Digests

A declaration that government-owned land is alienable and disposable does not, by itself, convert it into patrimonial property of the State; an express declaration that the land is no longer intended for public use or public service is required for acquisitive prescription to apply against the State.

Andrea Tan applied for original land registration based on acquisitive prescription, claiming continuous possession of a parcel of land declared alienable and disposable in 1965. The Municipal Trial Court granted her application, which was affirmed by the Court of Appeals. The Republic appealed, arguing that mere declaration of alienability is insufficient for prescription against the State.

781 SCRA 561 , 779 Phil. 32 , G.R. No. 197970

Metropolitan Bank and Trust Company vs. Fadcor, Inc

25th January 2016

ak549966

In an ex parte presentation of evidence resulting from the defendant's failure to appear at pre-trial, documentary evidence formally offered by the plaintiff and subsequently admitted by the trial court is properly considered in rendering judgment, even if the transcript of stenographic notes does not meticulously reflect the identification and marking of each specific exhibit during the witness's testimony; the rules on pre-marking and identification in A.M. No. 03-1-09-SC apply primarily to regular pre-trial proceedings where both parties participate.

Metrobank extended loans totaling P32,950,000.00 to Fadcor, Inc., secured by real estate mortgages over ten parcels of land and continuing surety agreements executed by individual respondents (Fadcor officers). Fadcor defaulted on its loan obligations.

779 SCRA 241 , 777 Phil. 280 , G.R. No. 212426 , G.R. No. 212444

Pre-trial

Saguisag vs. Ochoa, Jr.

12th January 2016

ak958005

The case was brought to the Supreme Court as the petitioners contended that the executive acted beyond its powers by entering into EDCA without Senate concurrence. They argued that the agreement allowed the presence of foreign military troops and facilities, which under the Constitution could only be authorized by a treaty concurred in by the Senate.

Constitutional Law I

Carpio-Morales vs. Court of Appeals (Sixth Division)

10th November 2015

ak551173

774 SCRA 431 , G.R. Nos. 217126-27

The jurisprudential doctrine of condonation is abandoned for being inconsistent with the 1987 Constitution's principles that public office is a public trust and that public officials are accountable to the people at all times; however, this abandonment is to be applied prospectively. Furthermore, Section 14 of Republic Act No. 6770 is declared partially unconstitutional for encroaching upon the Supreme Court's rule-making power and for improperly restricting the judicial review of the Ombudsman's acts.

The case arose from an investigation by the Office of the Ombudsman into alleged anomalous activities related to the procurement and construction of the Makati City Hall Parking Building. A complaint was filed against then-Mayor Jejomar Erwin S. Binay, Jr., and other city officials for Plunder and violations of the Anti-Graft and Corrupt Practices Act. The alleged irregularities spanned Binay, Jr.'s first term (2010-2013) and continued into his second term (2013-2016), leading the Ombudsman to initiate administrative and criminal proceedings against him.

774 SCRA 242 , 772 Phil. 483 , G.R. No. 202664

Gonzales, et al. vs. GJH Land, Inc., et al.

10th November 2015

ak690848

The jurisdiction over commercial cases, including intra-corporate disputes, is conferred by Republic Act No. 8799 upon Regional Trial Courts as courts of general jurisdiction, and the Supreme Court's designation of certain RTC branches as Special Commercial Courts is an administrative and procedural measure to promote expediency and efficiency in the exercise of that jurisdiction, not a conferment of jurisdiction itself; therefore, a commercial case erroneously raffled to a regular RTC branch within a station that has a designated Special Commercial Court should be transferred to the latter, not dismissed for lack of jurisdiction.

The case arose from a dispute over shares in S.J. Land, Inc. (later GJH Land, Inc.). Petitioners claimed they had fully paid for their subscribed shares, but these shares were subsequently offered for sale to other stockholders by the corporation, prompting petitioners to seek an injunction. This underlying dispute was recognized as an intra-corporate controversy.

768 SCRA 609 , 768 Phil. 217 , G.R. No. 186522

De Leon vs. Chu

2nd September 2015

ak032805

A violation of the rule on non-forum shopping, specifically the submission of a false certification or non-compliance with undertakings, does not automatically warrant dismissal; dismissal requires willful and deliberate forum shopping, or must follow a motion and hearing, unless the ground for dismissal (like litis pendentia) is evident motu proprio from the pleadings or evidence, a ground which became moot here upon case consolidation.

The dispute arose from conflicting claims over a 50-square meter parcel of land, originally part of a 600-square meter property owned by Domingo Delos Santos. Domingo allegedly sold the entire 600 sqm to Lolita Chu in 1990. Lolita entrusted the deed to Rowena De Leon before leaving for Japan. Subsequently, a different Deed of Sale emerged dated March 1993, purportedly showing Domingo sold 50 sqm to Rowena and the remaining 550 sqm to Lolita. Rowena registered the 50 sqm portion in her name, leading Lolita and Domingo to claim forgery and file for annulment, while Rowena sought the surrender of the title she claimed Lolita wrongfully withheld.

768 SCRA 204 , G.R. No. 162692

Motion

Chipongian vs. Benitez-Lirio

26th August 2015

ak861175

An appeal from a final order or judgment in a special proceeding, such as the dismissal of a complaint-in-intervention, must be perfected by filing both a notice of appeal and a record on appeal within thirty (30) days from notice of the judgment or final order; the failure to file the required record on appeal is a jurisdictional defect that prevents the appellate court from acquiring jurisdiction and renders the appealed judgment final and executory.

The late Vicente Benitez was married to Isabel Chipongian, the petitioner's sister. The couple had no children, and Isabel predeceased Vicente. After Isabel's death, petitioner Nilo Chipongian and Vicente executed an extrajudicial settlement of Isabel's estate, where Chipongian waived his rights. However, Chipongian claims that Vicente simultaneously executed an affidavit clarifying that the waiver did not cover Isabel's paraphernal properties. Upon Vicente's death, his relatives (respondents) initiated intestate proceedings for his estate. Chipongian intervened in these proceedings, seeking to exclude the paraphernal properties of his sister, Isabel, from Vicente's estate based on the alleged affidavit.

765 Phil. 605 , G.R. No. 166102

Manila Electric Company vs. The City Assessor

5th August 2015

ak880939

The Supreme Court affirmed the Court of Appeals' decision in part, declaring that MERALCO's electric facilities are subject to real property tax under the Local Government Code. However, it nullified the 1997 appraisal and assessment by the City Assessor of Lucena due to violation of MERALCO's right to due process and ordered a new assessment to be conducted in accordance with the Local Government Code.

MERALCO had been operating in Lucena City since 1922 under various franchises, some of which provided tax exemptions on certain electric facilities. Lucena City began assessing real property tax on MERALCO's electric facilities starting 1985. MERALCO contested these assessments, arguing that its facilities were exempt under its franchise and were personal property, not real property.

765 Phil. 429 , 764 SCRA 524 , G.R. No. 177168

Navy Officers' Village Association, Inc. (NOVAI) vs. Republic

3rd August 2015

ak461713

Land reserved for public or quasi-public purposes remains inalienable public domain unless explicitly withdrawn from such reservation by law or presidential proclamation and positively declared alienable and disposable. A sale of inalienable public land is void ab initio, and the title issued based on such sale is also void.

The land in question was originally part of Fort William McKinley, later Fort Andres Bonifacio Military Reservation (FBMR). Presidential Proclamation No. 423 reserved a large area for military purposes. Proclamation No. 461 excluded a portion as AFP Officers’ Village, intended for disposal under specific laws. Subsequently, Proclamation No. 478 reserved a smaller portion, including the property in dispute, for veterans rehabilitation. NOVAI claimed to have purchased the land from the Republic based on a Deed of Sale referring to a fictitious Proclamation No. 2487.

Obergefell vs. Hodges

26th June 2015

ak784523

576 U.S. 644

The Fourteenth Amendment to the United States Constitution requires a State to license a marriage between two people of the same sex and to recognize a marriage between two people of the same sex when their marriage was lawfully licensed and performed in another State.

758 Phil. 724 , G.R. No. 180771 , G.R. No. 181527

The cases arose from Michigan, Kentucky, Ohio, and Tennessee, states whose laws defined marriage solely as a union between one man and one woman, reflecting a long-standing historical definition but contrasting with evolving societal understandings and legal developments regarding the rights of gay and lesbian individuals and the nature of marriage itself. Petitioners sought marriage licenses within their home states or recognition of marriages performed legally in other states, facing denials based on these state laws. This legal challenge occurred against a backdrop of increasing public debate, legislative changes in some states, and numerous court decisions addressing same-sex marriage following landmark cases like Lawrence v. Texas and United States v. Windsor.

Constitutional Law II

Equal Protection

Resident Marine Mammals of the Protected Seascape Tañon Strait, et al. vs. Secretary Reyes, et al.

21st April 2015

ak704946

Service contracts for the exploration, development, and utilization of petroleum resources with foreign-owned corporations are permissible under paragraph 4, Section 2, Article XII of the 1987 Constitution, provided they adhere to specific safeguards: (1) the contract must be crafted in accordance with a general law setting standard terms; (2) the President must be the signatory for the government; and (3) the President must report the executed agreement to Congress within thirty days. Furthermore, any activity within a protected area under the National Integrated Protected Areas System (NIPAS) Act, such as exploration for energy resources, requires an Environmental Impact Assessment (EIA) and an Environmental Compliance Certificate (ECC), and if exploitation is involved, a specific law passed by Congress.

757 Phil. 599 , G.R. No. 176114

The Tañon Strait, a critical marine habitat located between Negros and Cebu, was declared a protected seascape in 1998. Despite this status, the Philippine government, through the Department of Energy (DOE), entered into agreements with Japan Petroleum Exploration Co., Ltd. (JAPEX) for oil exploration in the area, culminating in Service Contract No. 46 (SC-46). This led to concerns from environmental groups and local fisherfolk about the project's impact on the marine ecosystem and their livelihoods.

Constitutional Law I

San Diego vs. CA

8th April 2015

ak478899

An employee who, by virtue of their position (e.g., accountant, cashier, teller), has access to and physical possession of company funds but does not have juridical possession over them, commits qualified theft, not estafa, if they take and appropriate such funds with grave abuse of confidence and intent to gain.

Petitioner Grace San Diego was employed as an accountant for Obando Fisherman's Multi-Purpose Cooperative, Inc. (OFMPCI) from January 1993 to March 11, 1997. Her responsibilities included accounting for all business transactions, performing cashier and teller functions, granting loans, check discounting, recording bank transactions, and handling pre-signed blank checks. She also temporarily acted as cashier and teller on separate occasions, giving her complete access to cash vaults and cooperative documents.

755 SCRA 182 , 757 Phil. 534 , G.R. No. 211833

Qualified Theft

Villanueva vs. Judicial and Bar Council

7th April 2015

ak748641

The Supreme Court held that the JBC's policy requiring five years of service as a first-level court judge before qualifying for promotion to a second-level court is constitutional and does not violate the equal protection or due process clauses. The Court also ruled that the JBC must publish its policies to ensure transparency.

Judge Ferdinand R. Villanueva was appointed as a first-level court judge in 2012. In 2013, he applied for promotion to several Regional Trial Court (RTC) positions but was disqualified by the JBC due to its policy requiring five years of service as a first-level court judge. Villanueva challenged this policy, arguing that it was unconstitutional and violated his rights to equal protection and due process.

Constitutional Law I Constitutional Law II Philosophy of Law

Aquino vs. Quiazon

11th March 2015

ak636229

753 SCRA 98 , 755 PHIL. 793 , G.R. No. 201248

When a motion to dismiss (or an affirmative defense treated as such) is based on the ground that the complaint states no cause of action, the court must determine the sufficiency of the cause of action based solely on the allegations in the complaint, hypothetically admitting their truth, and cannot consider external facts or evidence presented during a preliminary hearing, except in very limited circumstances not present in this case.

The dispute arose from conflicting claims of ownership over a 557-square meter parcel of land in Magalang, Pampanga. Petitioners, heirs of Epifanio Makam and Severina Bautista, claimed acquisition through a Deed of Sale dated April 20, 1894, and continuous possession. Respondents, heirs of Fausta Baluyut, claimed ownership based on Transfer Certificate of Title (TCT) No. 213777-R, derived from an Original Certificate of Title (OCT) issued pursuant to a Land Registration Decree in 1919. The conflict escalated when respondents sent demand letters to petitioners to vacate the property in June 2005, leading petitioners to file a complaint for Annulment and Quieting of Title.

755 Phil. 145 , G.R. No. 203466

Benabaye vs. People

25th February 2015

ak922866

An employee who receives money or property on behalf of an employer acquires only material or physical possession, not juridical possession; thus, the misappropriation or conversion of such money or property by the employee constitutes theft, not Estafa under Article 315, paragraph 1(b) of the Revised Penal Code.

The case arose from an internal audit conducted by Siam Bank Inc., Iligan City Branch, which uncovered alleged fraud and irregularities in its loan transactions. Specifically, the audit revealed non-remittance of loan payments collected by its employees, including petitioner Cherry Ann Benabaye, who was a Loans Bookkeeper.

751 SCRA 389 , 754 Phil. 513 , G.R. No. 212081

Theft

Department of Environment and Natural Resources (DENR) vs. United Planners Consultants, Inc

23rd February 2015

ak719310

The CA correctly dismissed DENR’s petition for certiorari as it was filed out of time under the Special ADR Rules, and the confirmed arbitral award’s execution remains subject to COA’s approval.

DENR entered a consultancy agreement with UPCI in 1993 but paid only 47% of the contract price. After UPCI sued for non-payment, the case was referred to arbitration, resulting in a monetary award. DENR challenged the award’s confirmation and execution but failed to follow procedural rules.

Statutory Construction

Leus vs. St. Scholastica's College Westgrove

28th January 2015

ak411346

748 SCRA 378 , 752 PHIL. 186 , G.R. No. 187226

Pre-marital sexual relations between two consenting adults who have no impediment to marry each other, and consequently conceiving a child out of wedlock, gauged from a purely public and secular view of morality, does not amount to disgraceful or immoral conduct under Section 94(e) of the 1992 Manual of Regulations for Private Schools (MRPS).

This case revolves around the dismissal of a non-teaching staff member from a Catholic school after becoming pregnant out of wedlock, leading to a legal battle over whether such circumstance constitutes valid grounds for termination of employment.

Philosophy of Law

Kalaw vs. Fernandez

14th January 2015

ak745229

745 SCRA 512 , G.R. No. 166357

The determination of psychological incapacity under Article 36 of the Family Code should be based on the totality of evidence presented in each case, and courts must consider expert opinions as decisive evidence, even without a personal examination of the subject, provided the opinion is based on verifiable facts on record. A rigid and overly strict application of the Molina guidelines should be avoided, as the concept of psychological incapacity is not meant to be a "strait-jacket" but should be applied with resiliency to give a "decent burial to a stillborn marriage." Psychological incapacity may be proven to exist in either or both spouses, and if established, justifies the declaration of the marriage as null and void.

Valerio E. Kalaw (petitioner) and Ma. Elena Fernandez (respondent) were married on November 4, 1976. The petitioner filed a complaint to declare their marriage null and void on the ground of respondent's psychological incapacity. He alleged that her constant mahjong sessions, neglect of their children, infidelity, and obsessive need for attention were manifestations of a Narcissistic Personality Disorder that rendered her incapable of performing her essential marital duties. The respondent denied these allegations and countered that it was the petitioner who was psychologically incapacitated.

Article 36 of the Family Code

Del Socorro vs. Van Wilsem

10th December 2014

ak580817

749 Phil. 823 , G.R. No. 193707

A foreign national can be held criminally liable under R.A. No. 9262 for unjustly refusing or failing to give financial support to his minor child, even if his national law might not impose such an obligation, if said foreign law is not proven in Philippine courts (invoking processual presumption) or if applying such foreign law would be contrary to Philippine public policy or work an injustice to a resident child.

Petitioner Norma A. Del Socorro, a Filipina, and respondent Ernst Johan Brinkman Van Wilsem, a Dutch national, were married in Holland and had a son, Roderigo. Their marriage was dissolved by a divorce decree in Holland. Petitioner and her son returned to the Philippines. Respondent, who also came to the Philippines and remarried, allegedly failed to provide the promised monthly support to their son.

744 SCRA 31 , G.R. Nos. 204944-45

VAWC

Fuji Television Network, Inc. vs. Espiritu

3rd December 2014

ak058947

An employer has the burden to prove that a person it pays for services is an independent contractor; otherwise, the person is presumed to be a regular employee. Termination of an employee due to disease is only valid if a competent public health authority certifies that the disease is incurable within six months and that continued employment is prejudicial to health, and such termination must comply with due process.

In 2005, Fuji Television Network, Inc. engaged Arlene S. Espiritu as a news correspondent/producer for its Manila Bureau. Her employment was governed by a one-year fixed-term contract that was renewed annually for four years. In January 2009, Arlene was diagnosed with lung cancer and informed Fuji of her condition. Subsequently, Fuji's management told her that they would have a problem renewing her contract due to her illness, despite her insistence that she was still fit to work. This led to a dispute over the nature of her employment and the legality of the non-renewal of her contract.

743 SCRA 113 , 748 Phil. 760 , G.R. No. 198677

Commissioner of Internal Revenue vs. BASF Coating + Inks Phil., Inc

26th November 2014

ak919594

The BIR’s right to assess deficiency taxes against BASF for 1999 prescribed under the three-year statutory period under the National Internal Revenue Code (NIRC). The Formal Assessment Notice (FAN) was invalid because it was sent to BASF’s former address despite the BIR’s documented awareness of its new location.

BASF dissolved on March 31, 2001, and relocated to Calamba, Laguna. The BIR issued a FAN for 1999 tax deficiencies on January 17, 2003, but mailed it to BASF’s old Las Piñas address. BASF protested the assessment, arguing prescription and lack of valid notice. The CTA and CTA En Banc ruled in favor of BASF, prompting the BIR to appeal to the Supreme Court.

Statutory Construction

Zuñiga-Santos vs. Santos-Gran

8th October 2014

ak127777

738 SCRA 33 , 745 Phil. 171 , G.R. No. 197380

An amended complaint that fails to sufficiently allege ultimate facts establishing the plaintiff's right to the subject properties and the invalidity of their transfer, and which seeks reconveyance based on an implied trust more than ten years after the registration of the disputed titles in the defendant's name, is dismissible for failure to state a cause of action and for prescription.

The case originated from a dispute over three parcels of land allegedly owned by petitioner Eliza Zuñiga-Santos. Petitioner claimed these properties were fraudulently transferred to respondent Maria Divina Gracia Santos-Gran, purportedly the petitioner's daughter through a forged birth certificate, by petitioner's second husband, Lamberto C. Santos, using void and voidable documents, specifically a Deed of Sale that could not initially be located.

735 SCRA 102 , 743 Phil. 8 , G.R. No. 206510

Arigo vs. Swift

16th September 2014

ak295910

The grounding of the USS Guardian on Tubbataha Reef, a UNESCO World Heritage Site and protected area under Philippine law, caused significant environmental damage. The incident sparked public outrage and raised questions about the US military presence in Philippine waters under the Visiting Forces Agreement (VFA). Various environmental and activist groups filed a petition for a Writ of Kalikasan, seeking accountability and compensation for the reef damage.

Constitutional Law I

Pulgar vs. The Regional Trial Court of Mauban, Quezon, Br. 64, et al.

10th September 2014

ak670551

734 SCRA 527 , 742 Phil. 557 , G.R. No. 157583

Jurisdiction over an intervention is contingent upon the court's jurisdiction over the main action; an intervention is ancillary and supplemental, not an independent proceeding, and thus ceases to exist when the main case is dismissed, particularly on jurisdictional grounds.

The dispute originated from the Municipal Assessor of Mauban, Quezon's assessment of substantial realty taxes on the Mauban Plant, a power generation facility owned by QPL, based on a market value of approximately P29.6 billion. QPL contested this assessment, declaring a much lower value of about P15 billion, and tendered a significantly smaller amount as its first quarter installment for realty taxes, which was rejected by the Municipal Assessor.

733 SCRA 68 , 756 PHIL. 354 , G.R. No. 203655

Intervention

SM Land, Inc. vs. Bases Conversion and Development Authority

13th August 2014

ak100107

Administrative issuances duly promulgated pursuant to delegated rule-making power, such as the NEDA JV Guidelines issued under presidential directives (EO 109, EO 109-A, EO 423), have the force and effect of law and are binding on the government agencies covered, which cannot unilaterally deviate from the mandatory procedures therein, like the competitive challenge process following successful negotiation of an unsolicited proposal.

The dispute originated from an unsolicited proposal submitted by SMLI to BCDA for the development of the Bonifacio South Property through a joint venture. After negotiations, BCDA accepted the proposal's terms and conditions and issued a Certification of Successful Negotiations (CSN), agreeing to subject SMLI's proposal to a competitive challenge (Swiss Challenge) as outlined in the NEDA JV Guidelines and the agreed Terms of Reference (TOR). Subsequently, BCDA unilaterally cancelled the competitive challenge process, intending to subject the property to public bidding instead, prompting SMLI to file a petition.

740 Phil. 212 , G.R. No. 200334

Intervention

People vs. Cogaed

30th July 2014

ak442715

Evidence obtained through a warrantless search based merely on an unverified tip from an informant or a third party's suspicion, without independent observation of suspicious activity by the police officer establishing a genuine reason, does not constitute a valid "stop and frisk" search, and such illegally seized evidence is inadmissible under the exclusionary rule.

728 SCRA 1 , 737 Phil. 457 , G.R. No. 209287 , G.R. NO. 209135 , G.R. NO. 209136 , G.R. NO. 209155 , G.R. NO. 209164 , G.R. NO. 209260 , G.R. NO. 209442 , G.R. NO. 209517 , G.R. NO. 209569

The case arose within the context of law enforcement efforts against illegal drug trafficking, specifically involving the transportation of marijuana in the province of La Union. Police acted based on a text message from an unidentified civilian informant regarding the transport of marijuana by a named individual, leading to the establishment of a checkpoint and the subsequent apprehension and search of the accused.

Constitutional Law II

Searches and Seizures

Araullo vs. Aquino

1st July 2014

ak306263

The Supreme Court issued a ruling declaring several aspects of the DAP (Disbursement Acceleration Program) unconstitutional, including: the withdrawal of unobligated allotments and their designation as savings before the fiscal year's end, the cross-border transfers of savings to offices outside the Executive branch, and the use of savings to fund programs, activities, or projects not covered by the GAA (General Appropriations Act). In applying the Operative Fact Doctrine, the Court established that while projects already implemented under the DAP in good faith would remain intact, the officials responsible for these actions could still be held accountable.

The Disbursement Acceleration Program (DAP) was a mechanism introduced by the Department of Budget and Management (DBM) under Secretary Florencio Abad. It allowed the executive branch to pool savings from various government agencies and realign them to other projects to accelerate economic growth. However, petitioners argued that it violated the constitutional power of Congress over appropriations.

Constitutional Law I Persons and Family Law Philosophy of Law Statutory Construction

People vs. Jumawan

21st April 2014

ak373008

722 SCRA 108 , 733 Phil. 102 , G.R. No. 187495

R.A. No. 8353, the Anti-Rape Law of 1997, unequivocally criminalizes marital rape, and the archaic doctrine of irrevocable implied consent to sexual intercourse within marriage is rejected; therefore, a husband can be convicted of raping his wife if the act is committed through force, threat, or intimidation, just like any other perpetrator, without requiring different elements of the crime or standards of proof.

The accused-appellant, Edgar Jumawan, and the private complainant, KKK, were married in 1975, raised four children, and established several businesses primarily managed by KKK. While their conjugal intimacy was initially fulfilling, the accused-appellant reportedly became sexually brutal starting in 1997, foregoing foreplay and causing physical pain, leading KKK to resist, which resulted in threats. In 1998, quarrels increased, often initiated by the accused-appellant complaining about KKK's preoccupation with their businesses' financial problems and her alleged failure to attend to him, stating a woman's place was at home and in bed.

721 SCRA 146 , 732 Phil. 1 , G.R. No. 204819 , G.R. No. 204934 , G.R. No. 204957 , G.R. No. 204988 , G.R. No. 205003 , G.R. No. 205043 , G.R. No. 205138 , G.R. No. 205478 , G.R. No. 205491 , G.R. No. 205720 , G.R. No. 206355 , G.R. No. 207111 , G.R. No. 207172 , G.R. No. 207563

Rape

Imbong vs. Ochoa Jr.

8th April 2014

ak609982

The Supreme Court declared certain provisions of the RH Law and its IRR unconstitutional, specifically those related to abortifacients as redefined by the IRR, restrictions on conscientious objectors, lack of parental or spousal consent in specific situations, and limitations on health facilities operated by religious groups. However, the majority of the RH Law was upheld as constitutional.

The Responsible Parenthood and Reproductive Health Act of 2012 (RH Law) was enacted to address population growth and improve reproductive health in the Philippines. It mandates government provision of reproductive health services and supplies, including contraceptives, and requires sex education in schools. The law generated significant controversy and strong opposition, particularly from religious groups. Shortly after its enactment, various groups filed petitions challenging its constitutionality.

Constitutional Law I Constitutional Law II Philosophy of Law

Republic vs. De Guzman Vda. de Joson

10th March 2014

ak697117

728 Phil. 550 , 718 SCRA 228 , G.R. No. 163767

The application for land registration is denied because the applicant failed to discharge the burden of proving that the subject land is alienable and disposable land of the public domain, a prerequisite for registration under Section 14(1) of the Property Registration Decree.

Rosario de Guzman Vda. de Joson applied for land registration based on her and her predecessors-in-interest's alleged open, continuous, exclusive, and notorious possession and occupation of the land since 1926. The Republic opposed, arguing the land was unclassified forest land and not subject to private appropriation. The CFI and CA ruled in favor of De Joson, but the Republic appealed to the Supreme Court.

717 SCRA 644 , G.R. No. 196894

Crisologo vs. JEWM Agro-Industrial Corporation

3rd March 2014

ak211551

Persons whose liens are annotated on a certificate of title are indispensable parties in any action for the cancellation of those liens; failure to implead them renders all court proceedings on the matter null and void for want of authority to act.

The controversy originated from several collection cases filed against So Keng Kok, the original owner of two parcels of land. Various creditors, including the petitioners Spouses Crisologo and the respondent JEWM's predecessor-in-interest, had their respective levies annotated on the titles of these properties. JEWM's predecessor acquired the properties through a compromise agreement and subsequently sold them to JEWM. When JEWM obtained new titles, the annotations in favor of other creditors, including the Spouses Crisologo, remained.

716 SCRA 207 , 727 Phil. 1 , G.R. No. 172302

Pryce Corporation vs. China Banking Corporation

18th February 2014

ak989956

The Supreme Court ruled that the principle of res judicata applied, affirming the validity of the rehabilitation court’s order approving Pryce Corporation’s rehabilitation plan. The Court also ruled that the Interim Rules of Procedure on Corporate Rehabilitation do not require a hearing before issuing a stay order.

Pryce Corporation filed for corporate rehabilitation in 2004. The Regional Trial Court (RTC) of Makati found the petition sufficient and issued a stay order. The rehabilitation receiver submitted an amended plan, which the RTC approved. China Banking Corporation (China Bank) and Bank of the Philippine Islands (BPI) challenged the approval, leading to conflicting rulings in the Court of Appeals. The Supreme Court resolved the issue in favor of Pryce Corporation.

Philosophy of Law

Disini vs. Secretary of Justice

11th February 2014

ak238408

727 Phil. 28 , G.R. No. 203335 , G.R. No. 203299 , G.R. No. 203306 , G.R. No. 203359 , G.R. No. 203378 , G.R. No. 203391 , G.R. No. 203407 , G.R. No. 203440 , G.R. No. 203453 , G.R. No. 203454 , G.R. No. 203469 , G.R. No. 203501 , G.R. No. 203501 , G.R. No. 203515 , G.R. No. 203518

The Cybercrime Prevention Act of 2012 (R.A. 10175) is constitutional in its general aim to regulate and punish cybercrimes, but specific provisions that unduly curtail fundamental rights, such as certain aspects of online libel, unsolicited commercial communications, real-time collection of traffic data without a warrant, and the power of the Department of Justice to restrict or block access to computer data, are unconstitutional.

Constitutional Law II Criminal Law II Philosophy of Law Statutory Construction

The proliferation of internet use and the rise of cyberspace activities brought about new avenues for communication, commerce, and information dissemination, but also new forms of criminal behavior collectively termed "cybercrimes." Recognizing the need to address these emerging threats, the Philippine government enacted Republic Act No. 10175, the Cybercrime Prevention Act of 2012, to define and penalize various offenses committed through or with the use of computer systems, and to provide for their prevention, investigation, and prosecution.

Police Power; Freedom of Expression, Libel, and Cyberlibel

Manila Memorial Park, Inc. vs. Secretary of the Department of Social Welfare and Development

3rd December 2013

ak580749

711 SCRA 302 , 722 Phil. 538 , G.R. No. 175356

The Supreme Court held that the 20% senior citizen discount mandated by RA 7432, as amended by RA 9257, and the corresponding tax deduction scheme are a valid exercise of the State's police power and do not constitute an unconstitutional taking of private property requiring just compensation.

Manila Memorial Park, Inc. and La Funeraria Paz-Sucat, Inc. challenged the constitutionality of the tax deduction scheme implemented for senior citizen discounts, claiming it violates the constitutional provision against taking private property for public use without just compensation.

Constitutional Law II

Republic vs. Bacas

20th November 2013

ak418209

710 SCRA 411 , 721 Phil. 808 , G.R. No. 182913

The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, holding that the Land Registration Court lacked jurisdiction to register inalienable public land, specifically land within a military reservation, and that the land titles obtained through fraudulent applications are void ab initio and must be cancelled.

President Quezon issued Proclamation No. 265 in 1938, reserving land for military purposes, creating Camp Evangelista. Despite this, the Bacases and Chabons filed separate land registration applications in 1964 and 1974, respectively, for parcels within the reservation. The Land Registration Court granted their applications, leading to Original Certificates of Title. The Republic then filed actions to annul these titles.

710 SCRA 1 , 721 Phil. 416 , G.R. No. 208566 , G.R. No. 208493 , G.R. No. 209251

Belgica vs. Ochoa

19th November 2013

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The Court held that the post-enactment authority granted to legislators under the PDAF and similar schemes constitutes an impermissible intrusion into the Executive's budget execution domain, and that lump-sum discretionary funds without specific guidelines amount to an undue delegation of legislative power and undermines the President's item-veto power.

The case arose from public outrage and concern over the alleged misuse and corruption associated with the Priority Development Assistance Fund (PDAF) and other lump-sum discretionary funds, particularly in light of the Commission on Audit (CoA) report and the "Napoles controversy."

Constitutional Law I Constitutional Law II Statutory Construction

Consolidated Industrial Gases, Inc. vs. Alabang Medical Center

13th November 2013

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721 Phil. 155 , G.R. No. 181983

In reciprocal obligations arising from the same cause, where each party is a debtor and creditor of the other, the performance of one obligation is conditioned upon the simultaneous fulfillment of the other; thus, a party cannot demand performance from the other if it has not complied or is not ready to comply in a proper manner with what is incumbent upon it.

Obligations and Contracts

Consolidated Industrial Gases, Inc. (CIGI), a seller and installer of industrial gas systems, and Alabang Medical Center (AMC), a hospital operator, entered into two contracts. The first, on August 14, 1995, was for the installation of a medical gas pipeline system for the hospital's first to third floors (Phase 1), which AMC fully paid. The dispute arose from a second contract on October 3, 1996, for the continuation of the system to the fourth and fifth floors (Phase 2), under the same terms as Phase 1.

Commissioner of Internal Revenue vs. San Roque Power Corporation

8th October 2013

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690 SCRA 336 , 719 Phil. 137 , G.R. No. 187485 , G.R. No. 196113 , G.R. No. 197156

The 120+30-day periods under Section 112(C) of the Tax Code are mandatory and jurisdictional, except for claims filed between December 10, 2003 (issuance of BIR Ruling DA-489-03) and October 6, 2010 (promulgation of Aichi), where taxpayers could rely on the erroneous ruling in good faith.

San Roque Power Corporation filed a judicial claim for VAT refund 13 days after its administrative claim, violating the 120-day waiting period. The Court of Tax Appeals granted the refund, but the Supreme Court reversed, emphasizing strict compliance with procedural timelines.

Statutory Construction

Heirs of Mario Malabanan vs. Republic of the Philippines

3rd September 2013

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704 SCRA 561 , 717 Phil. 141 , G.R. No. 179987

The motions for reconsideration from both the petitioners and the respondent are denied, reaffirming the original decision that the petitioners failed to sufficiently prove their right to land registration because they did not establish possession and occupation of the property or by their predecessors-in-interest since June 12, 1945, nor did they fully comply with the requirements of Section 14(1) or 14(2) of the Property Registration Decree and Section 48(b) of the Public Land Act.

Mario Malabanan applied for land registration in 1998 claiming ownership through purchase and continuous, open, public, and adverse possession for over 30 years, asserting the land was alienable and disposable public land. The Republic opposed, arguing failure to prove the land's alienable and disposable nature and insufficient possession as required by law.

702 SCRA 755 , G.R. No. 191219

Lihaylihay vs. People

31st July 2013

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Public officers who certify and approve documents for non-existent purchases through evident bad faith, despite glaring irregularities such as tampered dates and incomplete certifications, commit a violation of Section 3(e) of RA 3019, resulting in undue injury to the government; the Arias doctrine does not apply where circumstances demand higher circumspection from approving officers.

The case arose from a Commission on Audit special audit report revealing irregularities in PNP procurement, prompting an internal PNP investigation into alleged "ghost" purchases of combat, clothing, and individual equipment (CCIE) worth P133,000,000 from the PNP Service Store System to the PNP General Services Command, leading to charges against multiple PNP officers for corrupt practices under RA 3019.

702 SCRA 677 , 715 Phil. 651 , G.R. No. 183608

Chingkoe vs. Republic

13th July 2013

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An order dismissing a case for the plaintiff's failure to appear at pre-trial under Rule 18, Section 5 of the Rules of Court is a final order, considered an adjudication on the merits and with prejudice unless otherwise stated, and the proper remedy against such dismissal is an ordinary appeal under Rule 41, not a special civil action for certiorari under Rule 65.

The case originated from two separate collection suits filed by the Republic of the Philippines, represented by the Bureau of Customs (BOC), seeking to recover allegedly unpaid customs duties and taxes from Chiat Sing Cardboard Inc. and Filstar Textile Industrial Corporation (Filstar), along with individual defendants including the petitioners Faustino and Gloria Chingkoe. The basis for the collection suits was the alleged use of fake and spurious tax credit certificates originally issued to Filstar and subsequently used by Chiat Sing to settle import duties, and the fraudulent acquisition of tax credit certificates by Filstar itself.

G.R. No. 183805 , 700 SCRA 443

Pre-trial

Capili vs. People

3rd July 2013

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A subsequent judicial declaration of nullity of a second marriage is not a valid defense against a charge of bigamy, as the crime is consummated at the time the second marriage is contracted during the subsistence of a prior valid marriage.

Petitioner James Walter P. Capili was legally married to Karla Y. Medina-Capili. During the subsistence of this first marriage, he contracted a second marriage with private respondent Shirley G. Tismo. This led to the filing of a criminal information for bigamy against him. Subsequently, a separate civil case was initiated, which resulted in the judicial declaration of the second marriage as null and void. The petitioner then sought the dismissal of the bigamy charge, arguing that the nullity of the second marriage removed the basis for the criminal case.

700 SCRA 69 , G.R. No. 196049

Prejudicial Question

Fujiki vs. Marinay

26th June 2013

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A petition to recognize a foreign judgment relating to marital status does not require a re-litigation of the case but only proof of the judgment as a fact under the Rules of Court; it is a special proceeding, not a civil action for declaration of nullity governed by A.M. No. 02-11-10-SC, and the spouse of the prior subsisting marriage has the legal personality to file such a petition.

Petitioner Minoru Fujiki, a Japanese national, married respondent Maria Paz Marinay, a Filipino, in the Philippines in 2004. Due to family objections, they lived separately and eventually lost contact. In 2008, Marinay, without dissolving her first marriage, married another Japanese national, Shinichi Maekara, in Quezon City. After allegedly suffering abuse from Maekara, Marinay reconnected with Fujiki in Japan. In 2010, with Fujiki's help, Marinay obtained a judgment from a Japanese family court declaring her marriage to Maekara void on the ground of bigamy. Fujiki then sought to have this foreign judgment recognized in the Philippines to nullify the bigamous marriage under Philippine law and to correct the civil registry.

699 SCRA 667 , G.R. No. 179736

Article 15, Civil Code

Hing vs. Choachuy

26th June 2013

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The right to privacy under Article 26(1) of the Civil Code, which prohibits "prying into the privacy of another's residence," is not strictly confined to residential properties; it also protects areas like business offices where the public is excluded and where an individual has a reasonable expectation of privacy.

Petitioners Spouses Hing and respondents Choachuy are owners of adjacent commercial lots in Mandaue City, Cebu. The respondents operate an auto-repair shop, Aldo Goodyear Servitec, on their property. A prior legal dispute existed between the parties, initiated by the respondents' company (Aldo) against the petitioners concerning the construction of a fence. Following this, the respondents installed two video surveillance cameras on their building, which were directed at the petitioners' property. Petitioners alleged that this was an illegal act of surveillance intended to gather evidence for the prior case and was a violation of their privacy, prompting them to file the present case for injunction and damages.

Article 26(1) of the Civil Code

Garcia vs. Drilon

25th June 2013

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699 SCRA 352 , 712 Phil. 44 , G.R. No. 179267

Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act of 2004, is constitutional and does not violate the equal protection clause, the due process clause, or constitute an undue delegation of judicial power to barangay officials.

Constitutional Law II Criminal Law II

Republic Act No. 9262 was enacted by Congress in 2004 as a landmark law defining and criminalizing various forms of violence against women and their children (VAWC) perpetrated by intimate partners (husbands, former husbands, partners, etc.), providing protective measures like protection orders, and outlining duties of government officials in responding to VAWC complaints. The law was a response to the high prevalence of domestic violence against women in the Philippines, often committed by their intimate partners, and aimed to address the historically unequal power relations between men and women. This case arose when a husband, subjected to Temporary Protection Orders under RA 9262, challenged the law's fundamental validity before the courts.

Equal Protection, VAWC

Reblora vs. Armed Forces of the Philippines

18th June 2013

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698 SCRA 727 , G.R. No. 195842

Decisions of the Commission on Audit (COA) are reviewable by the Supreme Court not through an appeal by certiorari under Rule 45, but through a special civil action for certiorari under Rule 64, which limits the scope of review to errors of jurisdiction or grave abuse of discretion. Furthermore, under Presidential Decree No. 1638, prior civilian government service is included in the computation of a military officer's "active service," which can trigger the conditions for compulsory retirement (attaining 56 years of age or 30 years of active service, whichever is later) at an earlier date.

The petitioner, a retired military officer, had rendered service as a civilian employee in the Department of the Interior and Local Government (DILG) before joining the Philippine Navy. Upon his retirement, a dispute arose regarding the computation of his retirement benefits. The AFP calculated his benefits based only on his actual military service, excluding his prior civilian service. The petitioner contested this, believing his civilian service should be added to his military service for a higher benefit, leading him to seek redress from the Commission on Audit.

697 SCRA 359 , G.R. No. 187587

Rule 45

Nagkakaisang Maralita ng Sitio Masigasig, Inc. vs. Military Shrine Services-Philippine Veterans Affairs Office, Department of National Defense

5th June 2013

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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 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.

Article 2 and 8, Civil Code

Royal Plant Workers Union vs. Coca-Cola Bottlers Philippines, Inc.-Cebu Plant

15th April 2013

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696 SCRA 357 , G.R. No. 198783

The removal of chairs for bottling operators is a valid exercise of management prerogative when done in good faith to improve business efficiency and safety, especially when compensated by other measures like adjusted work schedules; the long-term provision of such chairs does not ripen into a vested right or a benefit protected under the non-diminution rule of Article 100 of the Labor Code, which applies to monetary benefits or privileges with monetary equivalents.

For over three decades, Coca-Cola Bottlers Philippines, Inc. (CCBPI) provided chairs for its bottling operators at its Cebu plant. In September 2008, pursuant to a national directive aligned with its "I Operate, I Maintain, I Clean" program, CCBPI removed these chairs. The company reasoned that the operators' tasks required constant movement and that removing the chairs would enhance efficiency and prevent operators from sleeping on the job, thereby reducing the risk of accidents. This unilateral decision by management prompted the Royal Plant Workers Union (ROPWU) to initiate a grievance, which eventually led to the legal dispute.

695 SCRA 714 , 708 Phil. 693 , G.R. No. 204700

Eagleridge Development Corporation vs. Cameron Granville 3 Asset Management, Inc.

10th April 2013

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A party defending against a claim based on an assigned credit, especially a credit in litigation, has the right under the rules of discovery (Rule 27) to compel the production of documents like a Loan Sale and Purchase Agreement (LSPA) that are explicitly mentioned in the Deed of Assignment and necessary to determine the consideration paid, particularly when invoking the right of legal redemption under Article 1634 of the Civil Code.

Export and Industry Bank (EIB) initiated a collection suit against Eagleridge Development Corporation (EDC) and its sureties, Marcelo N. Naval and Crispin I. Oben, for an outstanding loan obligation. During the pendency of this suit, EIB assigned EDC's loan obligation to Cameron Granville 3 Asset Management, Inc. (Cameron), a special purpose vehicle, through a Deed of Assignment which referenced an underlying Loan Sale and Purchase Agreement (LSPA). Cameron was subsequently substituted as the plaintiff in the collection case.

694 SCRA 12 , 707 Phil. 11 , G.R. No. 169533

Discovery

Bongalon vs. People

20th March 2013

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An act of laying hands on a child constitutes the crime of child abuse under Section 10(a) of Republic Act No. 7610 only if the prosecution proves beyond reasonable doubt that the accused specifically intended to debase, degrade, or demean the intrinsic worth and dignity of the child as a human being; otherwise, the act is punishable under the Revised Penal Code for physical injuries.

The incident occurred during an evening procession where the petitioner's minor daughters and the victim, Jayson dela Cruz (a 12-year-old minor), along with his brother, were participants or bystanders. An initial altercation involving alleged stone-throwing and name-calling between the children preceded the petitioner's confrontation with Jayson.