Digests

On 14 February 2005, an RRCG bus traversing EDSA in Makati City was bombed, resulting in four deaths and approximately forty injuries. The bombing was claimed by the Abu Sayyaf Group, whose spokesperson announced the attack as a "Valentine's Day gift" shortly before the explosion. Members of the group were subsequently charged with multiple murder and multiple frustrated murder. Three accused—Gamal B. Baharan, Angelo Trinidad, and Gappal Bannah Asali—were arrested and arraigned, while Rohmat Abdurrohim was later apprehended and tried alongside them.

A conviction based on an improvident plea of guilty need not be set aside if the trial court relied on sufficient and credible independent evidence proving the commission of the offense, rendering the sufficiency of the searching inquiry on the plea of guilt immaterial. Furthermore, a co-accused's in-court testimony implicating a co-conspirator is admissible against the latter, as Section 30, Rule 130 of the Rules of Court applies only to extrajudicial admissions and not to judicial confessions where the party adversely affected has the opportunity to cross-examine the declarant.

On August 24, 2000, Task Force Aduana received intelligence that contraband was being shipped at Villa Vicenta Resort in Barangay Bignay II, Sariaya, Quezon. A joint team of military and police operatives proceeded to the resort, positioned themselves about fifty meters away, and spotted six individuals loading transparent plastic bags containing white crystalline substance into a white L-300 Mitsubishi van. The area where the loading took place was well-lighted. When the team closed in and identified themselves, accused Chua Shilou Hwan responded in Tagalog and admitted the substance was shabu, pointing to Raymond Tan as the leader. A total of 172 bags of suspected shabu were seized. Labor…

A warrantless arrest under Rule 113, Section 5(a) of the Rules of Court is valid when police officers personally observe the accused committing an offense—even from a distance—as the offense is deemed committed in their presence; the subsequent seizure of contraband is likewise permissible under the plain view doctrine. An accused who fails to question the legality of the arrest before entering a plea waives any objection to it.

Teresita "Tessie" Laogo was the proprietor and manager of Laogo Travel Consultancy, a travel agency firm located along Padre Faura Street in Ermita, Manila. Her co-accused, Susan Navarro, was identified by some complainants as an employee of the travel agency, though Laogo denied any connection between Navarro and the firm. Under Philippine law, recruitment and placement of workers for overseas employment requires a license or authority from the Department of Labor and Employment, administered through the Philippine Overseas Employment Administration (POEA). Laogo Travel Consultancy was not so licensed, as certified by the POEA.

A person who, without the required license or authority from the POEA, gives complainants the distinct impression that she has the power or ability to send them abroad for work, such that the latter are convinced to part with their money to be employed, is guilty of illegal recruitment, and when committed against three or more persons individually or as a group, the offense constitutes illegal recruitment in large scale, a form of economic sabotage carrying the penalty of life imprisonment and a fine of ₱500,000.00.

Petitioner Elenita Fajardo and Zaldy Valerio, her bodyguard and a former Philippine Army soldier who had gone AWOL, were charged with illegal possession of firearms and ammunition under P.D. No. 1866, as amended by R.A. No. 8294. The case arose from a police operation responding to citizen complaints about armed men indiscriminately firing guns at petitioner's residence in Barangay Andagao, Kalibo, Aklan. Both accused stipulated during pre-trial that they were not duly licensed firearm holders.

Illegal possession of firearms, though a malum prohibitum, requires animus possidendi or intent to possess; mere incidental possession without knowledge of or consent to the possession by another does not constitute the offense.

Dispute over a parcel of land in Zamboanga del Sur originally owned by Domingo Valientes, which he mortgaged in 1939. The mortgagees allegedly obtained title through a forged deed of sale, and their successor-in-interest eventually sought to clear the title of the heirs' adverse claim.

An action for reconveyance based on an implied or constructive trust prescribes in ten years from the issuance of the Torrens title if the plaintiff is not in possession of the property; courts may dismiss cases motu proprio on the ground of prescription if it is apparent from the pleadings.

In 1945, Emiliana Coprada permitted her nephew, respondent's late husband Brigido Coprada, to occupy a parcel of land out of affection, allowing him to build a nipa hut on the then-wasteland. Upon Emiliana's death, ownership passed to her daughter, petitioner Victoria Sordevilla. Respondent and her family resided on the property rent-free for decades. Petitioners eventually demanded that respondent vacate the premises, prompting the filing of an ejectment suit.

A registered owner's right to recover possession of property is imprescriptible and cannot be barred by laches when the occupant's possession is by mere tolerance; further, an occupant by tolerance cannot claim builder in good faith status, and asserting an unproven oral sale constitutes a collateral attack on a Torrens title.

NAPOCOR, exercising its power of eminent domain under Republic Act No. 6395, filed an expropriation suit on January 8, 1997, to acquire an easement of right of way over respondent's 946 sq m property in Imus, Cavite, for its "Dasmariñas-Zapote 230 KV Transmission Line Project." The parties executed a partial compromise agreement settling the location and size of the pole site but left the determination of just compensation for trial.

A commissioners' report that is not based on documentary evidence is hearsay and must be disregarded in determining just compensation. Just compensation must be determined as of the time of the filing of the expropriation complaint, and a provincial appraisal committee resolution serves merely as a factor in the judicial evaluation of just compensation, not a substitute for the commissioners' report.

The Lucena Fishing Port Complex, situated on reclaimed land in Barangay Dalahican, Lucena City, was one of the fishery infrastructure projects under the Nationwide Fish Port Package. It was financed through loans from Japan’s Overseas Economic Cooperation Fund. PFDA was created by Presidential Decree No. 977, as amended by Executive Order No. 772, and tasked with managing, operating, and developing fishing port complexes. It took over management of the Lucena port in February 1992. In 1999 and 2000, the City Government of Lucena demanded payment of real property taxes on the complex, leading to the present dispute over PFDA’s liability.

A government instrumentality that is not organized as a stock or non‑stock corporation is exempt from local real property taxation under Section 133(o) of the Local Government Code; a port constructed by the State and devoted to public use is property of public dominion owned by the Republic and therefore exempt from real property tax under Section 234(a) of the same Code, except to the extent that its beneficial use has been granted to taxable persons through leases.

The case arises from a special proceeding for the declaration of heirship and settlement of the intestate estates of Hermogenes Rodriguez, Antonio Rodriguez, Macario J. Rodriguez, Delfin Rodriguez, and Consuelo M. Rodriguez, docketed as Special Proceeding No. IR-1110 before the RTC of Iriga City, Branch 34. Henry F. Rodriguez, Certeza F. Rodriguez, and Rosalina R. Pellosis filed the petition claiming to be the sole surviving heirs of Antonio and, through Antonio's alleged fraternal relationship with Hermogenes, of Hermogenes as well. Multiple groups of oppositors, including Jaime M. Robles, entered appearances asserting competing claims to the estate of Hermogenes. The proceeding spanned ov…

A party who stands to be injured or benefited by the outcome of a petition for certiorari is an indispensable party who must be impleaded as a private respondent under Section 5, Rule 65 of the Rules of Court; non-joinder of indispensable parties is not a ground for dismissal, the remedy being to order their impleading.

Lorenzo Shipping Corporation (LSC) is a domestic corporation engaged in the shipping industry, owning equipment necessary for its business. On September 29, 1997, LSC entered into a General Equipment Maintenance Repair and Management Services Agreement with Best Manpower Services, Inc. (BMSI), under which BMSI undertook to provide maintenance and repair services to LSC's container vans, heavy equipment, trailer chassis, and generator sets, as well as checkers to inspect containers. Simultaneously, LSC leased its equipment, tools, and tractors to BMSI, with the lease period coterminous with the Agreement. BMSI then hired the petitioners on various dates to work at LSC as checkers, welders, u…

A contractor is deemed engaged in prohibited labor-only contracting where it lacks substantial capital or investment, performs activities directly related to the principal's main business, and has no independent business apart from the principal; the workers supplied thereby become regular employees of the principal, entitled to security of tenure, reinstatement, and full backwages if dismissed without just or authorized cause.

Petitioners Ernesto Marcelo, Jr. and Lauro Llames were formerly employed as President and General Manager, respectively, of New Sampaguita Builders Construction Incorporated, owned by Eduardo R. Dee, Sr. The dispute originated from Dee's alleged non-payment of their wages, which prompted petitioners to file a criminal complaint for estafa and violation of Article 116 of the Labor Code. Respondent Rafael R. Villordon was the Assistant City Prosecutor of Quezon City assigned to conduct the preliminary investigation of that complaint. The petition before the Supreme Court arose from the dismissal of a petition for mandamus filed by petitioners to compel Villordon to resolve the preliminary inv…

Mandamus will not issue to compel a prosecutor to file a criminal information where the prosecutor's inaction stems from the parties' own failure to submit required pleadings, because the determination of whether to file an information is a discretionary, not ministerial, duty—and mandamus lies only to compel the performance of ministerial duties, absent grave abuse of discretion.

Andres C. Fontillas alias "Anding" was the biological father of AAA, who was 13 years old at the time of the incident on December 8, 2001. They resided in Barangay Bamban, Municipality of Masinloc, Zambales. The case was prosecuted under Articles 266-A(1)(c) and 266-B(1) of the Revised Penal Code, as amended, which define and penalize qualified rape where the offender is a parent and the victim is under 18 years of age. Following the enactment of Republic Act No. 9346, the imposition of the death penalty was prohibited, requiring reduction of the penalty to reclusion perpetua.

In incestuous rape of a minor, actual force or intimidation need not be employed because the moral and physical dominion of the father is sufficient to cow the victim into submission, and the defense of intoxication requires clear and convincing proof that the intoxication was not habitual or intentional and that the quantity consumed was sufficient to impair the offender's mental faculties.

The case involves the apprehension of several individuals inside a private residence in Dagupan City based on a tip from an unidentified concerned citizen alleging an ongoing "pot session." The decision addresses critical issues in Philippine drug enforcement operations regarding the validity of warrantless arrests under Rule 113 of the Revised Rules of Criminal Procedure and the strict procedural requirements for handling seized evidence under the Comprehensive Dangerous Drugs Act of 2002 (RA 9165), particularly the chain of custody rule necessary to establish the identity of the corpus delicti.

A warrantless arrest based solely on an unverified tip without personal knowledge by the arresting officers of the actual commission of the crime is illegal, rendering any evidence seized during such arrest inadmissible as the fruit of the poisonous tree. Furthermore, strict compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 is essential to establish the identity and integrity of the corpus delicti in dangerous drugs cases; non-compliance without justifiable grounds raises reasonable doubt as to the guilt of the accused and warrants acquittal.

Spouses Fortunato Tayco and Diega Regalado died, leaving three parcels of land in Aklan to their children: Francisco Tayco, Concepcion Tayco-Flores, and Consolacion Tayco. In September 1972, Francisco and Consolacion executed a "Deed of Extrajudicial Settlement of the Estate of the Deceased Diega Regalado with Confirmation of Sale of Shares," transferring their shares to Concepcion. On March 16, 1991, Concepcion and Consolacion executed a "Confirmation of Quitclaim of Shares in Three (3) Parcels of Land." Francisco claimed the 1972 deed was executed solely to allow Concepcion to mortgage the property as collateral for her son's wedding; because the loan never materialized due to the declara…

A notarized deed of extrajudicial settlement may be declared simulated and void when the true intent of the parties was merely to use the property as loan collateral and not to transfer ownership, especially when the consideration is grossly disproportionate to the property's value.

The case arises from a dispute over deficiency value-added tax and withholding tax assessments issued by the Bureau of Internal Revenue against Metro Star Superama, Inc., a domestic corporation operating a movie/cinema house, for the taxable year 1999. The controversy centers on the procedural validity of the assessment process, specifically whether the BIR complied with the statutory and regulatory due process requirements by serving a Preliminary Assessment Notice prior to issuing a Formal Letter of Demand and Warrant of Distraint and Levy, or whether the taxpayer was unlawfully deprived of its right to administrative hearing and contestation.

The mandatory service of a Preliminary Assessment Notice (PAN) informing the taxpayer in writing of both the law and the facts upon which a proposed deficiency tax assessment is based is a substantive due process requirement under Section 228 of the National Internal Revenue Code; failure to strictly comply with this requirement renders the subsequent Formal Assessment Notice and the entire assessment procedure void, as it denies the taxpayer the opportunity to present evidence and contest the liability administratively.

Edgardo Azote, a member of the Social Security System (SSS), married Rosemarie Teodora Sino in 1982 and designated her as his spouse-beneficiary in his 1982 Form E-4, with their son Elmer as a dependent. While this first marriage was still subsisting, Edgardo entered into a second marriage with Edna A. Azote in 1992. They had six children together. In 1994 and 2001, Edgardo submitted updated Forms E-4 designating Edna and their children as beneficiaries. Rosemarie died on November 6, 2004, and Edgardo died on January 13, 2005. Edna subsequently filed a claim for death benefits with the SSS, which was denied upon discovery of the 1982 marriage and designation.

The Social Security Commission has the authority to investigate and determine the validity of a claimant's marriage to a deceased member for purposes of awarding benefits under Republic Act No. 8282; a spouse of a void marriage contracted during the subsistence of a prior valid marriage is not a "legal spouse" entitled to death benefits despite being designated as beneficiary in the member's Form E-4, as the statutory requirement of being a "legal spouse" under Section 8(e) and (k) of RA 8282 cannot be overridden by the member's unilateral designation.

On 18 August 2004, Teresa C. Aguilar engaged Transcept to construct a two-storey vacation house in Batangas for ₱3,486,878.64. Following a billing dispute and work stoppage, testing revealed substandard workmanship and fraudulent billing. To rectify these defects, the parties executed a Second Contract on 30 May 2005, fixing the contract price at ₱1,632,436.29 and extending the deadline to 29 July 2005. Transcept again failed to complete the project on time, attributing the delay to additional works ordered by Aguilar.

A contractor that achieves substantial completion (95% or more) of a construction contract under CIAP Document No. 102 is not liable for liquidated damages, but the obligee is entitled to actual damages equivalent to the unaccomplished works, pursuant to Article 1234 of the Civil Code.

Merlyn Mercadera discovered that her Certificate of Live Birth registered her given name as "Marilyn" instead of "Merlyn," the name she had used in her baptismal records, educational diplomas, and government employment records. She initially sought administrative correction under Republic Act No. 9048 before the Local Civil Registrar of Dipolog City. The civil registrar refused to act without a court order, citing the lack of a permanent appointment as mandated by R.A. 9048. Consequently, a judicial petition for correction of entry was filed under Rule 108 of the Rules of Court.

A petition to correct a misspelled given name in the civil register falls under Rule 108 (correction of entries) and not Rule 103 (change of name), provided the alteration is a mere rectification of a clerical error to make the entry reflect the true name the person has consistently used.

Lourdes Q. Del Rosario-Suarez owned a 1,211-square-meter parcel of land in Quezon City, which she leased to Roberto D. Tuazon for three years beginning March 1994. Some six months into the lease, Lourdes, then nearly 80 years old and needing funds to move to the United States, sent Tuazon a personal letter offering to sell him the property for ₱37,541,000 and giving him two years to decide. Tuazon attempted to negotiate a lower price, but Lourdes did not accept his counter-offer. The lease expired in February 1997, and on June 19, 1997 — after the two-year option period had lapsed — Lourdes sold the land to her daughter Catalina Suarez-De Leon, son-in-law Wilfredo De Leon, and two grandsons…

An option contract is a preparatory contract that grants the offeree the right to purchase a determinate thing at a fixed price within a specified period; it is not binding on the offeror if unaccepted, or if accepted but without a consideration distinct from the price. In contrast, a right of first refusal requires an antecedent agreement that the grantee shall have the first opportunity to buy on terms yet to be determined, and it does not arise from a unilateral offer with definite price and period.

In 1978, Myrna P. Antone and Leo R. Beronilla were married. In 1991, while that marriage remained subsisting and without any judicial decree of nullity, Beronilla contracted a second marriage with Cecile Maguillo. On 12 March 2007, Antone filed an affidavit-complaint for bigamy against Beronilla. After the prosecution filed an Information before the Regional Trial Court of Pasay City, Beronilla moved to quash on the ground that the facts charged did not constitute an offense. He presented a final judgment rendered on 26 April 2007 by the Regional Trial Court of Naval, Biliran, declaring his marriage to Antone void ab initio, and argued that, the marriage being void from the beginning, no fi…

A judicial declaration of nullity of a prior marriage obtained after the celebration of a subsequent marriage is immaterial in a prosecution for bigamy because, under Article 40 of the Family Code, the crime is consummated by the mere act of contracting a second marriage without a prior final judgment declaring the first marriage void. In resolving a motion to quash an Information on the ground that the facts charged do not constitute an offense, the court cannot consider evidence contradicting the allegations in the Information; such matters of defense must be raised at trial.

Eusebio M. Honrado was employed by Philippine Long Distance Telephone Company (PLDT) on August 25, 1981, holding the position of senior lineman at the PLDT North Parañaque Exchange with a monthly salary of ₱21,600.00 prior to his termination on February 15, 2001. PLDT maintains a Quality Control Division (QCD) tasked with investigating irregularities involving its personnel, including unauthorized solicitation of payments from applicants for telephone service. Company policy prohibits employees from personally collecting payments for telephone installation, as all payments must be made directly to PLDT.

An employee's dismissal is valid where the employer affords both procedural due process—through notice, a confrontation proceeding, and a formal hearing with counsel—and establishes just cause by substantial evidence, even without cross-examination of the complainant. Positive identification by the complainant, corroborated by documentary evidence, prevails over a bare denial and an internally inconsistent alibi.

Petitioner Jocelyn M. Toledo was the Vice-President of College Assurance Plan (CAP) Phils., Inc. in Cebu City. Respondent Marilou M. Hyden was a private lender from whom Jocelyn, along with other CAP employees, obtained personal loans. The loans carried monthly interest rates of 6% to 7%, with advance interest deducted from the loan proceeds at the time of release. Jocelyn used the borrowed funds to make advance payments for prospective clients of educational plans offered by CAP, thereby increasing her sales production and entitling her to a 50% rebate on her sales. The lending arrangement between the two spanned more than five years.

A stipulated interest rate of 6% to 7% per month is not unconscionable where the borrower is a sophisticated businessperson who knowingly and voluntarily entered into the loan for profit-making purposes, benefited from the proceeds for years, and paid the stipulated interest without complaint. The borrower is estopped from later impugning the contract's validity after having enjoyed its benefits, and a threat to file a BP Blg. 22 case does not vitiate consent where the claim is just or legal.

Enrique Agraviador and Erlinda Amparo-Agraviador met in 1971 at a beerhouse where the latter worked as a waitress; they entered into a common-law relationship and married on May 23, 1973, producing four children. The marriage deteriorated over decades, with each party attributing fault to the other. Article 36 of the Family Code, as amended, provides the statutory framework for declarations of nullity of marriage on the ground of psychological incapacity, a concept the Supreme Court has progressively refined through a line of decisions culminating in the guidelines set forth in Republic vs. Court of Appeals (the Molina case) and subsequent clarifications.

Psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability, and the totality of evidence must establish a natal or supervening disabling factor in the personality structure that effectively incapacitates a party from assuming and complying with essential marital obligations — not mere refusal, neglect, difficulty, or ill will.

Spouses Andres and Eliza Flores are the registered owners of a condominium unit in Embassy Garden Homes, West Triangle, Quezon City, covered by Condominium Certificate of Title No. 2130 issued by the Register of Deeds of Quezon City. The spouses maintained a borrowing relationship with Bank of Commerce, obtaining multiple credit accommodations over time, each documented through promissory notes and secured by real estate mortgages over the same condominium unit. The mortgage deeds contained identically worded clauses purporting to secure not only the specific loan amounts stated therein but all present and future obligations of the mortgagor to the bank. The dispute centers on whether those…

A real estate mortgage containing an express continuing guaranty clause that unambiguously secures all present and future indebtedness of the mortgagor to the mortgagee remains valid and enforceable notwithstanding full payment of the loans specifically annotated on the title, so long as other obligations within the contemplation of the mortgage instrument remain outstanding.

The case arose from the historic May 2010 elections where then Senator Benigno Simeon Aquino III campaigned on the slogan "Kung walang corrupt, walang mahirap" (If there is no corruption, there is no poverty). Upon assumption of the presidency, Aquino issued Executive Order No. 1 on July 30, 2010, creating the Philippine Truth Commission (PTC) to investigate reported cases of graft and corruption allegedly committed during the previous administration. The order was challenged by a citizen-taxpayer and by incumbent members of the House of Representatives as an unconstitutional exercise of executive power that violated the separation of powers and the equal protection clause.

Executive Order No. 1 creating the Philippine Truth Commission is unconstitutional because its limitation of investigation to the "previous administration" constitutes arbitrary classification violative of the equal protection clause.

The dispute originated from two proclamations issued in 1986 and 1987 that excluded certain portions of Fort Andres Bonifacio in Taguig from military reservation and declared them open for disposition. Executive Secretary Catalino Macaraig issued Memorandum No. 119 creating a Committee on Awards tasked to study, evaluate, and recommend action on applications to purchase lands within the proclaimed areas. The respondent, Dante O. Tinga, served as a member of the Committee on Awards in his official capacity as the Congressman of Taguig and Pateros from 1987 to 1998. The complainant, Jovito S. Olazo, filed a sales application in March 1990 covering a parcel of land in Barangay Lower Bicutan. C…

A lawyer holding government office may be disciplined as a member of the Bar only when the misconduct alleged also constitutes a violation of the lawyer's oath; where the complainant fails to prove the ethical infraction by clear and convincing evidence, the administrative complaint must be dismissed. The mere fact that a lawyer formerly held a public position connected to a matter does not, without proof of actual intervention, establish a violation of the prohibition against accepting employment in a matter in which the lawyer had intervened while in government service.

The case involves three consolidated petitions challenging the qualification of Juan Miguel "Mikey" Arroyo as the first nominee of Ang Galing Pinoy Party-List (AGPP), a party-list organization claiming to represent tricycle drivers and security guards. Arroyo was at the time an incumbent member of the House of Representatives, Chairman of the House Energy Committee, and a member of the First Family. The petitions were filed under the framework of Republic Act No. 7941 (the Party-List System Act) and COMELEC Resolution No. 8807, which prescribed rules for disqualification cases against party-list nominees participating in the May 10, 2010 elections. The dispute centered on whether Arroyo, gi…

After a party-list nominee has been proclaimed, has taken the oath of office, and has assumed office as a member of the House of Representatives, the HRET has exclusive original jurisdiction over all contests relating to the nominee's qualifications, and the COMELEC's jurisdiction over such matters ends.

The dispute arose from a family feud involving respondent Ramon K. Ilusorio and his siblings who controlled the Baguio Country Club Corporation (BCCC). Ilusorio, a club member and owner of an assigned penthouse unit, was barred from using the unit and threatened with expulsion from membership following the escalation of the family conflict in 1998. BCCC subsequently sent demand letters to Ilusorio for alleged unpaid guest charges and rectification works dating back to 1995, totaling over P2.9 million. Viewing these demands as harassment designed to pressure him in the family dispute, Ilusorio filed a separate action for damages, while BCCC had already initiated a collection suit in another …

The act of sending demand letters by a creditor to enforce payment of contractual obligations, standing alone, does not constitute a cause of action for damages; a cause of action requires an act or omission that violates the right of another, and the exercise of a legal right to collect debts or threaten sanctions under club rules does not violate Article 19 of the Civil Code unless exercised in a manner that lacks justice, honesty, or good faith.

Petitioners BF Homes, Inc. and Philippine Waterworks and Construction Corporation (PWCC) owned and operated waterworks systems serving over 12,000 households in BF Homes subdivisions in Parañaque, Las Piñas, Caloocan, and Quezon City. Their water pumps ran on electricity supplied by respondent Manila Electric Company (MERALCO), a public utility holding a legislative franchise for electric power distribution. In the 2002 MERALCO Refund cases, the Supreme Court ordered MERALCO to refund an excess average amount of ₱0.167 per kilowatt‑hour to its customers, to be credited against future consumption in accordance with a February 16, 1998 Decision of the Energy Regulatory Board (ERB). MERALCO su…

A complaint seeking to compel a distribution utility to credit a previously ordered refund against present electric bills and to restrain disconnection of electric service is within the original and exclusive jurisdiction of the Energy Regulatory Commission, not the regular courts; the Regional Trial Court therefore acquires no jurisdiction over the main action and cannot validly issue a writ of preliminary injunction.

Petitioner Employees Union of Bayer Philippines (EUBP) was the exclusive bargaining agent of all rank-and-file employees of Bayer Philippines, and an affiliate of the Federation of Free Workers (FFW). A CBA was executed between EUBP and Bayer covering the period January 1, 1997 to December 31, 2001, following an arbitral award by the DOLE Secretary. During the CBA's lifetime, a splinter group led by respondent Avelina Remigio disaffiliated from FFW, reorganized as the Reformed Employees Union of Bayer Philippines (REUBP), and sought recognition from Bayer as the bargaining representative. The ensuing conflict between EUBP and REUBP over union dues and CBA administration gave rise to multipl…

An employer commits unfair labor practice when it negotiates and signs a new CBA with a splinter union despite the existence of a valid and subsisting CBA with the duly certified exclusive bargaining agent, as such conduct constitutes a gross violation of the CBA per se — utter disregard of the very existence of the CBA — and does not require proof that the violation pertained to economic provisions.

The dispute arose from conflicting claims of ownership over a parcel of land located in Biñan, Laguna. Respondent Romeo Carlos claimed he purchased the property from petitioner Abubakar A. Afdal and allowed the petitioners to remain as occupants by tolerance. When Carlos demanded the return of the property for his personal use, the petitioners refused, leading Carlos to file an unlawful detainer complaint. The petitioners, however, maintained they were the lawful owners who purchased the property from spouses Martha and Francisco Ubaldo, denied selling it to Carlos, and claimed they were unaware of the proceedings against them due to petitioner Abubakar's absence while campaigning for mayor…

In unlawful detainer cases where a petition for relief from judgment is prohibited under the Revised Rule on Summary Procedure, a defendant who was not validly served with summons may file a petition for certiorari under Rule 65 with the Regional Trial Court to assail the judgment as void for lack of jurisdiction over the person. Substituted service of summons must strictly comply with the requirements under Rule 14, Sections 6 and 7 of the Rules of Court: the return must demonstrate that personal service was impossible despite diligent efforts, and the recipient must be shown to be of suitable age and discretion residing in the defendant's residence or a competent person in charge of the d…

On October 1, 1994, Hyatt Elevators and Escalators Corporation entered into an "Agreement to Service Elevators" with Cathedral Heights Building Complex Association, Inc. to maintain four passenger elevators in the latter's building, which housed a hospital. The agreement stipulated that the customer shall pay additional charges for the repair and supply of parts other than those specifically mentioned. From April 1997 to July 1998, Hyatt incurred expenses for parts and maintenance amounting to Php 1,161,933.47. Cathedral Heights refused to pay, prompting Hyatt to demand payment and eventually file a complaint for sum of money.

A perfected contract of sale requires a meeting of minds on the price, and the fixing of the price can never be left to the decision of one of the contracting parties; a price fixed by one party, if accepted by the other, gives rise to a perfected sale, but absent such acceptance, no contract exists.

The spouses Andres Jarantilla and Felisa Jaleco were survived by eight children, whose heirs extrajudicially partitioned their parents' real properties in 1948. Among the heirs, the spouses Rosita Jarantilla and Vivencio Deocampo entered into a joint business arrangement with the spouses Buenaventura Remotigue and Conchita Jarantilla, establishing manufacturing and trading businesses and acquiring real properties; this arrangement was voluntarily dissolved in 1973. On April 29, 1957, the Remotigue spouses executed an "Acknowledgement of Participating Capital" identifying the co-owners and their respective capital contributions in three business establishments — Manila Athletic Supply, Remot…

A partner's share is limited to the assets of the partnership as stipulated in the governing agreement, and a claim of co-ownership over properties titled in another's name — unsupported by documentary evidence that such properties were acquired with partnership funds — cannot prevail over the conclusiveness of Torrens titles and constitutes a prohibited collateral attack.

Rodolfo G. Jalandoni died intestate on 20 December 1966 without issue. His brother, Bernardino G. Jalandoni, filed a petition for the issuance of letters of administration with the Court of First Instance of Negros Occidental, which commenced the judicial settlement of Rodolfo's estate, docketed as Spec. Proc. No. 338. The petitioners and their siblings claimed to be the children of Sylvia Blee Desantis, who was the daughter of Isabel Blee with one John Desantis, and they sought to intervene in the estate proceedings on behalf of Isabel, alleging that she was the legal spouse of Rodolfo at the time of his death.

A court has no authority to allow a person who has no interest in an action or proceeding to intervene therein, and when a court allows an uninterested person to intervene, the mistake is not simply an error of judgment but one of jurisdiction, reviewable in a special civil action for certiorari. Furthermore, the fact of marriage may be proven by relevant evidence other than the marriage certificate, and a person's birth certificate may be recognized as competent evidence of the marriage between his parents, with the entries therein accorded prima facie weight.

On March 18, 1996, the Spouses Johnson and Evangeline Sy obtained a PhP 16 million loan from Land Bank, secured by three residential lots, five cargo trucks, and a warehouse. The loan agreement included an acceleration clause. When the Spouses Sy found themselves unable to service the loan, they sought to transfer their obligation.

A bank that accepts a conditional payment from a third person for the assumption of a mortgage, and subsequently disapproves the application without notice while retaining the payment, is obligated to return the amount under the principle of unjust enrichment, as it has no legal ground to keep the money.

The case arose from a long-standing agrarian dispute involving land in Bulacan owned by Leonarda Belongilot (petitioner's wife). Juanito Constantino forcibly entered the property in 1979 and converted it into a fishpond. After Leonarda secured a final decision for ejectment from the Provincial Agrarian Reform Adjudicator (PARAD), Constantino sought relief from the DARAB through a petition for injunction, leading to the alleged corrupt acts by the respondents.

The Ombudsman commits grave abuse of discretion amounting to lack or excess of jurisdiction when, in determining probable cause for violations of the Anti-Graft and Corrupt Practices Act, it refuses to rule on the merits of the complaint based on wrong or irrelevant considerations, or when it ignores patent facts demonstrating that public officials acted with manifest partiality, evident bad faith, or gross inexcusable negligence.

The case involves a dispute over two parcels of land inherited by Lucia Barrameda Vda. de Ballesteros from her deceased husband. Her children allegedly executed a deed of extrajudicial partition without her knowledge or consent, allotting the parcels to her son Rico Ballesteros, who subsequently mortgaged one parcel to Rural Bank of Canaman, Inc. (RBCI). When the bank initiated foreclosure proceedings, Lucia filed a civil action for annulment of the partition and mortgage. Meanwhile, RBCI was placed under receivership and liquidation by the Philippine Deposit Insurance Corporation (PDIC), with the RTC of Makati constituted as the liquidation court to assist in the adjudication of claims aga…

The liquidation court constituted under Section 30 of RA 7653 has exclusive jurisdiction over all claims against an insolvent bank, whether money claims or otherwise, and the doctrine of adherence to jurisdiction does not prevent the transfer of pending cases to the liquidation court when the jurisdictional change is curative in character designed to prevent prejudice to other creditors and depositors.

Lorenzo Shipping Corporation, a domestic corporation engaged primarily in cargo shipping activities, decided to amend its Articles of Incorporation to remove stockholders' pre-emptive rights to newly issued shares. Philip and Elnora Turner, stockholders holding 1,010,000 shares, voted against this amendment and exercised their appraisal right under the Corporation Code, demanding payment for their shares based on book value. A dispute arose regarding the valuation of the shares and the corporation's obligation to pay, leading to the constitution of an appraisal committee and subsequent litigation.

A dissenting stockholder's cause of action to enforce the appraisal right and demand payment for shares under Section 82 of the Corporation Code only accrues when the corporation possesses unrestricted retained earnings sufficient to cover the payment at the time of demand; the absence of such earnings at the time of filing the complaint renders the action prematurely brought and dismissible, and the subsequent existence of earnings during the pendency of the case cannot cure this defect.

Following an examination of petitioner's books of account for the 1997 taxable year, the Commissioner of Internal Revenue issued deficiency tax assessments for income tax, expanded withholding tax, and value-added tax, totaling ₱173,063,711.58. Petitioner protested the assessments and, upon the CIR's inaction, elevated the dispute to the Court of Tax Appeals.

A tribunal does not commit grave abuse of discretion in denying a motion for postponement where the movant had ample time to prepare and was already afforded the opportunity to be heard.

KEPCO Philippines Corporation is a VAT-registered independent power producer engaged in generating electricity, selling exclusively to the National Power Corporation (NPC), an entity exempt from taxes under Section 13 of Republic Act No. 6395. Kepco's sales to NPC were approved as zero-rated under VAT Ruling 64-01 issued by the BIR. The dispute centers on whether Kepco properly substantiated its claim for refund of unutilized input VAT for taxable year 2002 by complying with the invoicing requirements prescribed by Revenue Regulations No. 7-95, particularly Section 4.108-1 thereof.

Compliance with the invoicing requirements under Section 4.108-1 of RR No. 7-95 — including the printing of "TIN-VAT" and the imprinting of "zero-rated" on VAT invoices and official receipts covering zero-rated sales — is mandatory for a VAT-registered taxpayer claiming a refund of unutilized input VAT attributable to zero-rated sales. The revenue regulation neither expanded nor supplanted the NIRC but merely supplemented it, and non-compliance results in the disallowance of the corresponding input VAT claim.

Domingo Dominguez, Jr., a farmer residing in Barangay Anibong, Magallanes, Sorsogon, was the father of seven children, including the private offended party AAA, born on January 3, 1989. He lived with his wife BBB and their children in a house on a hill without electricity, using only a kerosene lamp. The accused maintained discipline through physical punishment, which instilled fear in his children and wife. The charges arose under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, with the qualifying circumstances of minority and relationship, and the penalty was affected by the subsequent enactment of Republic Act No. 9346, which prohibited the imposition of the…

In incestuous rape of a minor, actual force or intimidation need not be employed; the overpowering moral influence and ascendancy of the father over his daughter suffices to establish the element of force. Undressing the victim and oneself without commencing penile penetration constitutes acts of lasciviousness, not attempted rape, because penetration is the essential act of execution that must have commenced for the crime of attempted rape.

Eugenio Reyes was the registered owner of a 4,527-square-meter parcel of land in Turo, Bocaue, Bulacan, covered by TCT No. 109456(M), derived from TCT No. T-62290 registered in the names of his siblings Eufracia and Susana Reyes. The property was adjudicated to Eugenio through an extrajudicial settlement among the heirs following the death of his parents. Godofredo Mauricio had worked on the land from 1936 until his death in May 1994, introducing permanent improvements including fruit-bearing trees, seasonal crops, and a residential house. His widow Librada and alleged daughter Leonida claimed succession to his tenancy rights, while Eugenio disputed any tenancy relationship and sought to en…

A tenancy relationship is not extinguished by the mere expiration of the leasehold contract's term or by the sale, alienation, or transfer of the landholding; the purchaser or transferee is subrogated to the rights and obligations of the former landholder, and the existence of tenancy is a question of fact binding on the Supreme Court in a Rule 45 petition where no exception to the factual-review bar obtains.

The respondent was a member of the Bar and the former counsel of Rosario P. Mercado in a civil case filed in 1984 with the Regional Trial Court of Davao City and an administrative case before the Securities and Exchange Commission, Davao City Extension Office. The practice of law is a privilege burdened with conditions, and a lawyer may be deprived of it for misconduct ascertained and declared by judgment of the court after opportunity to be heard. The purpose of suspending or disbarring an attorney is to remove from the profession a person whose misconduct has proved him unfit, and to protect the public and those charged with the administration of justice, rather than to punish the attorne…

A lawyer may be disbarred for professional malpractice and gross misconduct when he files a barrage of frivolous and vindictive lawsuits against his former client and others to harass and exact revenge, as such conduct violates his duty to assist in the speedy and efficient administration of justice and his obligation to preserve the confidence and secrets of his client even after the attorney-client relationship is terminated.

Lorna M. Villanueva filed criminal complaints against Vice-Mayor Constantino S. Tupa of Palompon, Leyte, for Qualified Seduction and violation of Section 5(b), Article III of R.A. No. 7610. The Municipal Trial Court (MTC) judge found probable cause for two counts of violation of Section 5(b) of R.A. No. 7610 and allowed Tupa to post bail of ₱100,000.00 per case. Upon review, the Assistant Provincial Prosecutor recommended filing two informations under R.A. No. 7610 in relation to Section 31 (which imposes the penalty in the maximum period if the offender is a public officer, resulting in reclusion perpetua), cancelling the previously approved bail, and recommending that no bail be granted…

Notice and hearing are mandatory in all bail applications, whether bail is a matter of right or discretion, to enable the court to exercise its discretion on the strength of evidence and to fix the proper amount of bail.

Marina Sales, Inc., the local manufacturing arm of CO-RO Food A/S of Denmark, regularly imports raw juice concentrates for its Sunquick products, which the Bureau of Customs (BOC) historically assessed under Tariff Heading H.S. 2106.90 10 at a 1% import duty rate. In 2003, the BOC contested this classification for two of Marina's import entries, seeking to reclassify them under Tariff Heading H.S. 2106.90 50 at a 7% duty rate on the ground that the concentrates were composite concentrates ready for simple dilution with water.

A motion for reconsideration with the CTA Division is a mandatory precondition before elevating a case to the CTA En Banc, pursuant to Section 1, Rule 8 of the Revised Rules of the Court of Tax Appeals, and imported juice compounds that have lost their original character and require further manufacturing to be consumable are classified as raw materials under Tariff Heading H.S. 2106.90 10.

The case stems from a vehicular accident in August 2004 involving conflicting interpretations of whether reckless imprudence is a distinct crime or merely a mode of committing intentional felonies, and how the rule on complex crimes (Article 48, RPC) applies to quasi-offenses. The SC used this case to settle the confusion caused by the abandoned doctrine in People v. Faller and affirm the Quizon and Diaz lines of cases.

Reckless imprudence under Article 365 of the Revised Penal Code is a single quasi-offense penalizing the negligent act itself, not the resulting consequences; therefore, a prior conviction or acquittal for reckless imprudence bars a subsequent prosecution for the same quasi-offense regardless of the number or severity of the consequences alleged in the second charge, provided both arise from the same imprudent act.

The case arose from the termination of a service contract between DNL Security Agency and the Government Service Insurance System (GSIS), which affected security guards assigned to GSIS offices. The dispute centers on the extent of monetary liability of a principal (indirect employer) for claims of contract employees, particularly regarding the nature of solidary liability under the Labor Code and the limits of statutory exemptions from execution under the GSIS Charter.

A principal who contracts with a security agency is jointly and severally liable with the contractor for unpaid wages, salary differentials, and 13th month pay of the agency's employees under Articles 106, 107, and 109 of the Labor Code; however, the indirect employer is not liable for separation pay unless it conspired in the illegal dismissal, and may seek reimbursement from the contractor under Article 1217 of the Civil Code.

Pfizer, Inc. was the registered owner of Philippine Letters Patent No. 21116, issued on July 16, 1987, covering a method of increasing the effectiveness of beta-lactam antibiotics using sulbactam sodium, specifically the combination known as Sulbactam Ampicillin marketed under the brand name "Unasyn." The patent was valid for seventeen years until July 16, 2004 under Republic Act No. 165. In early 2003, Phil Pharmawealth, Inc. began submitting bids to supply Sulbactam Ampicillin to various hospitals without Pfizer's authorization, prompting Pfizer to initiate administrative and judicial actions to enforce its patent rights.

The Supreme Court established that: (1) a patentee's exclusive right to make, use, and sell a patented product exists only during the term of the patent, and consequently, no injunctive relief may be issued to protect an expired patent; (2) the Court of Appeals has jurisdiction to review interlocutory orders of the Bureau of Legal Affairs of the Intellectual Property Office through a special civil action for certiorari under Rule 65 of the Rules of Court where the Intellectual Property Code provides no appeal therefrom; and (3) forum shopping exists when a party files multiple actions based on the same acts or omissions violating identical rights, regardless of whether different patents are…

Respondent Hambrecht & Quist Philippines, Inc. received a tracer letter in November 1993 demanding payment of deficiency income and expanded withholding taxes for the taxable year 1989, stemming from the disallowance of certain expense items including management fees. Respondent filed a protest and request for reinvestigation in December 1993. The CIR took no action on the protest for nearly eight years, ultimately denying it in October 2001 on the ground that it was filed beyond the 30-day reglementary period.

The Court of Tax Appeals has jurisdiction to resolve the issue of prescription of the right to collect taxes even if the underlying assessment has become final and unappealable, as the validity of an assessment is separate and distinct from the issue of whether the right to collect the assessed tax has prescribed. Moreover, the prescriptive period for collection is not suspended by a mere request for reinvestigation; suspension requires that the request be granted by the Commissioner of Internal Revenue.

Editha Broqueza, an employee of Hongkong and Shanghai Banking Corporation (HSBC) and a member of its Staff Retirement Plan (HSBCL-SRP), obtained a car loan and an appliance loan, both payable through automatic salary deduction. A labor dispute in 1993 resulted in her termination from HSBC. Consequently, the salary deductions ceased, and Broqueza defaulted on her monthly amortizations. HSBCL-SRP considered the accounts delinquent and demanded payment.

A loan obligation evidenced by a promissory note without a fixed maturity date constitutes a pure obligation demandable at once upon the debtor's default, and the cessation of salary deductions due to termination of employment does not suspend the obligation to pay.