There are 472 results on the current subject filter
Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
---|---|---|---|---|
Padillo vs. People (9th October 2024) |
AK536847 G.R. No. 271012 |
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. | 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. |
Criminal Law II |
People vs. Adrales (22nd May 2024) |
AK003925 G.R. No. 242473 |
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. | 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. |
Criminal Law II Anti-Trafficking in Persons Act |
People vs. ABC260708 (23rd January 2024) |
AK737802 G.R. No. 260708 |
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. | 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. |
Criminal Law II Rape |
People vs. XXX65439 (13th November 2023) |
AK529192 G.R. No. 265439 |
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. | 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. |
2025 BarOps Criminal Law |
People vs. Flores (11th October 2023) |
AK680841 G.R. No. 262686 |
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. | 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. |
Criminal Law II |
People vs. Yap (4th October 2023) |
AK900951 G.R. No. 255087 |
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. | 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. |
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 |
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. | 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. |
2025 BarOps Criminal Law |
People vs. Nuñez (14th August 2023) |
AK001850 G.R. No. 263706 |
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. | 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. |
2025 BarOps Criminal Law |
People vs. Delos Reyes (14th August 2023) |
AK686082 G.R. No. 264958 |
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. | 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. |
2025 BarOps Criminal Law |
Axel Tria y Cipriano vs. People (2nd August 2023) |
AK532384 G.R. No. 255583 |
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. | 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). |
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 |
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. | 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. |
2025 BarOps Criminal Law |
Quizon-Arciga vs. Baluyut (14th June 2023) |
AK168457 G.R. No. 256612 |
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. | 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. |
Civil Procedure I |
People vs. Custodio (14th June 2023) |
AK683442 G.R. No. 251741 |
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. | 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. |
2025 BarOps Criminal Law |
Odilao vs. Union Bank of the Philippines (26th April 2023) |
AK759840 G.R. No. 254787 |
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. | 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. |
Civil Procedure I Motion |
Go vs. Court of Appeals (29th March 2023) |
AK010365 G.R. No. 244681 |
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. | 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. |
Civil Procedure I |
Petron Corporation vs. Commissioner of Internal Revenue (20th March 2023) |
AK403390 G.R. No. 255961 |
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. | 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. |
Civil Procedure I |
Spouses Libiran vs. Elisan Credit Corporation (13th February 2023) |
AK651801 G.R. No. 255239 |
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. | 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. |
Civil Procedure I |
Monasterial vs. Fontamillas and Kingsville Construction and Development Corporation (13th February 2023) |
AK472331 G.R. No. 261457 |
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. | 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. |
Civil Procedure I |
Orillo v. People of the Philippines (30th January 2023) |
AK619123 934 Phil. 728 , G.R. No. 206905 |
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. | 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. |
Criminal Law II Libel and Cyberliberl |
Lastimosa v. People of the Philippines (5th December 2022) |
AK902976 932 Phil. 31 , G.R. No. 233577 |
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." | 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. |
Criminal Law II Libel and Cyberlibel |
Nisperos vs. People (29th November 2022) |
AK942626 G.R. No. 250927 |
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. | 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. |
Criminal Law II |
People vs. Agao (4th October 2022) |
AK513960 930 Phil. 559 , G.R. No. 248049 |
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. | 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. |
Criminal Law II Rape |
Knutson v. Judge Sarmiento-Flores (12th July 2022) |
AK144148 925 Phil. 638 , G.R. No. 239215 |
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. | 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. |
Criminal Law II VAWC |
Marquez vs. Commission on Elections (28th June 2022) |
AK986321 924 Phil. 179 , G.R. No. 258435 |
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. | 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. |
2025 BarOps Political Law |
Peñas v. Commission on Elections (15th February 2022) |
AK856264 919 Phil. 513 , UDK-16915 |
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. | 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. |
2025 BarOps Political Law |
Morales v. People of the Philippines (4th January 2022) |
AK148514 919 Phil. 86 , G.R. No. 240337 |
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. | 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. |
Criminal Law II Reckless Imprudence |
Calleja vs. Executive Secretary (7th December 2021) |
AK549249 G.R. No. 252578 |
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. | 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. |
Constitutional Law I Constitutional Law II Criminal Law II |
Baysa vs. Santos (2nd December 2021) |
AK431265 917 Phil. 372 , G.R. No. 254328 |
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. | 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. |
2025 BarOps Political Law |
Seares, Jr. vs. National Electrification Administration Board (18th November 2021) |
AK673905 916 Phil. 91 , G.R. No. 254336 |
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. | 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. |
2025 BarOps Political Law |
Venus Commercial Co., Inc. vs. Department of Health (18th November 2021) |
AK645370 916 Phil. 16 , G.R. No. 240764 |
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. | 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. |
2025 BarOps Political Law |
Power Sector Assets and Liabilities Management Corporation vs. Commission on Audit (16th November 2021) |
AK019777 915 Phil. 356 , G.R. No. 247924 |
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. | 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. |
2025 BarOps Political Law |
Cadajas vs. People (16th November 2021) |
AK683274 915 Phil. 220 , G.R. No. 247348 |
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. | 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. |
Criminal Law II Searches and Seizures |
RP vs. Spouses Nocom (15th November 2021) |
AK152147 914 Phil. 686 , G.R. No. 233988 |
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 |
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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 |
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. | 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. |
2025 BarOps Political Law |
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 |
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). | 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. |
2025 BarOps Political Law |
Roa v. Spouses Sy (14th September 2021) |
AK067727 910 Phil. 219 , G.R. No. 221586 |
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. | 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. |
Civil Procedure I |
Gemina v. Heirs of Gerardo V. Espejo, Jr (13th September 2021) |
AK810334 910 Phil. 48 , G.R. No. 232682 |
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. | 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. |
Civil Procedure I Pre-trial |
Ridao vs. Handmade Credit and Loans, Inc. (3rd February 2021) |
AK229915 895 Phil. 554 , G.R. No. 236920 |
Petitioner Gemma A. Ridao obtained loans from respondent Handmade Credit and Loans, Inc., represented by Ridao's brother-in-law, Teofilo Manipon. A dispute arose when Handmade Credit claimed Ridao failed to pay her obligations, including an alleged increased dollar loan and an additional peso loan, while Ridao asserted she had fully paid the admitted $4,300.00 loan obligation. | Once a debtor introduces evidence of payment, the burden of going forward with the evidence shifts to the creditor, who then has the duty to produce evidence to show non-payment; material alterations on a promissory note made without the assent of the other contracting party render the instrument void and unenforceable by the party causing the alteration. |
Criminal Law II |
Pante vs. People (18th January 2021) |
AK603265 969 SCRA 243 , 894 Phil. 54 , G.R. No. 218969 |
Dawson Word lost a bundle of money (US dollars and Philippine pesos). A minor, one of Pante's co-accused, found the money and shared it with Pante and another minor. Pante, the only adult, took a significant portion of the money and used it for personal expenses. He only returned a portion after police intervention. | A person who receives lost property from the original finder and subsequently misappropriates it, knowing it is not rightfully theirs, is considered a "finder in law" and can be held liable for theft under Article 308, par. 2(1) of the Revised Penal Code for failing to return the property to the owner or authorities. |
Property and Land Law |
Re: Letter of Mrs. Ma. Cristina Roco Corona Requesting the Grant of Retirement and Other Benefits to the Late Former Chief Justice Renato C. Corona and Her Claim for Survivorship Pension as His Wife Under Republic Act No. 9946 (12th January 2021) |
AK237996 968 SCRA 12 , 893 Phil. 231 , A.M. No. 20-07-10-SC |
Renato C. Corona served as an Associate Justice for eight years before being appointed Chief Justice in 2010. In 2011, impeachment proceedings were initiated against him by the House of Representatives on grounds including betrayal of public trust and culpable violation of the Constitution. Following a trial, the Senate convicted him in 2012 primarily based on Article II concerning his failure to accurately declare his Statement of Assets, Liabilities, and Net Worth (SALN), leading to his removal from office. Subsequently, criminal, tax, and forfeiture cases were filed against him but were all dismissed following his death in 2016, prior to any final judgment. | Removal from office via impeachment only results in removal and disqualification from holding public office and does not, by itself, cause the forfeiture of accrued retirement benefits; forfeiture requires a separate judicial conviction for criminal, civil, or administrative liabilities, which did not occur in the case of the late Chief Justice Corona due to his death terminating such proceedings. |
Constitutional Law I |
DPWH vs. Manalo (16th November 2020) |
AK226477 G.R. No. 217656 |
Respondents are owners of residential structures located on land owned by the Metropolitan Waterworks and Sewerage System (MWSS) along Luzon Avenue, Quezon City. These structures were directly affected by the Department of Public Works and Highways' (DPWH) C-5 extension project, designed to link the South Luzon Expressway and the North Luzon Expressway. The DPWH sought to clear the area for the project, leading to a dispute over compensation and the process of eviction and demolition. | The complaint filed by informal settlers whose residential structures are affected by a government infrastructure project sufficiently states a cause of action if it alleges their ownership of the structures, the government agency's obligation to respect their rights to due process (including procedures under R.A. No. 7279 for eviction and demolition), and the agency's violation of these rights. Underprivileged and homeless citizens cannot be summarily evicted or their dwellings demolished without adherence to the legal requirements for notice, consultation, and relocation or financial assistance as mandated by the Constitution and relevant statutes. |
Civil Procedure I |
Bank of the Philippine Islands vs. Central Bank of the Philippines (12th October 2020) |
AK149491 958 SCRA 224 , 887 Phil. 849 , G.R. No. 197593 |
The case revolves around a sophisticated bank fraud scheme that exploited vulnerabilities in the check clearing process. Syndicate members opened accounts at BPI and Citibank, then deposited fraudulent checks. CBP employees Valentino and Estacio intercepted and altered clearing documents, preventing BPI from dishonoring the checks. Citibank, unaware of the fraud, allowed withdrawals after the clearing period. BPI discovered the ₱9 million loss and sought full reimbursement from CBP, which only partially complied. The legal battle that ensued focused on CBP's liability for its employees' actions and the nature of its clearing house operations. |
Constitutional Law I |
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Araza vs. People (8th September 2020) |
AK703368 882 Phil. 905 , G.R. No. 247429 |
The case arose from the marital relationship between Jaime Araza (petitioner) and AAA (private complainant), who were married in 1989. Their relationship deteriorated around February 2007 when Araza went to Zamboanga City for a networking business. AAA later discovered that Araza was having an affair with Tessie Luy Fabillar and had fathered three children with her. This discovery and Araza's subsequent actions led to AAA experiencing emotional and psychological distress, prompting her to file a criminal complaint. | Marital infidelity, when it causes mental or emotional anguish to the wife, constitutes psychological violence under Section 5(i) of R.A. No. 9262, and the law does not require that the victim become psychologically ill but only that emotional anguish and mental suffering be proven, typically through the victim's testimony. |
Criminal Law II VAWC |
People vs. Leocadio, et al. (15th July 2020) |
AK428858 877 Phil. 819 , G.R. No. 237697 |
The case arose from the recruitment of young women, mostly minors, from impoverished island barangays in Getafe, Bohol, with promises of lucrative employment in an internet cafe in Angeles, Pampanga. This recruitment preyed on their vulnerability due to poverty, with the ultimate purpose being their engagement in cybersex operations. | The recruitment, transportation, transfer, harboring, or receipt of a child for the purpose of exploitation constitutes "trafficking in persons" even without the means enumerated for adult trafficking, and the crime is qualified if the victim is a child or if committed in large scale (against three or more persons); conspiracy can be inferred from the concerted acts of the accused towards a common criminal design. |
Criminal Law II Anti-Trafficking in Persons Act |
People vs. Meneses (30th June 2020) |
AK504298 940 SCRA 372 , 875 Phil. 724 , G.R. No. 233533 |
Joey Meneses was apprehended in a buy-bust operation conducted by police officers after a confidential informant reported his drug dealing activities. The operation stemmed from an initial transaction where Meneses sold marijuana to an undercover police officer. Subsequently, a planned buy-bust operation led to his arrest for selling both marijuana and shabu. | The Supreme Court affirmed the Court of Appeals' decision, which upheld the Regional Trial Court's conviction of Joey Meneses y Cano for illegal sale of dangerous drugs, finding him guilty beyond reasonable doubt of violating Section 5, Article II of R.A. No. 9165. |
Criminal Law II |
People vs. Sapla (16th June 2020) |
AK889679 874 Phil. 240 , G.R. No. 244045 |
The case arises amidst the State's campaign against illegal drugs, juxtaposed with the fundamental constitutional right of individuals against unreasonable searches and seizures, emphasizing that the fight against drugs cannot be pursued by sacrificing constitutionally protected rights. | Exclusive reliance on an unverified tip relayed by an anonymous informant is insufficient to engender probable cause that warrants an intrusive warrantless search and seizure; law enforcers must rely on their personal knowledge based on overt acts personally observed or other reliable circumstances, beyond the tip itself, to justify such a search. |
Criminal Law II Searches and Seizures |
Taisei Shimizu Joint Venture vs. Commission on Audit (2nd June 2020) |
AK421432 936 SCRA 359 , 873 Phil. 323 , G.R. No. 238671 |
After completing the New Iloilo Airport project, TSJV found that some of its billings remained unpaid. They sought arbitration through CIAC, which granted a substantial award in their favor. When TSJV attempted to enforce this award, they encountered resistance from government agencies, leading them to seek enforcement through COA. However, COA only partially approved the payment, effectively modifying the CIAC's final and executory award. TSJV then brought the case to the Supreme Court, challenging COA's decision. |
Constitutional Law I |
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People vs. Guillermo (27th November 2019) |
AK963268 926 SCRA 144 , 866 Phil. 690 , G.R. No. 229515 |
Nida and Desiree Guillermo were arrested in a buy-bust operation for allegedly selling shabu to a poseur-buyer. They were charged with violation of Section 5, in relation to Section 26, Article II of R.A. 9165. The prosecution presented the testimony of the arresting officers and the forensic chemist, while the defense presented testimonies denying the drug sale and alleging irregularities in the arrest and post-arrest procedures. | The Supreme Court held that the prosecution failed to prove the guilt of Nida and Desiree Guillermo beyond reasonable doubt for the crime of illegal sale of dangerous drugs, primarily due to inconsistencies and irregularities in the conduct of the buy-bust operation and the chain of custody of the seized evidence. |
Criminal Law II |
People vs. Dela Rosa (6th November 2019) |
AK098282 866 Phil. 36 , G.R. No. 227880 |
Ruth Dela Rosa and her common-law spouse Crisanto Samper took in and raised AAA, Crisanto's niece, for six years. Dela Rosa had a friend named Kim Caben, a Korean national who would visit Angeles City. The case arose from incidents in February and March 2013 involving the sexual exploitation of AAA and another minor, BBB, orchestrated through Dela Rosa's introduction of AAA to Kim. | The recruitment element in trafficking in persons includes providing the conditions for prostituting a minor, and a victim's consent is rendered meaningless when the victim is a minor, even without coercive means. Discrepancies between a witness's affidavit and testimony do not necessarily impair credibility as affidavits taken ex parte are generally considered inferior to testimony given in open court. |
Criminal Law II Anti-Trafficking in Persons Act |
PLDT vs. Citi Appliance M.C. Corporation (9th October 2019) |
AK339916 922 SCRA 518 , 864 Phil. 899 , G.R. No. 214546 |
Citi Appliance, owner of a land in Cebu City, discovered underground telephone lines, cables, and manholes installed by PLDT while excavating for a parking lot for its planned commercial building. These installations were preventing Citi Appliance from fully utilizing its property. Citi Appliance sought to have PLDT remove these installations or pay for parking exemption fees, leading to a forcible entry case when PLDT refused. | The Petition for Review is granted; the Court of Appeals' Decision and Resolution are set aside; the action for forcible entry is deemed to have prescribed, and the Municipal Trial Court in Cities had no jurisdiction over the case. |
Property and Land Law |
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