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Matabuena vs. Cervantes

31st March 1971

ak202413
38 SCRA 284 , 148 Phil. 295 , No. L-28771
Primary Holding
The statutory prohibition against donations between spouses during marriage (Article 133 of the Civil Code) applies with equal force to donations between persons living together as husband and wife without the benefit of marriage, based on public policy considerations and the need to prevent undue influence in such relationships.
Background
The case arose from a gap in the Civil Code, which explicitly prohibited donations between legally married spouses but was silent regarding donations between partners in a common-law relationship. The dispute centered on whether the policy behind the law—preventing the stronger party from exercising undue influence over the weaker party—should extend to irregular unions, thereby nullifying a land donation made by a man to his partner prior to their eventual marriage.
Persons and Family Law
Property relations; Art. 87

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 Wills and Succession

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

Ocampo vs. Florenciano

23rd February 1960

ak805771
107 Phil. 35 , G.R. No. L-13553
Primary Holding
A decree of legal separation may be granted even if the defendant spouse admits to the offense or expresses conformity to the separation, provided that the decree is based on independent evidence of the ground (adultery) and not solely on a confession of judgment, and provided there is no collusion between the parties to simulate the ground.
Background
The case arises from a petition for legal separation filed by a husband against his wife after discovering her in the act of sexual intercourse with another man in 1955. This incident followed a history of the wife's previous infidelity in 1951 and her eventual abandonment of the conjugal home in 1952.
Persons and Family Law
Legal separation

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

Lopez vs. Cuaycong et al.

24th March 1944

ak804682
74 Phil. 601 , No. 46079
Primary Holding
A contract purporting to sell a specific, concrete portion of co-owned property prior to partition is not void; it is valid and binding as an alienation of the seller's abstract and undivided share in the community property, subject to the ultimate result of the partition.
Background
The case stems from a dispute over the validity of a sale of a specific parcel of land (Lot 178-B) located within a larger hacienda owned in common by the widow of Cuaycong, her adult children, and three minor daughters. The widow and adult children sold this specific lot to Lopez Sugar Central Mill Co., Inc. (the Intervenor) without the participation of the minors and before the hacienda had been legally partitioned. The Intervenor subsequently built a distillery on the lot. Previous court actions had variously declared the sale void (partially or entirely) and ordered the removal of the buildings, prompting this specific resolution on a motion for reconsideration.
Persons and Family Law
Property relations; Liquidation

Nable Jose vs. Nable Jose

11th December 1916

ak626903
41 Phil. 713 , No. 7397
Primary Holding
The surviving husband, as the exclusive administrator of the conjugal partnership upon the death of the wife, possesses the full power to sell or mortgage the community property to satisfy partnership obligations pending liquidation; the heirs of the deceased wife hold no vested legal title to specific property until the liquidation is complete and the "net remainder" is determined.
Background
Mariano Nable Jose was married to Paz Borja, with whom he had several children. Paz Borja died in 1898, dissolving the marriage, but the conjugal partnership was never liquidated. Mariano continued to manage the properties acquired during the marriage. Years later, he incurred debts and executed mortgages on these properties in favor of Standard Oil Company of New York, Amparo Nable Jose, and Carmen Castro. When Standard Oil sought to foreclose, the children of Paz Borja intervened, arguing that their father had no authority to mortgage their mother's half-share of the unliquidated community property.
Persons and Family Law
Liquidation
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