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Mapulo Mining Corporation vs. Lopez

7th February 1992

ak606231
206 SCRA 9 , 282 Phil. 905 , G.R. No. L-30440
Summary
The case involves a dispute over the validity of mining claims and compliance with the publication requirements under the Mining Act (C.A. No. 137, as amended). The Supreme Court ruled on whether a private respondent complied with the mandatory publication requirements for its application for a mining lease. Petitioners argued deficiencies in the publication process and alleged violations of mining laws, ultimately leading the Court to set aside the orders of the Director of Mines and the Secretary of Agriculture and Natural Resources.
Background
The case arose when Project Ventures, Inc. (PROVEN) filed mining lease applications conflicting with prior claims by Mapulo Mining Association and E.V. Chavez & Associates. Petitioners opposed PROVEN’s applications, arguing that the notice's publication did not strictly comply with the Mining Act and that PROVEN’s claims violated sections of the law relating to mining claims on private lands.
Statutory Construction

Comendador vs. De Villa

2nd August 1991

ak165261
200 SCRA 80 , 277 Phil. 93 , G.R. No. 93177 , G.R. No. 95020 , G.R. No. 96948 , G.R. No. 97454
Summary
Military officers charged with mutiny and murder after a failed 1989 coup challenged the legality of their pre-trial investigation, the denial of their right to peremptory challenge, and the jurisdiction of civilian courts to interfere in military proceedings. The Supreme Court upheld the pre-trial process, revived the right to peremptory challenge, denied bail for military personnel, and reversed civilian court orders releasing the accused.
Background
Following a failed December 1989 coup, AFP officers were charged with mutiny, murder, and related offenses under the Articles of War. They contested the legality of the Pre-Trial Investigation (PTI) Panel, the General Court-Martial (GCM) No. 14’s composition, and the denial of peremptory challenges. Civilian RTCs granted provisional liberty to some officers via certiorari and habeas corpus, prompting appeals to the Supreme Court.
Statutory Construction

Co vs. Electoral Tribunal of the House of Representatives

30th July 1991

ak810844
199 SCRA 692 , 276 Phil. 758 , G.R. Nos. 92191-92 , G.R. Nos. 92202-03
Summary
Petitioners challenged respondent Jose Ong, Jr.’s eligibility as a House Representative, alleging he was not a natural-born Filipino citizen and lacked residency in Northern Samar. The Supreme Court upheld the House Electoral Tribunal (HRET) decision, ruling Ong qualified under the Constitution.
Background
Jose Ong, Jr. won the 1987 congressional election for Northern Samar’s second district. Petitioners Co and Balanquit filed protests with HRET, contesting Ong’s citizenship and residency. HRET ruled in Ong’s favor, prompting petitioners to seek certiorari before the Supreme Court.
Statutory Construction

Civil Liberties Union vs. Executive Secretary

22nd February 1991

ak233934
194 SCRA 317 , 272 Phil. 147 , G.R. No. 83896 , G.R. No. 83815
Summary
This consolidated case involves petitions challenging the constitutionality of Executive Order No. 284, which allowed members of the Cabinet, their undersecretaries, and assistant secretaries to hold additional government positions. The petitioners argued that E.O. No. 284 violated Section 13, Article VII of the 1987 Constitution, which prohibits the President, Vice-President, Cabinet members, and their deputies or assistants from holding any other office or employment during their tenure, unless otherwise provided in the Constitution. The Supreme Court ruled in favor of the petitioners, declaring E.O. No. 284 unconstitutional. The Court held that the prohibition in Section 13, Article VII is stricter than the general prohibition for other appointive officials in Section 7, Article IX-B, and that the exceptions to the former must be expressly provided in the Constitution itself. However, the Court clarified that positions held in an *ex-officio* capacity without additional compensation, as required by the primary functions of the office, do not constitute "any other office or employment" under the constitutional ban.
Background
The case arose from the issuance of Executive Order No. 284 by President Corazon C. Aquino on July 25, 1987. This E.O. allowed members of the Cabinet, undersecretaries, assistant secretaries, and other appointive officials of the Executive Department to hold, in addition to their primary positions, not more than two positions in the government and government corporations and receive corresponding compensation. This was issued following DOJ Opinion No. 73, s. 1987, which interpreted Section 13, Article VII in relation to Section 7, par. (2), Article IX-B of the Constitution. The practice of high-ranking executive officials holding multiple government posts, often with substantial emoluments, had been a contentious issue, particularly during the Marcos regime, and the 1987 Constitution sought to address this.
Constitutional Law I Statutory Construction

Luz Farms vs. Secretary of the Department of Agrarian Reform

4th December 1990

ak615135
192 SCRA 51 , 270 Phil. 151 , G.R. No. 86889
Summary
The Supreme Court declared portions of the Comprehensive Agrarian Reform Law of 1988 unconstitutional, specifically provisions extending the program's coverage to land used for livestock, poultry, and swine raising. The Court ruled that agricultural lands under agrarian reform do not include such industrial undertakings, as the use of land is merely incidental to such operations.
Background
Luz Farms, a corporation engaged in livestock and poultry raising, challenged certain provisions of R.A. No. 6657 arguing that livestock and poultry operations shouldn't be considered agricultural lands under agrarian reform laws. The petitioner claimed that the application of these provisions violated its property rights and due process.
Statutory Construction

Lazatin vs. House Electoral Tribunal

8th December 1988

ak403328
168 SCRA 391 , 250 Phil. 390 , No. L-84297
Summary
The Supreme Court ruled that the House Electoral Tribunal (HRET) has exclusive authority to set deadlines for election protests involving congressional members, dismissing Lazatin’s claim that Timbol’s protest was time-barred under the Omnibus Election Code.
Background
The case arose from the 1987 congressional election in Pampanga, where Timbol contested Lazatin’s proclamation due to alleged irregularities. After prolonged COMELEC proceedings, the Supreme Court reinstated Lazatin’s proclamation, prompting Timbol to file a protest with the HRET.
Statutory Construction

De Leon vs. Esguerra

31st August 1987

ak434466
153 SCRA 602 , 237 Phil. 582 , No. L-78059
Summary
Barangay officials challenged their replacement by designees of a provincial OIC Governor after the 1987 Constitution’s ratification. The Supreme Court ruled that the 1987 Constitution invalidated the replacements, as the officials’ six-year terms under Batas Pambansa Blg. 222 remained valid.
Background
Petitioners, elected barangay officials in 1982, faced replacement through memoranda issued by the OIC Governor in February 1987. The Court determined the memoranda were antedated and issued after the 1987 Constitution’s ratification.
Statutory Construction

Galman vs. Pamaran

30th August 1985

ak797659
138 SCRA 294 , Nos, L-71208-09 , Nos. L-71212-13
Summary
This case arises from the assassination of former Senator Benigno S. Aquino Jr. in 1983 at Manila International Airport. The primary issue concerns the admissibility of testimonies and evidence provided by suspects before the Agrava Fact-Finding Board, especially in light of their constitutional right against self-incrimination and the immunity granted under Presidential Decree No. 1886. The Supreme Court upheld the exclusion of the testimonies and evidence submitted to the Agrava Board, reinforcing constitutional protections against self-incrimination.
Background
The assassination of Senator Benigno S. Aquino Jr. on August 21, 1983, led to the creation of the Agrava Fact-Finding Board under P.D. 1886. The Board investigated the incident and gathered testimonies, including those from suspects. Legal questions arose during subsequent trials regarding the admissibility of evidence obtained under mandatory compulsion by the Board.
Statutory Construction

Arenas vs. City of San Carlos (Pangasinan)

5th April 1978

ak735400
82 SCRA 318 , 172 Phil. 306 , No. L-34024
Summary
This case involves Isidro G. Arenas, the City Judge of San Carlos City, who filed a petition for mandamus to compel the city government to pay his salary differential as mandated by Republic Act No. 5967. The Supreme Court dismissed his petition, affirming the lower court's ruling that the salary of a city judge should not exceed that of the city ma
Background
Isidro G. Arenas, serving as City Judge of San Carlos City, claimed entitlement to a higher salary based on Republic Act No. 5967. The city government refused to pay the differential, citing that the law mandates the judge's salary to be lower than the mayor's. Arenas filed a mandamus petition, which was dismissed by the Court of First Instance.
Statutory Construction

Bagatsing vs. Ramirez

17th December 1976

ak142723
74 SCRA 306 , 165 Phil. 909 , G.R. No. L-41631
Summary
The Supreme Court resolved a conflict between the publication requirements of Manila’s Revised City Charter (pre- and post-enactment publication) and the Local Tax Code (post-approval publication only). The Court ruled that the Local Tax Code, as a later general law, superseded the City Charter’s provisions for tax ordinances, upholding the validity of Manila’s Ordinance No. 7522.
Background
June 12–15, 1974: Manila’s Municipal Board enacted and Mayor Bagatsing approved Ordinance No. 7522, imposing fees on public market stalls. February 17, 1975: The Federation of Manila Market Vendors sued to invalidate the ordinance, claiming non-compliance with the City Charter’s publication rules. August 29, 1975: The Court of First Instance (Manila) nullified the ordinance for lacking pre-enactment publication.
Statutory Construction

Astorga vs. Villegas

30th April 1974

ak503127
56 SCRA 714 , No. L-23475
Summary
This case concerns the validity of Republic Act No. 4065, which allegedly did not reflect the version of House Bill No. 9266 that was duly passed by both the House of Representatives and the Senate. Vice-Mayor Herminio A. Astorga sought to enforce the provisions of the Act, while Mayor Antonio J. Villegas argued it never became law due to procedural defects during its enactment. The Supreme Court ruled that RA 4065 was not duly enacted and thus did not become law.
Background
The case originated from the passage of House Bill No. 9266, which sought to define the powers of the Manila Vice-Mayor. After its passage, controversy erupted when it was discovered that the version signed into law did not include substantial amendments made by Senator Tolentino on the Senate floor.
Statutory Construction

Commissioner of Customs vs. Court of Tax Appeals

31st January 1972

ak064106
43 SCRA 192 , 150 Phil. 222 , No. L-33471
Summary
The Supreme Court annulled the Court of Tax Appeals’ (CTA) resolutions ordering the release under bond of foodstuffs imported without a Central Bank release certificate, ruling the importation was prohibited by law and thus ineligible for bond release under the Tariff and Customs Code.
Background
Eusebio Dichoco’s shipment of 438 packages of foodstuffs was seized by customs for lacking a Central Bank release certificate. The CTA initially allowed release under bond, reversed itself, then reinstated the bond order. The Commissioner of Customs challenged this via certiorari.
Statutory Construction

Edu vs. Ericta

24th October 1970

ak811997
35 SCRA 481 , 146 Phil. 469 , No. L-32096
Summary
The Supreme Court upheld the constitutionality of the Reflector Law and its implementing administrative order, ruling that the law was a valid exercise of police power to promote public safety and that the administrative order did not constitute an improper delegation of legislative power.
Background
Respondent Teddy Galo challenged the Reflector Law and Administrative Order No. 2 (requiring vehicles to install reflectors) as violations of due process and non-delegation. The lower court issued a preliminary injunction against the order, prompting the petitioner to seek Supreme Court review.
Statutory Construction

Automotive Parts & Equipment Company, Inc. vs. Lingad

31st October 1969

ak801807
30 SCRA 248 , 140 Phil. 580 , No. L-26406
Summary
This case revolves around the interpretation of the Minimum Wage Law and the obligations of employers regarding wage payments. The Automotive Parts & Equipment Company sought to reduce its monthly wage liability for employees, arguing that the law did not apply retroactively to newly established businesses. The Supreme Court upheld the lower court's decision, affirming that the company must comply with the minimum wage requirements.
Background
The petitioner, Automotive Parts & Equipment Company, was incorporated in 1961 and had been paying its employees on both daily and monthly bases. Following the enactment of Republic Act No. 4180 in 1965, which amended the minimum wage law, the Secretary of Labor mandated an increase in monthly wages to a minimum of P180.00. The company contested this requirement, seeking a declaratory relief to interpret its obligations under the law.
Statutory Construction

National Marketing Corp. vs. Tecson

27th August 1969

ak067424
29 SCRA 70 , 139 Phil. 584 , No. L-29131
Summary
The Supreme Court resolved whether an action for the revival of a judgment filed exactly ten calendar years after its finality was barred under the statute of limitations in light of the Civil Code provision defining a "year" as 365 days. The Court affirmed the dismissal of the case, ruling that the ten-year limitation had already lapsed due to the inclusion of leap years, which made the total time span exceed 3,650 days.
Background
The Price Stabilization Corporation obtained a final judgment in 1955 against Miguel Tecson. Years later, the National Marketing Corporation, as its successor, attempted to revive this judgment in 1965. The trial court dismissed the case, finding that the action was filed beyond the ten-year prescription period. The only issue on appeal was whether the action to revive had prescribed.
Statutory Construction

City of Baguio vs. Marcos

28th February 1969

ak680073
27 SCRA 342 , 136 Phil. 569 , No. L-26100
Summary
This case revolves around the jurisdiction of the Court of First Instance of Baguio to reopen cadastral proceedings under Republic Act (R.A.) 931. Petitioners challenged the reopening petition filed by Belong Lutes, arguing they had standing as lessees of the disputed public land. The Supreme Court ruled that lessees have legal personality to oppose reopening under R.A. 931 and upheld the cadastral court’s jurisdiction.
Background
The case originated from a 1912 cadastral proceeding (Civil Reservation Case No. 1) declaring the land public in 1922. In 1961, Belong Lutes petitioned to reopen the case, claiming ancestral possession. Petitioners, as tree farm lessees, opposed the reopening but were dismissed by lower courts. The Supreme Court reversed these rulings.
Statutory Construction

Gonzales vs. Commission on Elections

9th November 1967

ak403726
21 SCRA 774 , 129 Phil. 7 , No. L-28196 , No. L-28224
Summary
Petitioners sought to prohibit the enforcement of Republic Act No. 4913, which submitted two constitutional amendments (increasing House representatives and allowing legislators to join a constitutional convention) for ratification during the November 1967 general elections. The Supreme Court dismissed the petitions, upholding the law’s constitutionality but with strong concurring opinions criticizing the sufficiency of public information.
Background
Congress passed Resolutions 1 and 3 (proposing amendments) and Resolution 2 (calling a future constitutional convention) on March 16, 1967. RA 4913 scheduled the plebiscite during the 1967 general election. Petitioners argued the amendments were rushed and inadequately publicized.
Statutory Construction

Lidasan vs. Commission on Elections

25th October 1967

ak047045
21 SCRA 496 , 128 Phil. 526 , No. L-28089
Summary
The Supreme Court declared Republic Act (RA) 4790 unconstitutional for violating the constitutional requirement that a law’s title must reflect its subject. The law created the Municipality of Dianaton in Lanao del Sur but included barrios from Cotabato without mentioning them in the title, misleading legislators and the public.
Background
RA 4790 aimed to create Dianaton from barrios in Lanao del Sur and Cotabato. The Office of the President urged suspending its implementation, but COMELEC enforced it. Petitioner Bara Lidasan, a Cotabato resident, challenged the law’s validity.
Statutory Construction

Caltex (Philippines), Inc. vs. Palomar

29th September 1966

ak979503
18 SCRA 247 , 124 Phil. 763 , No. L-19650
Summary
Caltex planned a promotional contest requiring participants to estimate gas pump output for prizes, with no purchase or fee required. The Postmaster General deemed it a prohibited lottery under the Postal Law and threatened a fraud order. The Supreme Court ruled the contest legal, as it lacked consideration, a key element of lotteries.
Background
Caltex designed the “Caltex Hooded Pump Contest” in 1960 to boost sales. Participants estimated gas pump output for prizes. The Postmaster General blocked mail use for the contest, calling it a lottery. Caltex sought declaratory relief to affirm its legality.
Statutory Construction

Bolinao Electronics Corporation vs. Valencia

30th June 1964

ak243676
11 SCRA 486 , 120 Phil. 469 , No. L-20740
Summary
Three broadcasting companies challenged the Secretary of Public Works and Communications' authority to investigate their license renewal applications after late submissions, arguing violations were condoned by a departmental circular. The Supreme Court ruled the investigation lacked legal basis and upheld the broadcasters' rights to operate on contested channels.
Background
The Secretary of Public Works and Communications improperly initiated license renewal investigations after condoning late filings through an official circular. The Philippine Broadcasting Service (PBS) unlawfully attempted to operate a TV channel in Luzon despite budgetary restrictions.
Statutory Construction

Commissioner Internal Revenue vs. Filipinas Compañia de Seguros

29th April 1960

ak186834
107 Phil. 1055 , No. L-14880
Summary
The Supreme Court ruled that the amended real estate dealer’s fixed annual tax under Republic Act No. 1612 could not be applied retroactively to 1956, as the respondent had already paid the tax in full under the original law. The Court affirmed the prospective application of tax laws absent clear legislative intent for retroactivity.
Background
Respondent Filipinas Compañía de Seguros, a real estate dealer, paid P150 as the 1956 fixed annual tax under the original National Internal Revenue Code. RA 1612 (effective August 24, 1956) introduced graduated rates. The Commissioner later demanded an additional P350, claiming retroactive application. The Court of Tax Appeals ruled for the respondent, prompting the Commissioner’s appeal to the Supreme Court.
Statutory Construction

Carandang vs. Santiago, etc. and Valenton

25th May 1955

ak105250
97 Phil. 94 , No. L-8238
Summary
Petitioner Cesar Carandang filed a civil action for damages against Tomas Valenton Jr. (convicted of frustrated homicide) and his parents. The trial court suspended the civil case pending the criminal appeal. The Supreme Court reversed, holding that under Article 33 of the Civil Code, a civil action for physical injuries proceeds independently of the criminal case, even if the crime charged is frustrated homicide.
Background
After Tomas Valenton Jr. was convicted of frustrated homicide for attacking Carandang, Carandang filed a civil suit for damages. The trial court suspended the civil case pending the criminal appeal. Carandang challenged this suspension via certiorari.
Statutory Construction

In re: Cunanan, et al.

18th March 1954

ak641009
94 Phil. 534
Summary
The Supreme Court declared Republic Act No. 972 (the "Bar Flunkers’ Act of 1953") unconstitutional for infringing on the Court’s exclusive authority to regulate bar admissions. The law retroactively lowered passing grades for bar exams from 1946–1952, allowing 1,094 unsuccessful candidates admission. The Court ruled it violated separation of powers and constituted arbitrary class legislation.
Background
Post-WWII bar candidates who narrowly failed petitions sought admission under RA 972, which retroactively reduced passing averages. The Court initially adjusted passing grades annually but rejected legislative interference, citing the need to protect public interest in legal practice standards.
Statutory Construction

Endencia and Jugo vs. David

31st August 1953

ak286628
93 Phil. 696 , 146 Phil. 469 , Nos. L-6355-56
Summary
The Supreme Court ruled that Section 13 of Republic Act No. 590, which allowed income taxation of judicial salaries, was unconstitutional. The Court held that taxing judges’ salaries constitutes a “diminution” of compensation prohibited by the Constitution and affirmed the judiciary’s exclusive authority to interpret the Constitution.
Background
Judges Pastor M. Endencia and Fernando Jugo sued for refunds of income taxes withheld from their salaries. The lower court ruled in their favor, citing Perfecto v. Meer. The Collector of Internal Revenue appealed, arguing Congress’s enactment of RA 590 validated the taxation.
Statutory Construction

Krivenko vs. Register of Deeds of Manila

15th November 1947

ak700773
79 Phil. 461 , No. L-630
Summary
The Supreme Court ruled in Krivenko v. Register of Deeds (1947) that residential land qualifies as “agricultural” under the 1935 Philippine Constitution, prohibiting non-citizens from acquiring such property. The decision upheld the denial of a Russian alien’s attempt to register a Manila residential lot, emphasizing that constitutional restrictions on land ownership aim to preserve national patrimony for Filipinos.
Background
The case emerged during post-WWII Philippines amid efforts to enforce constitutional protections over national patrimony. Article XIII of the 1935 Constitution prohibited alien ownership of "agricultural land," but ambiguity arose over whether this term included residential parcels. The dispute reflected tensions between foreign investments and safeguarding Filipino resources, requiring the Court to clarify the scope of constitutional land restrictions.
Statutory Construction

Mabanag vs. Lopez Vito

5th March 1947

ak966503
78 Phil. 1 , G.R. No. 1123
Summary
This case involves a petition for prohibition filed by members of the Philippine Congress challenging the validity of a resolution proposing an amendment to the Philippine Constitution. Petitioners argued that the resolution was not validly adopted, as it failed to meet the constitutional requirement of approval by three-fourths of all members of the Senate and House of Representatives voting separately. The Supreme Court dismissed the petition, ruling the issue as a political question beyond judicial review.
Background
The case arose after Congress passed a resolution proposing a constitutional amendment allowing American citizens and corporations to exploit natural resources in the Philippines, subject to a plebiscite for public ratification. Petitioners challenged this resolution, claiming it failed to meet the required three-fourths votes in both legislative chambers.
Statutory Construction

Laurel vs. Misa

30th January 1947

ak294241
77 Phil. 856 , G.R. No. 409
Summary
This case involves a petition for habeas corpus filed by Anastacio Laurel, who argued that a Filipino citizen who adhered to the enemy during the Japanese occupation could not be prosecuted for treason. Laurel contended that the sovereignty of the legitimate government and the correlative allegiance of Filipino citizens were suspended during the occupation, and that there was a change of sovereignty with the proclamation of the Philippine Republic. The Supreme Court denied the petition, holding that a citizen's absolute and permanent allegiance to their legitimate government is not abrogated by enemy occupation, and therefore, treason could be committed against the Philippine government during that period.
Background
The case arose in the aftermath of World War II, specifically following the Japanese occupation of the Philippines. During this period, some Filipino citizens were alleged to have collaborated with the Japanese forces. Anastacio Laurel was one such individual accused of treason for acts committed during the occupation.
Constitutional Law I Criminal Law II Statutory Construction

Co Kim Cham vs. Valdez Tan Keh and Dizon

17th September 1945

ak116370
75 Phil. 113 , No. L-5
Summary
A landmark case that determined the validity of judicial acts and proceedings conducted during the Japanese occupation of the Philippines, specifically addressing whether courts established under the Japanese regime could continue their proceedings after liberation.
Background
During World War II, the Japanese forces occupied the Philippines and established the Philippine Executive Commission and later the Republic of the Philippines. After liberation by American forces, questions arose about the validity of judicial proceedings conducted during the occupation period.
Philosophy of Law Statutory Construction

Gold Creek vs. Rodriguez and Abadilla

28th September 1938

ak685675
66 Phil. 259 , No. 45859
Summary
The Supreme Court ruled that a mining claim validly located and perfected under U.S. laws before the 1935 Philippine Constitution took effect is exempt from the constitutional prohibition on alienating natural resources, entitling the claimant to a patent upon fulfilling legal requirements.
Background
Gold Creek Mining Corp. applied for a patent for the “Nob Fraction” mining claim, but the government refused, citing the 1935 Constitution’s prohibition on alienating natural resources. The case centered on whether pre-Constitution mining rights survived the constitutional ban.
Statutory Construction

Chartered Bank vs. Imperial and National Bank

15th March 1921

ak799964
48 Phil. 931 , No. 17222
Summary
The Supreme Court ruled that secured creditors, like the Philippine National Bank (PNB), are not required to participate in insolvency proceedings and may enforce their mortgage rights independently. The case arose when PNB sought to recover mortgaged goods from an insolvent debtor, Umberto de Poli, while other creditors argued all proceedings should halt under insolvency laws.
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
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