There are 510 results on the current subject filter
Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
---|---|---|---|---|
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 |
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 | A contract of sale cannot be annulled or rescinded for alleged fraud or default if the party seeking such relief fails to establish by full, clear, and convincing evidence the existence of dolo causante or a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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
Alauya vs. Limbona (22nd March 2011) |
AK081419 646 SCRA 1 , 661 Phil. 380 , A.M. No. SCC-98-4 |
The case arose from complaints lodged with the Office of the Court Administrator (OCA) against Judge Casan Ali Limbona of the 10th Shari'a Circuit Court, Tamparan, Lanao del Sur. The complaints alleged chronic absenteeism and, more significantly, that the judge had filed a certificate of candidacy as a party-list nominee for the Development Foundation of the Philippines (DFP) in the May 11, 1998 elections while remaining an active member of the judiciary and continuing to receive his judicial salary. | A sitting judge who files a certificate of candidacy for an elective office violates the constitutional prohibition against partisan political activity by civil servants, commits gross misconduct and dishonesty by continuing to perform judicial functions and receive salary thereafter, and is consequently deemed unfit to remain in the judiciary, warranting dismissal from service effective from the date of filing the CoC. |
Constitutional Law I |
Air Transportation Office vs. Ramos (23rd February 2011) |
AK801657 644 SCRA 36 , 659 Phil. 104 , G.R. No. 159402 |
The Ramos spouses discovered that part of their land was being used by the ATO for the Loakan Airport. They agreed to sell the land to the ATO, but the ATO failed to pay. The Ramos spouses filed a lawsuit, and the lower courts ruled in their favor. The ATO appealed, invoking state immunity. | The ATO, as an agency engaged in proprietary functions, is not immune from suit and must compensate the Ramos spouses for the land used for the Loakan Airport. |
Philosophy of Law |
Gutierrez vs. The House of Representatives Committee on Justice, Hontiveros-Baraquel, et al. (15th February 2011) |
AK949647 643 SCRA 198 , 660 Phil. 271 , G.R. No. 193459 |
Gutierrez faced two impeachment complaints filed 11 days apart in 2010. The House referred both to its Committee on Justice. Gutierrez argued this violated the constitutional prohibition against multiple proceedings within one year. | Impeachment proceedings are “initiated” when a complaint is filed and referred to the House Committee on Justice, triggering the constitutional one-year bar against subsequent proceedings. |
Statutory Construction |
Mactan-Cebu International Airport Authority vs. Heirs of Estanislao Miñoza (2nd February 2011) |
AK335523 641 SCRA 520 , 656 Phil. 537 , G.R. No. 186045 |
The dispute originated from the sale of two lots (Lots 986 and 991-A) owned by the late Estanislao Miñoza to the National Airports Corporation (NAC), MCIAA's predecessor, in the late 1940s/early 1950s for the Lahug Airport expansion project, which allegedly included an assurance that the original owners' heirs could repurchase the lots if they were no longer needed for that purpose. The airport expansion did not proceed, leading the purported heirs (represented by Leila Hermosisima) to seek reconveyance based on the alleged buy-back option over forty years later. | Intervention under Rule 19 requires a legal interest that is actual, substantial, material, direct, and immediate in the matter being litigated; it is not proper when it seeks to inject an independent controversy, would unduly delay or prejudice the adjudication of the original parties' rights, or change the nature of the action, especially when the intervenor's rights can be fully protected in a separate proceeding. |
Civil Procedure I Intervention |
Bayan Muna vs. Romulo, et al. (1st February 2011) |
AK939314 641 SCRA 244 , 656 Phil. 246 , G.R. No. 159618 |
The Rome Statute established the International Criminal Court (ICC) to prosecute individuals for genocide, crimes against humanity, war crimes, and crimes of aggression. The Philippines signed the Rome Statute on December 28, 2000, but had not ratified it at the time of the petition. The United States, not a signatory to the Rome Statute, proposed a Non-Surrender Agreement to the Philippines to protect its nationals from prosecution by international tribunals, which was accepted by the Philippines through an exchange of notes. This agreement became the subject of the legal challenge. | An executive agreement, such as the RP-US Non-Surrender Agreement, entered into by the President pursuant to their foreign affairs powers, is valid and binding without Senate concurrence, and does not unconstitutionally derogate from the Philippines' obligations under international law, including those potentially arising from a signed but unratified treaty like the Rome Statute. |
Constitutional Law I Philosophy of Law |
Liban, et al. vs. Gordon (18th January 2011) |
AK626554 654 Phil. 680 , G.R. No. 175352 |
The original case involved a petition to declare Senator Richard J. Gordon as having forfeited his Senate seat for concurrently holding the office of Chairman of the PNRC Board of Governors, allegedly in violation of Section 13, Article VI of the 1987 Constitution. In its Decision dated July 15, 2009, the Supreme Court held that Gordon did not forfeit his seat because the office of PNRC Chairman is not a government office or an office in a government-owned or controlled corporation (GOCC). However, the same Decision declared void certain sections of the PNRC Charter (R.A. No. 95, as amended) for creating the PNRC as a private corporation through a special law and ruled that PNRC should incorporate under the Corporation Code if it wishes to be a private corporation. | The Philippine National Red Cross (PNRC) is a *sui generis* entity, not strictly a private corporation within the contemplation of the constitutional prohibition against the creation of private corporations by special law (Article XII, Section 16 of the 1987 Constitution). Therefore, Republic Act No. 95, as amended (the PNRC Charter), is valid and constitutional in its entirety. The Court should not rule on constitutional questions unless they are the very *lis mota* of the case and were raised by the parties. |
Constitutional Law I |
Heirs of Domingo Valientes v. Hon. Reinerio (Abraham) B. Ramas, et al. (15th December 2010) |
AK555963 653 Phil. 111 , G.R. No. 157852 |
The dispute originated from a parcel of land initially owned by Domingo Valientes under an Original Certificate of Title (OCT). In 1939, Valientes mortgaged the land to the spouses Belen. Later, the Belens allegedly used a forged "VENTA DEFINITIVA" to obtain a Transfer Certificate of Title (TCT No. T-5,427) in their names in 1969. Valientes' heirs attempted but failed to retrieve the property in the 1950s and filed an adverse claim in 1970. Upon the Belens' death, their heirs sold the property to respondent Vilma Minor, who currently possesses it. This led to conflicting legal actions initiated by both Minor (to cancel the adverse claim) and the Valientes heirs (to cancel the TCT and recover the property). | An action for reconveyance based on an implied or constructive trust, arising from property acquired through fraud (such as a forged deed leading to the issuance of a Torrens title), prescribes in ten (10) years from the date of the issuance of the certificate of title, if the plaintiff is not in possession of the property. |
Civil Procedure I Motion |
Ivler vs. Hon. Judge Modesto-San Pedro, et al. (17th November 2010) |
AK093224 649 Phil. 478 , G.R. No. 172716 |
The case arose from a vehicular collision in August 2004 involving petitioner Jason Ivler and the vehicle of respondent Evangeline Ponce and her husband, Nestor C. Ponce. This incident led to injuries to Evangeline Ponce, the death of Nestor C. Ponce, and damage to the Ponces' vehicle. | A prior conviction for a quasi-offense under Article 365 of the Revised Penal Code, such as Reckless Imprudence Resulting in Slight Physical Injuries, bars a subsequent prosecution for another quasi-offense, like Reckless Imprudence Resulting in Homicide and Damage to Property, if both arise from the same act of reckless imprudence, because reckless imprudence is a single offense and prosecuting its multiple consequences separately violates the constitutional right against double jeopardy. |
Criminal Law II Reckless Imprudence |
Espina vs. Zamora (21st September 2010) |
AK922354 631 SCRA 17 , 645 Phil. 269 , G.R. No. 143855 |
Prior to the enactment of R.A. 8762, Republic Act No. 1180 (Retail Trade Nationalization Act) absolutely prohibited foreign nationals from engaging in the retail trade business in the Philippines. R.A. 8762 was passed on March 7, 2000, expressly repealing R.A. 1180 and allowing foreign nationals to engage in the retail trade business under specified categories and conditions, thereby liberalizing this sector of the economy. | The Retail Trade Liberalization Act of 2000 (R.A. 8762) is constitutional; the general principles in Article II of the Constitution regarding national economy are not self-executing, and Article XII grants Congress the discretion to determine which areas of investment may be opened to foreign participation, making R.A. 8762 a valid exercise of legislative power to regulate trade in the interest of public welfare. |
Constitutional Law I Constitutional Law II Due Process |
Pormento vs. Estrada (31st August 2010) |
AK528121 629 SCRA 530 , 643 Phil. 735 , G.R. No. 191988 |
The case centered on the interpretation of the constitutional provision prohibiting presidential reelection, specifically as it applied to former President Joseph Estrada's attempt to run for president again in 2010, having previously served as president from 1998. | The Supreme Court dismissed the petition due to mootness, as there was no longer an actual case or controversy to resolve after Estrada lost the 2010 presidential election. |
Constitutional Law I |
Philippine Rural Reconstruction Movement (PRRM) vs. Pulgar (5th July 2010) |
AK143711 637 Phil. 244 , G.R. No. 169227 |
Virgilio Pulgar was the manager of PRRM's Tayabas Bay Field Office (TBFO). Following his reassignment to PRRM's central office, an investigation was conducted into alleged financial anomalies at the TBFO. The investigation report indicated missing or improperly accounted funds and the submission of fictitious receipts. Pulgar was asked to explain these findings. | Before an employer bears the burden of proving that a dismissal was for a valid or authorized cause, the employee must first establish by substantial evidence the fact of dismissal from service; bare allegations of constructive dismissal, uncorroborated by evidence, cannot be given credence. |
Constitutional Law I |
Lokin, Jr. vs. Commission on Elections (22nd June 2010) |
AK434539 621 SCRA 385 , 635 Phil. 372 , G.R. Nos. 179431-32 , G.R. No. 180443 |
CIBAC submitted its list of nominees for the 2007 elections, which included Lokin as the second nominee. Subsequently, CIBAC's president filed an amended list replacing Lokin and others with new nominees. COMELEC relied on Section 13 of Resolution No. 7804 to approve this substitution. Lokin challenged the substitution and sought to be proclaimed as CIBAC's second nominee. | The Supreme Court ruled that Section 13 of COMELEC Resolution No. 7804 was invalid to the extent it allowed a party to unilaterally change or substitute its nominees after submission of the list to the COMELEC. The statutory grounds for substitution under R.A. No. 7941 are exclusive. |
Statutory Construction |
Commissioner of Internal Revenue vs. Kudos Metal Corporation (5th May 2010) |
AK209769 620 SCRA 232 , 634 Phil. 314 , G.R. No. 178087 |
The BIR issued deficiency tax assessments against Kudos Metal Corporation for 1998 on September 26, 2003, after conducting an audit prompted by suspected tax fraud. The corporation contested these assessments, arguing they were issued beyond the three-year prescriptive period under the Tax Code. | The government’s right to assess taxes prescribed because the waivers executed to extend the three-year assessment period were invalid due to procedural defects. |
Statutory Construction |
Vinuya, et al. vs. The Hon. Executive Secretary Romulo, et al (28th April 2010) |
AK304437 633 Phil. 538 , G.R. No. 162230 |
During World War II, the Japanese Imperial Army established a system of "comfort women," forcibly recruiting and enslaving women from occupied territories, including the Philippines, for sexual servitude in military brothels. Petitioners are survivors of this system who have endured immense physical, psychological, and emotional suffering. Since 1998, they have sought assistance from the Philippine government to pursue their claims against Japan, but the Executive Department declined, citing the 1951 San Francisco Peace Treaty and the 1956 Reparations Agreement between the Philippines and Japan as having settled all war-related claims. | The Executive Department has the exclusive prerogative under domestic law to determine whether to espouse its nationals' claims against a foreign government, this being a political question involving foreign relations not subject to judicial review via certiorari, absent grave abuse of discretion. Furthermore, under contemporary international law, there is no binding obligation on the Philippines to espouse the petitioners' claims for reparations against Japan, as diplomatic protection is a sovereign right of the State, not a duty owed to its nationals. |
Constitutional Law I |
Fuentes vs. Roca (21st April 2010) |
AK735315 633 Phil. 9 , G.R. No. 178902 |
Sabina Tarroza sold a 358-square meter lot to her son, Tarciano T. Roca, in 1982. Tarciano did not immediately transfer the title to his name. In 1988, Tarciano, who was estranged from his wife Rosario Gabriel Roca, offered to sell this lot to petitioners Manuel and Leticia Fuentes. The property was conjugal, acquired during Tarciano and Rosario's marriage in 1950. | A sale of conjugal property made after the effectivity of the Family Code, without the written consent of the other spouse, is void, and the action to declare its inexistence does not prescribe; the heirs of the non-consenting spouse can bring such action. |
Obligations and Contracts |
Ang Ladlad LGBT Party vs. COMELEC (8th April 2010) |
AK675246 618 SCRA 32 , 632 Phil. 32 , G.R. No. 190582 |
The case arose from the COMELEC's refusal to accredit Ang Ladlad, an organization representing the lesbian, gay, bisexual, and transgender (LGBT) community, as a party-list organization eligible to participate in the Philippine legislative elections under Republic Act No. 7941 (Party-List System Act). | The COMELEC cannot disqualify a party-list applicant based on religious or moral grounds lacking a clear secular justification, as doing so violates the non-establishment clause, the equal protection clause, and the rights to freedom of expression and association; moral disapproval alone is not a legitimate state interest sufficient to justify infringing upon these fundamental rights. |
Constitutional Law II Philosophy of Law Equal Protection |
Sen. Aquino III, et al. vs. COMELEC, et al. (7th April 2010) |
AK469049 631 Phil. 595 , G.R. No. 189793 |
The 250,000 minimum population requirement for the creation of a legislative district, as stated in Article VI, Section 5(3) of the 1987 Constitution ("Each city with a population of at least two hundred fifty thousand, or each province, shall have at least one representative."), applies specifically to cities to be entitled to an initial representative, and does not apply as an indispensable minimum population for the creation or reapportionment of legislative districts within a province. | The 250,000 minimum population requirement for the creation of a legislative district, as stated in Article VI, Section 5(3) of the 1987 Constitution ("Each city with a population of at least two hundred fifty thousand, or each province, shall have at least one representative."), applies specifically to cities to be entitled to an initial representative, and does not apply as an indispensable minimum population for the creation or reapportionment of legislative districts within a province. |
Constitutional Law I |
Reyes-Mesugas vs. Reyes (22nd March 2010) |
AK071678 616 SCRA 345 , 630 Phil. 334 , G.R. No. 174835 |
Petitioner Anita Reyes-Mesugas and respondent Alejandro A. Reyes are siblings and heirs of Lourdes Aquino Reyes, who died intestate leaving several properties, including a lot covered by TCT No. 24475. Respondent initiated proceedings for the settlement of Lourdes' estate, which eventually led to a compromise agreement partitioning the estate among the heirs. | A notice of lis pendens annotated in connection with an estate settlement proceeding should be cancelled when the proceeding has terminated by virtue of a judicially approved compromise agreement, and the basis for its continued annotation is an alleged extraneous agreement that falls outside the limited jurisdiction of the probate court. |
Civil Procedure I |
Aldaba, et al. vs. COMELEC (15th March 2010) |
AK307550 629 Phil. 537 , G.R. No. 188078 |
Republic Act No. 9591 was enacted, creating a legislative district for the City of Malolos. This law was challenged, leading to a Supreme Court Decision on January 25, 2010, which presumably found the law unconstitutional. The respondent, COMELEC, filed a motion for reconsideration of this decision, arguing primarily that Congress's reliance on certain population data was a non-justiciable political question. | The Court held that the determination of compliance with constitutional requirements for creating legislative districts, including the authoritativeness and reliability of population indicators, is a justiciable question subject to judicial review, and that population certifications for such purposes must adhere to standards ensuring reliability, such as those outlined in Executive Order No. 135. |
Constitutional Law I |
Quinto, et al. vs. Commission on Elections (22nd February 2010) |
AK860874 627 Phil. 193 , G.R. No. 189698 |
The case arose from legal provisions requiring appointive public officials to be considered automatically resigned from their posts upon filing a certificate of candidacy for an elective office. These "resign-to-run" provisions were challenged by petitioners, leading to an initial Supreme Court decision declaring them unconstitutional. This prompted motions for reconsideration from the COMELEC and various intervenors, arguing for the validity of these provisions based on distinctions between elective and appointive officials and the need to maintain a non-partisan civil service. | The second proviso in the third paragraph of Section 13 of Republic Act No. 9369, Section 66 of the Omnibus Election Code, and Section 4(a) of COMELEC Resolution No. 8678, which provide that an appointive official is deemed ipso facto resigned from office upon the filing of a certificate of candidacy, are not unconstitutional and do not violate the equal protection clause or suffer from overbreadth. |
Constitutional Law I |
Funa vs. Exec. Sec. Ermita, et al. (11th February 2010) |
AK819913 626 Phil. 218 , G.R. No. 184740 |
The case arose from the President's designation of respondent Maria Elena H. Bautista, then DOTC Undersecretary for Maritime Transport, as Officer-in-Charge (OIC) of the Maritime Industry Authority (MARINA) on September 1, 2008, following the resignation of the MARINA Administrator. This designation was made in a concurrent capacity with her existing role as DOTC Undersecretary. | The designation of a Department Undersecretary (a deputy of a Cabinet Member) to concurrently serve as Officer-in-Charge of an attached agency, such as MARINA, is unconstitutional for violating Section 13, Article VII of the 1987 Constitution, which imposes a stricter prohibition against holding multiple offices on the President, Vice-President, Members of the Cabinet, and their deputies or assistants, allowing exceptions only when expressly provided in the Constitution itself. |
Constitutional Law I |
Intestate Estate of Manolita Gonzales Vda. De Carungcong vs. People, et al. (11th February 2010) |
AK055613 612 SCRA 272 , 626 Phil. 177 , G.R. No. 181409 |
Mediatrix Carungcong, administratrix of her mother Manolita’s estate, accused her brother-in-law William Sato of estafa for fraudulently inducing Manolita (blind and elderly) to sign a falsified Special Power of Attorney (SPA) to sell her properties. Lower courts dismissed the case based on Article 332’s exemption for relatives by affinity. | The Court reversed lower court rulings, holding that while affinity survives death, William Sato was not exempt from criminal liability for the complex crime of estafa through falsification. |
Statutory Construction |
Soriano vs. People (1st February 2010) |
AK193031 625 Phil. 33 , G.R. No. 162336 |
The Office of Special Investigation (OSI) of the Bangko Sentral ng Pilipinas (BSP) transmitted a letter with five affidavits to the Department of Justice (DOJ), alleging that Hilario P. Soriano, then president of the Rural Bank of San Miguel (Bulacan), Inc. (RBSM), orchestrated a fraudulent P8 million loan. The loan appeared in the name of spouses Enrico and Amalia Carlos, who denied applying for or receiving it. It was alleged that Soriano ordered, facilitated, and received the loan proceeds without board authorization or proper reporting, using an unsuspecting depositor's name. | A bank officer violates the DOSRI law (Section 83 of RA 337) when he acquires bank funds for his personal benefit, even if such acquisition was facilitated by a fraudulent loan application using a third party's name; such fraudulent acquisition does not negate the "indirect borrowing" and can concurrently constitute the crime of estafa through falsification of commercial documents, as the officer holds the funds in a fiduciary capacity and misappropriates them. |
Criminal Law II Estafa |
Sps. Tongson vs. Emergency Pawnshop Bula, Inc., et al. (15th January 2010) |
AK781820 624 Phil. 146 , G.R. No. 167874 |
The dispute arose from an agreement for the sale of a 364-square meter parcel of land in Davao City by the Spouses Tongson to Danilo R. Napala for P3,000,000. The transaction involved the execution of a Deed of Absolute Sale indicating a lower consideration, a partial cash payment, and a postdated check for the substantial balance, which was subsequently dishonored. | Fraud committed during the consummation stage of a contract of sale, such as the issuance of a worthless check for payment, does not constitute causal fraud (dolo causante) that vitiates consent and annuls the contract; rather, it is incidental fraud (dolo incidente) and a substantial breach of the buyer's obligation to pay, which entitles the seller to rescind the contract under Article 1191 of the Civil Code. |
Obligations and Contracts |
Office of the Solicitor General vs. Ayala Land (18th September 2009) |
AK679178 600 SCRA 617 , 616 Phil. 587 , G.R. No. 177056 |
The case arose from a Senate investigation into the legality of shopping malls charging parking fees. The Senate Committees concluded that charging parking fees was contrary to the National Building Code and recommended the Office of the Solicitor General (OSG) to enjoin the practice. Subsequently, the OSG filed a petition seeking to prohibit mall operators from collecting parking fees, arguing that the National Building Code impliedly mandates free parking. | Shopping mall operators cannot be legally compelled to provide free parking spaces to their patrons and the general public under the National Building Code and its Implementing Rules and Regulations. |
Constitutional Law II |
Pundaodaya vs. Commission on Elections, et al. (17th September 2009) |
AK663988 616 Phil. 167 , G.R. No. 179313 |
The case arose from the May 14, 2007 Synchronized National and Local Elections. Arsenio Densing Noble filed a Certificate of Candidacy for municipal mayor of Kinoguitan, Misamis Oriental, claiming 15 years of residency. Makil U. Pundaodaya, whose wife Judith Pundaodaya was also a mayoral candidate, filed a petition to disqualify Noble, alleging he lacked the residency qualification as he was actually a resident of Lapasan, Cagayan de Oro City. | To successfully effect a change of domicile for election purposes, a candidate must demonstrate by clear and positive proof: (1) an actual removal or an actual change of domicile; (2) a bona fide intention of abandoning the former place of residence and establishing a new one; and (3) definite acts which correspond with that purpose. Mere registration as a voter or voting in a few elections in a locality is not conclusive proof of domicile. |
Constitutional Law I |
Pobre vs. Defensor-Santiago (25th August 2009) |
AK600796 597 SCRA 1 , A.C. No. 7399 |
The case arose following Senator Miriam Defensor-Santiago's privilege speech on the Senate floor where she expressed extreme frustration and used insulting language directed at the Supreme Court and its members, particularly then Chief Justice Artemio Panganiban, after the Judicial and Bar Council (JBC) effectively excluded non-incumbent justices, like herself, from nomination for the position of Chief Justice. | Statements made by a Senator during a Senate speech, even if offensive and violative of a lawyer's ethical duties towards the courts, are covered by parliamentary immunity under Article VI, Section 11 of the Constitution and cannot be the basis for disciplinary action by the Court, although such immunity is intended for the benefit of the legislative institution and the people, not for personal attacks. |
Constitutional Law I |
Jacinto vs. People (13th July 2009) |
AK482641 610 Phil. 100 , G.R. No. 162540 |
The case originated from an employer-employee relationship where the petitioner, a collector for Mega Foam International Inc., was entrusted with receiving payments from customers. The dispute arose when a check payment collected by the petitioner was not remitted to the company but was instead deposited into an account linked to her family and was subsequently dishonored, leading to accusations of theft with grave abuse of confidence. | The taking of a worthless check, even with intent to gain and grave abuse of confidence, constitutes an impossible crime under Article 4, paragraph 2, in relation to Article 59 of the Revised Penal Code, because the inherent lack of value in the check at the time of taking makes the consummation of theft factually impossible. |
Criminal Law II Impossible Crime |
Matthews vs. Taylor (22nd June 2009) |
AK576607 590 SCRA 394 , 608 Phil. 193 , G.R. No. 164584 |
Benjamin Taylor, a British citizen, and Joselyn Taylor, a Filipina, were married. Joselyn purchased a property in Boracay using funds allegedly provided by Benjamin and developed it into a resort. Later, without Benjamin's express consent, Joselyn leased the property to Philip Matthews. Benjamin filed a case to nullify the lease agreement arguing it was void without his consent as the property was community property and his funds were used for its acquisition. | The Agreement of Lease between Joselyn Taylor and Philip Matthews is valid because Benjamin Taylor, the alien husband, has no legal right to nullify the lease on property exclusively owned by his Filipino wife. Aliens are constitutionally prohibited from owning land in the Philippines, thus Benjamin's claim of ownership or need for consent is without legal basis. |
Property and Land Law |
In Re: Petition for Adoption of Michelle P. Lim, et al. (21st May 2009) |
AK982276 588 SCRA 98 , 606 Phil. 82 , G.R. Nos. 168992-93 |
Monina and her late husband Primo Lim raised three abandoned children (including Michelle and Michael) as their own, simulating their births. After Primo’s death, Monina remarried an American citizen, Angel Olario. She later sought to legitimize the children’s status through adoption under RA 8552’s amnesty provision for simulated births. | Married individuals must adopt jointly under RA 8552; exceptions do not apply here, so the petitions were correctly dismissed. |
Statutory Construction |
Soriano vs. Laguardia (29th April 2009) |
AK448960 587 SCRA 79 , 605 Phil. 43 , G.R. No. 164785 |
Petitioner Eliseo F. Soriano, as host of the television program "Ang Dating Daan" aired on UNTV 37, made remarks on August 10, 2004, which included profane and offensive language directed at Michael M. Sandoval, a minister of Iglesia ni Cristo and host of a rival TV program. These utterances prompted complaints filed with the MTRCB by members of the Iglesia ni Cristo, leading to the challenged regulatory actions by the MTRCB. | The Movie and Television Review and Classification Board (MTRCB) has the authority, derived from PD 1986, to regulate television program content, including the power to impose preventive suspension and subsequent administrative sanctions like program suspension, when such content is deemed obscene or indecent, especially considering the pervasive nature of television and its accessibility to children; such regulation, when balanced against the State's compelling interest in protecting the youth, does not unconstitutionally abridge freedom of speech. |
Constitutional Law I |
Barangay Association for National Advancement and Transparency (BANAT) vs. COMELEC (21st April 2009) |
AK772249 604 Phil. 131 , G.R. No. 179271 |
The case arose from the May 14, 2007 national elections, specifically concerning the allocation of seats for party-list representatives in the House of Representatives. The COMELEC, acting as the National Board of Canvassers (NBC), applied the formula established in _Veterans Federation Party v. COMELEC_ (the "Panganiban formula" or "Veterans formula") to determine the winners and allocate seats. This application led to dissatisfaction among several party-list groups who believed the formula was unconstitutional and did not allow for the full 20% allocation of seats for party-list representatives as mandated by the Constitution. | The two percent threshold prescribed in Section 11(b) of R.A. No. 7941 is unconstitutional for the purpose of distributing *additional* party-list seats, as it makes it mathematically impossible to achieve the maximum number of available party-list seats and frustrates the constitutional mandate for proportional representation. A new four-step procedure for allocating party-list seats was established: (1) Rank parties from highest to lowest votes; (2) Parties receiving at least 2% of total votes get one guaranteed seat; (3) Additional seats are distributed proportionally based on total votes until all available seats are filled, disregarding fractional seats; (4) Each party is limited to a maximum of three seats. |
Constitutional Law I |
Deutsche Gesellschaft Für Technische Zusammenarbeit vs. Court of Appeals (16th April 2009) |
AK268315 585 SCRA 150 , 603 Phil. 150 , G.R. No. 152318 |
The case arose from a technical cooperation agreement between the Federal Republic of Germany and the Republic of the Philippines, initiated in 1971 and extended by subsequent arrangements. One such arrangement in 1999 concerned a project called Social Health Insurance--Networking and Empowerment (SHINE), designed to improve health care for Philippine families. The German government designated GTZ as its implementing agency for its contributions to the SHINE project, while the Philippines designated the Department of Health (DOH) and Philippine Health Insurance Corporation (Philhealth). | An entity claiming state immunity from suit, especially one described as a private company organized under foreign law even if state-owned, bears the burden of proving its entitlement to such immunity; failure to adduce evidence of its legal status under its parent country's law consenting to or restricting suit, or to secure an endorsement from the Department of Foreign Affairs, can lead to the denial of the claim for immunity. |
Constitutional Law I State Immunity |
Dr. Señeres vs. Commission on Elections, et al. (16th April 2009) |
AK746986 603 Phil. 552 , G.R. No. 178678 |
The case arose from an intra-party leadership dispute within Buhay Hayaan Yumabong (Buhay), a registered party-list organization, concerning who had the authority to nominate its representatives for the May 2007 party-list elections. This dispute occurred against the backdrop of Buhay's previous participation in the 2001 and 2004 elections with Melquiades Robles as its recognized president, and the upcoming 2007 elections where two conflicting Certificates of Nomination were filed with the COMELEC. | The House of Representatives Electoral Tribunal (HRET) has sole and exclusive jurisdiction over contests relating to the election, returns, and qualifications of members of the House of Representatives once they have been proclaimed, taken their oath, and assumed office; thus, a petition for certiorari before the Supreme Court is an improper remedy to question the qualifications or authority of those who nominated such members. |
Constitutional Law I |
Manubay, et al. vs. Sec. Garilao (16th April 2009) |
AK319606 603 Phil. 135 , G.R. No. 140717 |
The case revolves around a 124-hectare parcel of land in Barrio Cadlan, Pili, Camarines Sur, owned by the petitioners. In 1994, this property was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the Municipal Agrarian Reform Officer (MARO). Subsequently, the petitioners applied for the conversion of this land from agricultural to residential/commercial use, which was denied by the DAR, leading to this legal dispute. | An application for land conversion can be validly denied if the subject property has already been placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) prior to the application, and a party aggrieved by a DAR Secretary's decision must first exhaust available administrative remedies, such as an appeal to the Office of the President as provided by DAR rules, before resorting to a petition for certiorari in court, unless grave abuse of discretion is clearly shown and no other plain, speedy, and adequate remedy exists. |
Constitutional Law I |
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