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AAA vs. BBB

11th January 2018

ak337012
823 Phil. 607 , G.R. No. 212448
Primary Holding
Philippine courts may exercise jurisdiction over a charge of psychological violence under Section 5(i) of R.A. No. 9262, even if the act causing such violence (e.g., marital infidelity) occurred outside the Philippines, provided that the victim, who is a resident of the Philippines, experienced the resulting mental or emotional anguish within the territorial jurisdiction of the Philippine court.
Background
Petitioner AAA and respondent BBB were married in the Philippines and had two children. BBB started working in Singapore and later allegedly engaged in an extramarital affair there. AAA claimed this affair, along with other alleged abuses like lack of financial support and abandonment, caused her mental and emotional anguish while she was residing in Pasig City, Philippines.
Criminal Law II
VAWC

Career Executive Service Board vs. Civil Service Commission

11th January 2018

ak041015
850 SCRA 563 , G.R. No. 196890
Primary Holding
Permanent status and security of tenure in the Career Executive Service (CES) require the concurrence of two distinct requisites: (1) possessing CES eligibility and (2) being appointed by the President to an appropriate CES rank; possessing eligibility alone is insufficient to confer a permanent appointment.
Background
Following a change in presidential administration in 2010, the Office of the President issued Memorandum Circular No. 1 (MC 1), which declared all non-Career Executive Service positions in the Executive Branch vacant as of June 30, 2010. Subsequent implementing guidelines and Memorandum Circular No. 2 (MC 2) extended the service of non-Career Executive Service Officers (non-CESOs) until a specified date or until their replacements were appointed. This policy led to the termination of officials, like respondent Lodevico, who held CES positions but were not appointed to a specific CES rank, prompting legal challenges regarding their employment status and security of tenure.
Civil Procedure II

Laya, Jr. vs. Philippine Veterans Bank

10th January 2018

ak558145
850 SCRA 315 , G.R. No. 205813
Primary Holding
An employer's imposition of an early retirement age (below the 65-year compulsory age under the Labor Code) is only valid if the employee's consent to such a plan is explicit, voluntary, free, and uncompelled; consent cannot be inferred from a general statement of "membership" in a retirement program in an appointment letter or from automatic membership in a plan that is essentially a contract of adhesion.
Background
Alfredo F. Laya, Jr. was hired by Philippine Veterans Bank (PVB) as its Chief Legal Counsel with the rank of Vice President. The bank had an existing Retirement Plan, established years before Laya's employment, which set the normal retirement age for its members at 60. Upon reaching this age, PVB informed Laya of his retirement. Laya contested this, claiming he did not consent to be retired at an age earlier than the 65-year compulsory age provided by the Labor Code, leading him to file a case for illegal dismissal.
Civil Procedure II

De Lima vs. Guerrero

10th October 2017

ak175936
843 SCRA 1 , 819 Phil. 616 , G.R. No. 229781
Primary Holding
The Petition for Certiorari and Prohibition is dismissed for lack of merit due to prematurity, violation of the hierarchy of courts and the rule against forum shopping, and for failure to demonstrate grave abuse of discretion by the respondent judge. The Regional Trial Court of Muntinlupa City, Branch 204 has jurisdiction over Criminal Case No. 17-165.
Background
Legislative inquiries into drug syndicates at the New Bilibid Prison led to complaints against Senator De Lima for illegal drug trading. These complaints were consolidated before the Department of Justice (DOJ) Panel of Prosecutors for preliminary investigation. De Lima challenged the DOJ Panel's jurisdiction, arguing that the Ombudsman had exclusive jurisdiction.
Criminal Law II

Philippine National Bank vs. Gregorio

18th September 2017

ak003970
840 SCRA 37 , G.R. No. 194944
Primary Holding
The Court of Appeals' review of a National Labor Relations Commission (NLRC) decision through a special civil action for certiorari under Rule 65 is strictly limited to determining whether the NLRC committed grave abuse of discretion amounting to a lack or excess of jurisdiction, and does not extend to correcting mere errors of judgment in the appreciation of evidence.
Background
The dispute originated when a depositor of PNB's Sucat Branch inquired about a unique high-return investment product supposedly offered by branch personnel. This prompted PNB's Internal Audit Group (IAG) to conduct a credit review, which uncovered irregular loan activities allegedly orchestrated by the branch manager, Teresita Fe A. Gregorio. The investigation, supported by affidavits from other depositors, suggested Gregorio was running an unauthorized lending scheme where depositors were convinced to take out loans against their deposits, with the proceeds being re-loaned to other borrowers at a high interest rate, all under Gregorio's supervision but without any official benefit to the bank.
Civil Procedure II
Rule 45

Cortal vs. Inaki A. Larrazabal Enterprises

30th August 2017

ak292177
838 SCRA 255 , G.R. No. 199107
Primary Holding
The dismissal of an appeal on purely technical and formal grounds is improper when it prevents the full, just, and equitable litigation of claims, particularly when the case involves intricate issues of social justice, expropriation, and just compensation under agrarian reform laws; procedural rules may be relaxed in the interest of substantial justice to afford every litigant the opportunity to establish the merits of their case.
Background
Private respondent Inaki A. Larrazabal Enterprises owned three parcels of land in Ormoc City. In 1988, these lands were placed under the Compulsory Acquisition Scheme of Presidential Decree No. 27. Consequently, Emancipation Patents and new transfer certificates of title were issued to farmer-beneficiaries, which included the petitioners. Eleven years later, in 1999, Larrazabal Enterprises filed an action to recover the properties, alleging that it had not received just compensation, a prerequisite for the valid expropriation of its land.
Civil Procedure II

Cortal vs. Inaki A. Larrazabal Enterprises

30th August 2017

ak665608
838 SCRA 255 , G.R. No. 199107
Primary Holding
Procedural rules may be relaxed for persuasive reasons to prevent an injustice that is not commensurate with the degree of a litigant's procedural thoughtlessness, especially when substantial rights concerning property and livelihood are at stake; an inordinate fixation on technicalities cannot defeat the need for a full, just, and equitable litigation of claims on the merits.
Background
The case originated from the implementation of the agrarian reform program under Presidential Decree No. 27. Three parcels of land owned by private respondent Inaki A. Larrazabal Enterprises were placed under the Compulsory Acquisition Scheme in 1988. Consequently, Emancipation Patents and new transfer certificates of title were issued to the petitioners, who were the farmer-beneficiaries. The dispute arose when Larrazabal Enterprises filed an action to recover the properties, alleging that it had never been paid the required just compensation, thus rendering the transfer of titles to the petitioners void.
Civil Procedure II
Rule 43

Frondozo vs. Manila Electric Company

22nd August 2017

ak780189
837 SCRA 378 , G.R. No. 178379
Primary Holding
The Supreme Court held that the NLRC did not commit grave abuse of discretion in granting MERALCO's prayer for a preliminary injunction to suspend execution proceedings due to conflicting final and executory decisions from different Court of Appeals divisions, one of which was affirmed by the Supreme Court on the merits upholding the employees' dismissal for participating in an illegal strike; the case was remanded to the NLRC for execution of the Supreme Court's prior resolutions affirming the dismissals.
Background
The dispute arose from labor unrest at MERALCO involving unfair labor practices, union busting allegations, and strikes by rank-and-file employees under MEWA in 1991, certified to the NLRC for compulsory arbitration by the DOLE Secretary, resulting in terminations of union officers and members for alleged illegal acts during the strikes, and subsequent illegal dismissal complaints amid ongoing conciliation efforts and certifications that enjoined further strikes and ordered return-to-work.
Civil Procedure II
Rule 65

Typoco, Jr. vs. People

16th August 2017

ak004152
837 SCRA 306 , G.R. No. 221857 , G.R. No. 222020
Primary Holding
The alteration of a date on a public document, such as a Purchase Order, to conceal the absence of a prior public bidding constitutes the crime of Falsification of Public Document under Article 171 of the Revised Penal Code, as it makes the document speak a falsehood regarding an essential fact.
Background
In 2005, the Provincial Government of Camarines Norte initiated a "Medical Indigency Program" to provide medicines to indigent families. The case arose from the procurement of medicines worth over P1.6 million for this program, where the transaction was completed before the legally required public bidding was held, leading to the subsequent falsification of documents to simulate compliance with procurement laws.
Civil Procedure II

Estipona, Jr. vs. Lobrigo

15th August 2017

ak282688
837 SCRA 160 , 816 Phil. 789 , G.R. No. 226679
Primary Holding
Section 23 of Republic Act No. 9165, which prohibits plea bargaining in all cases involving violations of the said Act, is unconstitutional because it contravenes the exclusive power of the Supreme Court to promulgate rules concerning pleading, practice, and procedure in all courts, as mandated by Section 5(5), Article VIII of the 1987 Constitution.
Background
* The case arose within the context of the Philippine government's intensified campaign against illegal drugs, governed by Republic Act No. 9165. * RA 9165 contained a specific provision, Section 23, that explicitly disallowed plea bargaining for any offense under the Act, diverging from the general availability of plea bargaining in other criminal cases under the Rules of Court.
Civil Procedure I Criminal Law I Criminal Procedure
Rule-making power of the SC

Joson vs. Office of the Ombudsman

9th August 2017

ak126199
836 SCRA 252 , G.R. Nos. 197433 and 197435
Primary Holding
The Supreme Court affirmed that judicial review of the Office of the Ombudsman's decisions requires strict adherence to procedural rules: dismissal of an administrative complaint where the respondent is exonerated must be challenged via a Rule 43 petition before the Court of Appeals, while dismissal of a criminal complaint may be challenged via a Rule 65 petition before the Supreme Court only upon a clear showing of grave abuse of discretion. Furthermore, the relaxation of procedural rules, such as deadlines for filing motions, is not a matter of right and is granted only for compelling reasons, which were absent in this case.
Background
The dispute arose from a political rivalry within the Provincial Government of Nueva Ecija. The petitioner, Edward Thomas F. Joson, was the Vice Governor, while the primary respondent, Aurelio M. Umali, was the Governor. The complaint centered on the alleged anomalous disbursement of public funds amounting to P1,272,000.00 for catering services during Governor Umali's oath-taking ceremony on July 4, 2007. Joson alleged that the payment was made to a caterer who did not actually provide the service, and the transaction was a fraudulent scheme involving the governor and other provincial officials to misappropriate public funds.
Civil Procedure II
Rule 65

National Housing Authority vs. Laurito

31st July 2017

ak182462
833 SCRA 380 , 814 Phil. 1019 , G.R. No. 191657
Primary Holding
Where two certificates of title are issued to different persons covering the same land, the certificate of title issued earlier in date must prevail, and the reconstitution of a title does not determine ownership nor grant priority based merely on the date of reconstitution, especially when the reconstitution itself is dubious and pertains to a title already cancelled prior to the reconstitution.
Background
The case arose from conflicting claims of ownership over Lot F-3 of subdivision plan Psd-12274 in Carmona, Cavite. The heirs of Spouses Laurito based their claim on TCT No. T-9943 registered in 1956 (later reconstituted as RT-8747 in 1962), derived from TCT No. T-8237. Petitioner NHA based its claim on TCT Nos. T-3717 and T-3741, derived through a series of transfers originating from an alleged administrative reconstitution of the same parent title, TCT No. T-8237, in 1960 (as RT 3909) and subsequent subdivisions/transfers starting in 1960.
Civil Procedure I
Intervention

Espere vs. NFD International Manning Agents, Inc.

26th July 2017

ak175263
833 SCRA 156 , G.R. No. 212098
Primary Holding
The medical assessment of a company-designated physician, who has conducted extensive and continuous monitoring and treatment of a seafarer's condition over a significant period, is given greater evidentiary weight than the contrary opinion of a seafarer's chosen physician which is based on a single consultation and is not supported by comprehensive medical tests and records.
Background
Petitioner Julio C. Espere was employed as a Bosun by respondent NFD International Manning Agents, Inc. and was declared "Fit for Sea Duty" in his Pre-Employment Medical Examination (PEME). Approximately five months into his nine-month contract aboard the vessel M.V. Kalpana Prem, he experienced dizziness, body malaise, and chills. He was diagnosed in Vancouver, Canada with "uncontrolled hypertension," declared unfit for duty, and was medically repatriated to the Philippines for further treatment and evaluation.
Civil Procedure II

Integrated Bar of the Philippines Pangasinan Legal Aid vs. Department of Justice

25th July 2017

ak758754
832 SCRA 36 , 814 Phil. 440 , G.R. No. 232413
Primary Holding
The waiver of Article 125 of the Revised Penal Code must coincide with the prescribed period for preliminary investigation. Detention beyond this period violates the accused's constitutional right to liberty. Detainees must be released if preliminary investigations exceed statutory timelines or if their cases are dismissed (even pending review), unless lawfully held for other causes.
Background
The Integrated Bar of the Philippines (IBP) discovered pre-trial detainees languishing in jail for years without charges due to DOJ circulars requiring automatic reviews. Jay-Ar Senin, arrested in a 2015 drug buy-bust, waived Article 125 of the RPC, but his case was dismissed and remained under DOJ review for eight months.
Criminal Law II

Tilar vs. Tilar

12th July 2017

ak872417
831 SCRA 116 , G.R. No. 214529
Primary Holding
Regional Trial Courts have exclusive original jurisdiction over petitions for the declaration of nullity of marriage, regardless of whether the marriage was solemnized in a church, because the state governs the civil and legal consequences of marriage as a special contract and an inviolable social institution under the Family Code.
Background
The petitioner and private respondent were married in a Catholic church in 1996. After their relationship deteriorated due to the respondent's alleged psychological incapacity, the petitioner filed a civil case to have their marriage declared void. The trial court, however, refused to hear the case, believing that it had no authority to rule on the validity of a marriage performed by the church, citing the constitutional principle of separation of church and state. This led the petitioner to appeal directly to the Supreme Court on a pure question of law regarding the court's jurisdiction.
Persons and Family Law

Almario-Templonuevo vs. Office of the Ombudsman

28th June 2017

ak232325
828 SCRA 283 , G.R. No. 198583
Primary Holding
A decision of the Ombudsman imposing a penalty of suspension for not more than one month is final, executory, and unappealable, which justifies direct resort to a petition for certiorari under Rule 65 without the prior filing of a motion for reconsideration. Furthermore, the condonation doctrine applies to an official elected to a different public office, provided that the electorate or "body politic" is the same for both positions.
Background
Respondent Chito M. Oyardo filed an administrative complaint before the Office of the Ombudsman against petitioner Arlyn Almario-Templonuevo for an alleged violation of law committed while she was serving as a Sangguniang Bayan Member of Caramoan, Catanduanes, from 2007 to 2010. This complaint led to the Ombudsman's investigation and subsequent decision finding her liable for simple misconduct.
Civil Procedure II
Rule 65

Edron Construction Corporation vs. Provincial Government of Surigao Del Sur

5th June 2017

ak304488
826 SCRA 47 , 810 Phil. 347 , G.R. No. 220211
Primary Holding
Defenses not pleaded in the Answer or in a timely Motion to Dismiss, except for lack of jurisdiction over the subject matter, litis pendentia, res judicata, and prescription, are deemed waived pursuant to Section 1, Rule 9 of the Rules of Court, and a party failing to raise such defenses is estopped from relying on them later in the proceedings.
Background
The dispute originated from three separate construction agreements entered into by petitioners Edron Construction Corporation and Edmer Y. Lim with the respondent, the Provincial Government of Surigao Del Sur, for the construction of the Learning Resource Center of Tandag, Tandag Bus/Jeepney Terminal, and Tandag Public Market.
Civil Procedure I
Motion

Castro vs. Mendoza

26th April 2017

ak470027
809 Phil. 789 , G.R. No. 212778
Primary Holding
An agricultural lessee's right of redemption under Section 12 of RA 3844, as amended, must be validly exercised through timely tender and consignation of the full and reasonable redemption price; failure to do so, coupled with the property's actual conversion and devotion to public use, prevents the lessee from acquiring ownership and possession, although they remain entitled to disturbance compensation.
Background
The case originates from the sale of a portion of agricultural land, tenanted by the petitioners, by one of the co-owning heirs to the respondent Municipality of Bustos for the expansion of its public market. The sale occurred without written notice to the petitioners, triggering their right of redemption under agrarian law. The property had already been classified as commercial, and a public market was constructed and operating on it before the petitioners formally sought redemption.
Civil Procedure I
Intervention

Asiatrust Development Bank, Inc. vs. Commissioner of Internal Revenue

19th April 2017

ak311801
823 SCRA 648 , G.R. No. 201530 , G.R. Nos. 201680-81
Primary Holding
An application for a tax abatement is considered approved only upon the issuance of a termination letter by the Bureau of Internal Revenue (BIR); without such a letter, a tax assessment is not considered closed and terminated. Furthermore, an appeal of a CTA Division's decision (including an amended decision) to the CTA En Banc requires a prior and timely-filed motion for reconsideration, the absence of which is a fatal procedural defect that warrants dismissal of the appeal.
Background
The Commissioner of Internal Revenue assessed Asiatrust for deficiency internal revenue taxes for the fiscal years 1996, 1997, and 1998. Asiatrust protested the assessments, and upon the CIR's inaction, elevated the matter to the Court of Tax Appeals. During the proceedings, Asiatrust claimed it had settled its liabilities by availing of various government tax relief programs, including a compromise on certain taxes, a tax abatement program for its deficiency final withholding tax, and the 2007 Tax Amnesty Law for its deficiency documentary stamp tax. The core dispute centered on whether Asiatrust had sufficiently proven its availment of these programs to extinguish the assessed tax liabilities.
Civil Procedure II

Re: Letter of Tony Q. Valenciano, Holding of Religious Rituals at the Hall of Justice Building in Quezon City

7th March 2017

ak274299
819 SCRA 313 , 806 Phil. 822 , A.M. No. 10-4-19-SC
Primary Holding
The temporary and voluntary holding of religious rituals, such as Catholic masses during lunch breaks, in a common area of a public building like a Hall of Justice, does not violate the Establishment Clause or the prohibition against the appropriation of public money or property for religious purposes, provided it does not involve coercion, expenditure of public funds, permanent appropriation of the space, or prejudice to other religions, and represents a permissible accommodation of the employees' right to free exercise of religion under the principle of benevolent neutrality.
Background
The controversy began with letters from Tony Q. Valenciano to then Chief Justice Reynato S. Puno, complaining that the basement of the Quezon City (QC) Hall of Justice was being used as a Roman Catholic Chapel for daily masses, complete with religious icons and an offertory table. Valenciano asserted this practice violated constitutional provisions and caused various practical inconveniences.
Constitutional Law I Constitutional Law II
Freedom of Religion

Gamaro vs. People

27th February 2017

ak713753
806 Phil. 483 , G.R. No. 211917
Primary Holding
The actual recital of facts in the information, not the caption or the specific provision of law cited, determines the nature and cause of the accusation against an accused; thus, an accused can be convicted of a crime adequately described by the facts in the information, even if it's different from the specific paragraph of the statute initially designated, provided the accused is not deprived of the right to be informed of the charge.
Background
The case originated from a business venture in 2002 where Joan Fructoza E. Fineza (private complainant) would provide jewelry to petitioner Norma C. Gamaro and her daughters, petitioner Josephine G. Umali and accused Rowena Gamaro, for them to sell. The agreement involved Fineza purchasing foreclosed jewelry identified by Umali (a pawnshop manager), Norma Gamaro selling them, and profits being split. Checks were issued as security for the jewelry.
Criminal Law II
Estafa

E. Ganzon, Inc. (EGI) vs. Ando, Jr.

20th February 2017

ak204746
818 SCRA 165 , G.R. No. 214183
Primary Holding
An employee in the construction industry hired on a project-to-project basis is considered a project employee, and the repeated and successive rehiring of such an employee does not, by itself, confer regular employment status; the validity of the project employment is not impaired by a contractual provision allowing for the extension or shortening of the employment period, as long as the termination remains tied to the completion of the specific project or a phase thereof.
Background
The case arose from the common employment practice in the construction industry where workers are hired for specific projects. E. Ganzon, Inc. (EGI), a construction company, engaged the services of Fortunato B. Ando, Jr. as a carpenter for two different construction projects under three separate project employment contracts. The dispute centered on whether Ando's repeated hiring for tasks necessary to EGI's business made him a regular employee entitled to security of tenure beyond the completion of the projects.
Civil Procedure II

Belen vs. People

13th February 2017

ak787101
805 Phil. 628 , G.R. No. 211120
Primary Holding
Defamatory statements made by a party or counsel in pleadings filed during judicial or administrative proceedings lose the protection of absolute privilege if such statements are irrelevant or impertinent to the cause or subject of inquiry, particularly when they constitute personal attacks on the character, honor, or reputation of an individual.
Background
The petitioner, Medel Arnaldo B. Belen, then a practicing lawyer, filed a criminal complaint for estafa against his uncle. This complaint was assigned to Assistant City Prosecutor (ACP) Ma. Victoria Suñega-Lagman for preliminary investigation. ACP Suñega-Lagman subsequently dismissed the estafa complaint, which aggrieved the petitioner and led him to file an Omnibus Motion (for Reconsideration & Disqualify) containing the statements that became the basis for the libel charge.
Criminal Law II
Libel and Cyberlibel

Galindo vs. Commission on Audit

10th January 2017

ak489503
814 SCRA 73 , G.R. No. 210788
Primary Holding
Decisions of the Commission on Audit in administrative disciplinary cases are not reviewable by the Supreme Court through a petition for certiorari under Rule 64; the proper remedy is an appeal to the Civil Service Commission, as provided by the Administrative Code of 1987.
Background
The case arose from a long-standing practice within the Metropolitan Waterworks and Sewerage System (MWSS) of granting bonuses, allowances, and other benefits to personnel of the Commission on Audit (COA) assigned to audit it. This practice was brought to the attention of the COA Chairman through a letter from the MWSS Administrator, which detailed how unrecorded checks were being issued from cash advances to pay these benefits, bypassing usual accounting procedures. This prompted the COA to form a fact-finding investigation team, which ultimately led to the filing of administrative charges against the petitioners and other COA personnel involved.
Civil Procedure II

Association of Medical Clinics for Overseas Workers, Inc. (AMCOW) vs. GCC Approved Medical Centers Association, Inc.

6th December 2016

ak148530
812 SCRA 452 , 802 Phil. 116 , G.R. No. 207132 , G.R. No. 207205
Background
The case revolves around the practice of "referral decking" for medical examinations of overseas Filipino workers (OFWs). This system required OFWs to go through GAMCA for referral to specific clinics for health examinations. The DOH initially allowed this practice but later sought to prohibit it through administrative orders and eventually through legislation (RA 10022). When the DOH issued cease and desist orders against GAMCA to stop the referral decking system, GAMCA challenged this in court, leading to a legal battle over the validity of the prohibition and its implementation.
Constitutional Law I

Majestic Plus Holdings International, Inc. vs. Bullion Investment and Development Corporation

5th December 2016

ak807038
812 SCRA 91 , 801 Phil. 883 , G.R. No. 201017 , G.R. No. 215289
Primary Holding
Summary judgment is improper when there are genuine issues of fact that require the presentation of evidence during a full-blown trial, such as disputes over compliance with contractual obligations, the validity of an extrajudicial rescission, and the substantiation of claimed expenses; furthermore, the designation of a Regional Trial Court branch as a Special Commercial Court (SCC) does not divest it of its general jurisdiction over ordinary civil cases.
Background
The City of Manila leased a property to Bullion for development, requiring the construction of a City Hall extension and a commercial building (Meisic Mall). Bullion completed the extension but struggled with the mall construction, prompting it to seek investment from Majestic. This led to a Memorandum of Agreement (MOA) where Majestic agreed to acquire 80% equity in Bullion and infuse capital to complete the mall.
Civil Procedure I

Coca-Cola Bottlers Philippines, Inc. vs. Bernardo

7th November 2016

ak790851
807 SCRA 29 , G.R. No. 190667
Primary Holding
A manufacturer that employs deceit, oppression, and high-handed business methods to unjustly take over the market of its own distributor, such as by using a customer list obtained through a false promise and implementing discriminatory pricing schemes, is liable for damages under the principles of abuse of rights (Articles 19, 20, and 21) and unfair competition (Article 28) of the Civil Code.
Background
The dispute arose from a long-standing business relationship between petitioner Coca-Cola Bottlers Philippines, Inc. (CCBPI), a large-scale beverage manufacturer, and respondents Spouses Bernardo, who operated "Jolly Beverage Enterprises" as a wholesaler and exclusive distributor of CCBPI's products in certain areas of Quezon City since 1987. Their partnership, formalized through exclusive dealership agreements, deteriorated when CCBPI, towards the end of their last contract, implemented strategic actions that the respondents claimed were aimed at eliminating them as a competitor and taking over their established customer base.
Persons and Family Law
Article 19, 20, 21, and 28, Civil Code

Nicolas vs. Agrarian Reform Beneficiaries Association (ARBA)

19th October 2016

ak689125
806 SCRA 453 , G.R. No. 179566
Primary Holding
The Supreme Court held that procedural rules should be relaxed to avoid injustice where lapses are excusable and merits demand review; the execution pending appeal by petitioners violated DARAB Rules requiring a motion and good reasons, rendering subsequent title acts void, but the DARAB decision must be annulled to conform with the final Supreme Court ruling in the related case exempting the land from CARP coverage; petitioners are liable for nominal damages, attorney's fees, and costs for violating respondents' due process rights through bad faith execution.
Background
The dispute arises from the erroneous inclusion of two urban-zoned parcels of land in Davao City under the Comprehensive Agrarian Reform Program (CARP) in 1994, leading to their cancellation and award via CLOA to agrarian reform beneficiaries; petitioners acquired the lands from Philippine Banking Corporation via deed of assignment and sought cancellation of the CLOA, claiming exemption as non-agricultural land, which triggered multiple proceedings challenging the validity of title transfers and executions pending appeal in the agrarian reform adjudication system.
Civil Procedure II

Escoto vs. Philippine Amusement and Gaming Corporation

17th October 2016

ak896965
806 SCRA 116 , G.R. No. 192679
Primary Holding
An appeal from a decision of a Regional Trial Court rendered in the exercise of its original jurisdiction that raises only pure questions of law must be filed directly with the Supreme Court through a petition for review on certiorari under Rule 45 of the Rules of Court; an erroneous appeal to the Court of Appeals on such grounds is not subject to transfer and must be dismissed outright.
Background
The petitioner, Antonio Escoto, and the late Edgar Laxamana were promoters for Legend International Resort Limited (LIRL) located within the Subic Bay Freeport Zone. As part of their promotional activities, they organized a tourist-oriented cockfighting derby and secured a permit from the Subic Bay Metropolitan Authority (SBMA). The Philippine Amusement and Gaming Corporation (PAGCOR) intervened, advising LIRL to cancel the event on the grounds that cockfighting was outside its competence as a hotel casino resort, which led to the legal dispute.
Civil Procedure II
Rule 45

Sangguniang Panlalawigan of Bataan vs. Garcia, Jr.

5th October 2016

ak518566
804 SCRA 629 , 796 Phil. 414 , G.R. No. 174964
Primary Holding
The Supreme Court held that the subject parcels of land are considered communal property of the State, held in trust by the Province of Bataan, and therefore are subject to the absolute control and disposition of the National Government through Congress. A writ of mandamus compelling the transfer of land titles to BPSC was correctly issued.
Background
The Province of Bataan owned land occupied by the Medina Lacson de Leon School of Arts and Trades (MLLSAT) and Bataan Community Colleges (BCC). Republic Act No. 8562 converted MLLSAT into Bataan Polytechnic State College (BPSC) and integrated BCC into it, declaring the lands occupied by these schools as property of BPSC and mandating the transfer of titles. The Province of Bataan refused to transfer the titles, claiming the lands were patrimonial property and mortgaged.
Property and Land Law

Ursua vs. Republic

5th October 2016

ak913389
805 SCRA 1 , 796 Phil. 439 , G.R. Nos. 177857-58 , G.R. No. 178193
Primary Holding
The Court lacks jurisdiction to order San Miguel Corporation (SMC), a non-party to Civil Case No. 0033-F, to deliver the 25.45 million SMC treasury shares (originating from the 1990 Compromise Agreement) to the Republic, as doing so without impleading SMC violates its constitutional right to due process.
Background
The case originates from the sequestration of assets, including SMC shares held by Coconut Industry Investment Fund (CIIF) Holding Companies, alleged to have been acquired using coco levy funds during the Marcos regime. A 1986 sale of 33.1 million SMC shares by CIIF Holding Companies (administered by UCPB) to the SMC Group was partially rescinded through a 1990 Compromise Agreement between UCPB Group and SMC Group, which required PCGG approval. This agreement recognized SMC's ownership of shares corresponding to its initial P500 million payment (which became 25.45 million shares due to stock dividends/splits) and designated them as SMC treasury shares, while the rest reverted to CIIF Holding Companies. The Republic later sought to include these 25.45 million treasury shares in the assets declared as publicly owned and subject to reconveyance.
Civil Procedure I

In the Matter of the South China Sea Arbitration

12th July 2016

ak804567
PCA Case No. 2013-19
Background
The South China Sea, rich in natural resources and strategically important for international shipping, has been a subject of territorial disputes among several nations. The Philippines, concerned about China's increasing assertiveness in the region, initiated arbitration proceedings in 2013 to clarify the maritime entitlements of both nations under UNCLOS. Despite China's non-participation and rejection of the tribunal's jurisdiction, the arbitration proceeded. The case attracted global attention due to its potential impact on regional stability and the interpretation of international maritime law.
Constitutional Law I

The Diocese of Bacolod vs. COMELEC, et al.

5th July 2016

ak726602
789 Phil. 197 , G.R. No. 205728
Primary Holding
The Commission on Elections (COMELEC) does not have the authority to regulate the content or size of political expressions made by private citizens who are not candidates, especially when such expressions involve an advocacy on a social issue, even if they incidentally name candidates and are posted during an election period; any such regulation must withstand strict constitutional scrutiny and is generally an impermissible infringement on the fundamental right to freedom of expression.
Background
The case arose in the context of the 2013 national elections in the Philippines and the then-recent, highly controversial passage of Republic Act No. 10354, the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law). The RH Law was a divisive piece of legislation, with strong opposition from various sectors, including the Catholic Church, to which the petitioners belong. The tarpaulins in question were a direct response to the RH Law, linking candidates' stances on it to a "conscience vote."
Constitutional Law II
Freedom of Expression

Mercader, Jr. vs. Bardilas

27th June 2016

ak382375
788 Phil. 136 , 794 SCRA 387 , G.R. No. 163157
Primary Holding
The owner of the servient estate retains ownership of the portion of land burdened by a road right of way easement and may use it, provided such use does not hinder the easement's purpose. The phrase "with existing Right of Way" in a title doesn't automatically grant the dominant estate ownership of the easement area.
Background
The dispute arose between owners of subdivided lots originally part of a larger property. Spouses Mercader and Spouses Bardilas owned adjacent lots, with Spouses Bardilas' lot being burdened by a right of way for the benefit of Spouses Mercader's lot and others to access Clarita Village. A fence erected by the Clarita Village Association restricted the original exit of the right of way, leading to conflicts about encroachment and the extent of rights over the easement.
Property and Land Law

Capitol Wireless, Inc. vs. Provincial Treasurer of Batangas

30th May 2016

ak786051
791 SCRA 272 , 785 Phil. 712 , G.R. No. 180110
Primary Holding
The Supreme Court denied Capwire's petition, affirming the dismissal of its appeal. The Court held that Capwire should have exhausted administrative remedies before resorting to court action because factual issues were involved, and that submarine communication cables are considered taxable real property.
Background
Capwire, a telecommunications company, claimed co-ownership of the "Wet Segment" of submarine cable systems laid internationally and reported "Indefeasible Rights in Cable Systems" as property. For loan restructuring, Capwire assessed the value of its right and submitted a sworn statement for real properties. The Provincial Assessor of Batangas then issued real property tax assessments on these cable systems. Capwire contested the assessments, arguing the cables were in international waters and not taxable in the Philippines.
Property and Land Law

Alolino vs. Flores

4th April 2016

ak909292
788 SCRA 92 , 783 Phil. 605 , G.R. No. 198774
Primary Holding
The respondents' house/sari-sari store, illegally constructed on a barrio road (public property), is deemed a public and private nuisance per se and must be demolished. The reclassification of the barrio road to residential by the Sanggunian resolution was ineffective because it was not done through a valid ordinance approved by two-thirds of the Sanggunian members.
Background
Petitioner Alolino owned property with a two-story house. Respondents Flores spouses built a house/sari-sari store on an adjacent municipal/barrio road without a building permit. This structure blocked Alolino's light and ventilation and access to the municipal road from his rear door, prompting him to seek its removal.
Property and Land Law

Republic vs. Tan

10th February 2016

ak918613
783 SCRA 643 , 780 Phil. 764 , G.R. No. 199537
Primary Holding
A declaration that government-owned land is alienable and disposable does not, by itself, convert it into patrimonial property of the State; an express declaration that the land is no longer intended for public use or public service is required for acquisitive prescription to apply against the State.
Background
Andrea Tan applied for original land registration based on acquisitive prescription, claiming continuous possession of a parcel of land declared alienable and disposable in 1965. The Municipal Trial Court granted her application, which was affirmed by the Court of Appeals. The Republic appealed, arguing that mere declaration of alienability is insufficient for prescription against the State.
Property and Land Law

Metropolitan Bank and Trust Company vs. Fadcor, Inc

25th January 2016

ak549966
781 SCRA 561 , 779 Phil. 32 , G.R. No. 197970
Primary Holding
In an *ex parte* presentation of evidence resulting from the defendant's failure to appear at pre-trial, documentary evidence formally offered by the plaintiff and subsequently admitted by the trial court is properly considered in rendering judgment, even if the transcript of stenographic notes does not meticulously reflect the identification and marking of each specific exhibit during the witness's testimony; the rules on pre-marking and identification in A.M. No. 03-1-09-SC apply primarily to regular pre-trial proceedings where both parties participate.
Background
Metrobank extended loans totaling P32,950,000.00 to Fadcor, Inc., secured by real estate mortgages over ten parcels of land and continuing surety agreements executed by individual respondents (Fadcor officers). Fadcor defaulted on its loan obligations.
Civil Procedure I
Pre-trial

Saguisag vs. Ochoa, Jr.

12th January 2016

ak958005
779 SCRA 241 , 777 Phil. 280 , G.R. No. 212426 , G.R. No. 212444
Background
The case was brought to the Supreme Court as the petitioners contended that the executive acted beyond its powers by entering into EDCA without Senate concurrence. They argued that the agreement allowed the presence of foreign military troops and facilities, which under the Constitution could only be authorized by a treaty concurred in by the Senate.
Constitutional Law I

Gonzales, et al. vs. GJH Land, Inc., et al.

10th November 2015

ak690848
774 SCRA 242 , 772 Phil. 483 , G.R. No. 202664
Primary Holding
The jurisdiction over commercial cases, including intra-corporate disputes, is conferred by Republic Act No. 8799 upon Regional Trial Courts as courts of general jurisdiction, and the Supreme Court's designation of certain RTC branches as Special Commercial Courts is an administrative and procedural measure to promote expediency and efficiency in the exercise of that jurisdiction, not a conferment of jurisdiction itself; therefore, a commercial case erroneously raffled to a regular RTC branch within a station that has a designated Special Commercial Court should be transferred to the latter, not dismissed for lack of jurisdiction.
Background
The case arose from a dispute over shares in S.J. Land, Inc. (later GJH Land, Inc.). Petitioners claimed they had fully paid for their subscribed shares, but these shares were subsequently offered for sale to other stockholders by the corporation, prompting petitioners to seek an injunction. This underlying dispute was recognized as an intra-corporate controversy.
Civil Procedure I

Carpio-Morales vs. Court of Appeals (Sixth Division)

10th November 2015

ak551173
774 SCRA 431 , G.R. Nos. 217126-27
Primary Holding
The jurisprudential doctrine of condonation is abandoned for being inconsistent with the 1987 Constitution's principles that public office is a public trust and that public officials are accountable to the people at all times; however, this abandonment is to be applied prospectively. Furthermore, Section 14 of Republic Act No. 6770 is declared partially unconstitutional for encroaching upon the Supreme Court's rule-making power and for improperly restricting the judicial review of the Ombudsman's acts.
Background
The case arose from an investigation by the Office of the Ombudsman into alleged anomalous activities related to the procurement and construction of the Makati City Hall Parking Building. A complaint was filed against then-Mayor Jejomar Erwin S. Binay, Jr., and other city officials for Plunder and violations of the Anti-Graft and Corrupt Practices Act. The alleged irregularities spanned Binay, Jr.'s first term (2010-2013) and continued into his second term (2013-2016), leading the Ombudsman to initiate administrative and criminal proceedings against him.
Civil Procedure II

De Leon vs. Chu

2nd September 2015

ak032805
768 SCRA 609 , 768 Phil. 217 , G.R. No. 186522
Primary Holding
A violation of the rule on non-forum shopping, specifically the submission of a false certification or non-compliance with undertakings, does not automatically warrant dismissal; dismissal requires willful and deliberate forum shopping, or must follow a motion and hearing, unless the ground for dismissal (like *litis pendentia*) is evident *motu proprio* from the pleadings or evidence, a ground which became moot here upon case consolidation.
Background
The dispute arose from conflicting claims over a 50-square meter parcel of land, originally part of a 600-square meter property owned by Domingo Delos Santos. Domingo allegedly sold the entire 600 sqm to Lolita Chu in 1990. Lolita entrusted the deed to Rowena De Leon before leaving for Japan. Subsequently, a different Deed of Sale emerged dated March 1993, purportedly showing Domingo sold 50 sqm to Rowena and the remaining 550 sqm to Lolita. Rowena registered the 50 sqm portion in her name, leading Lolita and Domingo to claim forgery and file for annulment, while Rowena sought the surrender of the title she claimed Lolita wrongfully withheld.
Civil Procedure I
Motion

Chipongian vs. Benitez-Lirio

26th August 2015

ak861175
768 SCRA 204 , G.R. No. 162692
Primary Holding
An appeal from a final order or judgment in a special proceeding, such as the dismissal of a complaint-in-intervention, must be perfected by filing both a notice of appeal and a record on appeal within thirty (30) days from notice of the judgment or final order; the failure to file the required record on appeal is a jurisdictional defect that prevents the appellate court from acquiring jurisdiction and renders the appealed judgment final and executory.
Background
The late Vicente Benitez was married to Isabel Chipongian, the petitioner's sister. The couple had no children, and Isabel predeceased Vicente. After Isabel's death, petitioner Nilo Chipongian and Vicente executed an extrajudicial settlement of Isabel's estate, where Chipongian waived his rights. However, Chipongian claims that Vicente simultaneously executed an affidavit clarifying that the waiver did not cover Isabel's paraphernal properties. Upon Vicente's death, his relatives (respondents) initiated intestate proceedings for his estate. Chipongian intervened in these proceedings, seeking to exclude the paraphernal properties of his sister, Isabel, from Vicente's estate based on the alleged affidavit.
Civil Procedure II

Manila Electric Company vs. The City Assessor

5th August 2015

ak880939
765 Phil. 605 , G.R. No. 166102
Primary Holding
The Supreme Court affirmed the Court of Appeals' decision in part, declaring that MERALCO's electric facilities are subject to real property tax under the Local Government Code. However, it nullified the 1997 appraisal and assessment by the City Assessor of Lucena due to violation of MERALCO's right to due process and ordered a new assessment to be conducted in accordance with the Local Government Code.
Background
MERALCO had been operating in Lucena City since 1922 under various franchises, some of which provided tax exemptions on certain electric facilities. Lucena City began assessing real property tax on MERALCO's electric facilities starting 1985. MERALCO contested these assessments, arguing that its facilities were exempt under its franchise and were personal property, not real property.
Property and Land Law

Navy Officers' Village Association, Inc. (NOVAI) vs. Republic

3rd August 2015

ak461713
765 Phil. 429 , 764 SCRA 524 , G.R. No. 177168
Primary Holding
Land reserved for public or quasi-public purposes remains inalienable public domain unless explicitly withdrawn from such reservation by law or presidential proclamation and positively declared alienable and disposable. A sale of inalienable public land is void ab initio, and the title issued based on such sale is also void.
Background
The land in question was originally part of Fort William McKinley, later Fort Andres Bonifacio Military Reservation (FBMR). Presidential Proclamation No. 423 reserved a large area for military purposes. Proclamation No. 461 excluded a portion as AFP Officers’ Village, intended for disposal under specific laws. Subsequently, Proclamation No. 478 reserved a smaller portion, including the property in dispute, for veterans rehabilitation. NOVAI claimed to have purchased the land from the Republic based on a Deed of Sale referring to a fictitious Proclamation No. 2487.
Property and Land Law

Obergefell vs. Hodges

26th June 2015

ak784523
576 U.S. 644
Primary Holding
The Fourteenth Amendment to the United States Constitution requires a State to license a marriage between two people of the same sex and to recognize a marriage between two people of the same sex when their marriage was lawfully licensed and performed in another State.
Background
The cases arose from Michigan, Kentucky, Ohio, and Tennessee, states whose laws defined marriage solely as a union between one man and one woman, reflecting a long-standing historical definition but contrasting with evolving societal understandings and legal developments regarding the rights of gay and lesbian individuals and the nature of marriage itself. Petitioners sought marriage licenses within their home states or recognition of marriages performed legally in other states, facing denials based on these state laws. This legal challenge occurred against a backdrop of increasing public debate, legislative changes in some states, and numerous court decisions addressing same-sex marriage following landmark cases like _Lawrence v. Texas_ and _United States v. Windsor_.
Constitutional Law II
Equal Protection

Resident Marine Mammals of the Protected Seascape Tañon Strait, et al. vs. Secretary Reyes, et al.

21st April 2015

ak704946
758 Phil. 724 , G.R. No. 180771 , G.R. No. 181527
Primary Holding
Service contracts for the exploration, development, and utilization of petroleum resources with foreign-owned corporations are permissible under paragraph 4, Section 2, Article XII of the 1987 Constitution, provided they adhere to specific safeguards: (1) the contract must be crafted in accordance with a general law setting standard terms; (2) the President must be the signatory for the government; and (3) the President must report the executed agreement to Congress within thirty days. Furthermore, any activity within a protected area under the National Integrated Protected Areas System (NIPAS) Act, such as exploration for energy resources, requires an Environmental Impact Assessment (EIA) and an Environmental Compliance Certificate (ECC), and if exploitation is involved, a specific law passed by Congress.
Background
The Tañon Strait, a critical marine habitat located between Negros and Cebu, was declared a protected seascape in 1998. Despite this status, the Philippine government, through the Department of Energy (DOE), entered into agreements with Japan Petroleum Exploration Co., Ltd. (JAPEX) for oil exploration in the area, culminating in Service Contract No. 46 (SC-46). This led to concerns from environmental groups and local fisherfolk about the project's impact on the marine ecosystem and their livelihoods.
Constitutional Law I

San Diego vs. CA

8th April 2015

ak478899
757 Phil. 599 , G.R. No. 176114
Primary Holding
An employee who, by virtue of their position (e.g., accountant, cashier, teller), has access to and physical possession of company funds but does not have juridical possession over them, commits qualified theft, not estafa, if they take and appropriate such funds with grave abuse of confidence and intent to gain.
Background
Petitioner Grace San Diego was employed as an accountant for Obando Fisherman's Multi-Purpose Cooperative, Inc. (OFMPCI) from January 1993 to March 11, 1997. Her responsibilities included accounting for all business transactions, performing cashier and teller functions, granting loans, check discounting, recording bank transactions, and handling pre-signed blank checks. She also temporarily acted as cashier and teller on separate occasions, giving her complete access to cash vaults and cooperative documents.
Criminal Law II
Qualified Theft

Villanueva vs. Judicial and Bar Council

7th April 2015

ak748641
755 SCRA 182 , 757 Phil. 534 , G.R. No. 211833
Primary Holding
The Supreme Court held that the JBC's policy requiring five years of service as a first-level court judge before qualifying for promotion to a second-level court is constitutional and does not violate the equal protection or due process clauses. The Court also ruled that the JBC must publish its policies to ensure transparency.
Background
Judge Ferdinand R. Villanueva was appointed as a first-level court judge in 2012. In 2013, he applied for promotion to several Regional Trial Court (RTC) positions but was disqualified by the JBC due to its policy requiring five years of service as a first-level court judge. Villanueva challenged this policy, arguing that it was unconstitutional and violated his rights to equal protection and due process.
Constitutional Law I Constitutional Law II Philosophy of Law

Aquino vs. Quiazon

11th March 2015

ak636229
753 SCRA 98 , 755 PHIL. 793 , G.R. No. 201248
Primary Holding
When a motion to dismiss (or an affirmative defense treated as such) is based on the ground that the complaint states no cause of action, the court must determine the sufficiency of the cause of action based solely on the allegations in the complaint, hypothetically admitting their truth, and cannot consider external facts or evidence presented during a preliminary hearing, except in very limited circumstances not present in this case.
Background
The dispute arose from conflicting claims of ownership over a 557-square meter parcel of land in Magalang, Pampanga. Petitioners, heirs of Epifanio Makam and Severina Bautista, claimed acquisition through a Deed of Sale dated April 20, 1894, and continuous possession. Respondents, heirs of Fausta Baluyut, claimed ownership based on Transfer Certificate of Title (TCT) No. 213777-R, derived from an Original Certificate of Title (OCT) issued pursuant to a Land Registration Decree in 1919. The conflict escalated when respondents sent demand letters to petitioners to vacate the property in June 2005, leading petitioners to file a complaint for Annulment and Quieting of Title.
Civil Procedure I