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Tenebro vs. Court of Appeals

18th February 2004

ak750372
423 SCRA 272 , G.R. No. 150758
Primary Holding
A subsequent judicial declaration of nullity of a second marriage on the ground of psychological incapacity does not retroact to the date of its celebration for the purpose of extinguishing criminal liability for bigamy; the crime is consummated upon the very act of contracting a second marriage while a prior marriage is still valid and subsisting.
Background
The case arose from the multiple marriages contracted by petitioner Veronico Tenebro. He first married Hilda Villareyes in 1986. While this marriage was subsisting, he married Leticia Ancajas in 1990. After Tenebro left Ancajas to cohabit with his first wife, he contracted a third marriage with Nilda Villegas in 1993. Upon learning of the third marriage, Ancajas verified the existence of the first marriage and subsequently filed a criminal complaint for bigamy against Tenebro for contracting their marriage (the second one) while his first marriage was still valid.
Persons and Family Law

DM. Consunji, Inc. vs. Court of Appeals

20th April 2001

ak928097
357 SCRA 249 , G.R. No. 137873
Primary Holding
An employee's dependent who has claimed and received benefits from the State Insurance Fund under the Labor Code is not barred from subsequently suing the employer for damages under the Civil Code if the initial choice of remedy was made without knowledge of the employer's negligence or of the existence of the alternative remedy, as such ignorance negates a knowing and intelligent waiver.
Background
The case arose from a fatal workplace accident on November 2, 1990, where Jose Juego, a construction worker for petitioner D.M. Consunji, Inc. (DMCI), died after falling 14 floors when the platform he was on collapsed. The incident prompted his widow, Maria Juego, to seek compensation. This led to a legal conflict over whether her initial claim for statutory death benefits under the Labor Code prevented her from later seeking higher damages from the employer through a civil lawsuit based on negligence.
Persons and Family Law

Marcos vs. Marcos

19th October 2000

ak266337
343 SCRA 755 , G.R. No. 136490
Primary Holding
Psychological incapacity as a ground for nullity of marriage under Article 36 of the Family Code may be established by the totality of evidence presented, and a personal medical or psychological examination of the respondent is not a mandatory requirement or *conditio sine qua non* for such a declaration.
Background
Brenda and Wilson Marcos were married in 1982 and had five children. Both were members of the military assigned to Malacañang Palace. After the 1986 EDSA Revolution, both left the military service. Wilson struggled with unemployment and failed business ventures, leading to frequent quarrels, his failure to provide financial support, and instances of physical abuse against Brenda and their children. The couple eventually separated in 1992, and a series of violent incidents prompted Brenda to file a petition to declare their marriage null and void based on Wilson's alleged psychological incapacity.
Persons and Family Law
Article 36, Family Code

University of the East vs. Jader

17th February 2000

ak405597
325 SCRA 804 , G.R. No. 132344
Primary Holding
An educational institution has a contractual obligation to timely inform its students of their academic status and can be held liable for damages if its negligence misleads a student into believing they have completed all graduation requirements, thereby causing injury; this liability is anchored on Articles 19 and 20 of the Civil Code concerning the principle of abuse of rights and liability for negligent acts.
Background
The case arose from the relationship between an educational institution and its student concerning the fulfillment of academic requirements for a law degree. The dispute centered on the university's responsibility to communicate a student's final grade and academic standing, especially when the student's eligibility for graduation and the bar examinations was at stake.
Persons and Family Law

Palmares vs. Court of Appeals

31st March 1998

ak070111
288 SCRA 422 , G.R. No. 126490
Primary Holding
A person who signs a promissory note as a co-maker and explicitly binds herself to be "jointly and severally" or "solidarily" liable with the principal debtor is considered a surety, not a guarantor; as a surety, she is an insurer of the debt itself, directly and primarily liable, and may be sued by the creditor alone for the entire obligation upon the principal debtor's default.
Background
Private respondent M.B. Lending Corporation extended a loan of P30,000.00 to the spouses Osmeña and Merlyn Azarraga. Petitioner Estrella Palmares signed the corresponding promissory note as a co-maker. The terms of the note stipulated that Palmares was "jointly and severally or solidarily liable" with the principal debtors. After partial payments were made, the Azarraga spouses defaulted on the remaining balance, prompting the lending corporation to seek collection.
Persons and Family Law

Republic vs. Court of Appeals (Molina Case)

13th February 1997

ak581680
268 SCRA 198 , G.R. No. 108763
Primary Holding
Psychological incapacity under Article 36 of the Family Code must be a medically or clinically identified, grave, and permanent or incurable psychological illness existing at the time of the marriage that renders a spouse truly incapable of knowing and assuming the essential marital obligations; mere refusal, neglect, difficulty, or irreconcilable differences are not sufficient grounds.
Background
The introduction of "psychological incapacity" under Article 36 of the Family Code created a novel ground for declaring a marriage void, leading to a surge in petitions and inconsistent interpretations by lower courts. The Solicitor General expressed concern that the provision was being applied so liberally that it was effectively becoming a "divorce procedure," which is contrary to Philippine law and culture. This case presented the Supreme Court with the opportunity to clarify the provision's meaning and establish uniform standards for its application by the bench and bar.
Persons and Family Law
Article 36, Family Code

Chi Ming Tsoi vs. Court of Appeals

16th January 1997

ak887142
266 SCRA 324 , G.R. No. 119190
Primary Holding
The persistent and unjustified refusal of a spouse to engage in sexual intercourse, an essential marital obligation, for a prolonged period is equivalent to psychological incapacity under Article 36 of the Family Code, as it demonstrates an utter insensitivity or inability to give meaning and significance to the marriage.
Background
Chi Ming Tsoi and Gina Lao-Tsoi were married on May 22, 1988. Throughout their cohabitation, which lasted until March 15, 1989, they never engaged in sexual intercourse. The wife, Gina, alleged that her husband consistently refused to consummate the marriage, leading her to believe he was either impotent or a closet homosexual who married her merely to maintain his residency status in the Philippines. This complete lack of sexual intimacy and the husband's emotional distance prompted the wife to file a complaint for the annulment of their marriage.
Persons and Family Law
Article 36, Family Code

Apa vs. Fernandez

20th March 1995

ak915647
G.R. No. 112381 , 242 SCRA 509
Primary Holding
A pending civil action that directly questions the ownership of a property constitutes a prejudicial question to a criminal prosecution for squatting on the same property, as the resolution of the ownership issue is determinative of the guilt or innocence of the accused.
Background
Petitioners were criminally charged under the Anti-Squatting Law (P.D. 772) for allegedly occupying a portion of Lot No. 3635-B and constructing their houses thereon without the consent of the registered owner, private respondent Rosita Tigol. However, three years prior to the filing of the criminal case, the petitioners had already initiated a civil action against the private respondents. This civil case sought to annul Rosita Tigol's title (TCT No. 13250) over the same lot and to have the property partitioned among them as co-heirs, asserting that they were co-owners of the land in question.
Persons and Family Law

Santos vs. Court of Appeals

4th January 1995

ak322702
240 SCRA 20 , 310 Phil. 21 , G.R. No. 112019
Primary Holding
Psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability; it refers to a mental, not physical, incapacity that causes a party to be truly incognitive of the basic marital covenants, and it must be a malady so deep-seated that it renders the person incapable of fulfilling the essential obligations of marriage, which must be proven to have existed at the time of the celebration of the marriage.
Background
The case arose from the application of the then-novel provision of Article 36 of the Family Code, which took effect in 1988. This provision, which introduced "psychological incapacity" as a ground to void a marriage, was adopted from Canon Law but was not defined in the statute itself. This lack of a clear definition led to varying interpretations and necessitated a definitive ruling from the Supreme Court to establish jurisprudential guidelines for its application by the courts.
Persons and Family Law Philosophy of Law
Article 36, Family Code

Gashem Shookat Baksh vs. Court of Appeals

19th February 1993

ak910606
219 SCRA 115 , G.R. No. 97336
Primary Holding
A breach of promise to marry is not actionable per se, but it can be the basis for recovering damages under Article 21 of the Civil Code if the promise was made in a fraudulent and deceptive manner to entice a woman into sexual congress (moral seduction), thereby causing willful injury to her honor and reputation in a manner contrary to morals, good customs, or public policy.
Background
The case arose from a romantic relationship between Gashem Shookat Baksh, an Iranian medical student residing in Dagupan City, and Marilou T. Gonzales, a 22-year-old Filipina working at a luncheonette. Baksh courted Gonzales and promised to marry her, which led her to live with him with her parents' consent. The dispute began when Baksh later repudiated his promise, prompting Gonzales to file a suit for damages based on the alleged fraudulent promise and the resulting injury to her honor.
Persons and Family Law

Yu vs. Court of Appeals

21st January 1993

ak986897
G.R. No. 86683 , 217 SCRA 328
Primary Holding
A third party or a stranger to an exclusive distributorship contract can be enjoined from interfering with that contract; the right to perform such an agreement and reap the profits therefrom is a proprietary right, and its violation through deceptive means that results in continuous and repeated injury to a party's business and goodwill constitutes irreparable harm warranting the issuance of a writ of preliminary injunction.
Background
Petitioner Philip S. Yu held an exclusive sales agency agreement with the House of Mayfair in England to be the sole distributor of its wallcovering products in the Philippines since 1987. Private respondent Unisia Merchandising Co., Inc., which was previously a dealer for the petitioner, began importing and selling the same Mayfair products in the Philippine market. Unisia sourced the products not directly from House of Mayfair, but through FNF Trading, a firm in West Germany, which allegedly misled House of Mayfair into believing the products were intended for Nigeria. This created direct competition and led the petitioner to seek legal action to protect his exclusive rights.
Persons and Family Law

Albenson Enterprises Corp. vs. Court of Appeals

11th January 1993

ak134873
217 SCRA 16 , G.R. No. 88694
Primary Holding
A party who files a criminal complaint against another based on probable cause and in good faith cannot be held liable for damages under the principle of abuse of rights or for malicious prosecution, even if it is later discovered that the complaint was filed against the wrong person due to an honest mistake of identity. The law does not penalize the right to litigate, and an adverse result of an action does not, by itself, make the act wrongful or subject the actor to payment of damages.
Background
Albenson Enterprises Corporation delivered mild steel plates to Guaranteed Industries, Inc. but was paid with a check that was subsequently dishonored for "Account Closed." The check was drawn against the account of E.L. Woodworks. In an attempt to collect the payment, Albenson conducted inquiries which led them to believe that Eugenio S. Baltao, the president of Guaranteed Industries, was the same "Eugenio Baltao" who owned E.L. Woodworks and issued the check. This belief was based on records from the SEC, the Ministry of Trade and Industry, and the drawee bank. This case of mistaken identity led to the filing of a criminal complaint and the subsequent civil suit for damages.
Persons and Family Law

Amelita Constantino and Michael Constantino vs. Ivan Mendez and the Honorable Court of Appeals

14th May 1992

ak349766
G.R. No. 57227
Primary Holding
Paternity and filiation must be established by clear and convincing evidence, and the burden of proof rests on the claimant. Furthermore, moral damages for breach of promise to marry are not recoverable when sexual intercourse is a product of voluntariness and mutual desire, rather than deceit or fraud.
Background
In August 1974, Amelita Constantino, a 28-year-old waitress in Manila, met Ivan Mendez, a prosperous businessman from Davao City. Mendez allegedly professed his love and, through a promise of marriage, convinced Constantino to have sexual intercourse with him in his hotel room. Immediately after, he confessed that he was already married. Despite this revelation, they continued their sexual relationship in the succeeding months. Constantino became pregnant and later gave birth to a son, Michael Constantino. When her pleas for support were ignored, she filed a suit for acknowledgment, support, and damages against Mendez.
Persons and Family Law

Valenzuela vs. Court of Appeals

19th October 1990

ak911327
G.R. No. 83122 , 191 SCRA 1
Primary Holding
A principal's power to revoke an agency agreement is not absolute and may not be exercised in bad faith or with an abuse of right; a termination tainted with bad faith makes the principal liable for damages. Furthermore, an agency is considered "coupled with an interest" and is not freely revocable by the principal when the agent has been induced to assume a responsibility or incur a liability, such that the agent would be exposed to personal loss if the authority were withdrawn.
Background
Arturo P. Valenzuela had been a General Agent for the Philippine American General Insurance Company, Inc. (Philamgen) since 1965. Over thirteen years, he built a successful insurance agency. The dispute arose from a particularly large marine insurance account he secured from Delta Motors, Inc., which entitled him to a 32.5% commission. In 1977, Philamgen expressed its desire to share in this specific commission on a fifty-fifty basis, which Valenzuela consistently refused, asserting his rights under their existing General Agency Agreement.
Persons and Family Law

Pilapil vs. Ibay-Somera

30th June 1989

ak800714
174 SCRA 653 , G.R. No. 80116
Primary Holding
For the crime of adultery, the complainant's status as an "offended spouse" must exist at the time of the filing of the criminal complaint, not just at the time of the alleged offense. Consequently, a foreigner who has obtained a valid final divorce decree under his national law is no longer the husband of his former Filipino spouse and thus lacks the legal personality and capacity to file an adultery case against her.
Background
The case arose from the marital relationship between Imelda Manalaysay Pilapil, a Filipino citizen, and Erich Ekkehard Geiling, a German national, who were married in Germany in 1979. After living in Manila and having a child, the couple experienced marital discord and separated de facto. This led to Geiling filing for divorce in Germany and Pilapil filing for legal separation in the Philippines, which culminated in Geiling filing criminal complaints for adultery against Pilapil after their divorce was finalized.
Persons and Family Law

De Lima vs. Laguna Tayabas Co.

15th April 1988

ak258258
160 SCRA 70 , G.R. No. L-35697-99
Primary Holding
As an exception to the well-settled rule that a party who does not appeal a judgment cannot obtain affirmative relief, an appellate court may, on equitable grounds, modify the judgment in favor of the non-appealing party, especially when said party is an indigent litigant, the opposing party's appeal is dilatory, and substantial justice would otherwise be denied due to procedural technicalities.
Background
The case originated from a vehicular collision on June 3, 1958, between a passenger bus owned by Laguna Tayabas Bus Co. (LTB) and a delivery truck of the Seven-Up Bottling Co. The incident resulted in the death of Petra de la Cruz and serious physical injuries to Eladia de Lima and Nemesio Flores, who were all passengers of the LTB bus. This led to the filing of three separate civil suits for damages against the respondents, which were consolidated for trial.
Persons and Family Law
Article 24, Civil Code

Aberca vs. Ver

15th April 1988

ak179011
G.R. No. L-69866 , 160 SCRA 590
Primary Holding
A civil action for damages based on violations of constitutional rights, as provided for under Article 32 of the Civil Code, may be filed against public officers, including military personnel, and is not barred by either the suspension of the privilege of the writ of habeas corpus or the doctrine of state immunity. Furthermore, superior officers may be held liable as joint tortfeasors for the wrongful acts of their subordinates if they are found to be directly or indirectly responsible for the constitutional violations.
Background
The case arose from a series of "pre-emptive strikes" ordered by then-General Fabian Ver against alleged communist-terrorist underground houses in Metro Manila. These operations were carried out by various intelligence units of the Armed Forces of the Philippines, collectively known as Task Force Makabansa (TFM). The petitioners were individuals whose homes were raided and who were subsequently arrested, detained, and subjected to various forms of abuse by TFM elements during these operations.
Persons and Family Law
Article 32, New Civil Code

Ledesma vs. Court of Appeals

15th April 1988

ak841741
G.R. No. L-54598 , 160 SCRA 449
Primary Holding
A public officer who refuses or neglects, without just cause, to perform an official duty, causing material or moral loss to another, is personally liable for damages under Article 27 of the Civil Code. Defiance of a lawful directive from a superior, coupled with actions showing bad faith and callousness, constitutes a wrongful act that justifies the imposition of moral and exemplary damages.
Background
Violeta Delmo, a student and treasurer of the Student Leadership Club at West Visayas College, extended loans from club funds to other students pursuant to a club resolution. The College President, petitioner Jose B. Ledesma, considered this action a violation of school rules. Consequently, he dropped Delmo from the club's membership and declared her ineligible for any academic awards or citations, which jeopardized her chance of graduating with honors as a consistent full scholar.
Persons and Family Law
Article 27 of the Civil Code

Tañada vs. Tuvera

29th December 1986

ak242154
146 SCRA 446 , G.R. No. L-63915
Primary Holding
Publication in the Official Gazette is an indispensable prerequisite for the effectivity of all statutes, presidential decrees, executive orders, and administrative rules intended to enforce or implement existing laws; the clause "unless it is otherwise provided" in Article 2 of the Civil Code pertains only to the fifteen-day effectivity period and does not grant the legislature the power to dispense with the publication requirement itself.
Background
This case arose from a prior petition where the petitioners demanded the publication of numerous presidential decrees issued during the Marcos administration, which had not been published as required by law. The Supreme Court's initial decision on April 24, 1985, ordered the government to publish all unpublished presidential issuances "which are of general application." Finding this directive ambiguous, the petitioners filed a motion for reconsideration and clarification to precisely define the scope of laws requiring publication, the meaning of "publication," and the proper medium and timing for such publication.
Persons and Family Law

Van Dorn vs. Romillo, Jr.

8th October 1985

ak986888
No. L-68470 , 139 SCRA 139
Primary Holding
An absolute divorce obtained abroad by an alien spouse is valid and binding in the Philippines, and it effectively terminates the marital bond from the perspective of the alien spouse; consequently, the alien spouse loses the standing to sue the Filipino spouse in the Philippines for rights arising from the marriage, such as the management or division of alleged conjugal property.
Background
Petitioner Alice Reyes Van Dorn, a Filipino citizen, and private respondent Richard Upton, a US citizen, were married in Hongkong in 1972 and established their residence in the Philippines. They had two children. In 1982, they obtained a divorce decree from a court in Nevada, USA, where Upton acknowledged that they had no community property. Subsequently, Van Dorn remarried. A year after the divorce, Upton filed a lawsuit in the Philippines, claiming that a business owned by Van Dorn was conjugal property and seeking an accounting and the right to manage it.
Persons and Family Law
Article 15, Civil Code

Floresca vs. Philex Mining Corporation

30th April 1985

ak256751
136 SCRA 141 , G.R. No. 30642
Primary Holding
An injured worker or their heirs have a choice of remedies between availing of the limited, no-fault compensation under the Workmen's Compensation Act or suing for greater damages under the Civil Code where the injury or death is caused by the employer's gross negligence; however, these remedies are mutually exclusive. An initial choice to receive compensation under the Act will not bar a subsequent civil suit for damages if that choice was based on ignorance or a mistake of fact, such as being unaware of the employer's culpable negligence at the time.
Background
The case arose from a tragic mining accident where several employees of Philex Mining Corporation died. At the time, two distinct legal frameworks governed compensation for work-related injuries and deaths. The Workmen's Compensation Act (WCA) provided a system of limited, no-fault liability, ensuring that employees or their heirs received swift but modest compensation regardless of who was at fault. In contrast, the Civil Code allowed for actions based on tort (quasi-delict) or breach of contract, which could result in significantly higher awards for actual, moral, and exemplary damages, but required the claimant to prove the employer's fault or negligence. This created a legal conflict over which remedy was proper, particularly in cases where an employer's negligence was the direct cause of the accident.
Persons and Family Law

Marcia vs. Court of Appeals

27th January 1983

ak812962
G.R. No. 34529 , 205 Phil. 147 , 120 SCRA 193
Primary Holding
An acquittal of an accused in a criminal case for reckless imprudence, which is based on a final judicial declaration that the fact from which civil liability may arise did not exist, bars a subsequent civil action for damages arising from the same incident.
Background
The case originated from a vehicular collision on December 23, 1956, in Lubao, Pampanga, between a passenger bus operated by Victory Liner, Inc. and driven by Felardo Paje, and a jeep driven by Clemente Marcia. The collision resulted in the death of Clemente Marcia and physical injuries to the petitioners, Edgar Marcia and Renato Yap, who were passengers in the jeep. This led to the filing of both a criminal action against the bus driver and a separate civil action for damages by the injured parties against the driver and the bus company.
Persons and Family Law

Manila Gas Corporation vs. Court of Appeals

30th October 1980

ak184426
100 SCRA 602 , G.R. No. L-44190
Primary Holding
A public utility corporation that files a baseless criminal complaint for qualified theft against a customer with malicious intent to vex and humiliate, and subsequently disconnects the customer's service without the required prior notice in breach of contract and in bad faith, is liable for moral and exemplary damages; however, the amount of such damages may be reduced by the court based on the specific circumstances of the case, including the financial capacity of the utility and any mitigating actions or faults of the customer.
Background
Manila Gas Corporation, a public utility, supplied gas to the residence and 46-door apartment complex of Isidro M. Ongsip, a prominent businessman. After new appliances were installed in 1965, the gas meter readings remained unusually low, registering zero consumption in May and June 1966. This discrepancy prompted Manila Gas to investigate, leading to the discovery of an alleged illegal "jumper" or by-pass valve, which became the basis for the ensuing legal conflict.
Persons and Family Law

Vda. de Laig vs. Court of Appeals

21st November 1978

ak844009
86 SCRA 641
Primary Holding
The prohibition under Article 1491, paragraph 5 of the Civil Code, which prevents lawyers from acquiring by purchase the property and rights which are the object of litigation in which they take part, applies only during the pendency of the litigation. A sale of such property to the lawyer after the judgment has become final and the property is no longer in litigation is valid.
Background
The dispute originated from a double sale of a parcel of land originally owned by Petre Galero. Galero first engaged the services of Atty. Benito Laig to recover the property in a civil case. After winning the case and after the decision became final, Galero transferred the entire property to Atty. Laig—one-half by sale and the other half as contingent attorney's fees. Years later, Galero, with the assistance of Atty. Jose L. Lapak, fraudulently obtained a new owner's duplicate title and sold the same property to Carmen Verso. This second sale was registered by the Register of Deeds, Atty. Baldomero M. Lapak, who was the father of Atty. Jose L. Lapak. This prompted the heirs of Atty. Laig to file a suit to annul the second sale and for reconveyance, leading to the present protracted legal battle.
Persons and Family Law

Lim vs. Ponce de Leon

29th August 1975

ak198759
66 SCRA 299 , G.R. No. L-22554
Primary Holding
A public officer, such as a provincial fiscal, has no authority to order the seizure of private property without a valid search warrant, even if the property is the *corpus delicti* of a crime. A violation of the constitutional right against unreasonable searches and seizures by a public officer gives rise to civil liability for damages under Article 32 of the New Civil Code, and the officer's good faith is not a valid defense.
Background
Jikil Taha sold a motor launch to Alberto Timbangcaya. A year later, Timbangcaya filed a criminal complaint, alleging that Taha had forcibly retaken the launch. Based on this, Fiscal Francisco Ponce de Leon initiated a criminal case for robbery against Taha. In the interim, Taha had sold the same motor launch to Delfin Lim. The fiscal, upon learning of the launch's location and its subsequent sale to Lim, ordered its seizure as evidence in the pending criminal case, leading to the present civil suit for damages.
Persons and Family Law
Article 32, New Civil Code

People vs. Licera

22nd July 1975

ak629032
G. R. No. L-39990 , 65 SCRA 270
Primary Holding
A new judicial doctrine in the field of penal law that abrogates a previous one must be applied prospectively and cannot be given retroactive effect if it would be prejudicial to an accused who acted in reliance on the old doctrine.
Background
The case arose from a legal uncertainty created by two conflicting Supreme Court decisions regarding the illegal possession of firearms. The earlier doctrine, established in _People vs. Macarandang_, interpreted Section 879 of the Revised Administrative Code to include secret agents appointed by governors as "peace officers" exempt from firearm licensing requirements. A later case, _People vs. Mapa_, explicitly overturned this interpretation. The accused, Rafael Licera, was appointed as a secret agent and apprehended for possessing a firearm while the _Macarandang_ doctrine was still in effect, but was tried and convicted after the _Mapa_ doctrine had been established.
Persons and Family Law

People vs. Jabinal

27th February 1974

ak908521
55 SCRA 607 , G.R. No. L-30061
Primary Holding
When a judicial doctrine is overruled and a new one is adopted, the new doctrine should be applied prospectively and should not retroactively prejudice parties who had relied on the old doctrine and acted on the faith thereof, especially in the construction and application of criminal laws.
Background
The legal context of this case revolves around the interpretation of firearm laws, specifically the exemption for "peace officers." Initially, in the cases of _People vs. Macarandang_ (1959) and _People vs. Lucero_ (1958), the Supreme Court held that individuals appointed as secret agents with duties related to maintaining peace and order were considered "peace officers" and thus exempt from the requirement of a license to possess firearms. This interpretation was abruptly overturned in 1967 by the ruling in _People vs. Mapa_, which adopted a strict and literal interpretation of the law, holding that secret agents are not included in the list of exempted persons and are therefore liable for illegal possession. The present case arose from an act committed in 1964, when the old, more lenient doctrine was still in effect, but was decided by the trial court in 1968, after the new, stricter doctrine was established.
Persons and Family Law

Gongon vs. Court of Appeals

30th April 1970

ak161579
32 SCRA 412 , G.R. No. L-24421
Primary Holding
The preferential right to purchase a lot under Commonwealth Act No. 539, which gives preference first to "bona fide tenants" and second to "occupants," is not absolute and must be interpreted in line with the constitutional principle of social justice. Where the parties are not on an equal footing, as when the lessee is a non-occupant and already a landowner while the sublessee is the actual occupant and landless, equity and justice demand that the preferential right be granted to the actual occupant to fulfill the law's purpose of giving land to the landless.
Background
The case arose from the government's acquisition of the Tambobong Estate in Malabon, Rizal, from the Roman Catholic Church on December 31, 1947, under Commonwealth Act No. 539. This law authorized the President to acquire private lands and subdivide them for resale to bona fide tenants, occupants, or other qualified individuals. The lot in question, Lot 18-B, Block 23, was part of this estate. Amada Aquino was the original lessee, who then sublet the property to Matias Gongon in 1934. When the government began reselling the lots, both Aquino (as lessee) and Gongon (as occupant) filed applications to purchase the same lot, leading to a legal conflict over who had the preferential right.
Persons and Family Law

Laura Corpus, et al. vs. Felardo Paje and The Victory Liner Transportation Co., Inc.

31st July 1969

ak122160
G.R. No. L-26737
Primary Holding
The acquittal of an accused in a criminal case for reckless imprudence on the ground that the fact from which civil liability might arise did not exist is a bar to a subsequent civil action for damages based on the same act (delict). Alternatively, if the civil action is founded on quasi-delict, it must be filed within the four-year prescriptive period from the date of the incident, which is not interrupted by the institution of the criminal action.
Background
The case originated from a vehicular accident on December 23, 1956, in Lubao, Pampanga. A passenger bus owned by Victory Liner Transportation Co., Inc. and driven by Felardo Paje collided with a jeep driven by Clemente Marcia. The collision resulted in the death of Clemente Marcia and physical injuries to two other individuals. This event triggered both criminal and civil proceedings to determine liability for the death and damages.
Persons and Family Law
Article 33, Civil Code

Bellis vs. Bellis

6th June 1967

ak036910
20 SCRA 358 , G.R. No. L-23678
Primary Holding
The national law of a foreign decedent determines the intrinsic validity of their will, the order of succession, the amount of successional rights, and the capacity to succeed, even if the properties are located in the Philippines; Philippine laws on legitimes and public policy do not apply to the succession of foreign nationals.
Background
Amos G. Bellis, a citizen of Texas, U.S.A., had legitimate children from two marriages and three illegitimate children. He executed a will in the Philippines, where some of his assets were located, providing specific legacies for his first wife and his three illegitimate children, with the remainder of his estate going to his seven legitimate children. At the time of his death, he was a resident of Texas. The will did not conform to the Philippine system of legitimes, which grants compulsory shares to illegitimate children.
Persons and Family Law

Wassmer vs. Velez

26th December 1964

ak912210
12 SCRA 648 , G.R. No. L-20089
Primary Holding
While a mere breach of promise to marry is not an actionable wrong in itself, a person who, after making formal wedding preparations (such as applying for a license, sending invitations, and preparing for the ceremony), abruptly and unjustifiably cancels the wedding, causing public humiliation and injury, commits an act contrary to good customs and can be held liable for damages under Article 21 of the Civil Code.
Background
Francisco Velez and Beatriz Wassmer were engaged and had formally planned their wedding. This included securing a marriage license, distributing invitations, purchasing attire, and receiving bridal shower gifts. Two days before the set date, Velez suddenly left a note cancelling the wedding, citing his mother's opposition. He then sent a telegram promising to return but never did, prompting Wassmer to sue for damages due to the public humiliation and expenses incurred.
Persons and Family Law

Brehm vs. Republic

30th September 1963

ak978065
9 SCRA 172 , G.R. No. L-18566
Primary Holding
The absolute prohibition in Article 335(4) of the New Civil Code, which states that non-resident aliens "cannot adopt," is a mandatory provision that disqualifies a non-resident alien from adopting in the Philippines, even if he is the step-father of the child to be adopted.
Background
Gilbert R. Brehm, an American citizen serving in the U.S. Navy and temporarily assigned at Subic Bay, married Ester Mira, a Filipina citizen. Ester had a daughter, Elizabeth, from a previous relationship with another American who had left the country. After their marriage, the couple and the child resided in Manila, with Gilbert providing care and support. To formalize their family unit and give the child a legitimate status, the spouses filed a joint petition to adopt Elizabeth.
Persons and Family Law

Aznar vs. Garcia

31st January 1963

ak099588
7 SCRA 95 , No. L-16749
Primary Holding
When Philippine law directs the application of a foreign national's law to matters of succession, the term "national law" is understood to encompass the entirety of that foreign law, including its conflict-of-laws rules. If the foreign law contains a conflict-of-laws rule that refers the matter back to the law of the decedent's domicile, the Philippine court shall accept this referral (renvoi) and apply its own internal law on succession.
Background
Edward E. Christensen, a citizen of the State of California, lived for most of his life in the Philippines, where he died. He left a will that provided a legacy of P3,600 to Helen Christensen Garcia, who had been judicially declared his acknowledged natural child in a separate proceeding, while leaving the bulk of his substantial estate to his other daughter, Maria Lucy Christensen. This disposition was valid under the internal law of California, which grants testators complete freedom of disposition. However, it contravened Philippine law, which designates acknowledged natural children as forced heirs entitled to a specific portion of the estate known as the legitime. The conflict arose as to which law should govern the intrinsic validity of the will's provisions.
Persons and Family Law

Mendoza vs. Alcala

29th August 1961

ak406778
G.R. No. L-14305 , 2 SCRA 1032
Primary Holding
An acquittal in a criminal case on the ground that the accused's guilt has not been proven beyond a reasonable doubt does not extinguish the civil liability arising from the same act or omission and does not bar a subsequent civil action to enforce it.
Background
The dispute originated from a transaction where Gaudencio T. Mendoza gave Maximo M. Alcala the sum of P1,100. A receipt signed by Alcala indicated this amount was an advance payment for 100 cavans of palay that Alcala promised to deliver by a specific date. When Alcala failed to deliver the palay, Mendoza initiated criminal proceedings for estafa against him.
Persons and Family Law
Article 29 & 33, New Civil Code

Hermosisima vs. Court of Appeals, et al.

30th September 1960

ak130576
109 Phil. 629 , G.R. No. L-14628
Primary Holding
An action for breach of a promise to marry is not a valid basis for recovering moral damages under Philippine law, as Congress deliberately omitted provisions from the Civil Code that would have sanctioned such claims.
Background
The case originated from an intimate relationship between Soledad Cagigas, a 36-year-old former teacher, and Francisco Hermosisima, an apprentice pilot nearly ten years her junior. Their relationship led to Cagigas becoming pregnant. Hermosisima promised to marry her but subsequently married another woman. Cagigas filed a suit for acknowledgment of their child, support, and moral damages for the broken promise. The lower courts granted the moral damages, framing the petitioner's actions as a form of seduction, which prompted the petitioner to elevate the issue to the Supreme Court.
Persons and Family Law

Velayo, etc. vs. Shell Co. of the Phils., et al.

31st October 1956

ak120965
100 Phil. 186 , G.R. No. L-7817
Primary Holding
A creditor who, after participating in a meeting with other creditors of an insolvent debtor to arrange for a fair pro-rata distribution of assets, takes advantage of information obtained therein to secretly assign its credit to another entity to attach the debtor's property abroad, acts in bad faith and contrary to morals and public policy, and is liable for damages to the insolvent's estate under the Civil Code.
Background
Commercial Air Lines, Inc. (CALI), a Philippine corporation, was in a state of insolvency, owing significant debts to multiple creditors, including a substantial amount to Shell Company of the Philippine Islands, Ltd. (Shell) for fuel supplies. CALI's management, seeking to avoid formal insolvency proceedings and ensure an equitable settlement, convened a meeting of its principal creditors to disclose its financial situation and discuss a plan for the fair distribution of its remaining assets, one of which was a valuable Douglas C-54 airplane located in California, USA.
Persons and Family Law

Republic of the Philippines vs. Encarnacion

29th December 1950

ak028894
87 Phil. 843 , G.R. No. L-3936
Primary Holding
A law that states it shall take effect on the day of its approval becomes effective from the very first moment of that day, as the law does not recognize fractions of a day for the purpose of determining a statute's effectivity.
Background
The case arose from a naturalization proceeding governed by the then-existing law. A new statute, Republic Act No. 530, was enacted, fundamentally altering the naturalization process by mandating that a decision granting citizenship would only become executory after a two-year waiting period from its promulgation. The dispute centered on whether this new law applied to the respondent, Si Kee, whose naturalization decision was set to become final and executory on the very same day that R.A. 530 was approved by the President. The core of the conflict was the interpretation of the law's effective date and its applicability to cases that were on the cusp of finality.
Persons and Family Law
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