There are 472 results on the current subject filter
Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
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National Electrification Administration vs. Morales (24th July 2007) |
AK115653 528 SCRA 79 , 555 Phil. 74 , G.R. No. 154200 |
The case revolves around NEA employees seeking payment of various allowances they believed they were entitled to under R.A. No. 6758. After winning in the RTC, they sought to execute the judgment through garnishment of NEA's funds. NEA resisted, citing laws protecting government funds from execution. The case then went through various stages of appeal and review, ultimately reaching the Supreme Court. |
Constitutional Law I |
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Carlos Superdrug Corp. vs. DSWD (29th June 2007) |
AK712617 526 SCRA 130 , 553 Phil. 120 , G.R. No. 166494 |
Petitioners, drugstore owners, questioned the constitutionality of Section 4(a) of R.A. No. 9257, which provides senior citizens with a 20% discount on medicines, arguing that the provided tax deduction mechanism does not fully reimburse them and results in financial losses, amounting to confiscation of property without just compensation. They contended that it violates their rights to due process and equal protection and the constitutional mandate to make essential goods available at affordable cost. | Section 4(a) of Republic Act No. 9257, the Expanded Senior Citizens Act of 2003, is constitutional as it is a valid exercise of police power and does not violate the constitutional rights to due process, equal protection, or constitute unjust taking of private property. |
Constitutional Law II Police Power |
Adasa vs. Abalos (19th February 2007) |
AK799445 516 SCRA 261 , 545 Phil. 168 , G.R. No. 168617 |
The case originated from two complaints filed by Cecille S. Abalos against Bernadette L. Adasa for estafa, alleging that Adasa encashed two checks without her consent. The Office of the City Prosecutor of Iligan City found probable cause and filed criminal cases against Adasa. Adasa sought reinvestigation, and the DOJ later reversed the prosecutor's resolution, leading to the withdrawal of the charges. The trial court dismissed the case based on the DOJ's resolution, but the Court of Appeals reversed this decision, prompting Adasa to file a Petition for Review with the Supreme Court. | The Supreme Court denied Adasa's petition, affirming the Court of Appeals' decision. The Court held that the DOJ should not have entertained Adasa's petition for review after her arraignment, as it violated DOJ Circular No. 70. The trial court's dismissal of the case was also void as it was based on the DOJ's void resolutions. |
Statutory Construction |
Balagtas Multi-Purpose Cooperative, Inc. vs. Court of Appeals (27th October 2006) |
AK270160 505 SCRA 654 , 536 Phil 511 , G.R. No. 159268 |
Josefina Hipolito-Herrero was hired by Balagtas Multi-Purpose Cooperative in 1991. After closing a branch office in 1994, she resigned and later filed a complaint for illegal dismissal and unpaid benefits. The Labor Arbiter ruled in her favor, ordering Balagtas to pay backwages, separation pay, and 13th-month pay. Balagtas appealed to the NLRC but refused to post the required bond, citing Article 62(7) of the Cooperative Code. The NLRC and Court of Appeals rejected this argument. | Cooperatives are not exempt from posting an appeal bond under Article 223 of the Labor Code when appealing to the NLRC. The exemption in Article 62(7) of the Cooperative Code applies only to appeals from decisions of inferior courts (e.g., municipal or regional trial courts), not quasi-judicial agencies. |
Statutory Construction |
Lambino vs. Commission on Elections (25th October 2006) |
AK596385 505 SCRA 160 , 536 Phil. 1 , G.R. No. 174153 , G.R. No. 174299 |
The petitioners, led by Raul Lambino and Erico Aumentado, sought to amend the 1987 Constitution via a people’s initiative by collecting signatures from registered voters. They filed a petition with the COMELEC requesting a plebiscite to ratify their proposed amendments. COMELEC dismissed their petition, citing the Supreme Court’s ruling in Santiago v. COMELEC, which declared R.A. 6735 inadequate to allow an initiative for constitutional amendments. The petitioners then sought recourse with the Supreme Court. | The Supreme Court ruled that the initiative petition filed by the Lambino Group was fatally defective because it failed to comply with constitutional requirements. It also reaffirmed the Santiago v. COMELEC ruling that R.A. 6735 is inadequate to implement the people’s initiative to amend the Constitution. |
Constitutional Law II |
Aquino vs. Quezon City (3rd August 2006) |
AK382783 497 SCRA 497 , 529 Phil. 486 , G.R. No. 137534 , G.R. No. 138624 |
G.R. No. 137534 (Aquino Case): The Aquino spouses' 612-square meter lot in East Avenue Subdivision, Diliman, Quezon City, was sold in 1984 for non-payment of property taxes from 1975 to 1982. They withheld payment as a protest against the Marcos regime. G.R. No. 138624 (Torrado Case): A 407-square meter property at No. 20 North Road, Cubao, Quezon City, owned by Solomon Torrado, was sold in 1983 due to unpaid property taxes from 1976 to 1982. Notices were sent to an insufficient address, "Butuan City," causing them to be undelivered. | The Supreme Court upheld the validity of the auction sales, ruling that the notice requirements under P.D. No. 464 were sufficiently complied with. The Court emphasized that personal service of notice via registered mail satisfies the legal requirements even if the notice was not personally received. Constructive notice through compliance with statutory procedures was deemed adequate. |
Statutory Construction |
Sevilla vs. Cardenas (31st July 2006) |
AK546972 497 SCRA 428 , 529 Phil. 419 , G.R. No. 167684 |
Jaime O. Sevilla and Carmelita N. Cardenas were married in civil rites on May 19, 1969, and in a church ceremony on May 31, 1969. Jaime later filed a complaint for the nullity of their marriage, claiming that no marriage license was issued for their union. The Regional Trial Court (RTC) declared the marriage null and void, but the Court of Appeals reversed this decision, leading to the present petition. | The Supreme Court denied the petition, affirming the Court of Appeals' decision that the marriage between Jaime O. Sevilla and Carmelita N. Cardenas was valid, as the certifications from the Local Civil Registrar did not conclusively prove the absence of a marriage license. |
Philosophy of Law |
Rufino vs. Endriga (21st July 2006) |
AK344369 528 Phil. 473 , G.R. No. 139554 |
Presidential Decree No. 15 created the Cultural Center of the Philippines (CCP) as a non-municipal public corporation governed by a Board of Trustees. PD 15, as amended, provided that vacancies in the Board were to be filled by election by a majority of the remaining trustees. Only if the Board became entirely vacant could the President of the Philippines fill such vacancies. This case arose from a dispute between a group of trustees appointed by then-President Joseph E. Estrada (Rufino group) and the incumbent trustees (Endriga group) who claimed their terms had not yet expired and that vacancies should be filled according to PD 15. | Section 6(b) and (c) of Presidential Decree No. 15, as amended, are unconstitutional insofar as they authorize the remaining trustees of the Cultural Center of the Philippines Board to fill vacancies in the Board by election, as this mechanism infringes upon the President's constitutional power of appointment and power of control. |
Constitutional Law I |
Preysler, Jr. vs. Court of Appeals (11th July 2006) |
AK116882 494 SCRA 547 , 527 Phil. 129 , G.R. No. 158141 |
Petitioner owned landlocked parcels adjacent to Respondent's Tali Beach Subdivision, needing access through the subdivision roads. Respondent initially allowed access but later barricaded the property. Petitioner sought a right of way and preliminary injunction. The trial court initially granted a preliminary injunction to remove barricades and allow passage. This was later amended to include passage for contractors, equipment, and power line installation. | The Supreme Court partially granted the petition, affirming the Court of Appeals' decision to reinstate the original writ of preliminary injunction (maintaining status quo). However, the Supreme Court recognized the petitioner's need for temporary easement for construction purposes under Article 656 of the Civil Code and remanded the case to the trial court to determine the proper indemnity for this temporary right of way. The installation of power lines was deemed a permanent easement not covered by the temporary easement provisions. |
Property and Land Law |
Public Interest Center, Inc. vs. Elma (30th June 2006) |
AK754720 526 Phil. 550 , G.R. No. 138965 |
The case arose from the appointment of Magdangal B. Elma to two significant government positions: first as Chairman of the PCGG and subsequently, during his tenure there, as Chief Presidential Legal Counsel. This dual appointment raised concerns about potential conflicts of interest and violations of constitutional provisions designed to prevent officials from holding multiple public offices, particularly given the distinct and potentially overlapping or conflicting responsibilities of the two roles. | The concurrent appointments of an individual as Chairman of the Presidential Commission on Good Government (PCGG) and as Chief Presidential Legal Counsel (CPLC) are unconstitutional because the two offices are incompatible, violating the prohibition against holding multiple offices under Section 7, Article IX-B of the 1987 Constitution. |
Constitutional Law I |
Estrada vs. Escritor (22nd June 2006) |
AK431336 492 SCRA 1 , 525 Phil. 110 , A.M. No. P-02-1651 |
The case arose from a sworn letter-complaint filed by Alejandro Estrada against Soledad Escritor, a court interpreter, alleging that her living arrangement with Luciano Quilapio, Jr.—a man married to another woman—constituted disgraceful and immoral conduct tarnishing the image of the judiciary. Escritor, a widow whose own husband was previously estranged, admitted the cohabitation but claimed it conformed to the religious doctrines and practices of the Jehovah's Witnesses, formalized through a "Declaration of Pledging Faithfulness" approved by her congregation, as Quilapio faced legal impediments to remarriage. This created a conflict between state laws penalizing such relationships and Escritor's constitutional right to religious freedom. | The State failed to demonstrate a compelling interest that would justify infringing upon the respondent's fundamental right to the free exercise of her religion, and failed to show that the means adopted was the least restrictive; therefore, the respondent's conjugal arrangement, sanctioned by her religious beliefs and practices as a Jehovah's Witness, cannot be penalized as disgraceful and immoral conduct, and she is entitled to an exemption based on her right to religious freedom. |
Constitutional Law I Constitutional Law II Philosophy of Law Freedom of Religion |
Mirasol, et al. vs. Department of Public Works and Highways and Toll Regulatory Board (8th June 2006) |
AK762874 523 Phil. 713 , G.R. NO. 158793 |
The case arose from the implementation of various administrative orders and regulations issued over several decades by the Department of Public Works and Highways (DPWH) and its predecessors, aiming to regulate traffic on limited access highways, commonly known as tollways or expressways. Specifically, these issuances involved restrictions and prohibitions on the use of motorcycles on these facilities, prompting challenges from motorcycle riders regarding the issuing body's authority and the constitutionality of the restrictions. | The authority to regulate, restrict, or prohibit access to limited access facilities (tollways) under Republic Act No. 2000, originally vested in the Department of Public Works and Communications, was transferred to the Department of Transportation and Communications (DOTC) by Executive Order 546 in 1979; consequently, subsequent issuances by the Department of Public Works and Highways (DPWH) regulating such access are void for lack of authority, while regulations issued by the predecessor department prior to the transfer remain valid if consistent with the Constitution. |
Constitutional Law II Liberty of Abode |
David vs. Macapagal-Arroyo (3rd May 2006) |
AK973659 489 SCRA 160 , 522 Phil. 705 , G.R. No. 171396 , G.R. No. 171409 , G.R. No. 171485 , G.R. No. 171483 , G.R. No. 171400 , G.R. No. 171489 , G.R. No. 171424 |
In February 2006, amidst alleged conspiracies to destabilize the government, President Arroyo issued PP 1017 and G.O. No. 5, directing the AFP and Philippine National Police (PNP) to maintain law and order, prevent acts of terrorism and lawless violence. These actions led to arrests, dispersal of rallies, and a raid on a newspaper office, prompting several petitions questioning the constitutionality of the President's actions. | PP 1017 is constitutional insofar as it constitutes a call by the President for the Armed Forces of the Philippines (AFP) to prevent or suppress lawless violence, invasion, or rebellion; however, the authority to promulgate decrees and the provision allowing the takeover of privately-owned public utilities or businesses without congressional authority are unconstitutional. The "acts of terrorism" portion of G.O. No. 5 is also unconstitutional. |
Constitutional Law I Constitutional Law II Philosophy of Law |
Senate of the Philippines vs. Ermita (20th April 2006) |
AK395231 488 SCRA 1 , 522 Phil. 1 , G.R. No. 169777 , G.R. No. 169659 , G.R. No. 169660 , G.R. No. 169667 , G.R. No. 169834 , G.R. No. 171246 |
The case arose from several Senate investigations where executive officials failed to appear, citing E.O. 464 which President Gloria Macapagal-Arroyo issued requiring executive department officials to secure presidential consent before appearing in congressional inquiries. This led to multiple petitions challenging the constitutionality of E.O. 464. | The Supreme Court ruled that while executive privilege is valid, it cannot be invoked through a blanket requirement of prior presidential consent for all executive officials appearing before Congress. Such privilege must be explicitly claimed on a case-by-case basis with specific grounds stated. |
Constitutional Law I Philosophy of Law Statutory Construction |
Star Paper Corporation vs.Simbol (12th April 2006) |
AK657436 521 Phil. 364 , G.R. No. 164774 |
Petitioner Star Paper Corporation implemented a policy in 1995 stating that if two employees marry each other, one must resign. This policy also barred the hiring of new applicants who had relatives up to the third degree of relationship already employed by the company. The case arose when three regular employees, Ronaldo D. Simbol, Wilfreda N. Comia, and Lorna E. Estrella, were affected by this policy or related circumstances leading to their separation from the company. | A company policy prohibiting spouses from working in the same company (no-spouse policy) is illegal and constitutes marital discrimination unless the employer can prove that the policy is founded on a reasonable business necessity and that the qualification is reasonably related to the essential operation of the job involved. |
Obligations and Contracts |
Office of the Court Administrator vs. Floro, Jr. (31st March 2006) |
AK855285 486 SCRA 66 , 520 Phil. 591 , A.M. No. RTJ-99-1460 , A.M. No. 99-7-273-RTC , A.M. No. RTJ-06-1988 |
The case centers on Judge Florentino V. Floro Jr.'s fitness to serve as a judge of the Regional Trial Court. After withdrawing his first application in 1995 due to concerning psychological evaluations, he reapplied in 1998 and was appointed despite similar psychological concerns, mainly due to his impressive academic background. Upon his own request for an audit in March 1999, various issues about his conduct came to light, leading to his preventive suspension by July 1999, merely eight months into his position. The Office of the Court Administrator filed administrative charges against him, encompassing 13 different allegations ranging from procedural violations to fundamental concerns about his mental fitness, particularly given his proclaimed beliefs in psychic powers, dwarf friends, and unusual practices like wearing colored robes in court. The case became a landmark decision addressing the intersection of mental fitness, judicial temperament, and the limits of personal beliefs in judicial service. | The Supreme Court ruled to relieve Judge Florentino V. Floro, Jr. of his functions as Judge of RTC Branch 73, Malabon City due to a medically disabling condition of the mind that rendered him unfit to discharge judicial functions, while awarding him back wages for 3 years on equitable grounds. |
Philosophy of Law |
Commissioner of Internal Revenue vs. PLDT (15th December 2005) |
AK383011 478 SCRA 61 , 514 Phil. 255 , G.R. No. 140230 |
PLDT sought a tax refund/credit for indirect taxes paid on imported equipment, citing Section 12 of RA 7082. The BIR and lower courts disagreed on whether the franchise’s “in lieu of all taxes” clause covered indirect taxes. | PLDT’s “in lieu of all taxes” franchise clause exempts only direct taxes on its franchise/earnings, not indirect taxes like VAT; however, advance sales and compensating taxes collected during 1992–1994 were erroneous and refundable. |
Statutory Construction |
Agulto vs. Tecson (29th November 2005) |
AK349241 476 SCRA 395 , 512 Phil. 760 , G.R. No. 145276 |
Respondent William Z. Tecson filed an action for damages against petitioners Rolando Agulto, Maxima Agulto, Cecille Tenorio, and Maribel Mallari in the Regional Trial Court (RTC) of Quezon City, alleging malicious prosecution. | Service of notice of pre-trial on the counsel of record (or on the party if they have no counsel) is mandatory under Section 3, Rule 18 of the 1997 Rules of Civil Procedure; failure to serve such notice renders the pre-trial and all subsequent proceedings null and void for violating the party's right to due process, and constitutes grave abuse of discretion correctible by certiorari. |
Civil Procedure I Pre-trial |
Guingguing vs. Court of Appeals (30th September 2005) |
AK025163 508 Phil. 193 , G.R. No. 128959 |
The case arose from a criminal complaint for libel filed by Cirse "Choy" Torralba, a broadcast journalist with programs on radio stations DYLA and DYFX in Cebu City, which aired over a large portion of the Visayas and Mindanao. The complaint was against Segundo Lim, who paid for an advertisement, and Ciriaco "Boy" Guingguing, the editor-publisher of the Sunday Post, a weekly newspaper circulated in Bohol, Visayas, and Mindanao, where the advertisement was published. | A publication containing truthful information about criminal cases filed against a public figure, even if it tends to cause dishonor or discredit, is not libelous if it was not published with actual malice—that is, with knowledge of its falsity or with reckless disregard of whether it was false or not—as such publication falls within the bounds of constitutionally protected freedom of speech and expression concerning matters of public interest. |
Constitutional Law II Freedom of Expression |
Abakada Guro Party List vs. Ermita (1st September 2005) |
AK134713 469 SCRA 14 , 506 Phil. 1 , G.R. No. 168056 , G.R. No. 168207 , G.R. No. 168461 , G.R. No. 168463 , G.R. No. 168730 |
Republic Act No. 9337 (Expanded VAT Law) was enacted to address the Philippines’ fiscal deficit by increasing government revenue through an expanded VAT system. Several petitions challenged its constitutionality, particularly the provisions authorizing the President to increase the VAT rate, arguing that this was an undue delegation of legislative power. | The Supreme Court ruled that Republic Act No. 9337 is constitutional, particularly the provisions granting the President the authority to raise the VAT rate to 12%. The law merely delegates the ascertainment of facts and does not constitute undue delegation of legislative power. |
Philosophy of Law Statutory Construction |
Misamis Occidental II Cooperative, Inc. vs. David (25th August 2005) |
AK092221 468 SCRA 63 , 505 Phil. 181 , G.R. No. 129928 |
Respondent Virgilio S. David, a supplier of electrical hardware, entered into a transaction with petitioner Misamis Occidental II Electric Cooperative, Inc. (MOELCI II) concerning the supply of a 10 MVA Power Transformer. A dispute arose regarding the nature of the document governing the transaction and MOELCI II's alleged failure to pay the agreed price, leading David to file a suit for specific performance and damages. | A preliminary hearing on affirmative defenses pleaded in an answer, as provided under Section 5, Rule 16 of the old Rules of Court (now Section 6, Rule 16 of the 1997 Rules), is not mandatory but rests upon the sound discretion of the trial court; its denial is not correctible by certiorari absent grave abuse of discretion amounting to lack or excess of jurisdiction. |
Civil Procedure I Motion |
Coconut Oil Refiners Association, Inc. vs. Torres (29th July 2005) |
AK371894 465 SCRA 47 , 503 Phil. 42 , G.R. No. 132527 |
Republic Act No. 7227 (Bases Conversion and Development Act of 1992) aimed to convert former U.S. military bases into productive economic zones to promote development in Central Luzon. It created the Subic Special Economic Zone (SSEZ) with tax incentives but did not explicitly extend these privileges to other zones like Clark. Several executive issuances, including Executive Orders No. 80 and 97-A, sought to implement these incentives in both SSEZ and CSEZ, prompting legal challenges from businesses outside these zones. | The Supreme Court ruled that portions of Executive Order No. 97-A and related issuances were unconstitutional for allowing tax-free removal of goods from the Subic Special Economic Zone to other parts of the Philippines and extending incentives to Clark Special Economic Zone without statutory basis. |
Statutory Construction |
Herrera vs. Alba (15th June 2005) |
AK188258 460 SCRA 197 , 499 Phil. 185 , G.R. No. 148220 |
DNA paternity testing is a valid and admissible method to establish filiation in paternity suits, provided that proper procedures are followed, and it does not violate the right against self-incrimination. | DNA paternity testing is a valid and admissible method to establish filiation in paternity suits, provided that proper procedures are followed, and it does not violate the right against self-incrimination. |
Philosophy of Law |
Portic vs. Cristobal (22nd April 2005) |
AK058410 456 SCRA 577 , 496 Phil. 456 , G.R. No. 156171 |
Spouses Portic sold property to Anastacia Cristobal under an agreement that included conditions about payment of a balance. A dispute arose when Cristobal registered the title in her name despite allegedly not fully paying the balance, and Spouses Portic sought to quiet title, claiming the sale was void due to non-payment. | The Supreme Court held that the agreement was a contract to sell, and because the vendee failed to fully pay the purchase price, ownership of the property did not transfer to her. Consequently, the action for quieting of title filed by the vendors was deemed proper and not prescribed as they remained in possession and legal owners of the property. |
Property and Land Law |
National Housing Authority vs. Court of Appeals (13th April 2005) |
AK266478 456 SCRA 17 , 495 Phil. 693 , G.R. NO. 148830 |
President Marcos issued Proclamation No. 481 reserving a 120-hectare NHA-owned land for the National Government Center (NGC). Later, Proclamation No. 1670 segregated seven hectares from the NGC and granted MSBF usufructuary rights over it, to be determined by future survey. MSBF occupied an area exceeding seven hectares and leased a portion to BGC. NHA, under Memorandum Order No. 127 which revoked the reserved status of the remaining 50 hectares, sought to demolish BGC's facilities, leading BGC to file for injunction. | The Supreme Court set aside the Court of Appeals' decision and remanded the case to the trial court to order a joint survey by NHA and MSBF to determine the precise metes and bounds of the seven-hectare usufruct granted to MSBF, ensuring contiguity and inclusion of MSBF's major existing facilities as much as possible within that area, while also ensuring MSBF respects the seven-hectare limit and vacates any area exceeding it. |
Property and Land Law |
City of Manila vs. Laguio, Jr. (12th April 2005) |
AK416215 455 SCRA 308 , 495 Phil. 289 , G.R. No. 118127 |
Malate Tourist Development Corporation (MTDC) questioned the validity of Ordinance No. 7783, which included motels and inns among the prohibited establishments in the Ermita-Malate area, arguing it was unconstitutional and beyond the City Council's powers. | Ordinance No. 7783 is an invalid exercise of police power because it violates the constitutional rights to due process and equal protection and exceeds the regulatory powers granted to the City of Manila under the Local Government Code. |
Constitutional Law II Statutory Construction Police Power |
Soria vs. Desierto (31st January 2005) |
AK603974 450 SCRA 339 , 490 Phil. 749 , G.R. Nos. 153524-25 |
The Supreme Court upheld the time-honored practice of non-interference in preliminary investigations conducted by prosecutory bodies absent grave abuse of discretion, affirming that Sundays, holidays, and election days are excluded in computing the periods prescribed in Article 125 of the Revised Penal Code. |
Criminal Law II |
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Civil Service Commission vs. Belagan (19th October 2004) |
AK604656 440 SCRA 578 , 483 Phil. 601 , G.R. No. 132164 |
Dr. Allyson Belagan, a Superintendent of DECS in Baguio City, was accused of sexual harassment by Magdalena Gapuz, a private school teacher, and Ligaya Annawi, a public school teacher. Gapuz alleged that Belagan kissed her during an inspection of her school premises, while Annawi accused him of multiple instances of sexual harassment and other administrative malfeasances. The DECS conducted an investigation and found Belagan guilty, leading to his dismissal. The CSC affirmed the DECS decision regarding Gapuz but dismissed Annawi's complaint. The Court of Appeals reversed the CSC's decision, prompting the CSC to appeal to the Supreme Court. | The Supreme Court held that the Civil Service Commission's findings were supported by substantial evidence, and while Belagan was guilty of grave misconduct, his long service and unblemished record warranted a modified penalty of one-year suspension without pay instead of dismissal. |
Philosophy of Law |
Duncan Association of Detailman-PTGWO vs. Glaxo Wellcome Philippines, Inc (17th September 2004) |
AK533184 481 Phil. 687 , G.R. No. 162994 |
The case arose from the highly competitive pharmaceutical industry where companies like Glaxo Wellcome Philippines, Inc. (Glaxo) and Astra Pharmaceuticals (Astra) are direct competitors. Glaxo implemented a policy, reflected in its employment contracts and Employee Code of Conduct, requiring employees to disclose relationships with employees of competitor companies and, if a conflict of interest is perceived, to explore solutions including transfer or resignation. This policy was intended to safeguard Glaxo's trade secrets, marketing strategies, and other confidential information. | A company policy prohibiting employees from marrying employees of competitor companies, aimed at preventing conflicts of interest and protecting trade secrets, is a valid exercise of management prerogative and does not violate the equal protection clause or the right to marry, provided it is reasonable and applied impartially. |
Obligations and Contracts |
Baloloy vs. Hular (9th September 2004) |
AK688555 438 SCRA 80 , 481 Phil. 398 , G.R. No. 157767 |
Alfredo Hular claimed ownership of land originally owned by his father, Astrologo Hular, part of Lot No. 3347. He alleged that Iluminado Baloloy fraudulently secured a Free Patent and OCT over Lot No. 3353, which included a portion of his father's land (later found to be 1,405 square meters, not 287 sqm as initially thought). Hular sought to quiet title, nullify the Baloloy's OCT, and reconveyance, citing prior ownership and acquisitive prescription. Baloloys, heirs of Iluminado, argued their title's sanctity and Hular's lack of cause of action. | The petition is granted. The decisions of the Court of Appeals and the Regional Trial Court are reversed and set aside. The complaint of the respondent is dismissed. The respondent failed to implead indispensable parties and failed to prove his claim of ownership by preponderance of evidence sufficient to overcome the petitioners' Torrens title. |
Property and Land Law |
People vs. Comadre (8th June 2004) |
AK679022 431 SCRA 366 , 475 PHIL. 293 , G.R. No. 153559 |
The case arose from an incident where victims were having a drinking session on the terrace of a house when the appellants allegedly stopped in front, and one of them, Antonio Comadre, lobbed a hand grenade onto the roof, which subsequently exploded, causing death and injuries. | A single act, such as detonating a hand grenade, that results in death (Murder) and injuries (Attempted Murder) constitutes a complex crime under Article 48 of the RPC, punishable with the penalty for the most serious crime (Murder) applied in its maximum period; when both treachery and explosion attend the killing, explosion qualifies the crime to Murder if it was the principal means employed, while treachery is considered a generic aggravating circumstance. Conspiracy must be proven by positive acts of cooperation beyond mere presence or relationship, and absent such proof, co-accused cannot be held liable. |
Criminal Law II Murder |
Ong vs. Mazo (4th June 2004) |
AK982901 431 SCRA 56 , 474 Phil. 807 , G.R. No. 145542 |
The case originated from a vehicular accident where a passenger bus owned by petitioner Elena S. Ong and driven by Iluminado J. Caramoan allegedly bumped a jeep owned and driven by respondent Elvira C. Lanuevo, who had respondent Charito A. Tomilloso as a passenger. This incident led respondents Lanuevo and Tomilloso to file a complaint for damages against Ong and Caramoan. | A petition for certiorari under Rule 65 filed after the effectivity of A.M. No. 00-2-03-SC benefits from the fresh 60-day period counted from the notice of denial of the motion for reconsideration, even if the original period under the prior rule (Circular No. 39-98) had partially lapsed; furthermore, denying a party the use of written interrogatories based on the outdated notion that it constitutes a "fishing expedition" is a grave abuse of discretion correctible by certiorari, as modes of discovery are liberally granted to enable parties to obtain relevant facts and expedite proceedings. |
Civil Procedure I Discovery |
Tecson vs. Commission on Elections (3rd March 2004) |
AK663881 424 SCRA 277 , 468 Phil. 421 , G.R. No. 161434 , G.R. No. 161634 , G.R. No. 161824 |
The case arose when Victorino X. Fornier filed a petition before the COMELEC to disqualify FPJ from running for president, alleging that FPJ was not a natural-born Filipino citizen. The COMELEC dismissed the petition, and Fornier, along with other petitioners, elevated the case to the Supreme Court. | The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing the petition to disqualify FPJ, as the petitioners failed to prove that FPJ deliberately misrepresented his citizenship in his certificate of candidacy. |
Philosophy of Law |
Tolentino vs. Commission on Elections (21st January 2004) |
AK379108 420 SCRA 438 , 465 Phil. 385 , G.R. No. 148334 |
Following the appointment of Senator Teofisto Guingona as Vice-President in 2001, a Senate vacancy arose. The Senate passed a resolution calling for a special election to fill the vacancy, to be held simultaneously with the May 14, 2001, regular elections. The 13th placer in the senatorial race would serve the unexpired term. Petitioners challenged the validity of the special election, arguing that COMELEC failed to comply with legal requirements. | The Supreme Court held that the special election to fill the Senate vacancy was validly held, and COMELEC’s failure to give formal notice did not invalidate the election. The petition was dismissed for lack of merit. |
Philosophy of Law |
People vs. Suzuki (23rd October 2003) |
AK996295 414 SCRA 43 , G.R. No. 120670 |
The case stems from an airport security check at Bacolod Airport where the defendant, a Japanese national, was found in possession of marijuana concealed in a box of "Bongbong's piaya." The case raises important questions about the constitutionality of airport security searches and the rights of individuals against unreasonable searches and seizures. | The Supreme Court held that routine airport security procedures constitute a valid exception to the constitutional protection against warrantless searches and seizures. Persons may lose this protection due to reduced privacy expectations associated with air travel. When these procedures reveal contraband, and the accused is caught in flagrante delicto, both the warrantless search and subsequent arrest are valid. However, in imposing penalties for drug possession, courts must apply the lesser of two indivisible penalties when there are no aggravating or mitigating circumstances. |
Criminal Law II |
Allied Domecq Phil., Inc. vs. Villon (12th August 2003) |
AK813262 439 SCRA 667 , 482 Phil. 894 , G.R. No. 156264 |
Petitioner ADPI held an exclusive distributorship agreement for "Fundador" brandy in the Philippines, granted by the Spanish manufacturer Pedro Domecq, S.A. ADPI obtained the necessary Certificate of Registration from the Bureau of Food and Drugs (BFAD) for the product. Subsequently, the Bureau of Customs issued a circular requiring importers of "Fundador" brandy to present a valid BFAD certificate. Respondent Clark Liberty, a duty-free shop in the Clark Special Economic Zone (CSEZ), imported a significant quantity of "Fundador" brandy without such a certificate. | The Supreme Court held that pursuant to Section 21 of Republic Act No. 7227, only the Supreme Court has the jurisdiction to issue a restraining order or preliminary injunction against the implementation of projects for the conversion of former military reservations into alternative productive uses, which includes the operations of duly registered enterprises within the Clark Special Economic Zone like respondent Clark Liberty. |
Civil Procedure I |
Senate Blue Ribbon Committee vs. Majaducon (29th July 2003) |
AK802239 455 Phil. 61 , G.R. No. 136760 , G.R. NO. 138378 |
The case arose from two Senate Resolutions: No. 157, directing an inquiry into alleged coup d'etat plans related to probing AFP fund irregularities, and No. 160, directing an inquiry into alleged mismanagement of AFP-Retirement and Separation Benefits System (AFP-RSBS) funds. These resolutions were referred to the Senate Blue Ribbon Committee and the Committee on National Defense and Security for investigation. | A Regional Trial Court has no jurisdiction to prohibit the Senate or its committees from conducting inquiries in aid of legislation, as this would violate the principle of separation of powers; furthermore, the use of terms like "gross ignorance of the law" in pleadings challenging a judge's order, without malice, does not automatically constitute indirect contempt, especially when such terms are descriptive of alleged errors in applying fundamental legal principles. |
Constitutional Law I |
Republic vs. Sandiganbayan (21st July 2003) |
AK422271 407 SCRA 10 , 454 Phil. 504 , G.R. No. 104768 |
In the aftermath of the 1986 EDSA Revolution, President Corazon Aquino established the PCGG to spearhead the recovery of assets unlawfully acquired during the Marcos regime. The AFP Anti-Graft Board, under the PCGG's directive, initiated an inquiry into the financial dealings of Major General Ramas, uncovering properties and assets allegedly disproportionate to his lawful income. The investigation extended to Elizabeth Dimaano, purportedly Ramas' mistress, in whose possession substantial monetary sums and military-grade equipment were discovered. This led to a forfeiture petition grounded on the Anti-Graft and Corrupt Practices Act and the Forfeiture Law (RA No. 1379). | The Supreme Court adjudicated that the PCGG lacked the requisite jurisdiction to investigate and prosecute Major General Ramas and Elizabeth Dimaano, as Ramas did not meet the definitional criteria of a "subordinate" of former President Ferdinand Marcos under Executive Orders Nos. 1, 2, 14, and 14-A. The Court affirmed that such jurisdiction rightly resides with the Office of the Ombudsman and the Office of the Solicitor General. |
Philosophy of Law |
Commissioner of Internal Revenue vs. Michel J. Lhuillier Pawnshop, Inc (15th July 2003) |
AK922816 406 SCRA 178 , 453 Phil. 1043 , G.R. No. 150947 |
The BIR sought to impose a 5% lending investor’s tax on pawnshops through administrative issuances (RMO No. 15-91 and RMC No. 43-91). Michel J. Lhuillier Pawnshop challenged the assessment, arguing pawnshops were distinct from lending investors and the BIR overstepped its rulemaking authority. | Pawnshops are excluded from the definition of “lending investors” under Section 116 of the NIRC, rendering BIR’s assessment for deficiency percentage tax void. |
Statutory Construction |
Lawrence vs. Texas (26th June 2003) |
AK906927 539 U.S. 558 |
The case arose within the legal and social context of state laws criminalizing sodomy, often referred to as "crimes against nature" or "deviate sexual intercourse." Seventeen years prior, in _Bowers v. Hardwick_, the Supreme Court had upheld a Georgia sodomy law applied to homosexual conduct, finding no fundamental right to engage in such activity. Since _Bowers_, legal and social perspectives continued to evolve, with many states repealing their sodomy laws or ceasing enforcement against private, consensual adult conduct, and subsequent Court decisions like _Romer v. Evans_ casting doubt on laws motivated by animus towards homosexuals. | A Texas statute making it a crime for two persons of the same sex to engage in certain intimate sexual conduct violates the Due Process Clause of the Fourteenth Amendment, as the liberty protected by the Constitution includes the right for adults to engage in private, consensual homosexual activity without government intervention; consequently, _Bowers v. Hardwick_, 478 U.S. 186, is overruled. |
Constitutional Law II Equal Protection |
Buena Obra vs. Social Security System (9th April 2003) |
AK528677 401 SCRA206 , 449 Phil. 200 , G.R. No. 147745 |
Juanito Buena Obra, a dump truck driver for 24 years, died of a heart attack at work in 1988. His widow filed for SSS death benefits but learned about EC benefits a decade later. The SSS/ECC rejected her claim, alleging prescription and lack of work connection. | The Court held that (1) the claim was filed within a “reasonable time” due to the SSS’s failure to process her EC claim earlier, and (2) myocardial infarction was work-related under ECC Resolution No. 432 due to job strain. |
Statutory Construction |
Coronel vs. Constantino (7th February 2003) |
AK326196 445 Phil. 97 , G.R. No. 121069 |
The subject property, consisting of two parcels of land (Cadastral Lots Nos. 5737 and 5738) in Sta. Monica, Hagonoy, Bulacan, was originally owned by Honoria Aguinaldo. Upon Honoria's death, one-half (1/2) of the property was inherited by petitioner Emilia Meking Vda. de Coronel together with her sons, petitioner Benjamin, Catalino, and Ceferino, all surnamed Coronel. The other half was inherited by respondents Florentino Constantino and Aurea Buensuceso. The dispute arose from the sale of the portion inherited by Emilia and her sons. | A sale by a co-owner of the entire co-owned property is valid only with respect to the seller's pro-indiviso share, and the sale of the shares of other co-owners without their authority or legal representation is unenforceable; mere silence or inaction of such other co-owners, without proof of their awareness of the unauthorized sale and a voluntary, knowing adoption of the act, does not constitute ratification. |
Obligations and Contracts |
Dadole vs. Commission on Audit (3rd December 2002) |
AK714832 441 Phil. 537 , G.R. No. 125350 |
For several years, RTC and MTC judges in Mandaue City had been receiving monthly additional allowances from the city government through appropriation ordinances. In 1991, this amount was P1,500. In 1994, the Department of Budget and Management (DBM) issued Local Budget Circular No. 55 (LBC 55), which limited such additional allowances from provinces and cities to P1,000.00 per month. This circular led to the Mandaue City Auditor issuing notices of disallowance for the amounts received by the petitioner judges in excess of P1,000 and requiring reimbursement. | Local Budget Circular No. 55, issued by the Department of Budget and Management, is null and void because it overstepped the President's power of general supervision over local government units by imposing a specific monetary limit on additional allowances not found in the enabling law (R.A. 7160), and because it was not published as required for administrative rules intended to enforce or implement existing law. |
Constitutional Law I |
Francisco vs. Herrera (21st November 2002) |
AK748349 440 Phil. 841 , G.R. No. 139982 |
Eligio Herrera, Sr., the father of respondent Pastor Herrera, was the owner of two parcels of land located in Cainta, Rizal. In 1991, Eligio Sr. sold these properties to the petitioner, Julian Francisco, through two separate transactions. Subsequently, the children of Eligio Sr., including the respondent, contested these sales, primarily arguing that the agreed purchase price was grossly inadequate and, more significantly, that Eligio Sr. was suffering from senile dementia at the time of the sales, which allegedly rendered him incapable of giving valid consent to the contracts. | A contract entered into by a party whose capacity to consent is vitiated by senile dementia is not void ab initio but merely voidable; such a contract is susceptible to ratification, which can be implied through actions such as accepting and retaining the benefits of the contract, thereby rendering it perfectly valid. |
Obligations and Contracts |
Yau vs. Manila Banking Corporation (11th July 2002) |
AK716089 384 SCRA 340 , 433 Phil. 701 , G.R. No. 126731 , G.R. No. 128623 |
Esteban Yau obtained a final judgment against Ricardo Silverio, Sr. from RTC Cebu. The only known asset of Silverio was a proprietary share in Manila Golf and Country Club. This share, however, was already subject to preliminary attachments obtained by Manilabank in separate collection cases against Silverio pending before RTC Makati. This created a conflict when Yau, after purchasing the share at the execution sale ordered by RTC Cebu, sought to have the title transferred to his name. | A court (RTC Cebu) cannot interfere with property under the *custodia legis* (custody of the law) of a co-equal court (RTC Makati) by ordering the cancellation and transfer of title of such property; however, a judgment creditor who purchases property subject to a prior attachment at an execution sale has a sufficient legal interest to intervene in the action where the attachment was issued to protect their rights. |
Civil Procedure I Intervention |
Commission on Audit of the Province of Cebu vs. Province of Cebu (29th November 2001) |
AK875038 371 SCRA 196 , 422 Phil. 519 , G.R. No. 141386 |
The case arose from Notices of Suspension issued by the Commission on Audit (COA) to Cebu Province after it charged teacher salaries and scholarship expenses to its SEF. The province filed a petition for declaratory relief with the Regional Trial Court (RTC), which ruled in favor of Cebu Province. COA elevated the case to the Supreme Court. | The Supreme Court held that salaries and personnel-related benefits of teachers appointed for extension classes may be charged to the SEF, but college scholarship expenses cannot. |
Statutory Construction |
Estrada vs. Sandiganbayan (19th November 2001) |
AK529893 369 SCRA 394 , 421 Phil. 290 , G.R. No. 148560 |
Petitioner Joseph Ejercito Estrada, the highest-ranking official to be prosecuted under RA 7080 (Plunder Law), faced charges before the Sandiganbayan for allegedly amassing ill-gotten wealth during his presidency. This case arose from his efforts to quash the Information against him by challenging the constitutionality of the Plunder Law itself, which defines and penalizes the crime of plunder. | Republic Act No. 7080, the Plunder Law, as amended by RA 7659, is constitutional and does not suffer from the vice of vagueness, nor does it violate the accused's rights to due process and to be informed of the nature and cause of the accusation. The law provides ascertainable standards and well-defined parameters for the crime of plunder. |
Constitutional Law II Philosophy of Law Statutory Construction Freedom of Expression |
Benedicto vs. Court of Appeals (4th September 2001) |
AK713363 364 SCRA 334 , 416 Phil. 722 , G.R. No. 125359 |
The case arose from multiple criminal charges filed against Benedicto and Rivera for failing to report foreign exchange earnings as required by Central Bank Circular No. 960. The petitioners argued that their liability was extinguished due to the circular's repeal and other defenses such as prescription and immunity under a compromise agreement with the government. | The Supreme Court ruled that the repeal of Circular No. 960 did not extinguish petitioners' criminal liability as saving clauses preserved pending cases. It also held that jurisdiction was proper in the Regional Trial Court (RTC), and claims of prescription, exemption, and immunity were unmeritorious. |
Statutory Construction |
Estrada vs. Desierto (2nd March 2001) |
AK430917 353 SCRA 452 , 406 Phil. 1 , G.R. Nos. 146710-15 , G.R. No. 146738 |
Joseph Estrada’s presidency began in 1998 with broad public support but was marred by corruption allegations, including his involvement in illegal gambling operations (jueteng). A series of political and public upheavals culminated in his impeachment trial, which was aborted after senators voted to suppress key evidence. Massive public protests followed, leading to the withdrawal of military and police support for Estrada and the ascension of Vice President Gloria Macapagal-Arroyo. | The Supreme Court held that Joseph Ejercito Estrada had effectively resigned as President of the Philippines on January 20, 2001, and that Gloria Macapagal-Arroyo had validly assumed the presidency. |
Constitutional Law I |
De Rama vs. Court of Appeals (28th February 2001) |
AK337670 405 Phil. 531 , G.R. No. 131136 |
Upon assuming office as Mayor of Pagbilao, Quezon, petitioner Conrado L. de Rama sought to recall the appointments of fourteen municipal employees. These appointments were made by the outgoing mayor, Ma. Evelyn S. Abeja, in the period leading up to the end of her term and after the election of de Rama. The core of the dispute revolved around the petitioner's belief that these were "midnight appointments" and were therefore invalid, leading him to request their recall from the Civil Service Commission. | The constitutional prohibition against "midnight appointments" found in Article VII, Section 15 of the 1987 Constitution applies only to a President or Acting President and does not extend to appointments made by local elective officials. Furthermore, once an appointment is issued, accepted, and the appointee assumes office, they acquire a legal right to the position, protected by due process, and such appointment cannot be unilaterally revoked by the appointing authority or their successor without just cause and adherence to procedural requirements, with the Civil Service Commission having the authority to review and recall appointments only on specific grounds. |
Constitutional Law I |
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ak337670