Digests

Spouses Espino mortgaged their property to United Savings Bank, stipulating that the property would not be sold or encumbered without the mortgagee's written consent. Approximately eight years later, the Espinos entered into a conditional sale agreement with respondent Kambiak Y. Chan, Jr. without the bank's consent. Subsequently, the bank assigned its rights as mortgagee to petitioner Direct Funders Holdings Corporation, and the Espinos assigned their right of redemption to the bank and its successors-in-interest. Petitioner consolidated ownership, obtained a new title, and secured a writ of possession from the Regional Trial Court of Pasig, Branch 157.

A claim to possession based on an unconsummated and unregistered conditional sale executed without the mortgagee's consent cannot prevail over the right of a mortgagee's successor-in-interest who has consolidated ownership and obtained a writ of possession.

In 1986, the Philippine government obtained a US$310 million Economic Recovery Loan from the World Bank to rehabilitate the DBP, which was then burdened with non-performing loans. A condition of the loan required the DBP to engage a private external auditor in addition to the COA audit. To implement this, the Central Bank issued Circular No. 1124, mandating all banks, including government-owned ones, to undergo annual financial audits by external independent auditors. The DBP subsequently hired Joaquin Cunanan & Co. as its private external auditor for 1986.

The constitutional power of the Commission on Audit to examine and audit government entities is non-exclusive and permits concurrent audit by private external auditors, while the Commission's authority to define the scope of its audit and promulgate rules on disallowances remains exclusive.

Police officers on routine patrol in Pagsanjan, Laguna, flagged down a passenger jeep driven by petitioner because its cargo was unusually covered with kakawati leaves. Upon inspecting the vehicle, they discovered stolen aluminum conductor wires belonging to the National Power Corporation. Petitioner claimed he was acting as a civilian NARCOM agent in an entrapment operation and was transporting the wires with the knowledge of his superior, who was supposed to intercept him at a designated checkpoint.

A warrantless search of a moving vehicle based solely on the unusual appearance of its cargo, without probable cause, is unconstitutional, and evidence obtained therefrom is inadmissible.

International Communications Corporation (now Bayantel) filed an application with the NTC for a Certificate of Public Convenience or Necessity (CPCN) to install, operate, and maintain a digital CMTS. Pending resolution and due to the non-availability of frequencies, the NTC archived the application in 1993 without prejudice to its reinstatement. Years later, subsequent NTC Memorandum Circulars reallocated frequency bands for CMTS expansion. Citing the availability of new frequencies, Bayantel filed an ex-parte motion to revive its archived application. The NTC granted the revival and scheduled hearings. Extelcom, an existing CMTS operator and a company in which Bayantel held substantial stockholdings, opposed the revival and filed a motion to dismiss, arguing the application was outdated, there was no public need, and frequencies were unavailable. Notwithstanding the opposition, the NTC granted Bayantel a provisional authority to operate the CMTS.

Administrative rules and regulations must be published in the Official Gazette or a newspaper of general circulation before they can take effect and bind the public, and a party's direct resort to the courts via certiorari without first filing a motion for reconsideration with the administrative agency constitutes a violation of the doctrine of exhaustion of administrative remedies.

The COMELEC, pursuant to the Voter's Registration Act of 1996 (R.A. 8189), initiated the VRIS Project to computerize voter registration. After a public bidding process, PHOTOKINA was declared the winning bidder. However, the project's funding was a contentious issue, as the bid amount vastly exceeded the funds appropriated by Congress.

A government contract that obligates funds in excess of the appropriation made by law is void. Mandamus does not lie to compel the formalization or performance of such a void contract, as the right to it is not clear and unmistakable.

Pilipinas Kao, Inc. (PKI) manufactured methyl esters, refined glycerine, and fatty alcohols for export. Originally registered with the BOI in 1976 and 1978 under R.A. No. 6135, PKI sought additional registration in 1987 for its expanded production capacity under P.D. No. 1789, as amended by B.P. Blg. 391 (the Investment Incentive Policy Act of 1983). As an expanding export producer on pioneer status, PKI was entitled to tax credits on Net Value Earned (NVE) and Net Local Content (NLC). PKI's initial 1987 tax credit application was approved in full. However, for 1988 and 1989, the BOI substantially reduced the incentives by deducting a "base figure" representing PKI's highest attained production volume in the three years preceding its expansion registration—a formula derived from the BOI's Tax Credit on NLC and NVE Manual of Operations. Because PKI had exceeded its original registered capacity prior to 1987, the application of this base figure resulted in a larger deduction than if PKI had merely met its original registered capacity, effectively penalizing PKI for its export efficiency.

An administrative rule that enforces or implements existing law and substantially affects the rights of the public must be published to be effective, and such rule cannot impose requirements that defeat the legislative purpose or penalize efficiency.

Metropolitan Bank & Trust Company extended credit facilities to Blade International Marketing Corporation by opening letters of credit and paying suppliers against bills of exchange. The merchandise was delivered to the corporation under trust receipt agreements, which required the entrustees to hold the goods and their proceeds for the payment of their obligations to the bank. Without justifiable reason, the corporation and its officers failed to account for or turn over the proceeds of the sale to the bank.

A person who signs a commercial document containing a solidary liability clause is personally bound thereby, notwithstanding claims that the signature was affixed in a representative capacity or on a blank form, because an experienced businessman cannot disclaim the consequent liabilities of being a signatory to important legal papers.

Immediately after the 1986 EDSA Revolution, the Presidential Commission on Good Government (PCGG) was created to recover ill-gotten wealth. The PCGG sequestered shares of stock in the United Coconut Planters Bank (UCPB) registered in the names of COCOFED, the Coconut Industry Investment Fund (CIIF) companies, and Eduardo Cojuangco Jr. The funds used to purchase these shares came from the Coconut Consumer Stabilization Fund (CCSF), commonly known as the coconut levy funds, which were collected pursuant to presidential decrees exercising the State's police and taxing powers.

The right to vote sequestered shares acquired with public funds or funds affected with public interest belongs to the government, not the registered private owners, pending final judicial determination of ownership. The "two-tiered test" for voting sequestered shares applies only when the shares are alleged to have been acquired with ill-gotten wealth; when the shares are prima facie acquired with public funds, the "public character" exception applies.

Luis Bacus leased an agricultural land to Faustino Duray under a contract containing an option to buy a portion of the property within a specified period. Upon Bacus's death, his heirs (petitioners) refused to execute the deed of sale despite Duray's timely notice of intent to exercise the option, insisting on prior full payment of the purchase price.

In an option to buy creating reciprocal obligations, the option holder validly exercises the option by giving notice of the decision to buy and readiness to pay, without being required to deliver the purchase price or consign it in court prior to the grantor's execution of the deed of sale.

Catalina Quilala executed a two-page deed of donation inter vivos over a parcel of land in favor of Violeta Quilala. The first page contained the donation terms and an explicit acceptance clause, signed by the donor, donee, and two witnesses at the bottom. The second page contained the notarial acknowledgment, which mentioned only the donor. On this second page, the donor and one witness signed the left margin, while the donee and the other witness signed the right margin. Following the deaths of Catalina and Violeta, respondents, claiming to be Catalina's surviving relatives, sought to nullify the donation on the ground that Violeta's acceptance was not made in a public instrument.

A notarized deed of donation is a public instrument in its entirety and remains valid despite the donee's omission from the notarial acknowledgment, provided the acceptance is explicitly set forth within the deed. Additionally, the requirement under the Property Registration Decree that parties sign on the left margin of each page is merely directory; signing on the opposite margin substantially complies with the purpose of authentication.

Petitioner Rodil Enterprises, Inc. leased the Ides O'Racca Building, a former alien property owned by the Republic, since 1959 and subleased portions to private respondents in 1980. A 1987 attempt to renew the lease was disapproved by the Department of General Services and Real Estate Property Management (DGSREPM) in favor of the Ides O'Racca Building Tenants Association, prompting Rodil to file a specific performance suit. Years later, in 1992, the Republic, through the Department of Environment and Natural Resources (DENR), executed a renewal contract and a supplemental contract with Rodil, leading to conflicting claims over the property's possession and the validity of the lease.

A renewal lease contract executed by the government over its property is valid and binding notwithstanding the nullity of a prior unapproved lease, as it constitutes a valid exercise of the owner's jus disponendi, provided the contract is not contrary to law, morals, good customs, public policy, or public order.

Twenty individuals served as members of the Board of Directors of the National Housing Authority (NHA) from 1991 to 1996. They occupied these seats not in their own right, but as alternates to various Cabinet Secretaries (Finance, Labor, Trade and Industry, Public Works) and the Director-General of NEDA, pursuant to Section 7 of Presidential Decree No. 757. During their tenure, they received representation allowances and per diems totaling P276,600.00.

Alternates of Cabinet members sitting ex-officio on government boards are barred from receiving additional compensation (per diems, allowances) because their authority is derivative of their principals, who are constitutionally prohibited from receiving such compensation.

Petitioners, former members of the Philippine Constabulary-Integrated National Police (PC-INP) detailed with the National Bureau of Investigation (NBI), were involved in a shoot-out on July 10, 1990, at the Magallanes Commercial Complex, Makati City, which killed Colonel Rolando de Guzman, Major Franco Calanog, and civilian agent Avelino Manguerra. Conflicting findings by the NBI—which reported the incident as a drug buy-bust operation where suspects fired first—and the Criminal Investigation Services (CIS)—which concluded petitioners shot the victims at close range—prompted the creation of a Presidential Fact-Finding Committee (Elma Committee). The Committee recommended prosecution, leading to the filing of three amended informations for murder against the petitioners.

A motion to take oral depositions of defense witnesses outside the Philippines in a criminal case may be denied where the proposed testimonies are merely corroborative and other local witnesses are available to testify on the same facts.

Susana Realty, Inc. (SRI) sold several parcels of land to the Light Rail Transit Authority (LRTA), reserving the right of first refusal to develop the property. LRTA subsequently entered into a Commercial Stall Concession Contract with Phoenix-Omega Development and Management Corporation (Phoenix-Omega). SRI opposed the agreement but later honored it under a tripartite agreement, agreeing to lease its remaining adjacent property to Phoenix-Omega. Phoenix-Omega then assigned its rights over the remaining property to its sister company, PKA Development and Management Corporation (PKA), which entered into a lease contract with SRI. The lease was later amended to substitute a portion of the property that SRI had sold to a third party. PKA's building permit was revoked for violations of the National Building Code, and SRI withheld approval of PKA's amended construction plans pending correction of the defects. PKA sued SRI for rescission of the lease, while SRI claimed PKA violated the contract by failing to complete construction and by building without approved plans.

An alias writ of execution cannot be enforced against the properties of persons who were not impleaded and over whom the trial court never acquired jurisdiction, and the veil of corporate fiction may only be pierced upon clear and convincing proof that the corporate vehicle is used to defeat public convenience, justify wrong, protect fraud, or defend crime.

Francisco Comille and his wife registered a 418-square-meter lot in Dipolog City in 1956. After his wife's death in 1980, Francisco became the sole owner. Childless and retired, he hired his niece, a cousin, and petitioner Cirila Arcaba to care for him and his store. When the others left upon marriage, Arcaba remained as his sole caregiver. On January 24, 1991, Francisco executed a notarized Deed of Donation Inter Vivos, ceding 150 square meters of the lot and his house to Arcaba in consideration of her faithful services over the past ten years. Francisco died on October 4, 1991.

A donation inter vivos between persons living together as husband and wife without a valid marriage is void under Article 87 of the Family Code where the common-law relationship is established by public assumption of marital relations, cohabitation, the donee's use of the donor's surname, and the donee's lack of regular compensation for services rendered.

Carmelo & Bauermann, Inc. leased property to Mayfair Theater, Inc. under contracts containing a right of first refusal. Without offering the property to Mayfair, Carmelo sold it to Equatorial Realty Development, Inc. on July 30, 1978. Mayfair promptly objected and filed suit, resulting in the judicial rescission of the sale. Equatorial subsequently claimed back rentals from Mayfair for the period after the lease expired, asserting ownership by virtue of the rescinded contract of sale.

A buyer in a rescinded sale cannot claim rentals or civil fruits of the property if delivery was never effected due to a legally sufficient impediment, or if the buyer acted in bad faith.

On August 2, 1999, Reynolan T. Sales, the incumbent mayor of Pagudpud, Ilocos Norte, fatally shot former mayor and political rival Atty. Rafael Benemerito in an alleged shootout. Sales surrendered to the municipal police and was transferred to the Provincial PNP Headquarters.

The right to file a motion for reconsideration is an integral part of the preliminary investigation, and the denial thereof renders the investigation incomplete, necessitating the quashal of the information and warrant of arrest.

On November 13, 1985, Hermogenes Fernando and Carmelita Leaño executed a contract to sell over a 431-square-meter lot in Bulacan, with Leaño agreeing to pay P107,750.00 via down payment and monthly amortizations over ten years. The contract reserved ownership with the seller until full payment and stipulated that failure to pay installments for ninety days beyond the grace period authorized the seller to cancel the contract and treat payments as rent. Leaño made several payments and constructed a house but defaulted after April 1, 1989, prompting Fernando to file an ejectment case.

A contract to sell involving real property on installment is not validly cancelled without compliance with Section 3(b) of R.A. No. 6552, which requires the seller to refund the cash surrender value to the buyer.

Complainant Antonio A. Arroyo filed an administrative complaint against Sancho L. Alcantara, Clerk of Court II of the Municipal Trial Court of Guinobatan, Albay. The complaint stemmed from Alcantara's issuance of a document that appeared to be a subpoena, directing Joaquin Opiana, Sr. (complainant's father-in-law) to appear at the MTC. The document was served by Barangay Captain Ruben Olayres, who had a dispute with the Opianas. Following the incident, Opiana, Sr. died, and complainant sought a copy of the subpoena and a certification from Alcantara, which the latter ignored or refused.

A clerk of court commits simple misconduct by exceeding their authority and using their position to summon private individuals for mediation, giving the impression of a court proceeding. Furthermore, deliberate failure to act on letters and requests within fifteen working days constitutes a violation of R.A. No. 6713, §5(a) and (d).

National Development Corporation (NDC), a government-owned and controlled corporation, leased portions of its ten-hectare compound in Sta. Mesa, Manila to Firestone Ceramics, Inc. (FIRESTONE) through a series of contracts beginning in 1965. In 1978, NDC extended the lease and expressly granted FIRESTONE a right of first refusal over the leased premises, which FIRESTONE improved with substantial constructions for its ceramic manufacturing business. In 1988, upon learning of plans to transfer the entire compound to the Polytechnic University of the Philippines (PUP), FIRESTONE sought to exercise its right of first refusal and subsequently filed an action for specific performance when its demands were ignored. President Corazon C. Aquino issued Memorandum Order No. 214, directing the transfer of the NDC compound to the National Government, which would then convey it to PUP at acquisition cost, effectively cancelling NDC's P57 million debt to the government. PUP intervened in the case, claiming status as a purchaser pendente lite.

A right of first refusal embodied in a lease contract is an integral and enforceable principal obligation, not a mere preparatory contract, such that any sale made in violation thereof is subject to rescission and the grantor may be compelled to offer the property to the grantee at the price and terms at which the property was sold to a third party.

Petitioner Fernando Santos and respondent Nieves Reyes, along with Meliton Zabat, agreed to engage in a money-lending business, with Santos as financier and the others handling solicitation and collection for a 70-15-15 profit split. Nieves later introduced Cesar Gragera, chairman of Monte Maria Development Corporation, leading to a separate lending agreement between Santos and Gragera. Zabat was eventually expelled for engaging in a competing business, and respondent Arsenio Reyes took his place. A dispute arose when Santos alleged that Nieves misappropriated funds intended for Gragera's commissions, while respondents asserted they were partners demanding their rightful profit shares.

An industrial partner's share in partnership profits must be based on net profit, not gross income. Gross income must be reduced by the expenses or losses sustained in the business before the industrial partner's proportionate share is determined.

The Sugar Regulatory Administration, a government-owned corporation, had been granting Social Amelioration Benefits to all its employees since 1963 pursuant to various legislative enactments and board resolutions. The controversy arose after the enactment of Republic Act No. 6758 (the Compensation and Position Classification Act of 1989, or Salary Standardization Law), which standardized compensation in the government sector and required prior authority for additional compensation not integrated into standardized rates.

The date of hiring is not a substantial distinction that justifies differential treatment in the grant of social amelioration benefits; distinctions in compensation must be based on substantive differences in duties, responsibilities, and qualification requirements of the positions, not on the mere date of employment.

Petitioner is the assignee of Letters Patent No. 12207 covering Cimetidine, a pharmaceutical product used as an antihistamine and for ulcer treatment, issued in 1978. Over a decade after the patent's issuance, private respondent sought a compulsory license to manufacture and sell medicines containing the same active ingredient, invoking the public health provisions of the Patent Law.

A compulsory license may be granted over a patented pharmaceutical product necessary for public health under Section 34(1)(e) of the Patent Law, as this constitutes a valid exercise of police power to prevent patent monopolies and is consistent with the Paris Convention.

The Republic, represented by the DPWH, filed an expropriation case for a flyover project against several property owners, presided over by Judge Renato A. Fuentes. The government won but owed the defendants over P15 million. A writ of execution was issued, and the sheriff levied scrap iron and junk equipment at a DPWH depot, which was subsequently sold at auction to Alex Bacquial. When a DPWH engineer prevented Bacquial from withdrawing the items—claiming some were still serviceable—Bacquial filed an ex parte urgent motion for a "break through" order. Judge Fuentes granted the motion, allowing Bacquial to haul off the equipment, including repairable items, over several days until the writ was temporarily suspended.

The Ombudsman lacks the authority to initiate or investigate a criminal or administrative complaint against a judge for acts done in relation to official functions; such complaints must be endorsed to the Supreme Court.

In 1978, Antonio Tan obtained multi-million peso loans from the Cultural Center of the Philippines (CCP). After defaulting and making partial payments, the loans were restructured in 1979 under a single promissory note. Tan defaulted again on the restructured loan. Despite multiple proposals for compromise and moratorium, CCP rejected them and filed suit for collection in 1984.

Courts may equitably reduce stipulated penalty charges under Article 1229 NCC when the penalty becomes unconscionable due to prolonged compounding, even if the debtor made partial payments showing good faith; however, penalty charges (compensatory interest) are distinct from monetary interest, and when the contract expressly permits capitalization (compounding) of unpaid interest, such stipulation has the force of law between the parties.

Elvira Ong and Yu Bun Guan, married in 1961, acquired a parcel of land in 1968 registered solely in Ong's name. In 1992, prior to their separation, Ong executed a Deed of Absolute Sale transferring the property to Yu based on his promise to construct a commercial building for their children and pay a bank loan. The stated consideration of P200,000 was never paid by Yu, and Ong even paid the capital gains tax. Yu subsequently obtained a replacement owner's copy of the title after falsely claiming it was lost, prompting Ong to file an action for nullification of the sale.

A simulated deed of sale is void and produces no legal effect, and the in pari delicto principle does not apply to such inexistent contracts.

Paulina Rigonan owned three parcels of land, a house, and a warehouse. In 1966, petitioners, claiming to be her closest surviving relatives, took possession of the properties. Private respondents, also claiming kinship, asserted ownership based on a deed of absolute sale purportedly executed by Paulina on January 28, 1965.

A deed of sale is void for lack of consent and consideration where the vendor was senile, the original document is missing, the carbon copy contains irregularities, and the price is grossly inadequate.

A land dispute between Linda Rance and Cornelio Regis, Jr. culminated in a confrontation at the Rance bodega on April 18, 1994. Barangay Captain Percival Orbe, Barangay Kagawad Antonio Macalipay, and Barangay Tanod Melchor Recto were present to pacify the parties. Appellant Julio Recto, accompanied by several others including Regis, Jr., arrived at the scene. After a heated exchange, appellant shot Macalipay, engaged in a gun duel with Emiliano "Renato" Santos, and fired at the fleeing Orbe and Melchor Recto, resulting in two deaths and two injuries.

Treachery cannot qualify a killing to murder if the accused did not deliberately seek to exploit the victim's vulnerability, particularly when the victim had the opportunity to escape or defend himself but instead placed himself in a position open to attack.

Ricardo Agliday and his wife Conchita quarreled over his drinking habit on the evening of February 25, 1999. Their 19-year-old son, Richard, intervened to pacify his father. Angered by the intervention, Agliday retrieved his unlicensed shotgun from the bedroom and shot Richard in the left buttock. Richard was rushed to three hospitals but died of hypovolemic shock. Agliday surrendered to the barangay captain shortly after the incident.

A deliberate intent to do an unlawful act is inconsistent with reckless imprudence, and malice negates the exempting circumstance of accident.

The case arises from the attempt of a litigant to seek favorable disposition of a pending case before the Supreme Court by approaching a person purporting to be a Justice of the Court, highlighting the vulnerability of litigants to fraudulent schemes involving court personnel who exploit their positions for private gain and the necessity of preserving public trust in the judiciary through strict accountability.

A court employee who poses as a magistrate to solicit money from litigants commits gross misconduct warranting dismissal from service with forfeiture of retirement benefits and subjects him to disciplinary action including disbarment, and resignation or retirement does not extinguish administrative liability or shield the respondent from disciplinary sanctions.

Respondent Tantuco Enterprises, Inc. owns two coconut oil mills in Lucena City. The first oil mill was insured for P3,000,000.00. In 1988, respondent began operating a second, "new" oil mill, which was insured for P6,000,000.00 under a separate policy from the same insurer, American Home Assurance Co. A fire on September 30, 1991, destroyed the new oil mill. The insurer rejected the claim, asserting the policy's boundary descriptions pertained to the first oil mill, not the burned new oil mill.

A misdescription in an insurance policy does not defeat recovery if the parties manifestly intended to insure the subject property, and evidence aliunde is admissible to clarify such intent under exceptions to the parol evidence rule.

Spouses Graciano del Rosario and Graciana Esguerra owned a parcel of land. Upon Graciana's death, Graciano and their six children extrajudicially settled her estate, subdividing the property. Graciano later donated a portion to his children, retaining a specific lot (TCT No. 107443). Graciano married petitioner Patricia Natcher in 1980 and subsequently sold the retained lot to her. Upon Graciano's death, his children by the first marriage sued Natcher, alleging fraud and impairment of their legitimes.

A Regional Trial Court acting in its general jurisdiction in an action for reconveyance and annulment of title lacks the authority to adjudicate matters relating to the settlement of a deceased person's estate, particularly questions of advancement of property, which must be resolved in a special proceeding before a probate court.

Rederick A. Recio, a Filipino, married Editha Samson, an Australian, in 1987. An Australian family court issued a divorce decree in 1989. Recio became an Australian citizen in 1992. He married Grace J. Garcia, a Filipina, in 1994, declaring himself "single" and "Filipino" in the marriage license application. They separated in 1995.

A foreign divorce decree and the alien spouse's national law validating it and capacitating the spouse to remarry must be specifically alleged and proven as facts, because Philippine courts do not take judicial notice of foreign laws.

Danilo B. de Jesus and Carolina Aves de Jesus were married on August 23, 1964. During this marriage, Jacqueline A. de Jesus and Jinkie Christie A. de Jesus were born on March 1, 1979, and July 6, 1982, respectively. On June 7, 1991, Juan G. Dizon executed a notarized document acknowledging Jacqueline and Jinkie as his own illegitimate children by Carolina. Juan G. Dizon died intestate on March 12, 1992, leaving substantial assets.

Children born within a valid marriage are conclusively presumed legitimate, and this status cannot be collaterally attacked in a partition suit; a direct action to impugn legitimacy must first succeed before illegitimate filiation to another can be established.

Reynaldo Villanueva, Sr., a stockholder of the Rural Bank of Lipa City, executed a Deed of Assignment transferring his shares and those of eight other shareholders to the bank's directors. The Villanueva spouses subsequently acknowledged a P4,000,000.00 debt to the bank, agreeing to pay it from the sale of real property. Upon their default, the board demanded the surrender of the stock certificates and additional collateral. The Villanuevas refused to surrender the certificates, prompting the bank to unilaterally convert the shares into treasury stocks. Excluded from the January 15, 1994 stockholders' meeting on the ground that they had relinquished their rights, the Villanuevas challenged the validity of the meeting and the election of officers.

A deed of assignment alone does not effect a valid transfer of shares of stock absent compliance with the statutory requisites of delivery of the duly endorsed certificate and recording in the corporate books under Section 63 of the Corporation Code.

In 1973, a religious group known as "The Church In Quezon City (Church Assembly Hall), Incorporated" was organized as a non-stock, non-profit religious corporation and registered with the Securities and Exchange Commission (SEC). Its Articles of Incorporation and By-laws decreed that its affairs be managed by a six-member Board of Directors. As a "brotherhood in Christ," the Church embraced specific Principles of Faith centered on the Holy Bible and the Trinity. To protect these principles, the members vested upon the Board of Directors the absolute power to admit and expel members. Admission was exacting, requiring members to be zealous of the Gospel and of sound knowledge of the Truth. Expulsion was prescribed under Article VII, paragraph 4 of the By-laws, which allowed the Board to expel a member by resolution without assigning any reason if the member's conduct was dishonorable, improper, or injurious to the institution. As early as 1988, the Board observed that certain members, including the petitioners, were introducing doctrines not based on the Holy Bible, such as worshiping Buddha or men. The Board repeatedly warned the erring members during Sunday worships, small group meetings, and one-on-one talks that continuing such conduct would result in their expulsion. The petitioners ignored these admonitions.

A religious corporation may expel a member without prior notice and hearing if its by-laws so provide, as the basis of membership is absolute adherence to a common religious belief, and civil courts will not interfere in such purely ecclesiastical matters.

On March 22, 1985, Antonio Palao sold an undivided portion of a lot to Alfonso Iringan for P295,000, payable in installments. Iringan paid a total of P50,000 but defaulted on the remaining balance. Palao, who needed the money to pay an SSS loan, sent a letter declaring the contract rescinded due to non-payment. Iringan did not oppose the revocation but demanded reimbursement. Negotiations failed, prompting Palao to seek judicial intervention.

A contract of sale involving immovable property cannot be unilaterally rescinded by mere notice; a judicial or notarial act is required, and the filing of a complaint for judicial confirmation of rescission satisfies this requirement.

The case involves Geminesse Enterprise, an informal partnership between Marjorie Tocao and Nenita Anay that was not registered with the Securities and Exchange Commission. The dispute arose when Anay was ousted from the partnership, leading her to file a complaint for accounting and damages against Tocao and William Belo, claiming Belo was also a partner. Belo contended he was merely a guarantor and friend of Tocao who occasionally assisted in business matters but never shared in profits.

The Supreme Court may reverse its previous decision upon motion for reconsideration when it honestly believes it committed an error that would cause injustice; moreover, a person who merely guarantees company obligations without participating in profits is not a partner, and a partner ousted from the business may withhold partnership assets as security for claims without being in bad faith.

The dispute originated from a 1976 Contract to Sell between Investco, Inc. and Solid Homes, Inc. covering real property in Quezon City and Marikina. Solid Homes, Inc. defaulted on its installment payments for over fourteen years. Investco, Inc. extra-judicially rescinded the contract and subsequently sold the property absolutely to AFP Mutual Benefit Association, Inc. (AFPMBAI), which paid in full and registered clean titles in its name. Meanwhile, Solid Homes, Inc. had filed Civil Case No. 40615, an action for collection of sums of money, against Investco, Inc., and attempted to annotate a notice of lis pendens on the titles through pencil markings.

A purchaser in good faith and for value is one who buys property without notice of another's claim and pays a full and fair price; provisional pencil markings on titles are ineffective as annotations of lis pendens which require proper formal annotation to protect the integrity of the Torrens system; and only the prevailing party, not the losing party, may move for execution of a final judgment as a matter of right.

The dispute arose from competing claims over a conjugal residential property covered by TCT No. 410603 registered in the names of spouses Alfonso Roxas Chua and Kiang Ming Chu Chua. Alfonso incurred separate money judgments with Metropolitan Bank and Trust Company (Metrobank) and subsequently with China Banking Corporation (Chinabank). The conflict centered on whether Alfonso's assignment of his statutory right to redeem his conjugal share (previously sold to Metrobank) to his son Paulino, and Paulino's subsequent redemption of the property, effectively divested Alfonso of any interest that Chinabank could later levy upon.

A conveyance by a debtor is not fraudulent when made for valuable consideration and in good faith, thereby rebutting the statutory presumption of fraud; furthermore, a judgment creditor acquires at an execution sale only the identical interest possessed by the judgment debtor at the time of the sale, and if the debtor has already transferred or otherwise lost such interest, the creditor acquires nothing.

The case involves the custodial rape of a minor by her uncle, highlighting the vulnerability of children placed under the care of relatives and the strict evidentiary requirements for imposing the death penalty in qualified rape cases.

For the imposition of the death penalty in rape cases under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, the twin circumstances of minority and relationship must be both alleged in the information and proved with equal certainty as the crime itself; otherwise, the accused can only be convicted of simple rape punishable by reclusion perpetua.

Severina San Miguel owned a 632-square-meter parcel of land in Panapan, Bacoor, Cavite. Dominador San Miguel subdivided it without her knowledge into three lots and obtained an original certificate of title in his favor. Severina filed a petition for review alleging fraudulent concealment, which resulted in the nullification of Dominador's title and the issuance of Transfer Certificate of Title No. T-223511 in Severina's name. Writs of possession and demolition were subsequently issued in her favor but remained unsatisfied.

A vendor cannot compel the vendee to pay the purchase price for a property the vendor has no title or proof of ownership to transfer, and an impossible condition annexed to the contract is void, leaving the principal obligation to deliver the title for the fully paid property enforceable.

The case arose from police intelligence operations targeting individuals suspected of illegal possession of high-powered firearms and explosives in Kalookan City. The operation involved the implementation of search warrants covering specific premises within a compound, which subsequently led to the discovery of weapons in both the targeted apartment and an adjacent unit not covered by the warrants, raising significant constitutional questions regarding the scope of judicial authorization and the admissibility of evidence obtained in violation of specific warrant limitations.

Evidence seized from premises not specified in a search warrant is inadmissible, as the place to be searched cannot be enlarged or amplified by the police; however, items seized from the specified premises are admissible if described with substantial particularity bearing direct relation to the offense charged, without requiring technical precision that would make obtaining warrants impossible.

On March 2, 1991, armed men boarded the M/T Tabangao, a PNOC cargo vessel laden with petroleum products worth over P40,000,000.00, off the coast of Mindoro. The pirates, led by Emilio Changco and including accused-appellants Tulin, Loyola, and Infante, seized the vessel, renamed it "Galilee," and forced the crew to sail to Singapore. In Singapore waters, the cargo was transferred to the "Navi Pride," a process supervised by accused-appellant Cheong San Hiong. The vessel returned to the Philippines, and the crew was released on April 10, 1991, with accused-appellant Cecilio Changco fetching some crew members. The accused were subsequently arrested and charged with qualified piracy under Presidential Decree No. 532.

The Court held that Presidential Decree No. 532 and Article 122 of the Revised Penal Code, as amended by Republic Act No. 7659, exist harmoniously as separate laws; piracy is an exception to the rule on territoriality in criminal law, such that Philippine courts retain jurisdiction over offenses committed outside Philippine waters if the initial attack and seizure occurred within Philippine waters; and an accused charged as a principal may be convicted as an accomplice when the evidence fails to establish conspiracy but proves aiding or abetting.

On November 27, 1997, Danilo Catubig ordered his 12-year-old daughter, Dannilyn, to a room in their house in San Jose del Monte, Bulacan, and had carnal knowledge of her. The assault was interrupted when Dannilyn's aunt, suspicious of the appellant's actions, informed the victim's mother. Upon confrontation, Dannilyn revealed the repeated abuse. A medico-legal examination confirmed a healed laceration consistent with sexual intercourse. Appellant denied the accusations, claiming his wife and daughter fabricated the charge out of resentment following a domestic quarrel.

An aggravating circumstance, whether ordinary or qualifying, entitles the offended party to exemplary damages under Article 2230 of the Civil Code, provided the circumstance was proven during trial, even if it was not alleged in the information and cannot be used to increase the criminal penalty.

Gualberto Castro, a public school teacher, faced an administrative complaint for disgraceful and immoral conduct stemming from an alleged illicit affair with a co-teacher. The DECS Regional Office VII found him guilty and imposed the penalty of dismissal, which the DECS Central Office affirmed. Castro's subsequent motions for reconsideration and review were denied by the DECS Secretary, prompting him to file a petition for mandamus with the Regional Trial Court to reduce the penalty and secure reinstatement.

The doctrine of exhaustion of administrative remedies may be dispensed with when the issue raised is a pure question of law, as administrative bodies cannot resolve such questions with finality, making an appeal to such bodies an exercise in futility.

Mamerto Ingjug died during the Second World War, leaving a parcel of land titled in his name. His five children—Romana, Francisco, Francisca, Luisa, and Maria—succeeded to the ownership of the property in common. On July 9, 1965, Luisa, Maria, Guillerma (daughter of Francisca), and Eufemio Ingjug (husband of Romana) sold the entire property to respondents through a Deed of Sale of Unregistered Land, representing themselves as the sole surviving heirs. Upon the issuance of a reconstituted title, the vendors executed an Extrajudicial Settlement and Confirmation of Sale in 1967, which purportedly bore the thumbprint of Francisco Ingjug, who had died on August 17, 1963. A new title was subsequently issued in respondents' names.

An action to declare the inexistence or nullity of a contract is imprescriptible and cannot be barred by laches, rendering a dismissal on such grounds premature when the validity of the underlying contract remains unresolved.

From 1974 to 1991, respondent Maersk-Filipinas Crewing, Inc. deployed petitioner Roberto R. Serrano as a seaman. From 1977 to 1978, Serrano instructed Maersk to send portions of his salary via money orders to his family in the Philippines. Maersk deducted the corresponding amounts totaling HK$4,600.00 and £1,050.00 Sterling Pounds from Serrano's salary, but the money orders were never transmitted to his family.

A money claim arising from employer-employee relations accrues, and the three-year prescriptive period begins to run, only upon the employer's definite denial of the employee's demand, especially where prior demands were warded off with indefinite promises of verification.

The Philippine Racing Club, Inc. (PRCI) sought to remit Australian dollars to the 20th Asian Racing Conference Secretariat in Sydney. Because respondent Far East Bank and Trust Company lacked an Australian dollar account in Sydney, the parties agreed to a roundabout remittance arrangement: the respondent bank would draw the draft against Westpac-Sydney, which would then reimburse itself from the respondent bank's U.S. dollar account in Westpac-New York.

The degree of diligence required of banks is that of a good father of a family in commercial transactions that do not involve their fiduciary relationship with depositors; the highest degree of care applies only when banks act in their fiduciary capacity as depositaries. Because the sale and issuance of a foreign exchange demand draft involves a buyer-seller relationship rather than a fiduciary one, the issuing bank is required to exert only the diligence of a good father of a family.

The case involves a parcel of land in Lingayen, Pangasinan originally owned by Adriano Soriano. Upon his death in 1947, the property passed to his heirs, including Roman Soriano, who acted as caretaker when the property was leased to third parties. Subsequently, portions of the land were sold to spouses Braulio and Aquilina Abalos. A complex history of litigation ensued involving land registration proceedings, agrarian disputes concerning tenancy rights, and civil actions for annulment of documents, culminating in the Abalos securing title to the land while Roman Soriano (later substituted by his heirs) claimed tenancy rights and continued occupation, leading to the present dispute over the issuance of a writ of possession.

A prevailing party in a land registration case cannot be granted a writ of possession to oust an occupant who claims to be an agricultural tenant with pending security of tenure rights before the DARAB; the determination of the tenancy relationship must first be resolved by the agrarian court before possession can be awarded, as the exercise of ownership rights is limited by the tenant's security of tenure.