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Magallona vs. Ermita

16th August 2011

ak124720
655 SCRA 476 , 671 Phil. 243 , G.R. No. 187167
Background
The case arose from the need to update the Philippines' maritime baselines to comply with UNCLOS III. RA 9522 was enacted for this purpose, but it was challenged by the petitioners on constitutional grounds. The case reached the Supreme Court, which had to determine whether the new baselines law was consistent with the Philippine Constitution's definition of national territory.
Constitutional Law I

Megan Sugar Corporation vs. Regional Trial Court of Iloilo, Branch 68, Dumangas, Iloilo

1st June 2011

ak127788
650 SCRA 100 , 665 Phil. 245 , G.R. No. 170352
Primary Holding
A party that actively participates in court proceedings through counsel, allows its officer to accompany said counsel, receives court orders and pleadings without repudiating the counsel's authority, and seeks affirmative relief from the court, is estopped from later questioning the counsel's authority and the court's jurisdiction over it, especially after receiving unfavorable rulings.
Background
New Frontier Sugar Corporation (NFSC) defaulted on a loan secured by real estate and chattel mortgages from Equitable PCI Bank (EPCIB). Due to financial difficulties, NFSC entered a Memorandum of Agreement (MOA) allowing Central Iloilo Milling Corporation (CIMICO) to operate its sugar mill. Subsequently, EPCIB foreclosed on the mortgaged properties. CIMICO then entered into another MOA with Megan Sugar Corporation (MEGAN), transferring its operational rights and obligations concerning the sugar mill to MEGAN. This transfer occurred amidst ongoing litigation involving NFSC, CIMICO, and EPCIB.
Civil Procedure I

League of Cities of the Philippines (LCP) vs. Commission on Elections

12th April 2011

ak614037
663 Phil. 496 , G.R. No. 176951 , G.R. No. 177499 , G.R. NO. 178056
Primary Holding
The Court's February 15, 2011 Resolution, upholding the constitutionality of the 16 Cityhood Laws, is affirmed, as the petitioners' procedural arguments regarding finality and jurisdiction, and substantive arguments regarding violations of the Constitution (Art. X, Secs. 6 & 10) and the Equal Protection Clause, are without merit; the prior judgment declaring the laws unconstitutional had not attained finality due to timely filed and entertained motions.
Background
Congress enacted 16 individual Republic Acts ("Cityhood Laws") converting specific municipalities into cities, incorporating exemption clauses that excused them from the P100 million income requirement established by R.A. No. 9009, which had amended the Local Government Code (LGC). These municipalities had cityhood bills pending before R.A. No. 9009's enactment. The League of Cities of the Philippines (LCP), representing existing cities, challenged these laws as unconstitutional for violating the LGC requirement that cityhood criteria be uniform and stated within the LGC itself, and for violating the equal protection clause. This led to a protracted legal battle involving multiple, conflicting Supreme Court rulings on the laws' validity, culminating in the February 15, 2011 Resolution upholding the laws, which petitioners sought to reconsider in the motion addressed by this present Resolution.
Constitutional Law I Constitutional Law II Philosophy of Law Statutory Construction
Equal Protection

Navarro vs. Ermita

12th April 2011

ak213242
648 SCRA 400 , 663 Phil. 546 , G.R. No. 180050
Primary Holding
The Supreme Court ruled RA 9355 constitutional, exempting provinces composed of islands from the land area requirement under the LGC, and validated Dinagat Islands’ status as a province.
Background
Dinagat Islands was created as a province in 2006. Petitioners argued it violated LGC criteria for population (250,000) and land area (2,000 km²). After initial nullification by the Court in 2010, the case was reopened due to post-election implications for local officials, leading to the final validation of the province.
Statutory Construction

Yusay vs. Court of Appeals

6th April 2011

ak797825
647 SCRA 269 , 662 Phil. 634 , G.R. No. 156684
Primary Holding
Certiorari and prohibition do not lie to assail the issuance of a resolution by the Sanggunian Panglungsod authorizing expropriation because a resolution is a legislative act, not a judicial or quasi-judicial one. Furthermore, initiating expropriation requires an ordinance, not a resolution, under the Local Government Code.
Background
Spouses Yusay owned land in Mandaluyong City, part of which they rented out. The City Council passed a resolution authorizing the City Mayor to initiate expropriation of the land for low-cost housing. The Yusays, fearing immediate action, filed certiorari and prohibition to annul the resolution.
Constitutional Law II

General vs. Urro

29th March 2011

ak549891
646 SCRA 567 , 662 Phil. 132 , G.R. No. 191560
Primary Holding
An acting appointee to a public office does not have the legal standing (cause of action) to file a quo warranto petition against a newly appointed individual to that same office. The court did not rule on the constitutionality of the new appointments.
Background
Then President Gloria Macapagal-Arroyo appointed several individuals to the NAPOLCOM, including General as an acting commissioner. Near the end of her term, she appointed Urro, de Guzman, and Escueta as permanent commissioners. General questioned these appointments, claiming they violated the ban on midnight appointments.
Constitutional Law II

Alauya vs. Limbona

22nd March 2011

ak081419
646 SCRA 1 , 661 Phil. 380 , A.M. No. SCC-98-4
Primary Holding
A sitting judge who files a certificate of candidacy for an elective office violates the constitutional prohibition against partisan political activity by civil servants, commits gross misconduct and dishonesty by continuing to perform judicial functions and receive salary thereafter, and is consequently deemed unfit to remain in the judiciary, warranting dismissal from service effective from the date of filing the CoC.
Background
The case arose from complaints lodged with the Office of the Court Administrator (OCA) against Judge Casan Ali Limbona of the 10th Shari'a Circuit Court, Tamparan, Lanao del Sur. The complaints alleged chronic absenteeism and, more significantly, that the judge had filed a certificate of candidacy as a party-list nominee for the Development Foundation of the Philippines (DFP) in the May 11, 1998 elections while remaining an active member of the judiciary and continuing to receive his judicial salary.
Constitutional Law I

Air Transportation Office vs. Ramos

23rd February 2011

ak801657
644 SCRA 36 , 659 Phil. 104 , G.R. No. 159402
Primary Holding
The ATO, as an agency engaged in proprietary functions, is not immune from suit and must compensate the Ramos spouses for the land used for the Loakan Airport.
Background
The Ramos spouses discovered that part of their land was being used by the ATO for the Loakan Airport. They agreed to sell the land to the ATO, but the ATO failed to pay. The Ramos spouses filed a lawsuit, and the lower courts ruled in their favor. The ATO appealed, invoking state immunity.
Philosophy of Law

Gutierrez vs. The House of Representatives Committee on Justice, Hontiveros-Baraquel, et al.

15th February 2011

ak949647
643 SCRA 198 , 660 Phil. 271 , G.R. No. 193459
Primary Holding
Impeachment proceedings are “initiated” when a complaint is filed and referred to the House Committee on Justice, triggering the constitutional one-year bar against subsequent proceedings.
Background
Gutierrez faced two impeachment complaints filed 11 days apart in 2010. The House referred both to its Committee on Justice. Gutierrez argued this violated the constitutional prohibition against multiple proceedings within one year.
Statutory Construction

Mactan-Cebu International Airport Authority vs. Heirs of Estanislao Miñoza

2nd February 2011

ak335523
641 SCRA 520 , 656 Phil. 537 , G.R. No. 186045
Primary Holding
Intervention under Rule 19 requires a legal interest that is actual, substantial, material, direct, and immediate in the matter being litigated; it is not proper when it seeks to inject an independent controversy, would unduly delay or prejudice the adjudication of the original parties' rights, or change the nature of the action, especially when the intervenor's rights can be fully protected in a separate proceeding.
Background
The dispute originated from the sale of two lots (Lots 986 and 991-A) owned by the late Estanislao Miñoza to the National Airports Corporation (NAC), MCIAA's predecessor, in the late 1940s/early 1950s for the Lahug Airport expansion project, which allegedly included an assurance that the original owners' heirs could repurchase the lots if they were no longer needed for that purpose. The airport expansion did not proceed, leading the purported heirs (represented by Leila Hermosisima) to seek reconveyance based on the alleged buy-back option over forty years later.
Civil Procedure I
Intervention

Bayan Muna vs. Romulo

1st February 2011

ak939314
641 SCRA 244 , 656 Phil. 246 , G.R. No. 159618
Primary Holding
The Supreme Court upheld the validity of the RP-US Non-Surrender Agreement as a proper executive agreement that does not require Senate concurrence.
Background
The case stems from the Philippines' signing of the Rome Statute establishing the ICC on December 28, 2000, followed by the execution of a bilateral Non-Surrender Agreement with the US on May 13, 2003 through an Exchange of Notes.
Philosophy of Law

Heirs of Domingo Valientes v. Hon. Reinerio (Abraham) B. Ramas, et al.

15th December 2010

ak555963
653 Phil. 111 , G.R. No. 157852
Primary Holding
An action for reconveyance based on an implied or constructive trust, arising from property acquired through fraud (such as a forged deed leading to the issuance of a Torrens title), prescribes in ten (10) years from the date of the issuance of the certificate of title, if the plaintiff is not in possession of the property.
Background
The dispute originated from a parcel of land initially owned by Domingo Valientes under an Original Certificate of Title (OCT). In 1939, Valientes mortgaged the land to the spouses Belen. Later, the Belens allegedly used a forged "VENTA DEFINITIVA" to obtain a Transfer Certificate of Title (TCT No. T-5,427) in their names in 1969. Valientes' heirs attempted but failed to retrieve the property in the 1950s and filed an adverse claim in 1970. Upon the Belens' death, their heirs sold the property to respondent Vilma Minor, who currently possesses it. This led to conflicting legal actions initiated by both Minor (to cancel the adverse claim) and the Valientes heirs (to cancel the TCT and recover the property).
Civil Procedure I
Motion

Ivler vs. Hon. Judge Modesto-San Pedro, et al.

17th November 2010

ak093224
649 Phil. 478 , G.R. No. 172716
Primary Holding
A prior conviction for a quasi-offense under Article 365 of the Revised Penal Code, such as Reckless Imprudence Resulting in Slight Physical Injuries, bars a subsequent prosecution for another quasi-offense, like Reckless Imprudence Resulting in Homicide and Damage to Property, if both arise from the same act of reckless imprudence, because reckless imprudence is a single offense and prosecuting its multiple consequences separately violates the constitutional right against double jeopardy.
Background
The case arose from a vehicular collision in August 2004 involving petitioner Jason Ivler and the vehicle of respondent Evangeline Ponce and her husband, Nestor C. Ponce. This incident led to injuries to Evangeline Ponce, the death of Nestor C. Ponce, and damage to the Ponces' vehicle.
Criminal Law II
Reckless Imprudence

Espina vs. Zamora

21st September 2010

ak922354
631 SCRA 17 , 645 Phil. 269 , G.R. No. 143855
Primary Holding
Republic Act No. 8762 (Retail Trade Liberalization Act of 2000) is constitutional; the constitutional provisions on developing a self-reliant and independent national economy effectively controlled by Filipinos (Art. II, Sec. 19) and related state policies are not self-executing commands imposing a Filipino monopoly, but rather guiding principles, and Congress has the discretion under the Constitution (Art. XII, Sec. 10) to determine when and how to regulate or allow foreign investments in the national interest, including in the retail trade sector.
Background
Prior to R.A. 8762, Republic Act No. 1180 (Retail Trade Nationalization Act) enacted in 1954 absolutely prohibited foreign nationals and corporations from engaging in the retail trade business in the Philippines. R.A. 8762, signed into law in 2000, expressly repealed R.A. 1180 and liberalized the retail trade sector by allowing foreign investment under specific capitalization thresholds and categories, prompting constitutional challenges based on economic nationalism principles enshrined in the 1987 Constitution.
Constitutional Law II
Due Process

Pormento vs. Estrada

31st August 2010

ak528121
629 SCRA 530 , 643 Phil. 735 , G.R. No. 191988
Primary Holding
The Supreme Court dismissed the petition due to mootness, as there was no longer an actual case or controversy to resolve after Estrada lost the 2010 presidential election.
Background
The case centered on the interpretation of the constitutional provision prohibiting presidential reelection, specifically as it applied to former President Joseph Estrada's attempt to run for president again in 2010, having previously served as president from 1998.
Constitutional Law I

Lokin, Jr. vs. Commission on Elections

22nd June 2010

ak434539
621 SCRA 385 , 635 Phil. 372 , G.R. Nos. 179431-32 , G.R. No. 180443
Primary Holding
The Supreme Court ruled that Section 13 of COMELEC Resolution No. 7804 was invalid to the extent it allowed a party to unilaterally change or substitute its nominees after submission of the list to the COMELEC. The statutory grounds for substitution under R.A. No. 7941 are exclusive.
Background
CIBAC submitted its list of nominees for the 2007 elections, which included Lokin as the second nominee. Subsequently, CIBAC's president filed an amended list replacing Lokin and others with new nominees. COMELEC relied on Section 13 of Resolution No. 7804 to approve this substitution. Lokin challenged the substitution and sought to be proclaimed as CIBAC's second nominee.
Statutory Construction

Commissioner of Internal Revenue vs. Kudos Metal Corporation

5th May 2010

ak209769
620 SCRA 232 , 634 Phil. 314 , G.R. No. 178087
Primary Holding
The government’s right to assess taxes prescribed because the waivers executed to extend the three-year assessment period were invalid due to procedural defects.
Background
The BIR issued deficiency tax assessments against Kudos Metal Corporation for 1998 on September 26, 2003, after conducting an audit prompted by suspected tax fraud. The corporation contested these assessments, arguing they were issued beyond the three-year prescriptive period under the Tax Code.
Statutory Construction

Fuentes vs. Roca

21st April 2010

ak735315
633 Phil. 9 , G.R. No. 178902
Primary Holding
A sale of conjugal property made after the effectivity of the Family Code, without the written consent of the other spouse, is void, and the action to declare its inexistence does not prescribe; the heirs of the non-consenting spouse can bring such action.
Background
Sabina Tarroza sold a 358-square meter lot to her son, Tarciano T. Roca, in 1982. Tarciano did not immediately transfer the title to his name. In 1988, Tarciano, who was estranged from his wife Rosario Gabriel Roca, offered to sell this lot to petitioners Manuel and Leticia Fuentes. The property was conjugal, acquired during Tarciano and Rosario's marriage in 1950.
Obligations and Contracts

Ang Ladlad LGBT Party vs. COMELEC

8th April 2010

ak675246
618 SCRA 32 , 632 Phil. 32 , G.R. No. 190582
Primary Holding
The COMELEC cannot disqualify a party-list applicant based on religious or moral grounds lacking a clear secular justification, as doing so violates the non-establishment clause, the equal protection clause, and the rights to freedom of expression and association; moral disapproval alone is not a legitimate state interest sufficient to justify infringing upon these fundamental rights.
Background
The case arose from the COMELEC's refusal to accredit Ang Ladlad, an organization representing the lesbian, gay, bisexual, and transgender (LGBT) community, as a party-list organization eligible to participate in the Philippine legislative elections under Republic Act No. 7941 (Party-List System Act).
Constitutional Law II Philosophy of Law
Equal Protection

Reyes-Mesugas vs. Reyes

22nd March 2010

ak071678
616 SCRA 345 , 630 Phil. 334 , G.R. No. 174835
Primary Holding
A notice of lis pendens annotated in connection with an estate settlement proceeding should be cancelled when the proceeding has terminated by virtue of a judicially approved compromise agreement, and the basis for its continued annotation is an alleged extraneous agreement that falls outside the limited jurisdiction of the probate court.
Background
Petitioner Anita Reyes-Mesugas and respondent Alejandro A. Reyes are siblings and heirs of Lourdes Aquino Reyes, who died intestate leaving several properties, including a lot covered by TCT No. 24475. Respondent initiated proceedings for the settlement of Lourdes' estate, which eventually led to a compromise agreement partitioning the estate among the heirs.
Civil Procedure I

Intestate Estate of Manolita Gonzales Vda. De Carungcong vs. People, et al.

11th February 2010

ak055613
612 SCRA 272 , 626 Phil. 177 , G.R. No. 181409
Primary Holding
The Court reversed lower court rulings, holding that while affinity survives death, William Sato was not exempt from criminal liability for the complex crime of estafa through falsification.
Background
Mediatrix Carungcong, administratrix of her mother Manolita’s estate, accused her brother-in-law William Sato of estafa for fraudulently inducing Manolita (blind and elderly) to sign a falsified Special Power of Attorney (SPA) to sell her properties. Lower courts dismissed the case based on Article 332’s exemption for relatives by affinity.
Statutory Construction

Soriano vs. People

1st February 2010

ak193031
625 Phil. 33 , G.R. No. 162336
Primary Holding
A bank officer violates the DOSRI law (Section 83 of RA 337) when he acquires bank funds for his personal benefit, even if such acquisition was facilitated by a fraudulent loan application using a third party's name; such fraudulent acquisition does not negate the "indirect borrowing" and can concurrently constitute the crime of estafa through falsification of commercial documents, as the officer holds the funds in a fiduciary capacity and misappropriates them.
Background
The Office of Special Investigation (OSI) of the Bangko Sentral ng Pilipinas (BSP) transmitted a letter with five affidavits to the Department of Justice (DOJ), alleging that Hilario P. Soriano, then president of the Rural Bank of San Miguel (Bulacan), Inc. (RBSM), orchestrated a fraudulent P8 million loan. The loan appeared in the name of spouses Enrico and Amalia Carlos, who denied applying for or receiving it. It was alleged that Soriano ordered, facilitated, and received the loan proceeds without board authorization or proper reporting, using an unsuspecting depositor's name.
Criminal Law II
Estafa

Sps. Tongson vs. Emergency Pawnshop Bula, Inc., et al.

15th January 2010

ak781820
624 Phil. 146 , G.R. No. 167874
Primary Holding
Fraud committed during the consummation stage of a contract of sale, such as the issuance of a worthless check for payment, does not constitute causal fraud (dolo causante) that vitiates consent and annuls the contract; rather, it is incidental fraud (dolo incidente) and a substantial breach of the buyer's obligation to pay, which entitles the seller to rescind the contract under Article 1191 of the Civil Code.
Background
The dispute arose from an agreement for the sale of a 364-square meter parcel of land in Davao City by the Spouses Tongson to Danilo R. Napala for P3,000,000. The transaction involved the execution of a Deed of Absolute Sale indicating a lower consideration, a partial cash payment, and a postdated check for the substantial balance, which was subsequently dishonored.
Obligations and Contracts

Office of the Solicitor General vs. Ayala Land

18th September 2009

ak679178
600 SCRA 617 , 616 Phil. 587 , G.R. No. 177056
Primary Holding
Shopping mall operators cannot be legally compelled to provide free parking spaces to their patrons and the general public under the National Building Code and its Implementing Rules and Regulations.
Background
The case arose from a Senate investigation into the legality of shopping malls charging parking fees. The Senate Committees concluded that charging parking fees was contrary to the National Building Code and recommended the Office of the Solicitor General (OSG) to enjoin the practice. Subsequently, the OSG filed a petition seeking to prohibit mall operators from collecting parking fees, arguing that the National Building Code impliedly mandates free parking.
Constitutional Law II

Pobre vs. Defensor-Santiago

25th August 2009

ak600796
597 SCRA 1 , A.C. No. 7399
Primary Holding
Statements made by a Senator during a Senate speech, even if offensive and violative of a lawyer's ethical duties towards the courts, are covered by parliamentary immunity under Article VI, Section 11 of the Constitution and cannot be the basis for disciplinary action by the Court, although such immunity is intended for the benefit of the legislative institution and the people, not for personal attacks.
Background
The case arose following Senator Miriam Defensor-Santiago's privilege speech on the Senate floor where she expressed extreme frustration and used insulting language directed at the Supreme Court and its members, particularly then Chief Justice Artemio Panganiban, after the Judicial and Bar Council (JBC) effectively excluded non-incumbent justices, like herself, from nomination for the position of Chief Justice.
Constitutional Law I

Jacinto vs. People

13th July 2009

ak482641
610 Phil. 100 , G.R. No. 162540
Primary Holding
The taking of a worthless check, even with intent to gain and grave abuse of confidence, constitutes an impossible crime under Article 4, paragraph 2, in relation to Article 59 of the Revised Penal Code, because the inherent lack of value in the check at the time of taking makes the consummation of theft factually impossible.
Background
The case originated from an employer-employee relationship where the petitioner, a collector for Mega Foam International Inc., was entrusted with receiving payments from customers. The dispute arose when a check payment collected by the petitioner was not remitted to the company but was instead deposited into an account linked to her family and was subsequently dishonored, leading to accusations of theft with grave abuse of confidence.
Criminal Law II
Impossible Crime

Matthews vs. Taylor

22nd June 2009

ak576607
590 SCRA 394 , 608 Phil. 193 , G.R. No. 164584
Primary Holding
The Agreement of Lease between Joselyn Taylor and Philip Matthews is valid because Benjamin Taylor, the alien husband, has no legal right to nullify the lease on property exclusively owned by his Filipino wife. Aliens are constitutionally prohibited from owning land in the Philippines, thus Benjamin's claim of ownership or need for consent is without legal basis.
Background
Benjamin Taylor, a British citizen, and Joselyn Taylor, a Filipina, were married. Joselyn purchased a property in Boracay using funds allegedly provided by Benjamin and developed it into a resort. Later, without Benjamin's express consent, Joselyn leased the property to Philip Matthews. Benjamin filed a case to nullify the lease agreement arguing it was void without his consent as the property was community property and his funds were used for its acquisition.
Property and Land Law

In Re: Petition for Adoption of Michelle P. Lim, et al.

21st May 2009

ak982276
588 SCRA 98 , 606 Phil. 82 , G.R. Nos. 168992-93
Primary Holding
Married individuals must adopt jointly under RA 8552; exceptions do not apply here, so the petitions were correctly dismissed.
Background
Monina and her late husband Primo Lim raised three abandoned children (including Michelle and Michael) as their own, simulating their births. After Primo’s death, Monina remarried an American citizen, Angel Olario. She later sought to legitimize the children’s status through adoption under RA 8552’s amnesty provision for simulated births.
Statutory Construction

Soriano vs. Laguardia

29th April 2009

ak448960
587 SCRA 79 , 605 Phil. 43 , G.R. No. 164785
Background
Eliseo Soriano, host of "Ang Dating Daan," made offensive remarks about Michael Sandoval and the Iglesia ni Cristo on his television program. This led to complaints filed with the MTRCB, which subsequently issued a preventive suspension and later a three-month suspension on Soriano. Soriano challenged these actions in the Supreme Court, arguing that they violated his right to freedom of expression.
Constitutional Law I

Deutsche Gesellschaft Für Technische Zusammenarbeit vs. Court of Appeals

16th April 2009

ak268315
585 SCRA 150 , 603 Phil. 150 , G.R. No. 152318
Background
The case revolves around the employment dispute between GTZ and its former employees who worked on the SHINE project. After their dismissal, the employees filed a complaint for illegal dismissal. GTZ claimed immunity from suit as an implementing agency of the German government. The Labor Arbiter ruled in favor of the employees, and GTZ sought to challenge this decision through various legal channels, ultimately reaching the Supreme Court.
Constitutional Law I

Manubay, et al. vs. Sec. Garilao

16th April 2009

ak319606
603 Phil. 135 , G.R. No. 140717
Primary Holding
An application for land conversion can be validly denied if the subject property has already been placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) prior to the application, and a party aggrieved by a DAR Secretary's decision must first exhaust available administrative remedies, such as an appeal to the Office of the President as provided by DAR rules, before resorting to a petition for certiorari in court, unless grave abuse of discretion is clearly shown and no other plain, speedy, and adequate remedy exists.
Background
The case revolves around a 124-hectare parcel of land in Barrio Cadlan, Pili, Camarines Sur, owned by the petitioners. In 1994, this property was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the Municipal Agrarian Reform Officer (MARO). Subsequently, the petitioners applied for the conversion of this land from agricultural to residential/commercial use, which was denied by the DAR, leading to this legal dispute.
Constitutional Law I

Geologistic, Inc. vs. Gateway Electronics Corporation

25th March 2009

ak146267
582 SCRA 434 , G.R. Nos. 174256-57
Primary Holding
The Supreme Court ruled that the RTC lacked sufficient justification for ordering execution pending appeal, considering the unresolved issues of liability and the absence of compelling "good reasons."
Background
Geologistics, Inc. sought to recover unpaid fees from Gateway Electronics Corporation for freight forwarding services, amounting to ₱4,769,954.32 plus interest and damages. The RTC ruled in favor of Geologistics, and the petitioner moved for execution pending appeal. Gateway Electronics and its surety, First Lepanto-Taisho Insurance Corp., filed separate petitions to annul the execution orders, which the Court of Appeals granted.
Statutory Construction

Ruby Shelter Builders and Realty Development Corporation vs. Formaran III

10th February 2009

ak620041
578 SCRA 283 , 598 Phil. 105 , G.R. No. 175914
Primary Holding
An action, although ostensibly for the annulment of deeds of sale, is considered a real action if its ultimate objective is the recovery of title to or possession of real property, and the docket fees must be computed based on the fair market value of the property as stated in Section 7(a) of Rule 141 of the Rules of Court, as amended.
Background
Petitioner Ruby Shelter Builders and Realty Development Corporation obtained a loan of P95,700,620.00 from respondents Romeo Y. Tan and Roberto L. Obiedo, secured by real estate mortgages over five parcels of land. Upon petitioner's inability to pay, a Memorandum of Agreement (MOA) was executed, granting an extension and providing for the execution of Deeds of Absolute Sale by way of *dacion en pago* for the mortgaged properties if the debt remained unpaid by December 31, 2005. The MOA also included redemption prices for the properties.
Civil Procedure I

Rufloe vs. Burgos

30th January 2009

ak442785
577 SCRA 264 , 597 Phil. 261 , G.R. No. 143573
Primary Holding
The respondents, including the Burgos siblings and Leonarda Burgos, were not innocent purchasers for value. Consequently, they did not acquire a valid title to the property despite relying on Transfer Certificates of Title derived from a forged Deed of Sale. The original title of the Rufloe spouses was reinstated.
Background
The case stems from a property originally owned by the Rufloe spouses. A Deed of Sale was forged, purportedly signed by the Rufloes, transferring the property to Elvira Delos Reyes. Delos Reyes then sold the property to the Burgos siblings, who later sold it to their aunt, Leonarda Burgos. The Rufloes filed a case to nullify these transactions, claiming forgery and asserting their continued ownership.
Property and Land Law

White Light Corporation vs City of Manila

20th January 2009

ak433804
576 SCRA 416 , 596 Phil. 444 , G.R. No. 122846
Primary Holding
Manila City Ordinance No. 7774, which prohibits short-time admission and wash-up rates in hotels and motels, is unconstitutional as it violates the due process clause of the Constitution.
Background
The City of Manila enacted an ordinance seeking to regulate public morals by prohibiting short-time rates in establishments often associated with illicit activities. Several businesses challenged the ordinance, arguing it infringed upon their rights and the rights of their customers. The case highlights the tension between government's power to regulate for public welfare and individual rights to liberty and privacy.
Constitutional Law II
Police Power

Laurel vs. Judge Abrogar

13th January 2009

ak193690
596 Phil. 45 , G.R. No. 155076
Primary Holding
The business of providing telecommunication and the telephone service itself are personal properties capable of appropriation and can be the subject of theft under Article 308 of the Revised Penal Code; the act of International Simple Resale (ISR), which involves unauthorized routing of international calls using a telecommunication company's facilities, constitutes unlawful taking (subtraction) of such business and service.
Background
The case arose from allegations that the petitioner, Luis Marcos P. Laurel, along with others, engaged in International Simple Resale (ISR). ISR is a method of routing and completing international long distance calls using a telecommunication company's lines, cables, antennae, and/or air wave frequency, connecting directly to local or domestic exchange facilities, thereby bypassing the official international gateway of the telecommunication company and depriving it of revenue.
Criminal Law II

Garcillano vs. House of Representatives Committees on Public Information, Public Order and Safety, National Defense and Security, Information and Communications Technology, and Suffrage and Electoral Reforms

23rd December 2008

ak565763
575 SCRA 170 , 595 Phil. 775 , G.R. No. 170338
Primary Holding
The Supreme Court dismissed the first petition (G.R. No. 170338) for being moot and academic but granted the second petition (G.R. No. 179275), prohibiting the Senate from conducting its legislative inquiry due to a lack of duly published procedural rules as required by the Constitution.
Background
The controversy arose from the release of wiretapped recordings allegedly involving then-President Gloria Macapagal-Arroyo and a Commission on Elections official discussing electoral manipulation. These tapes became a subject of public and legislative scrutiny, with both Houses of Congress initiating separate inquiries.
Constitutional Law II

Province of North Cotabato vs. Government of the Republic of the Philippines Peace Panel on Ancestral Domain (GRP)

14th October 2008

ak025291
568 SCRA 402 , 589 Phil. 387 , G.R. No. 183591 , G.R. No. 183752 , G.R. No. 183893 , G.R. No. 183951 , G.R. No. 183962
Primary Holding
The Supreme Court declared the MOA-AD unconstitutional due to violations of the right to information, lack of public consultation, and provisions that exceeded the government's authority and contradicted the Constitution and existing laws.
Background
The MOA-AD was a proposed agreement aimed at resolving the armed conflict in Mindanao by expanding the autonomous region and granting significant powers to the Bangsamoro Juridical Entity (BJE). However, concerns arose regarding the lack of transparency and potential constitutional violations.
Constitutional Law I Constitutional Law II Philosophy of Law

Securities and Exchange Commission vs. Interport Resources Corporation

6th October 2008

ak516001
567 SCRA 354 , 588 Phil. 651 , G.R. No. 135808
Primary Holding
The Supreme Court held that the SEC has the authority to investigate violations of the Revised Securities Act, and the absence of implementing rules does not render the provisions of the Act ineffective. The Court also ruled that the SEC's investigation interrupted the prescription period for filing charges.
Background
In 1994, IRC entered into a Memorandum of Agreement with Ganda Holdings Berhad (GHB) to acquire 100% of Ganda Energy Holdings, Inc. (GEHI). IRC also planned to acquire 67% of Philippine Racing Club, Inc. (PRCI). The SEC alleged that IRC failed to disclose these negotiations promptly and that some directors traded IRC shares using insider information. The SEC initiated an investigation, but the Court of Appeals issued an injunction, halting the SEC's actions.
Philosophy of Law

Abakada Guro Party List vs. Purisima

14th August 2008

ak884230
562 SCRA 251 , 584 Phil. 246 , G.R. No. 166715
Primary Holding
The Supreme Court upheld the constitutionality of RA 9335, except for Section 12, which created the Joint Congressional Oversight Committee. The Court ruled that the oversight committee violated the separation of powers doctrine.
Background
RA 9335 was enacted to improve the revenue collection performance of the BIR and BOC by creating a rewards and incentives fund and a Revenue Performance Evaluation Board. The law provides rewards for exceeding revenue targets and sanctions for failing to meet them. Petitioners, representing the Abakada Guro Party List, filed a petition challenging the constitutionality of the law, arguing that it violated several constitutional principles.
Statutory Construction

In the Matter of the Allegations Contained in the Columns of Mr. Amado P. Macasaet Published in Malaya Dated September 18, 19, 20 and 21, 2007

8th August 2008

ak206148
583 Phil. 391 , A.M. No. 07-09-13-SC
Primary Holding
The Supreme Court held that Amado Macasaet was guilty of indirect contempt for publishing false and baseless allegations of bribery within the Court, which tended to degrade the administration of justice.
Background
Amado Macasaet, a columnist for the newspaper Malaya, published a series of articles in September 2007 alleging that a Supreme Court Justice had received bribes in connection with a case involving a Filipino-Chinese businessman. The articles were based on information from confidential sources and claimed that five boxes containing ₱10 million were delivered to the Court. The Court initiated contempt proceedings against Macasaet for publishing unverified allegations that damaged the Court's reputation.
Philosophy of Law

Figueroa vs. People

14th July 2008

ak461685
558 SCRA 63 , 580 Phil. 58 , G.R. No. 147406
Primary Holding
A litigant is not estopped by laches from assailing the jurisdiction of a trial court over the subject matter for the first time on appeal if the challenge is made without unreasonable delay and the factual circumstances do not mirror the exceptional scenario of _Tijam v. Sibonghanoy_, where the jurisdictional challenge was raised only after almost 15 years. The general rule that a court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal, prevails, as jurisdiction is conferred by law and cannot be vested by consent or waiver of the parties.
Background
The case arose from a criminal information for reckless imprudence resulting in homicide filed against the petitioner, Venancio Figueroa y Cervantes. The core issue that reached the Supreme Court revolved around whether the petitioner was barred by estoppel by laches from questioning the jurisdiction of the Regional Trial Court (RTC) which tried and convicted him, given that he only raised the jurisdictional challenge for the first time during his appeal to the Court of Appeals.
Civil Procedure I

Gobenciong vs. Court of Appeals

31st March 2008

ak728096
550 SCRA 502 , 573 Phil. 613 , G.R. No. 159883
Primary Holding
The Supreme Court held that the Ombudsman's preventive suspension orders are immediately executory, the Ombudsman's disciplinary authority is not merely recommendatory but includes ensuring compliance, and RA 6770 does not constitute an unconstitutional delegation of authority or violate the equal protection clause.
Background
Dr. Pedro Gobenciong, an administrative officer at a regional hospital, was administratively charged for falsification of public documents and misconduct related to the allegedly anomalous purchase of a hemoanalyzer, leading to preventive suspension and subsequent disciplinary action by the Ombudsman.
Constitutional Law II
Due Process

Chavez vs. Gonzales, et al.

15th February 2008

ak123614
569 Phil. 155 , G.R. No. 168338
Primary Holding
Governmental warnings or press statements made by officials in their official capacity that threaten sanctions for the publication or broadcast of specific content, without satisfying the clear and present danger test, constitute an unconstitutional prior restraint on freedom of speech and of the press.
Background
The case arose from the political controversy surrounding the "Hello Garci" tapes, which allegedly contained a wiretapped phone conversation between then-President Gloria Macapagal Arroyo and a high-ranking COMELEC official, purportedly discussing the rigging of the 2004 national election results. Following the public emergence of these tapes, the Secretary of Justice and the NTC issued warnings to the media against their dissemination, citing potential violations of the Anti-Wiretapping Act and program standards for broadcast media.
Constitutional Law II
Freedom of Expression

Heirs of Marcelino Doronio vs. Heirs of Fortunato Doronio

27th December 2007

ak570269
541 SCRA 479 , 565 Phil. 766 , G.R. No. 169454
Primary Holding
The private deed of donation propter nuptias of real property executed in 1919 under the Old Civil Code is void for not being in a public instrument; therefore, it conveyed no title.
Background
Spouses Simeon Doronio and Cornelia Gante owned a parcel of land covered by Original Certificate of Title No. 352. They had children, including Marcelino and Fortunato Doronio. Simeon and Cornelia executed a private deed of donation propter nuptias in favor of Marcelino and his wife Veronica Pico. The description in the deed of donation differed slightly from OCT No. 352 regarding adjacent property owners. Petitioners, heirs of Marcelino, registered the deed through a petition case without naming respondents, heirs of Fortunato, leading to a new TCT in their predecessor's name, covering the entire property. Respondents contested this, claiming only half was intended for donation and the donation was invalid.
Property and Land Law

Garcia vs. Social Security Commission Legal and Collection

17th December 2007

ak000744
540 SCRA 456 , 565 Phil. 193 , G.R. No. 170735
Primary Holding
The Supreme Court upheld that as the only surviving director of the now-dissolved Impact Corporation, Immaculada L. Garcia was liable for unpaid Social Security System (SSS) contributions and penalties imposed under the Social Security Law.
Background
Impact Corporation, a manufacturer of aluminum tube containers, experienced financial difficulties in 1978, leading to labor unrest and eventual cessation of operations. Despite collecting SSS contributions from its employees, the company failed to remit them. The SSS pursued legal actions to recover the unremitted contributions.
Statutory Construction

Manotok Realty, Inc. vs. CLT Realty Development Corporation

14th December 2007

ak258876
540 SCRA 304 , 565 Phil. 59 , G.R. No. 123346 , G.R. No. 134385
Primary Holding
The Supreme Court remanded the consolidated cases to a Special Division of the Court of Appeals to conduct further proceedings and factually determine which of the contending parties' titles, if any, are validly derived from the genuine Original Certificate of Title No. 994 registered on May 3, 1917, and to resolve other factual issues crucial to determining rightful land ownership. Titles purportedly derived from a non-existent OCT No. 994 dated April 19, 1917 are declared void.
Background
The dispute centers on ownership claims over portions of the vast Maysilo Estate, all purportedly originating from OCT No. 994. Conflicting claims arose between Manotok Realty and Manotok Estate Corporation versus CLT Realty Development Corporation in one case, and Araneta Institute of Agriculture, Inc. versus the Heirs of Jose B. Dimson in the other. These cases reached the Supreme Court after conflicting decisions in the lower courts and the Court of Appeals concerning the validity of the parties' titles. Prior Supreme Court decisions in MWSS v. Court of Appeals and Gonzaga v. Court of Appeals had previously addressed claims emanating from OCT No. 994, but inconsistencies and new factual evidence necessitated a re-examination.
Property and Land Law

Heirs of Marcelina Arzadon-Crisologo vs. Rañon

5th September 2007

ak869857
532 SCRA 391 , 559 Phil. 169 , G.R. No. 171068
Primary Holding
The respondents, Heirs of Agrifina Rañon, validly acquired ownership of the subject property through extraordinary acquisitive prescription because they demonstrated continuous, peaceful, public, notorious, uninterrupted, and adverse possession in the concept of an owner for over thirty years.
Background
Agrifina Rañon filed a complaint against spouses Montemayor to quiet title over a residential lot, claiming ownership based on long and continuous possession since 1962. The Heirs of Arzadon-Crisologo intervened, asserting their rights as successors-in-interest of the original owners and claiming that Rañon's possession was not in good faith and did not ripen into ownership. The spouses Montemayor were later dropped as parties as they had repurchased the property from the Arzadons. The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the Arzadon heirs, but the Regional Trial Court (RTC) reversed this decision, favoring the Rañons through acquisitive prescription. The Court of Appeals affirmed the RTC’s decision.
Property and Land Law

Commissioner of Internal Revenue vs. Primetown Property Group, Inc

28th August 2007

ak667689
531 SCRA 436 , 558 Phil. 182 , G.R. No. 162155
Primary Holding
The two-year prescriptive period under Section 229 of the National Internal Revenue Code (NIRC) must be computed as 24 calendar months under the Administrative Code, not 730 days under the Civil Code.
Background
Primetown Property Group, a real estate company, suffered losses in 1997 due to the Asian Financial Crisis and sought a refund for overpaid quarterly income taxes. The Bureau of Internal Revenue (BIR) delayed acting on the claim, leading to a judicial dispute.
Statutory Construction

Cemco Holdings, Inc. vs. National Life Insurance Company of the Philippines, Inc.

7th August 2007

ak555743
529 SCRA 355 , 556 Phil. 198 , G.R. NO. 171815
Primary Holding
The Supreme Court affirmed that the Mandatory Tender Offer Rule under the Securities Regulation Code applies to indirect acquisitions of shares in a publicly listed company, protecting minority shareholders. The Securities and Exchange Commission (SEC) had jurisdiction to order Cemco Holdings to conduct a tender offer after it acquired indirect control of Union Cement Corporation (UCC) through purchasing shares in its holding company.
Background
Cemco Holdings acquired shares in Union Cement Holdings Corporation (UCHC), a non-listed company holding 60.51% of Union Cement Corporation (UCC), a publicly listed firm. This indirect acquisition increased Cemco’s beneficial ownership in UCC from 17.03% to 53%. National Life Insurance, a minority UCC shareholder, demanded Cemco comply with the Mandatory Tender Offer Rule. After Cemco refused, National Life filed a complaint with the SEC.
Statutory Construction