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Benabaye vs. People

25th February 2015

ak922866
755 Phil. 145 , G.R. No. 203466
Primary Holding
An employee who receives money or property on behalf of an employer acquires only material or physical possession, not juridical possession; thus, the misappropriation or conversion of such money or property by the employee constitutes theft, not Estafa under Article 315, paragraph 1(b) of the Revised Penal Code.
Background
The case arose from an internal audit conducted by Siam Bank Inc., Iligan City Branch, which uncovered alleged fraud and irregularities in its loan transactions. Specifically, the audit revealed non-remittance of loan payments collected by its employees, including petitioner Cherry Ann Benabaye, who was a Loans Bookkeeper.
Criminal Law II
Theft

Department of Environment and Natural Resources (DENR) vs. United Planners Consultants, Inc

23rd February 2015

ak719310
751 SCRA 389 , 754 Phil. 513 , G.R. No. 212081
Primary Holding
The CA correctly dismissed DENR’s petition for certiorari as it was filed out of time under the Special ADR Rules, and the confirmed arbitral award’s execution remains subject to COA’s approval.
Background
DENR entered a consultancy agreement with UPCI in 1993 but paid only 47% of the contract price. After UPCI sued for non-payment, the case was referred to arbitration, resulting in a monetary award. DENR challenged the award’s confirmation and execution but failed to follow procedural rules.
Statutory Construction

Leus vs. St. Scholastica's College Westgrove

28th January 2015

ak411346
748 SCRA 378 , 752 PHIL. 186 , G.R. No. 187226
Primary Holding
Pre-marital sexual relations between two consenting adults who have no impediment to marry each other, and consequently conceiving a child out of wedlock, gauged from a purely public and secular view of morality, does not amount to disgraceful or immoral conduct under Section 94(e) of the 1992 Manual of Regulations for Private Schools (MRPS).
Background
This case revolves around the dismissal of a non-teaching staff member from a Catholic school after becoming pregnant out of wedlock, leading to a legal battle over whether such circumstance constitutes valid grounds for termination of employment.
Philosophy of Law

Kalaw vs. Fernandez

14th January 2015

ak745229
745 SCRA 512 , G.R. No. 166357
Primary Holding
The determination of psychological incapacity under Article 36 of the Family Code should be based on the totality of evidence presented in each case, and courts must consider expert opinions as decisive evidence, even without a personal examination of the subject, provided the opinion is based on verifiable facts on record. A rigid and overly strict application of the Molina guidelines should be avoided, as the concept of psychological incapacity is not meant to be a "strait-jacket" but should be applied with resiliency to give a "decent burial to a stillborn marriage." Psychological incapacity may be proven to exist in either or both spouses, and if established, justifies the declaration of the marriage as null and void.
Background
Valerio E. Kalaw (petitioner) and Ma. Elena Fernandez (respondent) were married on November 4, 1976. The petitioner filed a complaint to declare their marriage null and void on the ground of respondent's psychological incapacity. He alleged that her constant mahjong sessions, neglect of their children, infidelity, and obsessive need for attention were manifestations of a Narcissistic Personality Disorder that rendered her incapable of performing her essential marital duties. The respondent denied these allegations and countered that it was the petitioner who was psychologically incapacitated.
Persons and Family Law
Article 36 of the Family Code

Del Socorro vs. Van Wilsem

10th December 2014

ak580817
749 Phil. 823 , G.R. No. 193707
Primary Holding
A foreign national can be held criminally liable under R.A. No. 9262 for unjustly refusing or failing to give financial support to his minor child, even if his national law might not impose such an obligation, if said foreign law is not proven in Philippine courts (invoking processual presumption) or if applying such foreign law would be contrary to Philippine public policy or work an injustice to a resident child.
Background
Petitioner Norma A. Del Socorro, a Filipina, and respondent Ernst Johan Brinkman Van Wilsem, a Dutch national, were married in Holland and had a son, Roderigo. Their marriage was dissolved by a divorce decree in Holland. Petitioner and her son returned to the Philippines. Respondent, who also came to the Philippines and remarried, allegedly failed to provide the promised monthly support to their son.
Criminal Law II
VAWC

Fuji Television Network, Inc. vs. Espiritu

3rd December 2014

ak058947
744 SCRA 31 , G.R. Nos. 204944-45
Primary Holding
An employer has the burden to prove that a person it pays for services is an independent contractor; otherwise, the person is presumed to be a regular employee. Termination of an employee due to disease is only valid if a competent public health authority certifies that the disease is incurable within six months and that continued employment is prejudicial to health, and such termination must comply with due process.
Background
In 2005, Fuji Television Network, Inc. engaged Arlene S. Espiritu as a news correspondent/producer for its Manila Bureau. Her employment was governed by a one-year fixed-term contract that was renewed annually for four years. In January 2009, Arlene was diagnosed with lung cancer and informed Fuji of her condition. Subsequently, Fuji's management told her that they would have a problem renewing her contract due to her illness, despite her insistence that she was still fit to work. This led to a dispute over the nature of her employment and the legality of the non-renewal of her contract.
Civil Procedure II

Commissioner of Internal Revenue vs. BASF Coating + Inks Phil., Inc

26th November 2014

ak919594
743 SCRA 113 , 748 Phil. 760 , G.R. No. 198677
Primary Holding
The BIR’s right to assess deficiency taxes against BASF for 1999 prescribed under the three-year statutory period under the National Internal Revenue Code (NIRC). The Formal Assessment Notice (FAN) was invalid because it was sent to BASF’s former address despite the BIR’s documented awareness of its new location.
Background
BASF dissolved on March 31, 2001, and relocated to Calamba, Laguna. The BIR issued a FAN for 1999 tax deficiencies on January 17, 2003, but mailed it to BASF’s old Las Piñas address. BASF protested the assessment, arguing prescription and lack of valid notice. The CTA and CTA En Banc ruled in favor of BASF, prompting the BIR to appeal to the Supreme Court.
Statutory Construction

Zuñiga-Santos vs. Santos-Gran

8th October 2014

ak127777
738 SCRA 33 , 745 Phil. 171 , G.R. No. 197380
Primary Holding
An amended complaint that fails to sufficiently allege ultimate facts establishing the plaintiff's right to the subject properties and the invalidity of their transfer, and which seeks reconveyance based on an implied trust more than ten years after the registration of the disputed titles in the defendant's name, is dismissible for failure to state a cause of action and for prescription.
Background
The case originated from a dispute over three parcels of land allegedly owned by petitioner Eliza Zuñiga-Santos. Petitioner claimed these properties were fraudulently transferred to respondent Maria Divina Gracia Santos-Gran, purportedly the petitioner's daughter through a forged birth certificate, by petitioner's second husband, Lamberto C. Santos, using void and voidable documents, specifically a Deed of Sale that could not initially be located.
Civil Procedure I

Arigo vs. Swift

16th September 2014

ak295910
735 SCRA 102 , 743 Phil. 8 , G.R. No. 206510
Background
The grounding of the USS Guardian on Tubbataha Reef, a UNESCO World Heritage Site and protected area under Philippine law, caused significant environmental damage. The incident sparked public outrage and raised questions about the US military presence in Philippine waters under the Visiting Forces Agreement (VFA). Various environmental and activist groups filed a petition for a Writ of Kalikasan, seeking accountability and compensation for the reef damage.
Constitutional Law I

Pulgar vs. The Regional Trial Court of Mauban, Quezon, Br. 64, et al.

10th September 2014

ak670551
734 SCRA 527 , 742 Phil. 557 , G.R. No. 157583
Primary Holding
Jurisdiction over an intervention is contingent upon the court's jurisdiction over the main action; an intervention is ancillary and supplemental, not an independent proceeding, and thus ceases to exist when the main case is dismissed, particularly on jurisdictional grounds.
Background
The dispute originated from the Municipal Assessor of Mauban, Quezon's assessment of substantial realty taxes on the Mauban Plant, a power generation facility owned by QPL, based on a market value of approximately P29.6 billion. QPL contested this assessment, declaring a much lower value of about P15 billion, and tendered a significantly smaller amount as its first quarter installment for realty taxes, which was rejected by the Municipal Assessor.
Civil Procedure I
Intervention

SM Land, Inc. vs. Bases Conversion and Development Authority

13th August 2014

ak100107
733 SCRA 68 , 756 PHIL. 354 , G.R. No. 203655
Primary Holding
Administrative issuances duly promulgated pursuant to delegated rule-making power, such as the NEDA JV Guidelines issued under presidential directives (EO 109, EO 109-A, EO 423), have the force and effect of law and are binding on the government agencies covered, which cannot unilaterally deviate from the mandatory procedures therein, like the competitive challenge process following successful negotiation of an unsolicited proposal.
Background
The dispute originated from an unsolicited proposal submitted by SMLI to BCDA for the development of the Bonifacio South Property through a joint venture. After negotiations, BCDA accepted the proposal's terms and conditions and issued a Certification of Successful Negotiations (CSN), agreeing to subject SMLI's proposal to a competitive challenge (Swiss Challenge) as outlined in the NEDA JV Guidelines and the agreed Terms of Reference (TOR). Subsequently, BCDA unilaterally cancelled the competitive challenge process, intending to subject the property to public bidding instead, prompting SMLI to file a petition.
Civil Procedure I
Intervention

People vs. Cogaed

30th July 2014

ak442715
740 Phil. 212 , G.R. No. 200334
Primary Holding
Evidence obtained through a warrantless search based merely on an unverified tip from an informant or a third party's suspicion, without independent observation of suspicious activity by the police officer establishing a genuine reason, does not constitute a valid "stop and frisk" search, and such illegally seized evidence is inadmissible under the exclusionary rule.
Background
The case arose within the context of law enforcement efforts against illegal drug trafficking, specifically involving the transportation of marijuana in the province of La Union. Police acted based on a text message from an unidentified civilian informant regarding the transport of marijuana by a named individual, leading to the establishment of a checkpoint and the subsequent apprehension and search of the accused.
Constitutional Law II
Searches and Seizures

Araullo vs. Aquino

1st July 2014

ak306263
728 SCRA 1 , 737 Phil. 457 , G.R. No. 209287 , G.R. NO. 209135 , G.R. NO. 209136 , G.R. NO. 209155 , G.R. NO. 209164 , G.R. NO. 209260 , G.R. NO. 209442 , G.R. NO. 209517 , G.R. NO. 209569
Primary Holding
The Supreme Court issued a ruling declaring several aspects of the DAP (Disbursement Acceleration Program) unconstitutional, including: the withdrawal of unobligated allotments and their designation as savings before the fiscal year's end, the cross-border transfers of savings to offices outside the Executive branch, and the use of savings to fund programs, activities, or projects not covered by the GAA (General Appropriations Act). In applying the Operative Fact Doctrine, the Court established that while projects already implemented under the DAP in good faith would remain intact, the officials responsible for these actions could still be held accountable.
Background
The Disbursement Acceleration Program (DAP) was a mechanism introduced by the Department of Budget and Management (DBM) under Secretary Florencio Abad. It allowed the executive branch to pool savings from various government agencies and realign them to other projects to accelerate economic growth. However, petitioners argued that it violated the constitutional power of Congress over appropriations.
Constitutional Law I Persons and Family Law Philosophy of Law Statutory Construction

People vs. Jumawan

21st April 2014

ak373008
722 SCRA 108 , 733 Phil. 102 , G.R. No. 187495
Primary Holding
R.A. No. 8353, the Anti-Rape Law of 1997, unequivocally criminalizes marital rape, and the archaic doctrine of irrevocable implied consent to sexual intercourse within marriage is rejected; therefore, a husband can be convicted of raping his wife if the act is committed through force, threat, or intimidation, just like any other perpetrator, without requiring different elements of the crime or standards of proof.
Background
The accused-appellant, Edgar Jumawan, and the private complainant, KKK, were married in 1975, raised four children, and established several businesses primarily managed by KKK. While their conjugal intimacy was initially fulfilling, the accused-appellant reportedly became sexually brutal starting in 1997, foregoing foreplay and causing physical pain, leading KKK to resist, which resulted in threats. In 1998, quarrels increased, often initiated by the accused-appellant complaining about KKK's preoccupation with their businesses' financial problems and her alleged failure to attend to him, stating a woman's place was at home and in bed.
Criminal Law II
Rape

Imbong vs. Ochoa Jr.

8th April 2014

ak609982
721 SCRA 146 , 732 Phil. 1 , G.R. No. 204819 , G.R. No. 204934 , G.R. No. 204957 , G.R. No. 204988 , G.R. No. 205003 , G.R. No. 205043 , G.R. No. 205138 , G.R. No. 205478 , G.R. No. 205491 , G.R. No. 205720 , G.R. No. 206355 , G.R. No. 207111 , G.R. No. 207172 , G.R. No. 207563
Primary Holding
The Supreme Court declared certain provisions of the RH Law and its IRR unconstitutional, specifically those related to abortifacients as redefined by the IRR, restrictions on conscientious objectors, lack of parental or spousal consent in specific situations, and limitations on health facilities operated by religious groups. However, the majority of the RH Law was upheld as constitutional.
Background
The Responsible Parenthood and Reproductive Health Act of 2012 (RH Law) was enacted to address population growth and improve reproductive health in the Philippines. It mandates government provision of reproductive health services and supplies, including contraceptives, and requires sex education in schools. The law generated significant controversy and strong opposition, particularly from religious groups. Shortly after its enactment, various groups filed petitions challenging its constitutionality.
Constitutional Law I Constitutional Law II Philosophy of Law

Republic vs. De Guzman Vda. de Joson

10th March 2014

ak697117
728 Phil. 550 , 718 SCRA 228 , G.R. No. 163767
Primary Holding
The application for land registration is denied because the applicant failed to discharge the burden of proving that the subject land is alienable and disposable land of the public domain, a prerequisite for registration under Section 14(1) of the Property Registration Decree.
Background
Rosario de Guzman Vda. de Joson applied for land registration based on her and her predecessors-in-interest's alleged open, continuous, exclusive, and notorious possession and occupation of the land since 1926. The Republic opposed, arguing the land was unclassified forest land and not subject to private appropriation. The CFI and CA ruled in favor of De Joson, but the Republic appealed to the Supreme Court.
Property and Land Law

Crisologo vs. JEWM Agro-Industrial Corporation

3rd March 2014

ak211551
717 SCRA 644 , G.R. No. 196894
Primary Holding
Persons whose liens are annotated on a certificate of title are indispensable parties in any action for the cancellation of those liens; failure to implead them renders all court proceedings on the matter null and void for want of authority to act.
Background
The controversy originated from several collection cases filed against So Keng Kok, the original owner of two parcels of land. Various creditors, including the petitioners Spouses Crisologo and the respondent JEWM's predecessor-in-interest, had their respective levies annotated on the titles of these properties. JEWM's predecessor acquired the properties through a compromise agreement and subsequently sold them to JEWM. When JEWM obtained new titles, the annotations in favor of other creditors, including the Spouses Crisologo, remained.
Civil Procedure II

Pryce Corporation vs. China Banking Corporation

18th February 2014

ak989956
716 SCRA 207 , 727 Phil. 1 , G.R. No. 172302
Primary Holding
The Supreme Court ruled that the principle of res judicata applied, affirming the validity of the rehabilitation court’s order approving Pryce Corporation’s rehabilitation plan. The Court also ruled that the Interim Rules of Procedure on Corporate Rehabilitation do not require a hearing before issuing a stay order.
Background
Pryce Corporation filed for corporate rehabilitation in 2004. The Regional Trial Court (RTC) of Makati found the petition sufficient and issued a stay order. The rehabilitation receiver submitted an amended plan, which the RTC approved. China Banking Corporation (China Bank) and Bank of the Philippine Islands (BPI) challenged the approval, leading to conflicting rulings in the Court of Appeals. The Supreme Court resolved the issue in favor of Pryce Corporation.
Philosophy of Law

Disini vs. Secretary of Justice

11th February 2014

ak238408
727 Phil. 28 , G.R. No. 203335 , G.R. No. 203299 , G.R. No. 203306 , G.R. No. 203359 , G.R. No. 203378 , G.R. No. 203391 , G.R. No. 203407 , G.R. No. 203440 , G.R. No. 203453 , G.R. No. 203454 , G.R. No. 203469 , G.R. No. 203501 , G.R. No. 203501 , G.R. No. 203515 , G.R. No. 203518
Primary Holding
The Cybercrime Prevention Act of 2012 (R.A. 10175) is constitutional in its general aim to regulate and punish cybercrimes, but specific provisions that unduly curtail fundamental rights, such as certain aspects of online libel, unsolicited commercial communications, real-time collection of traffic data without a warrant, and the power of the Department of Justice to restrict or block access to computer data, are unconstitutional.
Background
The proliferation of internet use and the rise of cyberspace activities brought about new avenues for communication, commerce, and information dissemination, but also new forms of criminal behavior collectively termed "cybercrimes." Recognizing the need to address these emerging threats, the Philippine government enacted Republic Act No. 10175, the Cybercrime Prevention Act of 2012, to define and penalize various offenses committed through or with the use of computer systems, and to provide for their prevention, investigation, and prosecution.
Constitutional Law II Criminal Law II Philosophy of Law Statutory Construction
Police Power; Freedom of Expression, Libel, and Cyberlibel

Manila Memorial Park, Inc. vs. Secretary of the Department of Social Welfare and Development

3rd December 2013

ak580749
711 SCRA 302 , 722 Phil. 538 , G.R. No. 175356
Primary Holding
The Supreme Court held that the 20% senior citizen discount mandated by RA 7432, as amended by RA 9257, and the corresponding tax deduction scheme are a valid exercise of the State's police power and do not constitute an unconstitutional taking of private property requiring just compensation.
Background
Manila Memorial Park, Inc. and La Funeraria Paz-Sucat, Inc. challenged the constitutionality of the tax deduction scheme implemented for senior citizen discounts, claiming it violates the constitutional provision against taking private property for public use without just compensation.
Constitutional Law II

Republic vs. Bacas

20th November 2013

ak418209
710 SCRA 411 , 721 Phil. 808 , G.R. No. 182913
Primary Holding
The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, holding that the Land Registration Court lacked jurisdiction to register inalienable public land, specifically land within a military reservation, and that the land titles obtained through fraudulent applications are void ab initio and must be cancelled.
Background
President Quezon issued Proclamation No. 265 in 1938, reserving land for military purposes, creating Camp Evangelista. Despite this, the Bacases and Chabons filed separate land registration applications in 1964 and 1974, respectively, for parcels within the reservation. The Land Registration Court granted their applications, leading to Original Certificates of Title. The Republic then filed actions to annul these titles.
Property and Land Law

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
Primary Holding
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.
Background
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."
Constitutional Law I Constitutional Law II Statutory Construction

Consolidated Industrial Gases, Inc. vs. Alabang Medical Center

13th November 2013

ak886820
721 Phil. 155 , G.R. No. 181983
Primary Holding
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.
Background
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.
Obligations and Contracts

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
Primary Holding
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.
Background
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.
Statutory Construction

Heirs of Mario Malabanan vs. Republic of the Philippines

3rd September 2013

ak741804
704 SCRA 561 , 717 Phil. 141 , G.R. No. 179987
Primary Holding
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.
Background
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.
Property and Land Law

Lihaylihay vs. People

31st July 2013

ak161655
702 SCRA 755 , G.R. No. 191219
Primary Holding
Public officers who certify and approve documents for non-existent purchases through evident bad faith, despite glaring irregularities such as tampered dates and incomplete certifications, commit a violation of Section 3(e) of RA 3019, resulting in undue injury to the government; the Arias doctrine does not apply where circumstances demand higher circumspection from approving officers.
Background
The case arose from a Commission on Audit special audit report revealing irregularities in PNP procurement, prompting an internal PNP investigation into alleged "ghost" purchases of combat, clothing, and individual equipment (CCIE) worth P133,000,000 from the PNP Service Store System to the PNP General Services Command, leading to charges against multiple PNP officers for corrupt practices under RA 3019.
Civil Procedure II

Chingkoe vs. Republic

13th July 2013

ak079924
702 SCRA 677 , 715 Phil. 651 , G.R. No. 183608
Primary Holding
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.
Background
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.
Civil Procedure I
Pre-trial

Capili vs. People

3rd July 2013

ak509180
G.R. No. 183805 , 700 SCRA 443
Primary Holding
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.
Background
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.
Persons and Family Law
Prejudicial Question

Fujiki vs. Marinay

26th June 2013

ak267379
700 SCRA 69 , G.R. No. 196049
Primary Holding
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.
Background
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.
Persons and Family Law
Article 15, Civil Code

Hing vs. Choachuy

26th June 2013

ak967276
699 SCRA 667 , G.R. No. 179736
Primary Holding
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.
Background
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.
Persons and Family Law
Article 26(1) of the Civil Code

Garcia vs. Drilon

25th June 2013

ak592766
699 SCRA 352 , 712 Phil. 44 , G.R. No. 179267
Primary Holding
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.
Background
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.
Constitutional Law II Criminal Law II
Equal Protection, VAWC

Reblora vs. Armed Forces of the Philippines

18th June 2013

ak765347
698 SCRA 727 , G.R. No. 195842
Primary Holding
Decisions of the Commission on Audit (COA) are reviewable by the Supreme Court not through an appeal by certiorari under Rule 45, but through a special civil action for certiorari under Rule 64, which limits the scope of review to errors of jurisdiction or grave abuse of discretion. Furthermore, under Presidential Decree No. 1638, prior civilian government service is included in the computation of a military officer's "active service," which can trigger the conditions for compulsory retirement (attaining 56 years of age or 30 years of active service, whichever is later) at an earlier date.
Background
The petitioner, a retired military officer, had rendered service as a civilian employee in the Department of the Interior and Local Government (DILG) before joining the Philippine Navy. Upon his retirement, a dispute arose regarding the computation of his retirement benefits. The AFP calculated his benefits based only on his actual military service, excluding his prior civilian service. The petitioner contested this, believing his civilian service should be added to his military service for a higher benefit, leading him to seek redress from the Commission on Audit.
Civil Procedure II
Rule 45

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
Primary Holding
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.
Background
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.
Persons and Family Law
Article 2 and 8, Civil Code

Royal Plant Workers Union vs. Coca-Cola Bottlers Philippines, Inc.-Cebu Plant

15th April 2013

ak849198
696 SCRA 357 , G.R. No. 198783
Primary Holding
The removal of chairs for bottling operators is a valid exercise of management prerogative when done in good faith to improve business efficiency and safety, especially when compensated by other measures like adjusted work schedules; the long-term provision of such chairs does not ripen into a vested right or a benefit protected under the non-diminution rule of Article 100 of the Labor Code, which applies to monetary benefits or privileges with monetary equivalents.
Background
For over three decades, Coca-Cola Bottlers Philippines, Inc. (CCBPI) provided chairs for its bottling operators at its Cebu plant. In September 2008, pursuant to a national directive aligned with its "I Operate, I Maintain, I Clean" program, CCBPI removed these chairs. The company reasoned that the operators' tasks required constant movement and that removing the chairs would enhance efficiency and prevent operators from sleeping on the job, thereby reducing the risk of accidents. This unilateral decision by management prompted the Royal Plant Workers Union (ROPWU) to initiate a grievance, which eventually led to the legal dispute.
Civil Procedure II

Eagleridge Development Corporation vs. Cameron Granville 3 Asset Management, Inc.

10th April 2013

ak544596
695 SCRA 714 , 708 Phil. 693 , G.R. No. 204700
Primary Holding
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.
Background
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.
Civil Procedure I
Discovery

Callo-Claridad vs. Esteban

20th March 2013

ak496970
694 SCRA 185 , G.R. No. 191567
Primary Holding
The determination of probable cause for filing a criminal information is an executive function exclusively within the competence of the Secretary of Justice, and courts cannot interfere absent a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction; in this case, no such abuse occurred as the circumstantial evidence was incompetent and insufficient to establish probable cause for charging the respondents with murder.
Background
The case arises from the unsolved stabbing death of 17-year-old Chase Callo Claridad on February 27, 2007, in the carport of an uninhabited house in Ferndale Homes, Quezon City, amid suspicions of involvement by respondent Philip Esteban, a friend of the victim, and his mother Teodora, fueled by observations of their vehicles at the scene, prior parking disputes in the subdivision, and the family's subsequent non-cooperation with investigators, though no direct evidence or motive linked them to the crime.
Civil Procedure II

Bongalon vs. People

20th March 2013

ak835327
694 SCRA 12 , 707 Phil. 11 , G.R. No. 169533
Primary Holding
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.
Background
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.
Criminal Law II
Slight Physical Injuries, Child Abuse

Anchor Savings Bank vs. Furigay

13th March 2013

ak235702
706 Phil. 378 , G.R. No. 191178
Primary Holding
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.
Background
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.
Obligations and Contracts

Cruz vs. Atty. Gruspe

13th March 2013

ak238573
706 Phil. 406 , G.R. No. 191431
Primary Holding
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.
Background
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.
Obligations and Contracts

Fernando vs. St. Scholastica's College

12th March 2013

ak827333
693 SCRA 141 , 706 Phil. 138 , G.R. No. 161107
Primary Holding
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.
Background
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.
Constitutional Law II

Pilar Development Corporation vs. Dumadag

11th March 2013

ak661257
693 SCRA 96 , 706 Phil. 93 , G.R. No. 194336
Primary Holding
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.
Background
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.
Property and Land Law

Civil Service Commission vs. Pililla Water District

5th March 2013

ak305171
705 Phil. 378 , G.R. No. 190147
Primary Holding
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.
Background
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.
Constitutional Law I

Dayao vs. Commission on Elections

29th January 2013

ak885502
689 SCRA 412 , 702 Phil. 348 , G.R. No. 193643
Primary Holding
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.
Background
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.
Statutory Construction

Giron vs. Commission on Elections

22nd January 2013

ak774340
689 SCRA 97 , 702 Phil. 30 , G.R. No. 188179
Primary Holding
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.
Background
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.
Statutory Construction

Spouses Mamaril vs. The Boy Scout of the Philippines

14th January 2013

ak436103
701 Phil. 400 , G.R. No. 179382
Primary Holding
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.
Background
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.
Obligations and Contracts

Tan, Jr. vs. Matsuura

9th January 2013

ak725361
688 SCRA 263 , G.R. No. 179003 , G.R. No. 195816
Primary Holding
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.
Background
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.
Civil Procedure II

University of the Philippines vs. Dizon

23rd August 2012

ak560575
679 SCRA 54 , 693 Phil. 226 , G.R. No. 171182
Primary Holding
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.
Background
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.
Constitutional Law I

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
Primary Holding
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.
Background
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.
Constitutional Law I

Madriaga, Jr. vs. China Banking Corporation

25th July 2012

ak464752
677 SCRA 560 , 691 Phil. 770 , G.R. No. 192377
Primary Holding
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.
Background
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.
Constitutional Law II

Chavez vs. Judicial and Bar Council

17th July 2012

ak960332
676 SCRA 579 , 691 Phil. 173 , G.R. No. 202242
Primary Holding
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.
Background
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.
Statutory Construction