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Yu Cong Eng vs. Trinidad (PH SC Case)

6th February 1925

ak907253
47 Phil. 385 , G.R. No. L-20479
Primary Holding
Act No. 2972 is interpreted to mean that persons and entities engaged in business in the Philippines must keep account books necessary for taxation purposes (specifically, sales books and other records and returns required by Bureau of Internal Revenue regulations) in English, Spanish, or a local dialect; this construction renders the Act constitutional as a valid fiscal measure.
Background
* The case arose from the Philippine government's efforts to effectively collect sales and income taxes, particularly from Chinese merchants, many of whom kept their account books exclusively in Chinese, making inspection difficult for revenue agents. * An earlier attempt by the Collector of Internal Revenue to mandate bookkeeping in English or Spanish via administrative circular was invalidated by the Supreme Court (_Young vs. Rafferty_) for exceeding administrative authority, prompting the Legislature to enact Act No. 2972. * The Act faced significant opposition from the Chinese community and diplomatic channels, and its enforcement was initially suspended before being pursued, leading to the arrest of petitioner Yu Cong Eng and this challenge.
Constitutional Law II
Due Process

People vs. Pomar

3rd November 1924

ak753803
46 Phil. 440 , No. 22008
Primary Holding
The provisions of Section 13 of Act No. 3071 are unconstitutional and void as they violate the constitutional right to liberty of contract under the first paragraph of section 3 of the Act of Congress of August 29, 1916.
Background
In 1923, the Philippine Legislature enacted Act No. 3071, which mandated employers to provide paid maternity leave to pregnant women workers. Under Section 13 of this law, women employees were entitled to receive wages for thirty days before and thirty days after childbirth. The case arose when Julio Pomar, managing La Flor de la Isabela tobacco factory, refused to pay such maternity benefits to Macaria Fajardo, a cigar-maker who had given birth. The prosecution filed charges against Pomar for violating the Act, leading to his conviction in the lower court. Pomar challenged the constitutionality of the law, arguing it violated fundamental rights to freedom of contract and property, ultimately bringing the case before the Supreme Court for review.
Philosophy of Law

Pensader vs. Pensader

7th February 1924

ak902639
47 Phil. 959 , No. 21271
Primary Holding
The Supreme Court upheld the lower court's judgment, ruling that the plaintiffs' action for partition was barred by prescription because the defendants and their predecessors had been in continuous, adverse possession of the coconut land for over thirty years, under claim of ownership.
Background
The case centers on a claim of inheritance versus a claim of ownership through donation and adverse possession. The plaintiffs, nephews of the deceased Canuto Pensader, sought to partition land they considered common inheritance. The defendants, niece and grand-nephew of Canuto, asserted exclusive rights based on donations made by Canuto and decades of uninterrupted possession. The legal context is property rights, inheritance laws, donation, and the principle of prescription through adverse possession.
Property and Land Law

People vs. Lol-lo and Saraw

27th February 1922

ak656044
43 Phil. 19 , No. 17958
Primary Holding
The Court held that piracy is a crime against all mankind (hostes humani generis) that can be punished by any country regardless of where it was committed, and that the Spanish Penal Code provisions on piracy remained valid law in the Philippines after the American occupation.
Background
The case arose from a horrific act of piracy in the Dutch East Indies where Moro pirates attacked Dutch subjects, committed robbery, rape, and attempted murder. The perpetrators later returned to the Philippines where they were arrested and tried, raising important questions about jurisdiction and the applicability of Spanish-era piracy laws.
Criminal Law II

Osorio vs. Osorio and Ynchausti Steamship Co.

30th March 1921

ak543470
41 Phil. 531 , No. 16544
Primary Holding
The donation made by Da. Petrona Reyes to Leonardo Osorio of her share in her deceased husband's inheritance, even before formal adjudication, is valid because she had a vested right to the inheritance at the time of donation, and such inheritance is not considered "future property" in the prohibitive sense of Article 635 of the Civil Code.
Background
D. Antonio Osorio had a share in a shipping business with Ynchausti & Co. Upon his death, his estate, including this share, was to be partitioned among his heirs, including his widow Da. Petrona Reyes. Before the formal partition, Da. Petrona Reyes donated a portion of her expected inheritance to her son, Leonardo Osorio. This donation later became contested when the shares of stock representing the inherited business interest were inventoried as part of Da. Petrona Reyes' estate after her death.
Property and Land Law

Chartered Bank vs. Imperial and National Bank

15th March 1921

ak799964
48 Phil. 931 , No. 17222
Primary Holding
Secured creditors retain the right to enforce their liens independently under the Insolvency Law (Act No. 1956) and are not compelled to participate in insolvency proceedings.
Background
PNB sued Umberto de Poli to recover goods under a chattel mortgage. After PNB obtained a writ of attachment, other creditors petitioned for de Poli’s insolvency. The insolvency court took control of all assets, including the attached goods. PNB argued its mortgage rights superseded insolvency proceedings. The lower court allowed PNB to proceed, prompting creditors to challenge via certiorari.
Statutory Construction

Kwong Sing vs. City of Manila

11th October 1920

ak900808
41 Phil. 103 , G. R. No. 15972
Primary Holding
Municipal ordinances enacted under the general welfare clause and the specific power to regulate businesses, requiring reasonable measures like issuing detailed receipts in official languages to prevent fraud and disputes and protect the public, constitute a valid exercise of police power, even if they impose some burden on business owners, provided they are not discriminatory, arbitrary, or unduly oppressive.
Background
The City of Manila enacted Ordinance No. 532, which mandated that all laundries, dyeing, and cleaning establishments issue signed duplicate receipts in English and Spanish, specifying the kind and number of articles received for service, aiming to regulate the delivery and return of clothes and prevent disputes and fraud, particularly targeting issues arising from receipts issued in Chinese characters.
Constitutional Law II
Due Process

Abrams vs. United States

10th November 1919

ak287637
250 U.S. 616
Primary Holding
The distribution of circulars advocating a general strike in ammunition factories during wartime, even if primarily motivated by a desire to protest U.S. policy towards Russia, constitutes sufficient evidence of an unlawful intent to curtail war production and hinder the prosecution of the war against Germany, thereby violating the Espionage Act and falling outside the protection of the First Amendment.
Background
The case arose during World War I, shortly after the U.S. sent troops to parts of Russia following the Bolshevik Revolution, an action perceived by the defendants (Russian immigrants and self-proclaimed anarchists/revolutionists) as an attempt to crush the revolution. The Espionage Act of 1917, amended in 1918, criminalized various forms of dissent and anti-war expression deemed harmful to the U.S. war effort against Germany.
Constitutional Law II
Freedom of Expression

City of Manila vs. Chinese Community of Manila

31st October 1919

ak178680
40 Phil. 349 , No. 14355
Primary Holding
In expropriation proceedings initiated by the City of Manila, the courts have the authority to inquire into and hear evidence regarding the necessity of the expropriation; the determination of necessity is not solely a legislative prerogative but a judicial question subject to review when general authority to expropriate is granted.
Background
The City of Manila sought to extend Rizal Avenue and filed a petition to expropriate certain parcels of land in Binondo, Manila, owned by the Chinese Community of Manila, which included a cemetery. The Chinese Community opposed the expropriation, arguing it was unnecessary, would desecrate a cemetery, and alternative routes were available.
Constitutional Law II
Eminent Domain

Rubi vs. Provincial Board of Mindoro

7th March 1919

ak549703
39 Phil. 660 , G.R. No. 14078
Primary Holding
The Supreme Court ruled that Section 2145 of the Administrative Code of 1917, which authorized provincial governors to direct "non-Christian" inhabitants to live in reservations, was constitutional and did not violate due process or equal protection guarantees, nor did it constitute slavery or involuntary servitude.
Background
Rubi and other Manguianes (indigenous people of Mindoro) were ordered by the provincial governor to leave their native habitats and establish residence on a reservation at Tigbao in Mindoro. One Manguian named Dabalos escaped and was imprisoned. The Manguianes filed for habeas corpus, challenging the provincial governor's authority to confine them to reservations.
Constitutional Law II
Police Power

United States vs. Constantino Tan Quingco Chua

29th January 1919

ak487241
39 Phil. 552 , No. 13708
Primary Holding
The court held that the transaction was a usurious loan disguised as a pacto de retro sale, and Chua was guilty of violating the Usury Law.
Background
The case originated from a loan of P100 made by Chua to Pedro Andres in 1911. Over five years, the debt grew to approximately P700 due to excessive interest. The transaction was later disguised as a pacto de retro sale to evade the Usury Law.
Philosophy of Law

Manzanares vs. Moreta

22nd October 1918

ak506216
38 Phil. 821 , No. 12306
Primary Holding
The Supreme Court held that an action for damages can be maintained in Philippine jurisdiction for the death of a person by wrongful act, and that in cases involving the death of a minor child, the law presumes pecuniary loss to the parent without need for specific proof of actual earnings or support.
Background
In this landmark case from 1918, an automobile accident occurred on the morning of March 5, 1916, at the intersection of Solana and Real Streets in Manila. Rafael Moreta was driving his automobile from the southern part of Solana Street when he encountered other vehicles at Real Street. After this encounter, instead of proceeding cautiously, he continued at high speed without sounding his horn. As he entered Solana Street, his vehicle struck and fatally injured Salvador Bona, a child between 8 and 9 years old, who was crossing from the right sidewalk to the left. The impact was so severe that even after hitting the child, the automobile continued moving for about two meters. The victim's mother, Simona Manzanares, a poor washerwoman, filed a civil case seeking P5,000 in damages. The Court of First Instance awarded her P1,000 as indemnity, which Moreta appealed after his motion for a new trial was denied. The case reached the Supreme Court through a bill of exceptions, where it became a pivotal decision establishing important principles about damage compensation in cases involving wrongful death, particularly concerning minor children.
Philosophy of Law

People vs. Bustos

8th March 1918

ak959486
37 Phil. 731 , G.R. No. 12592
Primary Holding
A communication made in good faith upon any subject-matter in which the party communicating has an interest, or in reference to which he has a duty, is privileged if made to a person having a corresponding interest or duty, even if it contains criminatory matter which would otherwise be slanderous or libelous; this qualified privilege applies to complaints against public officials addressed to the proper authorities for redress, and malice cannot be presumed but must be proven by the prosecution.
Background
In late 1915, numerous citizens of Pampanga, concerned about the alleged misconduct of Roman Punsalan, the justice of the peace of Macabebe and Masantol, prepared a petition detailing charges of malfeasance and asking for his removal from office. This petition, along with supporting affidavits, was submitted to the Executive Secretary, the proper authority for handling such complaints against justices of the peace at the time, through the law office of Crossfield & O'Brien.
Constitutional Law II
Freedom of Expression

United States vs. Guendia

20th December 1917

ak647225
37 Phil. 337 , No. 12462
Primary Holding
The Supreme Court ruled that Guendia was insane at the time of the commission of the crime and thus exempt from criminal liability under subsection 1 of Article 8 of the Penal Code.
Background
Simeon Guendia was charged with frustrated murder for attacking his querida. The lower court found him guilty, though it acknowledged his apparent insanity. Upon appeal, the Supreme Court examined the evidence regarding his mental state at the time of the offense and during the trial.
Philosophy of Law

The United States vs. Santos

10th September 1917

ak917783
36 Phil. 853 , No. 12779
Primary Holding
A peace officer who arrests a person without a warrant based on reasonable suspicion and in good faith is not liable, even if the arrested person is later found innocent.
Background
Dionisio Santos, a policeman in Pateros, Rizal, was tasked with preventing pilfering in a certain area. While patrolling, he saw two individuals near an uninhabited house and arrested them without a warrant, detaining them for six to seven hours before releasing them. The trial court convicted Santos of coercion, but the Supreme Court reviewed the case to determine if his actions were justified.
Philosophy of Law

Mendoza vs. De Leon

15th February 1916

ak987030
33 Phil. 508 , No. 9596
Primary Holding
The municipal council members are held jointly and severally liable for damages sustained by Marcos Mendoza due to the unlawful rescission of his ferry lease contract because their actions were not in good faith and were not a mere error in judgment, but a clear disregard of Mendoza's contractual rights for no valid reason.
Background
Marcos Mendoza was granted an exclusive ferry privilege by the municipality of Villasis under Act No. 1634. After operating the ferry for over a year, the municipal council, composed of the defendants, revoked his lease and awarded a franchise to another person, leading to Mendoza's forcible ejection. Mendoza then sued the individual council members for damages.
Property and Land Law

Legarda and Prieto vs. Saleeby

2nd October 1915

ak159516
31 Phil. 590 , No. 8936
Primary Holding
In cases of double registration under the Torrens system, the certificate of title earlier in date prevails over the later one; registered title holders are not obligated to continuously monitor subsequent land registration proceedings to protect their already registered title.
Background
Two owners of adjacent lots in Manila, Legarda and Saleeby, both registered their lands under the Torrens system. A stone wall situated on Legarda's property was mistakenly included in both their initial registration and Saleeby's subsequent registration, leading to conflicting claims over the wall and the land it occupied.
Property and Land Law

Herrera vs. Barretto and Joaquin

10th September 1913

ak952887
25 Phil. 245 , No. 8692
Primary Holding
he Supreme Court will not assess damages arising from an injunction issued by it in a certiorari proceeding; such damages, if any, must be claimed and proven in the court trying the main action where the merits of the case are ventilated, as certiorari is limited to reviewing jurisdictional errors and does not involve a "final trial" on the merits for the purpose of assessing damages under Section 170 of the Code of Civil Procedure.
Background
The underlying dispute involved an action for mandamus in the Court of First Instance (CFI) where Constancio Joaquin sought to compel the issuance of a cockpit license and obtained a mandatory injunction. Godofredo B. Herrera, the Municipal President, then filed a petition for a writ of certiorari with the Supreme Court challenging the CFI's jurisdiction. During this certiorari proceeding, a member of the Supreme Court issued an injunction restraining Joaquin from operating his cockpit. The Supreme Court ultimately dismissed Herrera's certiorari petition and dissolved the injunction.
Civil Procedure I

Carlos vs. Ramil

5th September 1911

ak314311
20 Phil. 183 , No. 6736
Primary Holding
An agreement to transfer land in exchange for future lifetime care constitutes an onerous donation (donacion con causa onerosa) governed by contract law, and is valid and enforceable upon fulfillment of the care obligation.
Background
An elderly couple, Agustin and Juliana Carlos, needed care and made an agreement with their adopted daughter and her husband, Antonio Ramil, to give them land if they stayed and cared for them for life, fearing the husband would take the daughter away.
Property and Land Law

United States vs. Toribio

26th January 1910

ak202554
15 Phil. 85 , G.R. No. 5060
Primary Holding
Act No. 1147 prohibits the slaughter of large cattle for human consumption anywhere in the Philippines without a permit, regardless of the presence of a municipal slaughterhouse. The law is a valid exercise of police power and not an infringement on private property rights.
Background
The case arose during a period when a contagious disease threatened the carabao population in the Philippines, impacting agriculture and the economy. Act No. 1147 was enacted to regulate the registration, branding, and slaughter of large cattle, aiming to protect the ownership and use of these animals.
Constitutional Law II
Police Power

Reynolds vs. United States

6th January 1879

ak870216
98 U.S. 145
Primary Holding
The First Amendment's guarantee of free exercise of religion protects religious beliefs and opinions but does not protect overt acts that violate generally applicable criminal laws, even if those acts are committed in pursuance of a religious duty; thus, a religious belief cannot be a defense to a charge of bigamy.
Background
The case arose from the conflict between federal anti-bigamy laws and the practice of polygamy by members of the Church of Jesus Christ of Latter-Day Saints (Mormon Church) in the Utah Territory. The federal government sought to suppress polygamy, viewing it as detrimental to social order, while many Mormons considered it a religious obligation. This tension led to prosecutions under federal statutes, with defendants often invoking religious freedom as a defense.
Constitutional Law II
Freedom of Religion

American Print Works vs. Lawrence

15th October 1847

ak008372
21 N.J.L. 248 (N.J. 1847)
Primary Holding
The defendant, Mayor Cornelius W. Lawrence, was not guilty of trespass because the destruction of the plaintiff's goods was a necessary and lawful act to prevent the spread of the Great Fire of 1835, justified under both a New York statute and common law necessity.
Background
In December 1835, a devastating fire broke out in New York City, rapidly spreading and threatening to consume a large portion of the city. Mayor Cornelius W. Lawrence, in consultation with city officials and military experts, ordered the destruction of several buildings using gunpowder to create firebreaks and halt the conflagration. Among the destroyed buildings were stores containing goods belonging to American Print Works.
Constitutional Law II
Police Power