale of registered land, a second buyer who is a privy of the vendor acquires constructive knowledge of prior unregistered dispositions and cannot be considered a buyer or registrant in good faith; where the property is occupied by persons other than the vendor, the second buyer is duty-bound to investigate the nature of the occupants’ possession, and failure to do so precludes a claim of good faith, regardless of a clean certificate of title. Registration alone does not confer priority when good faith is absent.

Golden Falcon Mineral Exploration Corporation filed an Application for Financial and Technical Assistance Agreement (FTAA) covering 61,136 hectares in Bulacan, which the Mines and Geosciences Bureau (MGB) Regional Office denied on April 29, 1998, for failure to secure area clearances. Golden Falcon appealed to the MGB Central Office. While the appeal was pending on February 10, 2004, private individuals filed Applications for Quarry Permit over the same area. The MGB Central Office denied Golden Falcon's appeal on July 16, 2004, making the denial final on August 11, 2004. On September 13, 2004, Atlantic Mines and Trading Corporation (AMTC) filed an Application for Exploration Permit over a …

Statutory provisions subjecting the provincial enforcement of small-scale mining laws to the supervision, control, and review of the DENR do not violate the constitutional guarantee of local autonomy, as local autonomy refers to administrative decentralization rather than sovereignty, and the State retains full control and supervision over the exploration and utilization of natural resources.

During the 2010 Elections, Saquilayan was proclaimed Mayor of Imus, Cavite. Maliksi, the candidate who garnered the second highest number of votes, filed an election protest in the RTC alleging irregularities in 209 clustered precincts. After a revision of votes, the RTC declared Maliksi the winner and ordered Saquilayan to cease and desist from performing the mayoral functions. Saquilayan appealed to the COMELEC. While the appeal was pending, the RTC granted Maliksi's motion for execution pending appeal, leading to Maliksi's installation as Mayor.

Ballot images, though accorded equal probative weight as official paper ballots, may be resorted to in election protests only after the proper Revision/Recount Committee determines that the integrity of the physical ballots has been compromised, and the decryption and printing of such images must be conducted with notice to and in the presence of the parties.

The Integrated Bar of the Philippines (IBP) is governed by a Board of Governors (BOG) composed of nine regional governors. The national president and executive vice president (EVP) are chosen by the BOG from among themselves. Following Bar Matter No. 491 in 1989, the Court abolished direct election of national officers by the House of Delegates and restored the system where the BOG elects the president and EVP, with the EVP automatically succeeding to the presidency, subject to a rotation rule. The rotation rule was intended to give each of the nine IBP regions an equal opportunity to hold the EVP position and, consequently, the presidency. Disputes regarding which region was entitled to fi…

The election for IBP Executive Vice President for the 2011-2013 term was opened to all regions, initiating a new rotational cycle, because irreconcilable conflicts between prior Court resolutions and the ruling in Velez v. De Vera had produced endemic confusion in the application of the rotation rule, and the Court's continuing supervisory power over the IBP permitted it to revisit and modify even final administrative issuances to restore order and fairness to the electoral process.