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Green vs. Green

17th February 2025

ak221240
G.R. No. 255706
Primary Holding
Psychological assessments based on the testimonies of the petitioner, respondent, respondent's mother, and a mutual friend can be given credence in proving psychological incapacity, especially when there is no reason to believe the testimonies are fabricated. The declaration of nullity of marriage is warranted as long as the totality of the evidence clearly and convincingly establishes one spouse's psychological incapacity to perform essential marital obligations.
Background
In 2006, Jeffery A. Green, a United States Navy retiree, met Rowena Manlutac in a bar in Angeles City. They developed a relationship, during which Jeffery was aware Rowena had two children from a previous relationship and Rowena knew Jeffery's divorce was still pending. In 2008, Rowena gave birth to a daughter, Abigail, whom Jeffery acknowledged as his own. They married on May 8, 2010. Following the marriage, Jeffery discovered Rowena's infidelity, pathological gambling, deceitfulness regarding finances and the paternity of Abigail, and accumulation of significant debt, which led him to file a petition to have their marriage declared void.
Persons and Family Law
Article 36, Family Code

Cabutaje vs. Republic

15th January 2025

ak080199
G.R. No. 248569
Primary Holding
The marriage is declared void ab initio on the ground of respondent Romelia A. Cabutaje's psychological incapacity, which was sufficiently established through the totality of evidence, including expert testimony based on collateral interviews and testimonies of witnesses who knew the respondent, without the need for the respondent's direct personal examination.
Background
Ericson Cabutaje and Romelia Cabutaje married in 2003 and had a daughter. To provide for their family, both spouses eventually worked abroad in Taiwan, but their relationship deteriorated due to distance and Romelia's inconsistent financial support. After her contract ended, Romelia returned to the Philippines, took their daughter, but then left the child in her sister's care to work in Hong Kong. She ceased providing financial support and entered into another romantic relationship. These events prompted Ericson to file a petition to have their marriage declared void, alleging that both he and Romelia were psychologically incapacitated to fulfill their essential marital obligations.
Persons and Family Law
Article 36, Family Code

Padillo vs. People

9th October 2024

ak536847
G.R. No. 271012
Primary Holding
The Supreme Court acquitted Roel Gementiza Padillo because the prosecution failed to establish the validity of the search warrant's issuance and implementation, violating his constitutional rights, and failed to prove the integrity of the chain of custody of the seized items beyond a reasonable doubt.
Background
The Philippine Drug Enforcement Agency (PDEA) suspected Roel Padillo of possessing shabu at his residence in Balingoan, Misamis Oriental, prompting them to apply for and obtain a search warrant to search the premises.
Criminal Law II

SHELA BACALTOS ASILO vs. PRESIDING JUDGE MARIA LUISA LESLE2 G. GONZALESBETIC, Branch 225, Regional Trial Court, Quezon City

10th July 2024

ak524241
G.R. No. 232269
Primary Holding
In a petition for recognition of a foreign divorce decree under Article 26(2) of the Family Code, the nationality of the alien spouse at the time of the divorce and the specific national law of the alien spouse that recognizes the divorce and capacitates them to remarry are ultimate facts that must be specifically alleged in the initiatory pleading and duly proven during trial to establish a cause of action.
Background
Shela Bacaltos Asilo, a Filipino citizen, married Tommy Wayne Appling, a foreign national, in Hong Kong on November 1, 2002. They lived together in Hong Kong until their separation on August 11, 2011. Subsequently, they obtained a divorce decree in Hong Kong. To have the divorce recognized in the Philippines and to be able to revert to her maiden name, Shela filed a Petition for Recognition of a Foreign Judgment of Divorce with the Regional Trial Court of Quezon City.
Persons and Family Law
Family Code, Article 26(2)

People vs. Adrales

22nd May 2024

ak003925
G.R. No. 242473
Primary Holding
The recruitment, transportation, transfer, harboring, or receipt of a child for the purpose of exploitation constitutes qualified trafficking in persons, even with the child's consent or knowledge; evidence of the child victim's past sexual conduct or predisposition is inadmissible under the sexual abuse shield rule to discredit the victim or negate the accused's liability.
Background
The case originated from accusations that Adrian Adrales, an adult, engaged in recruiting and facilitating the sexual exploitation of AAA, a 14-year-old minor, by introducing her to different men for sexual intercourse in exchange for money. These incidents allegedly occurred on multiple occasions in July and August 2011, leading to charges of qualified trafficking in persons due to the victim's minority.
Criminal Law II
Anti-Trafficking in Persons Act

Lanuza vs. Lanuza

17th April 2024

ak077510
953 Phil. 796 , G.R. No. 242362
Primary Holding
Unjustified absence from the marital home for decades, coupled with other manifestations such as infidelity and contracting subsequent marriages, can be considered as part of the totality of evidence proving that a person is psychologically incapacitated to comply with the essential obligations of marriage under Article 36 of the Family Code.
Background
Leonora O. Dela Cruz-Lanuza and Alfredo M. Lanuza, Jr. were married in June 1984 and had four children. According to Leonora, their married life started smoothly but later deteriorated when Alfredo began coming home late, neglecting his family, and engaging in illicit affairs. The couple eventually separated in 1994. Following their separation, Alfredo abandoned the family completely, failed to provide any financial support, and reportedly entered into two subsequent marriages with other women, which became the basis for Leonora's petition to have their marriage declared void.
Persons and Family Law
Family Code, Article 36

Republic of the Philippines vs. Ruby Cuevas Ng a.k.a. Ruby Ng Sono

27th February 2024

ak961631
G.R. No. 249238
Primary Holding
A foreign divorce obtained by mutual agreement between a Filipino spouse and a foreign spouse is within the ambit of Article 26, paragraph 2 of the Family Code and may be judicially recognized in the Philippines, as the law does not distinguish between divorces obtained through judicial proceedings and those obtained through other means, so long as the divorce is validly obtained abroad and capacitates the foreign spouse to remarry.
Background
Respondent Ruby Cuevas Ng, a Filipino citizen, married Akihiro Sono, a Japanese national, in the Philippines in 2004. They subsequently moved to Japan and had a child. After their relationship soured, they jointly secured a "divorce decree by mutual agreement" in Japan in 2007. This led Ng to file a petition in the Philippines for the judicial recognition of their foreign divorce to allow her to remarry under Philippine law.
Persons and Family Law
Article 26(2), Family Code

People vs. ABC260708

23rd January 2024

ak737802
G.R. No. 260708
Primary Holding
When the elements of statutory rape (victim below the statutory age) concur with special qualifying aggravating circumstances under Article 266-B of the Revised Penal Code (such as minority and relationship, victim below 7 years old, or offender's knowledge of victim's mental disability), the proper designation of the crime is "Qualified Rape of a Minor," not "qualified statutory rape"; the special qualifying circumstance absorbs the inherent circumstance of the victim's age, elevating the crime to qualified rape.
Background
The case arose from charges filed against the accused, ABC260708, for committing rape through carnal knowledge and rape through sexual assault (oral rape) against his own daughter, AAA260708, who was eight years old at the time of the incidents in March 2015.
Criminal Law II
Rape

People vs. XXX65439

13th November 2023

ak529192
G.R. No. 265439
Primary Holding
The accused, a minor who acted with discernment, is guilty of two counts of statutory rape, not qualified statutory rape, when the qualifying circumstance of relationship within the third civil degree is not specifically alleged in the Information, even if the victim is his niece. Furthermore, two penetrations committed without a significant interval constitute only one count of rape.
Background
The case arose from accusations that XXX265439, then 17 years old, raped his 9-year-old niece, AAA265439, on three separate occasions in February 2010. The relationship between the accused and the victim (uncle-niece) and the victim's age were central to the charges.
2025 BarOps Criminal Law

People vs. Flores

11th October 2023

ak680841
G.R. No. 262686
Primary Holding
The presumption of regularity in the performance of police duties cannot overcome the stronger presumption of innocence. The prosecution failed to establish guilt beyond reasonable doubt due to serious lapses in the chain of custody and the failure to properly prove the identities and credentials of mandatory insulating witnesses during the inventory of seized drugs. Accused-appellants are acquitted.
Background
Accused-appellants were apprehended in a buy-bust operation for allegedly selling and possessing methamphetamine hydrochloride (shabu). The Regional Trial Court (RTC) convicted them, and the Court of Appeals (CA) affirmed with slight modification. The case reached the Supreme Court via a Notice of Appeal. Accused-appellant Truelen passed away during the appeal process.
Criminal Law II

People vs. Yap

4th October 2023

ak900951
G.R. No. 255087
Primary Holding
The prosecution must prove beyond reasonable doubt all elements of Sections 3(e) and 3(g) of Republic Act No. 3019; a mere violation of procurement laws or contractual terms, without establishing the requisite criminal intent (manifest partiality, evident bad faith, or gross inexcusable negligence) or the specific harm (undue injury, unwarranted benefit, or a manifestly and grossly disadvantageous contract), is insufficient for conviction. The accused's constitutional right to be informed of the nature and cause of the accusation prevents conviction based on facts not alleged in the Information.
Background
In preparation for the 12th ASEAN Summit in Cebu in December 2006, the Mactan Cebu International Airport Authority (MCIAA), a government-owned and controlled corporation, sought to upgrade its firefighting capabilities by purchasing one unit of an Aircraft Rescue Fire Fighting Vehicle (ARFFV) through limited source bidding. This procurement process, the subsequent contract, and related payments became the subject of criminal charges against MCIAA officials and the supplier's representative.
2025 BarOps Criminal Law

People vs. Abdul Azis Y Sampaco a.k.a. Mohammad Macapundag Guimbor and Alibair Macadato Y Macadato

30th August 2023

ak970044
G.R. No. 258873
Primary Holding
A warrantless arrest _in flagrante delicto_ is lawful when police officers, from a close distance, observe overt acts indicating that the accused are committing or attempting to commit a crime, such as the handling and exchange of suspected illegal drugs; the subsequent search incidental to such lawful arrest is valid, and the seized items are admissible. Substantial compliance with the chain of custody rule under Section 21 of Republic Act No. 9165, as amended, is sufficient if the integrity and evidentiary value of the seized drugs are preserved, and justifiable grounds for non-compliance (such as safety concerns and unavailability of all required witnesses despite diligent efforts) are established, especially when dealing with a substantial quantity of drugs that negates the likelihood of planting or tampering.
Background
The case arose from an anti-drug operation called "Oplan Galugad" conducted by police operatives in Caloocan City. This operation was part of the broader governmental campaign against illegal drugs, targeting areas known for drug activities. The accused-appellants were apprehended during this specific operation.
2025 BarOps Criminal Law

People vs. Nuñez

14th August 2023

ak001850
G.R. No. 263706
Primary Holding
The recruitment of minors for sexual exploitation, evidenced by acts such as bringing them to a hotel, negotiating terms for sexual services with a decoy officer, and receiving payment, constitutes the consummated crime of qualified trafficking in persons under Republic Act No. 9208, especially when the victims' minority and the large-scale nature of the crime (three victims) are established; a minor's consent in such circumstances is legally irrelevant, and a defense of denial cannot overcome positive identification and evidence from a valid entrapment operation.
Background
The case arose from an information received by the Philippine National Police Regional Anti-Human Trafficking Task Force (PNP-RATTF) about a woman named "Faith" (later identified as the accused-appellant) offering minors for sex. This led to an entrapment operation planned and executed in Cebu City, involving a decoy police officer posing as a representative of an American customer interested in procuring minors for sexual exploitation.
2025 BarOps Criminal Law

People vs. Delos Reyes

14th August 2023

ak686082
G.R. No. 264958
Primary Holding
The actual deprivation of the victim's liberty, coupled with the indubitable proof of the accused's intent to effect such deprivation, and the victim being a minor, are sufficient to constitute the crime of serious illegal detention under Article 267 of the Revised Penal Code.
Background
The case arose from an incident where the accused-appellant, Jonnel Delos Reyes, allegedly detained a 15-year-old minor, AAA264958, between October 23 and October 25, 2014, in Bataan. This detention was purportedly part of the minor's initiation into the Triskellion Fraternity, during which he was subjected to acts that deprived him of his liberty and constituted child abuse.
2025 BarOps Criminal Law

Axel Tria y Cipriano vs. People

2nd August 2023

ak532384
G.R. No. 255583
Primary Holding
The commission of robbery through the use of information and communications technologies, such as demanding money in exchange for deleting compromising photos posted online, subjects the offender to a penalty one degree higher than that provided for by the Revised Penal Code, pursuant to Section 6 of Republic Act No. 10175 (Cybercrime Prevention Act of 2012).
Background
The case arose from a soured romantic relationship between petitioner Axel Tria y Cipriano (Tria) and private complainant AAA. After their relationship deteriorated, Tria allegedly posted nude photos of AAA online and demanded money from her in exchange for their deletion, leading to criminal charges for robbery and online libel.
2025 BarOps Criminal Law

People vs. Karen Aquino y Gabriel, Rey Rosal y Bobis, Jeffrey Dela Cruz y Sanchez, and Ericson Mariano y Peraldal

31st July 2023

ak197701
G.R. No. 263264
Primary Holding
The Supreme Court held that trafficking in persons may be committed with or without the victims' consent, and that when committed by three or more persons conspiring together, it qualifies as "trafficking committed by a syndicate" under Section 6(c) of R.A. No. 9208, warranting the penalties of life imprisonment and a fine of not less than PHP 2,000,000.00.
Background
The case arose from incidents between January 5, 2017 and February 1, 2017, where two minors, BBB263264 (13 years old) and AAA263264 (14 years old), were recruited through Facebook, transported to various locations, and made to engage in sexual acts with different men in exchange for money. The victims stayed with Aquino and Rosal for approximately one month and were subjected to sexual exploitation almost daily until they decided to leave and report the incidents to authorities.
2025 BarOps Criminal Law

People vs. Custodio

14th June 2023

ak683442
G.R. No. 251741
Primary Holding
The failure of police officers to conduct the inventory and taking of photographs of seized dangerous drugs at the place of seizure, or to provide a justifiable reason for conducting it elsewhere (such as at the nearest police station or office of the apprehending team), constitutes a significant breach in the chain of custody, warranting the acquittal of the accused.
Background
The case arose from a buy-bust operation conducted on October 19, 2015, in Dumaguete City, where accused-appellant Chris John Custodio y Argote, also known as "Bolongkoy," was arrested for allegedly selling and possessing shabu. The operation was initiated based on information from a confidential informant.
2025 BarOps Criminal Law

Quizon-Arciga vs. Baluyut

14th June 2023

ak168457
G.R. No. 256612
Primary Holding
A party is barred by estoppel by laches from questioning a court's jurisdiction over the subject matter if they actively participated in all stages of the case before the lower court and only raised the jurisdictional challenge belatedly after an unfavorable judgment, especially after a significant lapse of time.
Background
The case originated from a loan obtained by Relia Arciga from Jaycee P. Baluyut, secured by a Real Estate Mortgage (REM) over a property co-owned by Relia and her mother, Rita Quizon-Arciga. The authority to mortgage was derived from an Extra-Judicial Settlement of Estate/Partition with Special Power of Attorney (EJS-SPA). Upon default, Baluyut initiated judicial foreclosure proceedings.
Civil Procedure I

Odilao vs. Union Bank of the Philippines

26th April 2023

ak759840
G.R. No. 254787
Primary Holding
A restrictive venue stipulation in a contract specifying venue choices (e.g., Place A or Place B) "at the absolute option" of one party (the creditor/mortgagee) does not prevent the other party (debtor/mortgagor) from initiating a lawsuit in *either* of the specified venues; the "absolute option" primarily governs the venue choice when the party granted the option is the one filing the suit and does not serve as a condition precedent restricting the other party's right to file in a contractually permitted location.
Background
Petitioner Lucille Odilao and her husband entered into loan and real estate mortgage agreements with respondent Union Bank of the Philippines. The petitioner later sought judicial reformation of these agreements, contending they were contracts of adhesion and did not accurately reflect the parties' true intentions concerning various terms, including notices, interest, penalties, and venue procedures.
Civil Procedure I
Motion

Go vs. Court of Appeals

29th March 2023

ak010365
G.R. No. 244681
Primary Holding
A prior unregistered sale where ownership has already been vested in the buyer prevails over a subsequent registered levy on execution, as a judgment debtor can only transfer property in which they have an interest at the time of the levy; service of summons by publication is valid when, after diligent efforts to serve personally or by substitution prove futile, particularly due to the defendant's own ambiguous or misleading information regarding their address.
Background
Petitioner Vicente C. Go obtained a favorable judgment in a sum of money case against Setcom Inc. and others (RTC-Manila). To satisfy the judgment, a property registered under the name of Spouses Francisco and Ma. Teresa Bernardo (judgment debtors) was levied upon and sold at an execution sale to Go as the highest bidder. Go, however, failed to consolidate his title. Subsequently, Spouses Rafael and Rosario Colet filed a case to quiet their title over the same property (RTC-Quezon City), claiming they had purchased it from Spouses Bernardo several years prior to Go's levy, although this sale was unregistered. The RTC-QC ruled in favor of Spouses Colet.
Civil Procedure I

Petron Corporation vs. Commissioner of Internal Revenue

20th March 2023

ak403390
G.R. No. 255961
Primary Holding
Alkylate is not subject to excise tax under Section 148(e) of the 1997 NIRC, as amended, because it is not expressly listed therein, nor does it fall under the category of "other similar products of distillation" as it is produced through alkylation (a chemical process) rather than distillation (a physical separation process) and possesses distinct properties and uses compared to naphtha and regular gasoline.
Background
Petron Corporation, a manufacturer of petroleum products, imported alkylate for use as a blending component in gasoline production. Following a Bureau of Internal Revenue (BIR) letter dated June 29, 2012, implemented by Bureau of Customs (BOC) Customs Memorandum Circular (CMC) No. 164-2012 dated July 18, 2012, alkylate was deemed "similar to that of naphtha" and subjected to excise tax under Section 148(e) of the NIRC. Petron paid the taxes but contended they were erroneously imposed.
Civil Procedure I

Clavecilla vs. Clavecilla

6th March 2023

ak396412
937 Phil. 488 , G.R. No. 228127
Primary Holding
Either spouse, regardless of whether they are the one alleged to be psychologically incapacitated, may initiate a petition to declare the nullity of marriage under Article 36 of the Family Code, and the doctrine of unclean hands cannot be invoked to bar such a petition.
Background
The petitioner, Fernando Clavecilla, and respondent, Marivic Clavecilla, met and married while working as overseas Filipino workers in Saudi Arabia in the late 1980s. After nearly two decades of marriage and having one child, their relationship deteriorated, prompting Fernando to file a petition for the declaration of nullity of their marriage on the ground of psychological incapacity.
Persons and Family Law
Family Code, Article 36

Georfo vs. Republic

6th March 2023

ak019581
937 Phil. 518 , G.R. No. 246933
Primary Holding
Psychological incapacity under Article 36 of the Family Code is a legal concept, not a medical illness, and its existence can be proven by clear and convincing evidence showing a party's personality structure renders them truly unable to comprehend and discharge their essential marital obligations; consequently, a psychiatric examination of the alleged incapacitated spouse is not required, and an expert's psychological evaluation based on collateral information is admissible and can be given probative value as part of the totality of evidence.
Background
Agnes Padrique Georfo and Joe-Ar Jabian Georfo were married in 2002 after Agnes's family presumed they had engaged in premarital sex. The marriage was characterized by conflict with Joe-Ar's family, physical abuse, infidelity on Joe-Ar's part, and his failure to provide financial support. After eight years of separation, Agnes filed a petition to declare their marriage void on the ground of Joe-Ar's psychological incapacity, presenting her own testimony, her sister's corroborating testimony, and a psychological report from an expert who diagnosed Joe-Ar without personally examining him.
Persons and Family Law
Article 36, Family Code

Monasterial vs. Fontamillas and Kingsville Construction and Development Corporation

13th February 2023

ak472331
G.R. No. 261457
Primary Holding
A Petition for Review on Certiorari under Rule 45 of the Rules of Court is generally confined to questions of law, and factual findings of the trial court that are affirmed by the Court of Appeals are binding upon the Supreme Court unless specific exceptions apply; in actions to recover property, the plaintiff bears the burden of clearly identifying the property claimed and must rely on the strength of their own title, with unapproved survey plans being insufficient to establish property identity against a registered Torrens title, and an action for forcible entry is not the appropriate remedy for resolving what is essentially a boundary dispute.
Background
The case originated from a possessory dispute where petitioner Rosario N. Monasterial filed an action for forcible entry against respondents Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation. Monasterial alleged that respondents unlawfully deprived her of physical possession of a portion of land she claimed, prompting her to seek judicial remedy to recover said possession. The core of the dispute involved Monasterial's claim of prior possession over an unregistered property versus Kingsville's assertion of ownership based on a Torrens title.
Civil Procedure I

Spouses Libiran vs. Elisan Credit Corporation

13th February 2023

ak651801
G.R. No. 255239
Primary Holding
In a judicial foreclosure suit, which is a real action, the assessed value of the subject property must be alleged in the complaint to determine which court has original jurisdiction; failure to do so is fatal to the plaintiff's cause and warrants dismissal.
Background
Spouses Tomas Libiran and Potenciana Feliciano (Spouses Libiran) obtained several loans from Elisan Credit Corporation (Elisan), secured by a real estate mortgage over a parcel of land. The mortgage contract stipulated that the property would secure not only the initial loan but also all other obligations subsequently incurred. Spouses Libiran allegedly failed to pay their total obligation, including interests and penalties, prompting Elisan to file a complaint for judicial foreclosure.
Civil Procedure I

Orillo v. People of the Philippines

30th January 2023

ak619123
934 Phil. 728 , G.R. No. 206905
Primary Holding
The posting of documents detailing a criminal complaint against a private individual on a public bulletin board, motivated by ill will and without justifiable motive, constitutes libel because malice is presumed from the defamatory imputation, and such act does not fall under privileged communication when done by third parties not involved in the original proceedings.
Background
The case arose after an election of officers for the Pasay-Alabang-FTI South Expressway Jeepney Operators and Drivers Association (PAFSEJODA) on March 23, 2002. The petitioners, Orillo and Danieles, were losing candidates, while the complainant, Romeo Cabatian, a retired member of the Philippine National Police, won as Vice President. Approximately a month after the election, documents pertaining to a carnapping complaint filed by Jean Jardeleza against Cabatian were posted on the PAFSEJODA terminal's bulletin board.
Criminal Law II
Libel and Cyberliberl

Bayan Muna Party-List Representatives Ocampo and Casiño vs. President Macapagal-Arroyo

10th January 2023

ak943836
932 Phil. 753 , G.R. No. 182734
Primary Holding
The Tripartite Agreement for Joint Marine Seismic Undertaking (JMSU) is unconstitutional and void because it allows wholly-owned foreign corporations to participate in the exploration of the Philippines' natural resources (petroleum) without complying with the safeguards provided in Section 2, Article XII of the 1987 Constitution, particularly the requirement that such agreements be entered into by the President and that the State maintain full control and supervision.
Background
The case arose from the signing of the Tripartite Agreement for Joint Marine Seismic Undertaking (JMSU) on March 14, 2005, by the Philippine National Oil Company (PNOC), China National Offshore Oil Corporation (CNOOC), and Vietnam Oil and Gas Corporation (PETROVIETNAM). The JMSU aimed to conduct joint research of petroleum resource potential in a 142,886 square kilometer area in the South China Sea, designated as a "pre-exploration activity," with the stated goal of transforming the South China Sea into an area of peace, stability, cooperation, and development. This agreement became controversial due to its implications on national sovereignty and the constitutional provisions governing the exploration and utilization of natural resources within Philippine territory and its exclusive economic zone (EEZ).
Constitutional Law I

Lastimosa v. People of the Philippines

5th December 2022

ak902976
932 Phil. 31 , G.R. No. 233577
Primary Holding
For a libel suit to prosper, the element of identifiability of the victim must be established beyond reasonable doubt; it is insufficient that the complainant recognizes themselves as the person defamed if third persons reading the article could not reasonably ascertain that the article referred to the complainant, especially when the identification relies merely on auditory similarities of names or uncorroborated hearsay.
Background
The case arose from an allegedly libelous article written by petitioner Leo A. Lastimosa, a known media practitioner and critic of then Cebu Governor Gwendolyn F. Garcia. The article, titled "Si Doling Kawatan," described a character named "Doling" who suddenly amassed wealth and exhibited negative traits. Garcia filed a libel case, claiming she was the person referred to as "Doling."
Criminal Law II
Libel and Cyberlibel

Nisperos vs. People

29th November 2022

ak942626
G.R. No. 250927
Primary Holding
The conviction of Mario Nisperos y Padilla for violation of Section 5, Article II of R.A. No. 9165 is reversed and set aside due to the prosecution's failure to prove an unbroken chain of custody, specifically regarding the presence of mandatory witnesses at the place of apprehension for the immediate inventory of seized drugs, leading to reasonable doubt.
Background
Petitioner Mario Nisperos y Padilla was charged with selling methamphetamine hydrochloride (shabu) in a buy-bust operation. The prosecution presented evidence of a pre-arranged buy-bust conducted by police officers based on information from a confidential informant. The defense contested the legality of the operation, particularly the chain of custody of the seized drug.
Criminal Law II

People vs. Agao

4th October 2022

ak513960
930 Phil. 559 , G.R. No. 248049
Primary Holding
For the crime of rape by sexual intercourse through penile penetration to be consummated, the penis must penetrate the cleft of the labia majora (also known as the vulval or pudendal cleft), even in the slightest degree; mere touching or grazing of the external surface (mons pubis or fleshy part of the labia majora) without penetrating the cleft only constitutes attempted rape or acts of lasciviousness, depending on intent.
Background
The case arose from allegations of repeated sexual abuse committed by the accused-appellant, Efren Agao, against his minor stepdaughter, AAA, starting when she was 10 years old in 2009/2010 and continuing until 2012. Agao lived with AAA and her mother, BBB. The specific charges relate to incidents in July 2010 and January 2012.
Criminal Law II
Rape

Knutson v. Judge Sarmiento-Flores

12th July 2022

ak144148
925 Phil. 638 , G.R. No. 239215
Primary Holding
Republic Act No. 9262 allows a father to apply for protection and custody orders on behalf of his minor child against the child's mother who has allegedly committed acts of violence against the child; the mother can be considered an offender under the Act in such circumstances.
Background
Randy Michael Knutson, an American citizen, and Rosalina Sibal Knutson, a Filipina, married and had a daughter, Rhuby. After their estrangement due to Rosalina's alleged extra-marital affairs, gambling addiction, and neglect of Rhuby, Randy claimed Rosalina also maltreated Rhuby physically and psychologically, including threatening to kill her. These events led Randy to seek legal protection for Rhuby.
Criminal Law II
VAWC

Marquez vs. Commission on Elections

28th June 2022

ak986321
924 Phil. 179 , G.R. No. 258435
Primary Holding
The Commission on Elections gravely abuses its discretion when it declares a candidate a nuisance based on grounds such as being "virtually unknown" or lacking political party affiliation, as these are effectively indirect means of imposing a property or financial capacity requirement, which is unconstitutional. The bona fide intention to run for office cannot be conflated with a candidate's financial capacity, popularity, or political connections, and the burden of proving that a candidate is a nuisance rests on the party alleging it, not on the candidate.
Background
Norman Cordero Marquez filed his Certificate of Candidacy (COC) for Senator for the May 9, 2022 National and Local Elections. Subsequently, the COMELEC Law Department initiated a motu proprio petition to declare him a nuisance candidate, alleging he had no bona fide intention to run, was not publicly known, ran as an independent candidate without party support, and lacked the capability to mount a nationwide campaign. This was Marquez's second attempt to run for Senator, having been previously declared a nuisance candidate for the 2019 elections on grounds of financial incapacity, a declaration later overturned by the Supreme Court.
2025 BarOps Political Law

Republic vs. Kikuchi

22nd June 2022

ak901162
1020 SCRA 376 , G.R. No. 243646
Primary Holding
For a petition for judicial recognition of a foreign divorce to prosper under Article 26 of the Family Code, the petitioner must prove two distinct elements: (1) the fact of the divorce, and (2) the national law of the foreign spouse allowing for the divorce. While an authenticated "Acceptance Certificate" from a Japanese local government office suffices to prove the fact of an administrative divorce, a mere photocopy of an unofficial English translation of the foreign law, even if stamped by the foreign embassy's library, is insufficient to prove the foreign law itself.
Background
Jocelyn Asusano Kikuchi, a Filipino, married Fumio U. Kikuchi, a Japanese national, in 1993. In 2007, they jointly filed for and obtained a divorce before the City Hall of Sakado City, Saitama Prefecture, Japan. Subsequently, Jocelyn sought to have this foreign divorce recognized in the Philippines to regain her capacity to remarry under Philippine law, leading her to file a petition for judicial recognition.
Persons and Family Law
Family Code, Article 26

Cayabyab-Navarrosa vs. Navarrosa

20th April 2022

ak399202
1018 SCRA 644 , G.R. No. 216655
Primary Holding
Psychological incapacity under Article 36 of the Family Code is a legal, not a medical, concept, and it is not a mental incapacity or a personality disorder that must be proven through expert opinion; rather, it is a party's genuine inability to comprehend and comply with their essential marital obligations, which can be established by clear and convincing evidence of their dysfunctional behavior during the marriage, even without a formal psychological diagnosis of the incapacitated spouse.
Background
Petitioner Lovelle Shelly S. Cayabyab-Navarrosa and respondent Mark Anthony E. Navarrosa met in 2001 and became lovers. In 2004, they moved to Singapore to work. After the petitioner became pregnant, they returned to the Philippines and married on August 15, 2006. The respondent had lost his job prior to the wedding, making the petitioner the sole provider. The marriage quickly deteriorated due to the respondent's financial irresponsibility, emotional and verbal abuse, and eventual abandonment of the petitioner and their child in August 2007, prompting the petitioner to file for the nullity of their marriage.
Persons and Family Law
Article 36, Family Code

Peñas v. Commission on Elections

15th February 2022

ak856264
919 Phil. 513 , UDK-16915
Primary Holding
The COMELEC's inordinate and unjustified delay of approximately six years in conducting and resolving the preliminary investigation for an election offense violates the accused's constitutional right to a speedy disposition of cases, warranting the dismissal of the complaint.
Background
The case arose from petitioner Joseph Roble Peñas's candidacy for Mayor of Digos City in the 2010 National and Local Elections. After the election, he filed his Statement of Contributions and Expenditures (SOCE), declaring P600,000.00 in expenses. The COMELEC Campaign Finance Unit later informed him that, based on the number of registered voters and the P3.00 per voter limit for candidates belonging to a political party, his allowed expenditure was only P281,403.00, indicating he had overspent. This led to a formal complaint for election overspending.
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Morales v. People of the Philippines

4th January 2022

ak148514
919 Phil. 86 , G.R. No. 240337
Primary Holding
Article 365 of the Revised Penal Code punishes reckless imprudence as a distinct crime, not merely as a way of committing a crime. Consequently, Article 48 of the RPC (on complex crimes) does not apply to quasi-crimes. When a single act of reckless imprudence results in multiple consequences, such as physical injuries and damage to property, separate penalties must be imposed for each consequence: a penalty for the physical injuries based on their severity (grave, less grave, or light felony had they been intentional) and a fine for the damage to property, as prescribed under Article 365.
Background
The case arose from a vehicular collision on May 14, 2013, in Angeles City. Petitioner Francis O. Morales, driving a Mitsubishi Delica Van, overtook another vehicle and collided with an Isuzu Jitney driven by Rico Mendoza. The collision resulted in physical injuries to Rico Mendoza, Lailani Mendoza, Myrna Cunanan, and Albert Vital (passengers of the jeepney), and extensive damage to the jeepney owned by Noel G. Garcia.
Criminal Law II
Reckless Imprudence

Cariaga vs. Republic

7th December 2021

ak229521
1010 SCRA 398 , G.R. No. 248643
Primary Holding
A certification from the local civil registrar stating that there is no record of a specific marriage license being issued to the petitioning parties, and that the said license number was in fact issued to a different couple, is sufficient evidence to prove the absence of a valid marriage license and overcome the presumption of a valid marriage, especially when the State fails to present contrary evidence.
Background
Lovelle Cariaga and Henry Cariaga were college sweethearts who married in 2000 after Lovelle became pregnant. Their parents arranged for a friend to handle the documentary requirements for the civil wedding. After thirteen years and three children, the couple separated in 2013 due to differences. In 2015, upon learning that Henry was in a relationship with another woman, Lovelle consulted a lawyer to have her marriage annulled. On her lawyer's advice, she verified the authenticity of the marriage license indicated on their Certificate of Marriage with the Civil Registry of Quezon City. This investigation led to the discovery that the license was issued to another couple, prompting her to file a petition to declare her marriage void.
Persons and Family Law
Family Code, Articles 2, 3, and 4

Calleja vs. Executive Secretary

7th December 2021

ak549249
G.R. No. 252578
Primary Holding
The Court voided parts of Section 4 (the qualifiers "intent to intimidate" and "create risk to public safety") and Sections 12 (inciting to commit terrorism), 25(e) (automatic adoption of UN-designated terrorists), and 29 (detention without warrant for 24 days). Other provisions survived constitutional scrutiny.
Background
The Anti-Terrorism Act of 2020 (ATA) was enacted to replace the criticized Human Security Act of 2007, aiming to strengthen counter-terrorism measures and align with international standards (e.g., UN protocols, FATF guidelines). Civil society groups, journalists, and activists filed petitions arguing the law’s vague definitions (e.g., “terrorism,” “inciting”) and expanded executive powers threatened constitutional rights, enabling state abuse through arbitrary designations and surveillance. The government asserted the law was necessary to address evolving threats from groups like Abu Sayyaf and communist rebels while avoiding international sanctions for non-compliance with anti-terrorism financing rules. The case emerged amid heightened polarization over national security policies and concerns over “red-tagging” practices linking dissenters to terrorism.
Constitutional Law I Constitutional Law II Criminal Law II

Baysa vs. Santos

2nd December 2021

ak431265
917 Phil. 372 , G.R. No. 254328
Primary Holding
Administrative complaints are not the appropriate remedy for alleged errors committed by a quasi-judicial officer in the exercise of their adjudicative functions where judicial remedies exist and are available; administrative liability for such acts requires clear proof of bad faith, premeditation, obstinacy, or intentional wrongdoing, which was not established in this case.
Background
The case originated from DARAB Case No. R-03-02-990799, where petitioner Baysa, as PARAD, rendered a decision in favor of tenants Cabral and Vda. de Almario against Spouses Pascual. This decision became final and executory. During the execution stage, a writ of demolition was sought, and respondent Santos, who claimed ownership of an adjoining property allegedly affected by the demolition, became involved despite not being an original party. Santos alleged her property was erroneously included and that she was denied due process.
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Ordaneza vs. Republic

24th November 2021

ak046635
1007 SCRA 499 , G.R. No. 254484
Primary Holding
A petition for the judicial recognition of a foreign divorce decree is a distinct action from a petition for the cancellation or correction of an entry in the civil registry under Rule 108 of the Rules of Court; while the former may be granted based on Rule 39, the latter requires strict compliance with the jurisdictional requirements of Rule 108, including proper venue and the impleading of indispensable parties like the Local Civil Registrar and the Civil Registrar General.
Background
The case arises from the legal challenge faced by Filipino citizens who are married to foreign nationals and obtain a divorce abroad. Under Philippine law, absolute divorce is not permitted for Filipino citizens. However, Article 26, paragraph 2 of the Family Code provides a remedy, allowing a Filipino spouse to remarry if a divorce is validly obtained abroad by the alien spouse that capacitates the latter to remarry. This provision necessitates a judicial proceeding in the Philippines to recognize the foreign divorce decree before its effects, such as the change in civil status, can be recorded in the Philippine civil registry.

Rivera vs. Woo Namsun

23rd November 2021

ak651650
1007 SCRA 90 , G.R. No. 248355
Primary Holding
A party pleading a foreign divorce decree must prove the divorce as a fact and demonstrate its conformity to the foreign law allowing it, in accordance with Sections 24 and 25 of Rule 132 of the Rules of Court; however, in the interest of substantial justice and to uphold the purpose of Article 26 of the Family Code, the Supreme Court may remand the case for further proceedings and reception of evidence rather than dismiss it for failure to strictly comply with these evidentiary rules.
Background
Maricel L. Rivera, a Filipina, married Woo Namsun, a South Korean national, in the Philippines. After moving to South Korea, their marriage deteriorated, and Woo Namsun obtained a divorce decree from the Seoul Family Court, after which he remarried. Seeking to remarry as well, Rivera filed a petition in the Philippines for the judicial recognition of the foreign divorce decree to capacitate her to contract another marriage, as required under Philippine law. The case escalated to the Supreme Court after the Court of Appeals overturned the trial court's initial grant of her petition due to deficiencies in her evidentiary submissions.
Persons and Family Law
Article 26, Family Code

Venus Commercial Co., Inc. vs. Department of Health

18th November 2021

ak645370
916 Phil. 16 , G.R. No. 240764
Primary Holding
The challenged provisions of Republic Act No. 3720, as amended by Republic Act No. 9711, specifically Sections 10(ff), 12(a), and 30(4), as well as Section 2(b) paragraph (5), Article III of Department Circular No. 2011-0101 (IRR), and FDA Personnel Order No. 2014-220, are not unconstitutional. The FDA's authority to issue orders of seizure, hold products in custody, and padlock establishments, even pending hearing, is a valid exercise of police power for public health protection, falls under permissible administrative searches, does not constitute undue delegation of legislative power, and does not violate due process or the right against self-incrimination.
Background
The case arose from a complaint by EcoWaste Coalition to the Food and Drug Administration (FDA) regarding the alleged high lead content in Artex Fine Water Colors manufactured by petitioner Venus Commercial Co., Inc. (Venus) without FDA approval. Subsequent FDA laboratory analysis confirmed that the lead content in the watercolor samples exceeded the maximum tolerable limits. This led the FDA to issue Personnel Order No. 2014-220 authorizing the inspection of Venus's premises, seizure of the violative watercolors, and/or padlocking of the establishment, prompting Venus to challenge the legality and constitutionality of the FDA's actions and the underlying laws.
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Seares, Jr. vs. National Electrification Administration Board

18th November 2021

ak673905
916 Phil. 91 , G.R. No. 254336
Primary Holding
The National Electrification Administration Board (NEAB) violated a petitioner's right to due process when it failed to clearly and distinctly state the specific factual findings corresponding to each administrative charge, thereby preventing the petitioner from adequately preparing a defense. Furthermore, administrative liability requires substantial evidence, and mere reliance on an audit report without specific proof of corruption, willful intent to violate the law, or flagrant disregard of established rules for grave misconduct, malicious intent for dishonesty, or want of even slight care for gross negligence, is insufficient to hold an official liable.
Background
Petitioner Loreto P. Seares, Jr. was appointed General Manager of Abra Electric Cooperative, Inc. (ABRECO) in October 2007. The National Electrification Administration (NEA), through its Electric Cooperative Audit Department (ECAD), conducted a motu proprio audit of ABRECO covering July 1, 2013, to October 31, 2016. The audit revealed numerous issues, including deteriorating financial conditions, unpaid obligations, delayed remittances of mandatory contributions, borrowing from outside sources at high interest, overcharging consumers, high system losses, breakdown in disbursement and cash handling, non-submission of documents for subsidy funds, and improper procurement procedures, all attributed to ineffective management by Seares.
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Cadajas vs. People

16th November 2021

ak683274
915 Phil. 220 , G.R. No. 247348
Primary Holding
Inducing a minor, through persuasion via a computer system like Facebook Messenger, to create and send photos exhibiting their private parts constitutes the crime of child pornography under Section 4(c)(2) of R.A. No. 10175 in relation to Sections 4(a), 3(b), and (c)(5) of R.A. No. 9775; the crime is mala in se, requiring criminal intent (specifically, the intent to induce the prohibited act), which was proven in this case.
Background
The case arose from a romantic relationship between the petitioner (Christian Cadajas, 24 years old) and the victim (AAA, 14 years old), which started after AAA initiated contact. The relationship was discovered by AAA's mother (BBB) who disapproved due to AAA's minority. BBB later found messages on Facebook Messenger where petitioner was inducing AAA to send explicit photos, leading to the filing of criminal charges.
Criminal Law II
Searches and Seizures

Power Sector Assets and Liabilities Management Corporation vs. Commission on Audit

16th November 2021

ak019777
915 Phil. 356 , G.R. No. 247924
Primary Holding
The Commission on Audit (COA) commits grave abuse of discretion when it inordinately delays action on a government agency's request for concurrence to engage private legal counsel and subsequently denies the request solely on the ground of lack of such prior concurrence, especially when the delay hampers the agency's fulfillment of its mandate. Furthermore, while COA has the discretion to require pre-audit, its unreasonable delay in exercising this function can excuse non-compliance by the requesting agency.
Background
The case arose from PSALM's need to engage international and Philippine legal advisors for the privatization of generation assets and Independent Power Producer (IPP) contracts of the National Power Corporation (NPC), a mandate under the Electric Power Industry Reform Act (EPIRA) of 2001. PSALM sought the concurrence of both the Office of the Government Corporate Counsel (OGCC) and the COA for these engagements due to the highly technical expertise required, particularly in international public bidding and IPP contracts, which was crucial for bolstering investor confidence and meeting EPIRA's privatization timelines.
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RP vs. Spouses Nocom

15th November 2021

ak152147
914 Phil. 686 , G.R. No. 233988
Background
The case revolves around MIAA's occupation of private lands for airport expansion without proper expropriation proceedings. Initially, MIAA included the subject lots in its expropriation case but later moved to exclude some portions. Despite the exclusion, MIAA continued to occupy these portions without paying just compensation. The landowners, led by the Spouses Nocom, filed a case for recovery of possession and payment of rentals. The lower courts ruled in favor of the landowners, prompting MIAA to appeal to the Supreme Court.
Constitutional Law I

Field Investigation Office, Office of the Ombudsman vs. Yuzon

11th November 2021

ak931882
914 Phil. 426 , G.R. No. 215985 , G.R. No. 216001 , G.R. No. 216135
Primary Holding
Public officials commit grave misconduct and serious dishonesty when they flagrantly disregard procurement laws and rules by, among others, resorting to unauthorized alternative methods of procurement, awarding contracts to unqualified bidders based on non-responsive offers, allowing material alterations to project specifications after the award without a new bidding, and falsifying or certifying false information in official documents to conceal irregularities, thereby warranting their dismissal from service.
Background
The case originated from administrative complaints filed with the Office of the Ombudsman (OMB) under OMB-C-A-08-0659-L, charging several officials of the Provincial Government of Bataan with dishonesty, grave misconduct, and abuse of authority in connection with the alleged anomalous purchase of a patrol boat for the Bataan Provincial Anti-Illegal Fishing Task Force.
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Serrano vs. Fact-Finding Investigation Bureau, Office of the Deputy Ombudsman for the Military and Other Law Enforcement Offices

13th October 2021

ak361005
913 Phil. 300 , G.R. No. 219876
Primary Holding
A COA Resident Auditor's unjustified inaction and failure to perform mandated audit activities, such as prioritizing the audit of high-value transactions, demanding compliance with reportorial requirements, suspending salaries for non-compliance, and reporting irregularities, despite the lifting of pre-audit, constitutes grave misconduct due to a clear and deliberate intent to disregard established COA rules and regulations, warranting dismissal from service.
Background
The Philippine National Police (PNP) initiated a program for the repair and refurbishing of twenty-eight (28) V-150 Light Armored Vehicles (LAVs), for which the Department of Budget and Management (DBM) released P409,740,000.00. Subsequent investigations by the Commission on Audit (COA) and the Criminal Investigation and Detection Group (CIDG) revealed significant irregularities and illegalities in the procurement process undertaken by the PNP Logistics Support Service - Bids and Awards Committee (LSS-BAC).
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Roa v. Spouses Sy

14th September 2021

ak067727
910 Phil. 219 , G.R. No. 221586
Primary Holding
A court cannot dismiss a complaint _motu proprio_ on a ground not pleaded by the movant, specifically dismissing for "lack of cause of action" when the motion to dismiss alleged "failure to state a cause of action," as these are distinct grounds. Furthermore, when a defendant files a motion for bill of particulars or avails of modes of discovery like written interrogatories, they are deemed to have recognized the existence and sufficiency of the allegations of the adverse party's cause of action in the complaint, thereby barring them from subsequently challenging the complaint for failure to state a cause of action.
Background
Petitioner Zenaida D. Roa and her sister Amelia Roa were co-owners of a property in Makati City. Zenaida discovered that their title was cancelled and a new one was issued to their niece, Marie Antoinette R. Francisco, based on a purportedly forged deed of sale. Zenaida was in Washington D.C. at the time of the alleged execution, and Amelia suffered from Alzheimer's disease. Francisco subsequently sold the property to Spouses Robinson K. and Mary Valerie S. Sy. Zenaida filed a complaint to annul these transactions and recover the property, alleging that Spouses Sy were buyers in bad faith due to suspicious circumstances surrounding the sale.
Civil Procedure I

Gemina v. Heirs of Gerardo V. Espejo, Jr

13th September 2021

ak810334
910 Phil. 48 , G.R. No. 232682
Primary Holding
The mere absence of a defendant's counsel during pre-trial, when the defendant himself is present, does not automatically warrant allowing the plaintiff to present evidence ex parte under the then-applicable Rules of Court (prior to A.M. No. 19-10-20-SC); procedural rules may be relaxed to prevent manifest injustice and uphold the right to due process. Furthermore, in an action to recover possession (accion reivindicatoria), the plaintiff bears the burden of clearly identifying the property sought to be recovered and relying on the strength of their own title, not the weakness of the defendant's claim.
Background
The dispute centers on a parcel of land located at 156 Session Road, Woodcrest Homes, Talanav, Area B, Batasan Hills, Quezon City. Petitioner Gemina claims ownership and possession since 1978 based on a purported purchase, presenting various documents like deeds, tax declarations, and permits. Respondents, the Heirs of Espejo, assert co-ownership based on a Transfer Certificate of Title (TCT No. RIV786U [93809]) in the names of Gerardo V. Espejo, Jr. and Nenafe V. Espejo, and demanded Gemina vacate the property.
Civil Procedure I
Pre-trial