There are 599 results on the current subject filter
| Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
|---|---|---|---|---|
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Belgica vs. Ochoa (19th November 2013) |
AK249819 710 SCRA 1 , 721 Phil. 416 , G.R. No. 208566 , G.R. No. 208493 , G.R. No. 209251 |
The case arose from public outrage and concern over the alleged misuse and corruption associated with the Priority Development Assistance Fund (PDAF) and other lump-sum discretionary funds, particularly in light of the Commission on Audit (CoA) report and the "Napoles controversy." | The Court held that the post-enactment authority granted to legislators under the PDAF and similar schemes constitutes an impermissible intrusion into the Executive's budget execution domain, and that lump-sum discretionary funds without specific guidelines amount to an undue delegation of legislative power and undermines the President's item-veto power. |
Constitutional Law I Constitutional Law II Statutory Construction |
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Consolidated Industrial Gases, Inc. vs. Alabang Medical Center (13th November 2013) |
AK886820 721 Phil. 155 , G.R. No. 181983 |
Consolidated Industrial Gases, Inc. (CIGI), a seller and installer of industrial gas systems, and Alabang Medical Center (AMC), a hospital operator, entered into two contracts. The first, on August 14, 1995, was for the installation of a medical gas pipeline system for the hospital's first to third floors (Phase 1), which AMC fully paid. The dispute arose from a second contract on October 3, 1996, for the continuation of the system to the fourth and fifth floors (Phase 2), under the same terms as Phase 1. | In reciprocal obligations arising from the same cause, where each party is a debtor and creditor of the other, the performance of one obligation is conditioned upon the simultaneous fulfillment of the other; thus, a party cannot demand performance from the other if it has not complied or is not ready to comply in a proper manner with what is incumbent upon it. |
Obligations and Contracts |
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Commissioner of Internal Revenue vs. San Roque Power Corporation (8th October 2013) |
AK589834 690 SCRA 336 , 719 Phil. 137 , G.R. No. 187485 , G.R. No. 196113 , G.R. No. 197156 |
San Roque Power Corporation filed a judicial claim for VAT refund 13 days after its administrative claim, violating the 120-day waiting period. The Court of Tax Appeals granted the refund, but the Supreme Court reversed, emphasizing strict compliance with procedural timelines. | The 120+30-day periods under Section 112(C) of the Tax Code are mandatory and jurisdictional, except for claims filed between December 10, 2003 (issuance of BIR Ruling DA-489-03) and October 6, 2010 (promulgation of Aichi), where taxpayers could rely on the erroneous ruling in good faith. |
Statutory Construction |
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Heirs of Mario Malabanan vs. Republic of the Philippines (3rd September 2013) |
AK741804 704 SCRA 561 , 717 Phil. 141 , G.R. No. 179987 |
Mario Malabanan applied for land registration in 1998 claiming ownership through purchase and continuous, open, public, and adverse possession for over 30 years, asserting the land was alienable and disposable public land. The Republic opposed, arguing failure to prove the land's alienable and disposable nature and insufficient possession as required by law. | The motions for reconsideration from both the petitioners and the respondent are denied, reaffirming the original decision that the petitioners failed to sufficiently prove their right to land registration because they did not establish possession and occupation of the property or by their predecessors-in-interest since June 12, 1945, nor did they fully comply with the requirements of Section 14(1) or 14(2) of the Property Registration Decree and Section 48(b) of the Public Land Act. |
Property and Land Law |
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Chingkoe vs. Republic (13th July 2013) |
AK079924 702 SCRA 677 , 715 Phil. 651 , G.R. No. 183608 |
The case originated from two separate collection suits filed by the Republic of the Philippines, represented by the Bureau of Customs (BOC), seeking to recover allegedly unpaid customs duties and taxes from Chiat Sing Cardboard Inc. and Filstar Textile Industrial Corporation (Filstar), along with individual defendants including the petitioners Faustino and Gloria Chingkoe. The basis for the collection suits was the alleged use of fake and spurious tax credit certificates originally issued to Filstar and subsequently used by Chiat Sing to settle import duties, and the fraudulent acquisition of tax credit certificates by Filstar itself. | An order dismissing a case for the plaintiff's failure to appear at pre-trial under Rule 18, Section 5 of the Rules of Court is a final order, considered an adjudication on the merits and with prejudice unless otherwise stated, and the proper remedy against such dismissal is an ordinary appeal under Rule 41, not a special civil action for certiorari under Rule 65. |
Civil Procedure I Pre-trial |
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Capili vs. People (3rd July 2013) |
AK509180 G.R. No. 183805 , 700 SCRA 443 |
Petitioner James Walter P. Capili was legally married to Karla Y. Medina-Capili. During the subsistence of this first marriage, he contracted a second marriage with private respondent Shirley G. Tismo. This led to the filing of a criminal information for bigamy against him. Subsequently, a separate civil case was initiated, which resulted in the judicial declaration of the second marriage as null and void. The petitioner then sought the dismissal of the bigamy charge, arguing that the nullity of the second marriage removed the basis for the criminal case. | A subsequent judicial declaration of nullity of a second marriage is not a valid defense against a charge of bigamy, as the crime is consummated at the time the second marriage is contracted during the subsistence of a prior valid marriage. |
Persons and Family Law Prejudicial Question |
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Hing vs. Choachuy (26th June 2013) |
AK967276 699 SCRA 667 , G.R. No. 179736 |
Petitioners Spouses Hing and respondents Choachuy are owners of adjacent commercial lots in Mandaue City, Cebu. The respondents operate an auto-repair shop, Aldo Goodyear Servitec, on their property. A prior legal dispute existed between the parties, initiated by the respondents' company (Aldo) against the petitioners concerning the construction of a fence. Following this, the respondents installed two video surveillance cameras on their building, which were directed at the petitioners' property. Petitioners alleged that this was an illegal act of surveillance intended to gather evidence for the prior case and was a violation of their privacy, prompting them to file the present case for injunction and damages. | The right to privacy under Article 26(1) of the Civil Code, which prohibits "prying into the privacy of another's residence," is not strictly confined to residential properties; it also protects areas like business offices where the public is excluded and where an individual has a reasonable expectation of privacy. |
Persons and Family Law Article 26(1) of the Civil Code |
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Fujiki vs. Marinay (26th June 2013) |
AK267379 700 SCRA 69 , G.R. No. 196049 |
Petitioner Minoru Fujiki, a Japanese national, married respondent Maria Paz Marinay, a Filipino, in the Philippines in 2004. Due to family objections, they lived separately and eventually lost contact. In 2008, Marinay, without dissolving her first marriage, married another Japanese national, Shinichi Maekara, in Quezon City. After allegedly suffering abuse from Maekara, Marinay reconnected with Fujiki in Japan. In 2010, with Fujiki's help, Marinay obtained a judgment from a Japanese family court declaring her marriage to Maekara void on the ground of bigamy. Fujiki then sought to have this foreign judgment recognized in the Philippines to nullify the bigamous marriage under Philippine law and to correct the civil registry. | A petition to recognize a foreign judgment relating to marital status does not require a re-litigation of the case but only proof of the judgment as a fact under the Rules of Court; it is a special proceeding, not a civil action for declaration of nullity governed by A.M. No. 02-11-10-SC, and the spouse of the prior subsisting marriage has the legal personality to file such a petition. |
Persons and Family Law Article 15, Civil Code |
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Garcia vs. Drilon (25th June 2013) |
AK592766 699 SCRA 352 , 712 Phil. 44 , G.R. No. 179267 |
Republic Act No. 9262 was enacted by Congress in 2004 as a landmark law defining and criminalizing various forms of violence against women and their children (VAWC) perpetrated by intimate partners (husbands, former husbands, partners, etc.), providing protective measures like protection orders, and outlining duties of government officials in responding to VAWC complaints. The law was a response to the high prevalence of domestic violence against women in the Philippines, often committed by their intimate partners, and aimed to address the historically unequal power relations between men and women. This case arose when a husband, subjected to Temporary Protection Orders under RA 9262, challenged the law's fundamental validity before the courts. | Republic Act No. 9262, the Anti-Violence Against Women and Their Children Act of 2004, is constitutional and does not violate the equal protection clause, the due process clause, or constitute an undue delegation of judicial power to barangay officials. |
Constitutional Law II Criminal Law II Equal Protection, VAWC |
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Nagkakaisang Maralita ng Sitio Masigasig, Inc. vs. Military Shrine Services-Philippine Veterans Affairs Office, Department of National Defense (5th June 2013) |
AK977863 697 SCRA 359 , G.R. No. 187587 |
The dispute originates from the status of land within the Fort Bonifacio military reservation. In 1957, President Carlos P. Garcia reserved the area for military use through Proclamation No. 423. Over the years, subsequent proclamations excluded certain portions for other purposes. In 1986, President Ferdinand E. Marcos issued Proclamation No. 2476, declaring specific barangays within the reservation as alienable and disposable. The core of the controversy is a handwritten note he allegedly added to this proclamation to include Western Bicutan, which was omitted from the official publication, leading petitioners to claim rights over the land they occupy therein. | An unpublished portion of a law, such as a handwritten addendum to a presidential proclamation, has no legal force or effect; publication in full is an indispensable condition for the effectivity of all laws to ensure the public is duly informed of their contents and to comply with the due process requirement. |
Persons and Family Law Article 2 and 8, Civil Code |
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Eagleridge Development Corporation vs. Cameron Granville 3 Asset Management, Inc. (10th April 2013) |
AK544596 695 SCRA 714 , 708 Phil. 693 , G.R. No. 204700 |
Export and Industry Bank (EIB) initiated a collection suit against Eagleridge Development Corporation (EDC) and its sureties, Marcelo N. Naval and Crispin I. Oben, for an outstanding loan obligation. During the pendency of this suit, EIB assigned EDC's loan obligation to Cameron Granville 3 Asset Management, Inc. (Cameron), a special purpose vehicle, through a Deed of Assignment which referenced an underlying Loan Sale and Purchase Agreement (LSPA). Cameron was subsequently substituted as the plaintiff in the collection case. | A party defending against a claim based on an assigned credit, especially a credit in litigation, has the right under the rules of discovery (Rule 27) to compel the production of documents like a Loan Sale and Purchase Agreement (LSPA) that are explicitly mentioned in the Deed of Assignment and necessary to determine the consideration paid, particularly when invoking the right of legal redemption under Article 1634 of the Civil Code. |
Civil Procedure I Discovery |
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Bongalon vs. People (20th March 2013) |
AK835327 694 SCRA 12 , 707 Phil. 11 , G.R. No. 169533 |
The incident occurred during an evening procession where the petitioner's minor daughters and the victim, Jayson dela Cruz (a 12-year-old minor), along with his brother, were participants or bystanders. An initial altercation involving alleged stone-throwing and name-calling between the children preceded the petitioner's confrontation with Jayson. | An act of laying hands on a child constitutes the crime of child abuse under Section 10(a) of Republic Act No. 7610 only if the prosecution proves beyond reasonable doubt that the accused specifically intended to debase, degrade, or demean the intrinsic worth and dignity of the child as a human being; otherwise, the act is punishable under the Revised Penal Code for physical injuries. |
Criminal Law II Slight Physical Injuries, Child Abuse |
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Anchor Savings Bank vs. Furigay (13th March 2013) |
AK235702 706 Phil. 378 , G.R. No. 191178 |
Anchor Savings Bank (ASB) had an existing loan with Ciudad Transport Services, Inc. (CTS), its president Henry H. Furigay, and his wife Gelinda C. Furigay. When CTS and the Furigays defaulted on their loan obligation, ASB filed a complaint for sum of money. While this collection case was pending, the Furigay spouses donated several of their registered properties to their minor children, Hegem and Herriette Furigay. ASB, believing this donation was made to defraud creditors, subsequently filed a separate action for rescission of the deed of donation. | An action for rescission of a contract in fraud of creditors (accion pauliana) is subsidiary in nature and cannot be instituted except when the party suffering damage has no other legal means to obtain reparation for the same; the complaint for accion pauliana must allege that the creditor has exhausted all properties of the debtor and has no other legal remedy. |
Obligations and Contracts |
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Cruz vs. Atty. Gruspe (13th March 2013) |
AK238573 706 Phil. 406 , G.R. No. 191431 |
The dispute originated from a vehicular accident on October 24, 1999, where a minibus owned by petitioner Rodolfo G. Cruz and driven by Arturo Davin collided with the Toyota Corolla car belonging to respondent Atty. Delfin Gruspe, causing Gruspe's car to be a total wreck. This incident led to Cruz and Leonardo Q. Ibias executing a Joint Affidavit of Undertaking the following day to compensate Gruspe. | A document titled "Joint Affidavit of Undertaking" which contains clear promissory stipulations to perform an obligation (e.g., replace a damaged item or pay its value by a certain date) constitutes a binding contract if the essential elements of consent, object, and cause are present, irrespective of its title. Interest on a monetary obligation arising from such a contract, where the contract stipulates a payment deadline but is silent on when interest for delay begins, accrues only from the date of judicial or extrajudicial demand, not automatically from the payment deadline. Furthermore, courts may equitably reduce stipulated interest rates that are found to be excessive or unconscionable. |
Obligations and Contracts |
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Fernando vs. St. Scholastica's College (12th March 2013) |
AK827333 693 SCRA 141 , 706 Phil. 138 , G.R. No. 161107 |
The City of Marikina enacted Ordinance No. 192 aiming to regulate fence construction for public safety, security, beautification, and neighborliness. The ordinance set height limits and see-through requirements for fences and mandated a five-meter parking setback for certain establishments, including educational institutions. St. Scholastica's College, affected by this ordinance, challenged its validity. | Sections 3.1 and 5 of Ordinance No. 192 of Marikina City, which regulate fence height and setback requirements, are invalid exercises of police power because they are not reasonably necessary for the stated purposes, are unduly oppressive, and constitute a taking of private property without just compensation. |
Constitutional Law II |
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Pilar Development Corporation vs. Dumadag (11th March 2013) |
AK661257 693 SCRA 96 , 706 Phil. 93 , G.R. No. 194336 |
Pilar Development Corporation claimed ownership of a property within Pilar Village Subdivision, a portion of which was occupied by respondents who built shanties. PDC filed an accion publiciana to evict the respondents, arguing they built without consent on land designated for village recreational facilities. The respondents countered that the local government, not PDC, had jurisdiction over the area. The trial court and the Court of Appeals dismissed PDC's complaint, finding the occupied area was a public easement. | Pilar Development Corporation cannot recover possession of the 3-meter strip of land designated for public easement because it is considered part of the public dominion. The proper party to institute an action concerning this public easement is the Republic of the Philippines through the Office of the Solicitor General or the local government of Las Piñas City. |
Property and Land Law |
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Civil Service Commission vs. Pililla Water District (5th March 2013) |
AK305171 705 Phil. 378 , G.R. No. 190147 |
The case arose from the appointment and reappointment of Paulino J. Rafanan as General Manager (GM) of Pililla Water District (PWD). Issues emerged regarding the nature of his appointment (coterminous status), his continuation in service beyond the compulsory retirement age of 65, and the interpretation of relevant Civil Service Commission (CSC) circulars and Republic Act No. 9286, which amended the law governing water districts. | The position of General Manager of a local water district is primarily confidential in nature, and the amendment introduced by Republic Act No. 9286, requiring removal only for cause and after due process, does not convert it into a career service position; thus, an appointee may hold such a position on a coterminous basis even beyond the compulsory retirement age. |
Constitutional Law I |
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Dayao vs. Commission on Elections (29th January 2013) |
AK885502 689 SCRA 412 , 702 Phil. 348 , G.R. No. 193643 |
Petitioners, who are dealers of LPG and an association of industries, sought to cancel the registration of LPGMA as a sectoral organization under the Party-List System, arguing that LPGMA did not represent a marginalized sector. | The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing the complaint for cancellation of LPGMA's registration, as the grounds for cancellation were not among those listed in the Party-List System Act, and the complaint was essentially a belated opposition to the registration. |
Statutory Construction |
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Giron vs. Commission on Elections (22nd January 2013) |
AK774340 689 SCRA 97 , 702 Phil. 30 , G.R. No. 188179 |
The case was a special civil action for certiorari and prohibition filed by Giron against the Commission on Elections (COMELEC) regarding the implementation of the Fair Election Act. | The Supreme Court upheld the constitutionality of Sections 12 and 14 of RA 9006, finding that they are germane to the general subject of the law, which aims to ensure fair election practices. |
Statutory Construction |
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Spouses Mamaril vs. The Boy Scout of the Philippines (14th January 2013) |
AK436103 701 Phil. 400 , G.R. No. 179382 |
Spouses Benjamin C. Mamaril and Sonia P. Mamaril were jeepney operators who, since 1971, parked their six passenger jeepneys every night at the Boy Scout of the Philippines' (BSP) compound for a monthly fee of P300.00 per unit. BSP had a contract with AIB Security Agency, Inc. (AIB) for security services at its compound, which included the deployment of security guards. | A lessor of a parking space (BSP) is not liable for the loss of a vehicle parked therein due to the negligence of security guards supplied by an independent security agency (AIB), where there is no employer-employee relationship between the lessor and the guards, no principal-agent relationship, and the security contract between the lessor and the agency does not contain a stipulation pour autrui in favor of the lessee. The contractual relationship between the vehicle owner paying a parking fee and the parking lot owner, where the owner retains the keys and control of the vehicle, is one of lease, not bailment. |
Obligations and Contracts |
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Tan, Jr. vs. Matsuura (9th January 2013) |
AK725361 688 SCRA 263 , G.R. No. 179003 , G.R. No. 195816 |
The case arose from an intra-corporate dispute in TF Ventures, Inc., involving Tan and Matsuura, where Tan accused Matsuura and others of stealing company properties, including a pre-signed blank Deed of Trust; this led to a qualified theft case against Matsuura and associates, and Tan later claimed the deed was filled and notarized without his consent as part of a compromise attempt, prompting falsification charges amid ongoing hostilities and legal battles before the Securities and Exchange Commission. | The Court of Appeals correctly exercised its power to review the Department of Justice's findings for grave abuse of discretion, and there was no probable cause to indict the respondents for falsification under Articles 171 and 172 of the Revised Penal Code, as the elements of the crime, including alteration changing the document's meaning and damage, were not sufficiently established during the preliminary investigation. |
Civil Procedure II |
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University of the Philippines vs. Dizon (23rd August 2012) |
AK560575 679 SCRA 54 , 693 Phil. 226 , G.R. No. 171182 |
The University of the Philippines (UP) entered into a General Construction Agreement with Stern Builders Corporation (Stern Builders) for a project at UPLB. UP paid two of three progress billings but failed to pay the third billing, initially due to a COA disallowance which was later lifted. Stern Builders subsequently filed a suit for collection of the unpaid amount and damages against UP. | Government funds, including those of state universities like the University of the Philippines, are public in character and cannot be seized through writs of execution or garnishment to satisfy money judgments without the claim first being adjudicated by the Commission on Audit (COA) and a corresponding appropriation made by law; the power of courts in such cases ends with the judgment, as its satisfaction must follow the procedures outlined in P.D. No. 1445. |
Constitutional Law I |
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Re: COA Opinion on the Computation of the Appraised Value of the Properties Purchased by the Retired Chief/Associate Justice of the Supreme Court (31st July 2012) |
AK055973 678 SCRA 1 , 692 Phil. 147 , A.M. No. 11-7-10-SC |
The issue arose from a Commission on Audit (COA) Opinion finding an underpayment by five retired Supreme Court Justices who purchased personal properties (mostly vehicles) assigned to them during their tenure. The COA contested the valuation formula used by the Supreme Court's Property Division, which was based on the Constitutional Fiscal Autonomy Group (CFAG) Joint Resolution No. 35, insisting that a different COA formula should have been applied. This prompted the Supreme Court's Office of Administrative Services to seek clarification from the Court *En Banc* regarding the proper formula. | The Judiciary's constitutional fiscal autonomy grants it full flexibility to allocate and utilize its resources, including the authority to determine the manner and conditions for the disposal of its property, such as setting the appraisal formula for items purchased by retiring Justices, free from external interference or substitution of policy by the Commission on Audit. |
Constitutional Law I |
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Madriaga, Jr. vs. China Banking Corporation (25th July 2012) |
AK464752 677 SCRA 560 , 691 Phil. 770 , G.R. No. 192377 |
The dispute originated from a sale of properties by Spouses Trajano to Madriaga, Sr., followed by complications involving a mortgage with Asia Trust Bank, an execution sale in favor of Madriaga, Sr., and a subsequent mortgage with China Bank that led to foreclosure. | The petition is denied because the case was rendered moot and academic by the full implementation of the writ of possession, and the issuance of the ex parte writ of possession did not violate the petitioner's right to due process. |
Constitutional Law II |
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Chavez vs. Judicial and Bar Council (17th July 2012) |
AK960332 676 SCRA 579 , 691 Phil. 173 , G.R. No. 202242 |
After Chief Justice Renato Corona’s removal in May 2012, petitioner Francisco Chavez (a nominee for Chief Justice) challenged the JBC’s composition. The JBC had included two congressional representatives since 1994, initially splitting one vote and later granting each a full vote. | The JBC’s practice of allowing two congressional representatives (one from the Senate and one from the House) violated Section 8(1), Article VIII of the 1987 Constitution, which mandates only “a representative of Congress” as an ex-officio member. |
Statutory Construction |
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Liwag vs. Happy Glen Loop Homeowners Association, Inc (4th July 2012) |
AK931594 675 SCRA 744 , 690 Phil. 321 , G.R. No. 189755 |
In 1978, F.G.R. Sales, the original subdivision developer, assigned rights to Ernesto Marcelo due to financial obligations. Marcelo assured government agencies that water facilities were available in the subdivision. The water facility on Lot 11, Block 5 became the sole water source for residents for over 30 years. In 1995, Marcelo sold Lot 11, Block 5 to Hermogenes Liwag. After his death, Emeteria Liwag demanded the removal of the water tank, prompting the homeowners' association to file a case before the Housing and Land Use Regulatory Board (HLURB). | The Supreme Court affirmed that Lot 11, Block 5, as the site of the subdivision's water facility, is part of the required "open space" under Presidential Decree No. 957 and reserved for public use. The sale of the lot was void, and an easement for the water facility existed for the benefit of the community. |
Statutory Construction |
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United Church of Christ in the Philippines, Inc. vs. Bradford United Church of Christ, Inc., et al. (20th June 2012) |
AK736563 688 Phil. 408 , G.R. No. 171905 |
Petitioner UCCP is a national confederation of Evangelical churches. Respondent BUCCI, formerly Bradford Memorial Church, is a religious corporation that was a constituent local church of UCCP. A dispute arose in late 1989 when BUCCI began constructing a fence that encroached on a right-of-way allocated by UCCP. This, along with other disagreements, led to BUCCI's formal disaffiliation from UCCP, which UCCP contested, claiming the disaffiliation was invalid and that BUCCI could not amend its articles or continue using its name. | A local church, incorporated as a separate legal entity, has the right to disaffiliate from a national church confederation and amend its articles of incorporation to reflect such disaffiliation, especially where the confederation's polity recognizes local church autonomy, and such matters, involving corporate rights, are within the jurisdiction of civil courts and the SEC, not being purely ecclesiastical affairs. |
Constitutional Law I |
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Re: Request for Copy of 2008 Statement of Assets, Liabilities and Net Worth [SALN] and Personal Data Sheet or Curriculum Vitae of the Justices of the Supreme Court and Officers and Employees of the Judiciary (13th June 2012) |
AK617262 672 SCRA 27 , 687 Phil. 24 , A.M. No. 09-8-6-SC |
The case arose from initial requests by the Philippine Center for Investigative Journalism (PCIJ) in 2009 for the 2008 SALNs and PDS/CVs of Supreme Court and Court of Appeals Justices to update their database on government officials. Following these initial requests, numerous similar petitions were filed by various media outlets, organizations, individuals, and even government offices (like the Ombudsman and Malacañang seeking comment on a bill) for SALNs and other personal documents of judiciary members covering different years, spurred by interests in transparency, governance reporting, academic research, impeachment proceedings, and general public information. | Access to the SALNs, PDS, and CVs of members of the Judiciary is generally allowed pursuant to the right to information, but this right is not absolute and must be regulated to protect judicial independence and the security of judicial officers; thus, requests are subject to specific guidelines including proper filing, statement of legitimate purpose, limitations on the scope of documents released, potential requirement for En Banc approval (for appellate court Justices), and verification of the requester's identity and record. |
Constitutional Law I |
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Marcos, Jr. vs. Republic (25th April 2012) |
AK198765 671 SCRA280 , 686 Phil. 980 , G.R. No. 189434 |
This case involves the Republic's efforts to recover ill-gotten wealth allegedly acquired by the Marcoses during their time in power, specifically focusing on assets held by Arelma, S.A. | The assets of Arelma, S.A. are considered ill-gotten wealth and are rightly forfeited to the Republic; the Sandiganbayan did not err in granting the Motion for Partial Summary Judgment. |
Constitutional Law II |
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Hacienda Luisita, Inc. vs. Presidential Agrarian Reform Council, et al. (24th April 2012) |
AK280291 686 Phil. 377 , G.R. No. 171101 |
The case revolves around the implementation of the Comprehensive Agrarian Reform Program (CARP) in Hacienda Luisita, a large sugar plantation. Instead of direct land distribution, HLI implemented a Stock Distribution Plan (SDP) in 1989, approved by the Presidential Agrarian Reform Council (PARC). Years later, PARC revoked the SDP, leading to legal challenges by HLI. The Supreme Court initially affirmed PARC's revocation but allowed FWBs the option to remain HLI stockholders. Subsequent motions led to the revocation of this option and clarifications on just compensation and the distribution of proceeds from land sales, which are further addressed in this resolution. | The date of "taking" of Hacienda Luisita's agricultural lands for agrarian reform purposes is November 21, 1989, the date PARC approved HLI's Stock Distribution Plan (SDP); the option previously granted to FWBs to remain HLI stockholders is revoked, and control over agricultural lands must be in the hands of the farmers; the FWBs are entitled to the proceeds from the sale of converted lands (less specified deductions); and HLI is entitled to just compensation from the government for the homelots distributed to the FWBs. |
Constitutional Law I Persons and Family Law |
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Lockheed Detective and Watchman Agency, Inc. vs. University of the Philippines (18th April 2012) |
AK644609 670 SCRA 206 , 686 Phil. 191 , G.R. No. 185918 |
Petitioner Lockheed Detective and Watchman Agency, Inc. (Lockheed) had a contract for security services with respondent University of the Philippines (UP). This contractual relationship led to labor disputes when security guards assigned to UP filed complaints for various unpaid monetary benefits. | Government instrumentalities with separate juridical personalities, like the University of the Philippines, are suable and their funds are not exempt from execution or garnishment; however, any money judgment against them must first be filed as a claim with the Commission on Audit (COA) before execution can proceed. |
Constitutional Law I |
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Luz vs. People (29th February 2012) |
AK520853 683 Phil. 399 , G.R. No. 197788 |
The case arose from a routine traffic stop where a police officer flagged down the petitioner for driving a motorcycle without a helmet, a violation of a Naga City ordinance. | A stop for a minor traffic violation, particularly one punishable only by a fine like failing to wear a motorcycle helmet under a city ordinance, does not inherently constitute a lawful custodial arrest that justifies a subsequent warrantless search incidental to arrest; evidence obtained from such an illegal search is inadmissible. |
Constitutional Law II Searches and Seizures |
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Dela Llana vs. The Chairperson, Commission on Audit, et al (7th February 2012) |
AK783122 681 Phil. 186 , G.R. No. 180989 |
The COA's approach to pre-audit has evolved over time. In 1982, COA Circular No. 82-195 lifted the pre-audit system with exceptions, emphasizing agency head responsibility. Following the 1986 EDSA Revolution and the discovery of financial anomalies, COA Circular No. 86-257 reinstated selective pre-audit. With political and governmental stabilization, COA Circular No. 89-299 was issued, again lifting the pre-audit for national government agencies (NGAs) and government-owned or -controlled corporations (GOCCs) to reaffirm managerial fiscal responsibility and accelerate public service delivery. Subsequent circulars (94-006 and 95-006) expanded the lifting of pre-audit to local government units (LGUs). COA Circular No. 89-299A allowed for the reinstitution of pre-audit under certain circumstances. Later, COA Circular No. 2009-002 reinstated selective pre-audit due to rising irregularities, which was then lifted again by COA Circular No. 2011-002. | The Commission on Audit (COA) is not constitutionally mandated to conduct a pre-audit of all government transactions; the COA has the exclusive authority to define the scope of its audit and examination, and the conduct of pre-audit is discretionary, to be implemented when, for example, an agency's internal control system is inadequate. |
Constitutional Law I |
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China National Machinery & Equipment Corp. (Group) vs. Santamaria (7th February 2012) |
AK339749 665 SCRA 189 , 681 Phil. 198 , G.R. No. 185572 |
The case arose from the North Luzon Railways Project (Northrail Project), a large-scale infrastructure project involving the construction of a railway line from Caloocan to Malolos. This project involved agreements between Philippine government entities, Chinese government entities, and petitioner CNMEG, a Chinese state-owned corporation designated as the prime contractor. The project was financed through a Preferential Buyer's Credit extended by the Export Import Bank of China (EXIM Bank) to the Philippine government. | A state-owned corporation engaging in proprietary or commercial activities (acts jure gestionis) is not entitled to sovereign immunity from suit, and a contract entered into by such an entity for a commercial venture, governed by domestic law, does not constitute an executive agreement immune from judicial review. |
Constitutional Law I |
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Villareal vs. People (1st February 2012) |
AK884025 664 SCRA 519 , 680 Phil. 527 , G.R. No. 151258 , G.R. No. 154954 , G.R. No. 155101 , G.R. No. 178057 , G.R. No. 178080 |
Lenny Villa, a law student at Ateneo de Manila University, died during the initiation rites of the Aquila Legis Juris Fraternity in February 1991. The initiation involved physical beatings and psychological pressure, leading to Villa's death from cardiac failure due to multiple traumatic injuries. The case led to the enactment of the Anti-Hazing Law in 1995. | The Supreme Court found the accused fraternity members guilty of reckless imprudence resulting in homicide, emphasizing that the death of Lenny Villa was the cumulative effect of the physical injuries inflicted during the initiation rites. The Court also dismissed the case against Artemio Villareal due to his death, extinguishing his criminal liability. |
Philosophy of Law |
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Commissioner of Customs vs. Hypermix Feeds Corporation (1st February 2012) |
AK490989 664 SCRA 666 , 680 Phil. 681 , G.R. No. 179579 |
Hypermix Feeds Corporation challenged CMO No. 27-2003, which classified wheat imports as either food grade (3% tariff) or feed grade (7% tariff) based on factors like importer identity, country of origin, and port of discharge. Hypermix argued that the regulation unfairly classified its wheat as feed grade despite being food grade, subjected it to higher tariffs, and violated constitutional rights. | CMO No. 27-2003 was declared unconstitutional for violating procedural due process, substantive due process, and the equal protection clause. It also exceeded the Commissioner of Customs' delegated authority. |
Statutory Construction |
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Fontana Resort and Country Club, Inc. vs. Spouses Tan (30th January 2012) |
AK756215 680 Phil. 395 , G.R. No. 154670 |
Respondent spouses purchased two class "D" shares of stock in petitioner Fontana Resort and Country Club, Inc. (FRCCI) from petitioner RN Development Corporation (RNDC), allegedly enticed by promises of first-class leisure facilities at Fontana Leisure Park (FLP) to be fully operational by the first quarter of 1998, and specific accommodation privileges. Disputes arose when respondents experienced difficulties in availing their free accommodations and perceived the FLP development as incomplete and the club rules as obscure and changing. | A contract of sale cannot be annulled or rescinded for alleged fraud or default if the party seeking such relief fails to establish by full, clear, and convincing evidence the existence of dolo causante or a substantial and fundamental breach that defeats the object of the parties in making the agreement; mere negligence, while not justifying rescission, may entitle the aggrieved party to nominal damages. |
Obligations and Contracts |
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Alma Jose vs. Javellana (25th January 2012) |
AK630213 664 SCRA 11 , 680 Phil. 10 , G.R. No. 158239 |
The dispute originated from a 1979 Deed of Conditional Sale where Margarita Marquez Alma Jose sold two parcels of land to Ramon Javellana. Payment was partially made upfront, with the balance due upon registration under the Torrens System, an obligation Margarita undertook. After Margarita and her son/attorney-in-fact Juvenal died, the obligation fell upon her daughter and sole heir, Priscilla Alma Jose, who allegedly failed to comply and instead started developing the properties, prompting Javellana to sue for specific performance. | An order denying a motion for reconsideration of a final order (such as an order dismissing a case) is itself a final order and thus appealable; the aggrieved party is entitled to a fresh period of 15 days from receipt of the denial order within which to file the notice of appeal, pursuant to the "fresh period rule" established in _Neypes v. Court of Appeals_, which applies retroactively to pending cases. |
Civil Procedure I |
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Balao, et al. vs. Macapagal-Arroyo, et al (13th December 2011) |
AK153249 678 Phil. 532 , G.R. No. 186050 , G.R. No. 186059 |
James M. Balao, a co-founder of the Cordillera Peoples Alliance (CPA), an organization advocating for indigenous peoples' rights, was abducted on September 17, 2008. Prior to his abduction, James had reported surveillance activities against him to his family and CPA colleagues, allegedly by state agents. The CPA had been linked by military sources to the Communist Party of the Philippines-New People's Army (CPP-NPA), and petitioners cited a pattern of harassment and violence against CPA members and other activists, suggesting James's abduction was politically motivated and part of a counter-insurgency campaign. | The privilege of the writ of amparo shall be denied if the allegations of an enforced disappearance are not proven by substantial evidence establishing state participation or acquiescence; however, government officials remain accountable for failing to conduct an investigation with extraordinary diligence, and the case may be remanded for continued investigation and monitoring by the trial court. Presidential immunity from suit is applicable in amparo proceedings for an incumbent president, and the doctrine of command responsibility, while not a basis for criminal liability in amparo, can be used to determine accountability for failure to investigate or prevent violations. |
Constitutional Law I |
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Bureau of Customs Employees Association (BOCEA) vs. Hon Teves, et al. (6th December 2011) |
AK564613 677 Phil. 636 , G.R. No. 181704 |
Republic Act No. 9335, the Attrition Act of 2005, was enacted to optimize the revenue-generation capability and collection of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). It aimed to encourage BIR and BOC officials and employees to exceed their revenue targets by establishing a system of rewards and sanctions, including a Rewards and Incentives Fund and a Revenue Performance Evaluation Board. The law covered all officials and employees of the BIR and BOC with at least six months of service. | Republic Act No. 9335 (Attrition Act of 2005) and its Implementing Rules and Regulations are constitutional, do not constitute an undue delegation of legislative power, do not violate the rights to equal protection, security of tenure, or due process of covered employees, and do not constitute a bill of attainder. |
Constitutional Law I |
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People vs. Trestiza (16th November 2011) |
AK906974 660 SCRA 407 , 676 Phil. 420 , G.R. No. 193833 |
The Supreme Court affirmed that police officers can be held liable for kidnapping when they act in their private capacity rather than in furtherance of official functions, upholding the conviction of PO1 Trestiza and his co-accused for kidnapping for ransom. |
Criminal Law II |
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Datu Michael Abas Kida vs. Senate of the Philippines (18th October 2011) |
AK191813 659 SCRA 270 , 675 Phil. 316 , G.R. No. 196271 , G.R. NO. 196305 , G.R. NO. 197221 , G.R. NO. 197282 , G.R. NO. 197392 , G.R. NO. 197454 |
RA No. 10153 reset the August 2011 ARMM elections to May 2013 to align with national and local polls. Petitioners challenged the law, claiming it violated ARMM’s autonomy, legislative processes, and the constitutional requirement for elective regional positions. | RA No. 10153 is constitutional; the synchronization of ARMM elections with national elections and the President’s power to appoint interim officials (OICs) are valid under the 1987 Constitution. |
Constitutional Law I Statutory Construction |
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Barayuga vs. Adventist University of the Philippines (17th August 2011) |
AK907241 655 SCRA 640 , G.R. No. 168008 |
The Adventist University of the Philippines (AUP) is a non-stock, non-profit domestic educational institution. Petitioner Petronilo J. Barayuga was appointed President of AUP by its Board of Trustees. Subsequent external and internal audits revealed alleged irregularities in his management style and financial transactions, leading the Board to consider his removal. The core of the dispute revolved around the validity of his removal and the length of his term as President. | An injunctive relief protects only a right *in esse*; where the plaintiff fails to demonstrate an existing right to be protected by injunction, the suit for injunction must be dismissed for lack of a cause of action. The petitioner's term of office as President of AUP was for two years as per AUP's amended By-Laws, not five years, and by the time of his removal, he was already serving in a hold-over capacity. |
Civil Procedure I |
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Magallona vs. Ermita (16th August 2011) |
AK124720 655 SCRA 476 , 671 Phil. 243 , G.R. No. 187167 |
The Philippines, an archipelagic state, enacted Republic Act No. 3046 in 1961 to define its maritime baselines. Following its ratification of the United Nations Convention on the Law of the Sea (UNCLOS III) in 1984, there arose a need to align domestic law with the Convention's specific requirements for archipelagic baselines, such as water-land ratio, maximum length of baselines, and conformity to the general configuration of the archipelago. UNCLOS III also established a deadline for coastal states to submit claims for an extended continental shelf. Consequently, Congress enacted RA 9522 in March 2009, amending RA 3046 to comply with UNCLOS III by optimizing basepoints, adjusting baseline lengths, and classifying the Kalayaan Island Group (KIG) and Scarborough Shoal as "regimes of islands" under the Republic, whose islands would generate their own maritime zones distinct from the main archipelago's baselines. | Republic Act No. 9522, which adjusts the Philippines' archipelagic baselines and classifies the Kalayaan Island Group and Scarborough Shoal as "regimes of islands" in accordance with UNCLOS III, is constitutional; it serves as a statutory mechanism for demarcating the country's maritime zones and does not result in the diminution of Philippine territory or sovereignty. |
Constitutional Law I |
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Gamboa vs. Finance Secretary Teves, et al. (28th June 2011) |
AK128498 668 Phil. 1 , G.R. No. 176579 |
The Philippine government, through the Presidential Commission on Good Government (PCGG), decided to privatize its shares in Philippine Telecommunications Investment Corporation (PTIC). PTIC was a significant shareholder in Philippine Long Distance Telephone Company (PLDT), a public utility. First Pacific Company Limited, a foreign entity, through its subsidiary Metro Pacific Assets Holdings, Inc. (MPAH), sought to acquire these government shares in PTIC. This impending acquisition raised concerns about potentially breaching the constitutional 60-40 Filipino-foreign ownership requirement in PLDT, as First Pacific already had substantial interests in PTIC, and consequently, in PLDT. | The term "capital" in Section 11, Article XII of the 1987 Constitution, pertaining to the 60% Filipino ownership requirement for public utilities, refers only to shares of stock that are entitled to vote in the election of directors, not the total outstanding capital stock which includes non-voting preferred shares. |
Constitutional Law I |
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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 |
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. | 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. |
Civil Procedure I |
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Navarro vs. Ermita (12th April 2011) |
AK213242 648 SCRA 400 , 663 Phil. 546 , G.R. No. 180050 |
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. | 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. |
Statutory Construction |
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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 |
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. | 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. |
Constitutional Law I Constitutional Law II Philosophy of Law Statutory Construction Equal Protection |
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Yusay vs. Court of Appeals (6th April 2011) |
AK797825 647 SCRA 269 , 662 Phil. 634 , G.R. No. 156684 |
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. | 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. |
Constitutional Law II |
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General vs. Urro (29th March 2011) |
AK549891 646 SCRA 567 , 662 Phil. 132 , G.R. No. 191560 |
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. | 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. |
Constitutional Law II |
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