There are 628 results on the current subject filter
| Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
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Liwag vs. Happy Glen Loop Homeowners Association, Inc (4th July 2012) |
AK931594 675 SCRA 744 , 690 Phil. 321 , G.R. No. 189755 |
In 1978, F.G.R. Sales, the original subdivision developer, assigned rights to Ernesto Marcelo due to financial obligations. Marcelo assured government agencies that water facilities were available in the subdivision. The water facility on Lot 11, Block 5 became the sole water source for residents for over 30 years. In 1995, Marcelo sold Lot 11, Block 5 to Hermogenes Liwag. After his death, Emeteria Liwag demanded the removal of the water tank, prompting the homeowners' association to file a case before the Housing and Land Use Regulatory Board (HLURB). | The Supreme Court affirmed that Lot 11, Block 5, as the site of the subdivision's water facility, is part of the required "open space" under Presidential Decree No. 957 and reserved for public use. The sale of the lot was void, and an easement for the water facility existed for the benefit of the community. |
Statutory Construction |
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United Church of Christ in the Philippines, Inc. vs. Bradford United Church of Christ, Inc., et al. (20th June 2012) |
AK736563 688 Phil. 408 , G.R. No. 171905 |
Petitioner UCCP is a national confederation of Evangelical churches. Respondent BUCCI, formerly Bradford Memorial Church, is a religious corporation that was a constituent local church of UCCP. A dispute arose in late 1989 when BUCCI began constructing a fence that encroached on a right-of-way allocated by UCCP. This, along with other disagreements, led to BUCCI's formal disaffiliation from UCCP, which UCCP contested, claiming the disaffiliation was invalid and that BUCCI could not amend its articles or continue using its name. | A local church, incorporated as a separate legal entity, has the right to disaffiliate from a national church confederation and amend its articles of incorporation to reflect such disaffiliation, especially where the confederation's polity recognizes local church autonomy, and such matters, involving corporate rights, are within the jurisdiction of civil courts and the SEC, not being purely ecclesiastical affairs. |
Constitutional Law I |
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Re: Request for Copy of 2008 Statement of Assets, Liabilities and Net Worth [SALN] and Personal Data Sheet or Curriculum Vitae of the Justices of the Supreme Court and Officers and Employees of the Judiciary (13th June 2012) |
AK617262 672 SCRA 27 , 687 Phil. 24 , A.M. No. 09-8-6-SC |
The case arose from initial requests by the Philippine Center for Investigative Journalism (PCIJ) in 2009 for the 2008 SALNs and PDS/CVs of Supreme Court and Court of Appeals Justices to update their database on government officials. Following these initial requests, numerous similar petitions were filed by various media outlets, organizations, individuals, and even government offices (like the Ombudsman and Malacañang seeking comment on a bill) for SALNs and other personal documents of judiciary members covering different years, spurred by interests in transparency, governance reporting, academic research, impeachment proceedings, and general public information. | Access to the SALNs, PDS, and CVs of members of the Judiciary is generally allowed pursuant to the right to information, but this right is not absolute and must be regulated to protect judicial independence and the security of judicial officers; thus, requests are subject to specific guidelines including proper filing, statement of legitimate purpose, limitations on the scope of documents released, potential requirement for En Banc approval (for appellate court Justices), and verification of the requester's identity and record. |
Constitutional Law I |
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Marcos, Jr. vs. Republic (25th April 2012) |
AK198765 671 SCRA280 , 686 Phil. 980 , G.R. No. 189434 |
This case involves the Republic's efforts to recover ill-gotten wealth allegedly acquired by the Marcoses during their time in power, specifically focusing on assets held by Arelma, S.A. | The assets of Arelma, S.A. are considered ill-gotten wealth and are rightly forfeited to the Republic; the Sandiganbayan did not err in granting the Motion for Partial Summary Judgment. |
Constitutional Law II |
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Hacienda Luisita, Inc. vs. Presidential Agrarian Reform Council, et al. (24th April 2012) |
AK280291 686 Phil. 377 , G.R. No. 171101 |
The case revolves around the implementation of the Comprehensive Agrarian Reform Program (CARP) in Hacienda Luisita, a large sugar plantation. Instead of direct land distribution, HLI implemented a Stock Distribution Plan (SDP) in 1989, approved by the Presidential Agrarian Reform Council (PARC). Years later, PARC revoked the SDP, leading to legal challenges by HLI. The Supreme Court initially affirmed PARC's revocation but allowed FWBs the option to remain HLI stockholders. Subsequent motions led to the revocation of this option and clarifications on just compensation and the distribution of proceeds from land sales, which are further addressed in this resolution. | The date of "taking" of Hacienda Luisita's agricultural lands for agrarian reform purposes is November 21, 1989, the date PARC approved HLI's Stock Distribution Plan (SDP); the option previously granted to FWBs to remain HLI stockholders is revoked, and control over agricultural lands must be in the hands of the farmers; the FWBs are entitled to the proceeds from the sale of converted lands (less specified deductions); and HLI is entitled to just compensation from the government for the homelots distributed to the FWBs. |
Constitutional Law I Persons and Family Law |
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Lockheed Detective and Watchman Agency, Inc. vs. University of the Philippines (18th April 2012) |
AK644609 670 SCRA 206 , 686 Phil. 191 , G.R. No. 185918 |
Petitioner Lockheed Detective and Watchman Agency, Inc. (Lockheed) had a contract for security services with respondent University of the Philippines (UP). This contractual relationship led to labor disputes when security guards assigned to UP filed complaints for various unpaid monetary benefits. | Government instrumentalities with separate juridical personalities, like the University of the Philippines, are suable and their funds are not exempt from execution or garnishment; however, any money judgment against them must first be filed as a claim with the Commission on Audit (COA) before execution can proceed. |
Constitutional Law I |
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In Re: Letters of Atty. Estelito P. Mendoza Re: G.R. No. 178083—Flight Attendants and Stewards Association of the Philippines vs. Philippine Airlines, Inc. (PAL) (13th March 2012) |
AK112746 668 SCRA 11 , A.M. No. 11-10-1-SC |
In the wake of the 1997 Asian financial crisis, Philippine Airlines, Inc. (PAL) claimed to be suffering from severe financial distress, with liabilities allegedly amounting to P90 billion against assets of P85 billion. To mitigate these purported losses and avert bankruptcy, PAL decided to implement a massive cost-cutting program. This program included a drastic reduction of its aircraft fleet and the retrenchment of 5,000 employees, which set the stage for a major labor dispute with its cabin crew union, FASAP, over the legality of the dismissal of more than 1,400 of its members. | An employer's retrenchment program is illegal if the employer fails to satisfy its burden of proving, with sufficient and convincing evidence like audited financial statements, that the retrenchment was necessary to prevent substantial and imminent business losses, and if the criteria used for selecting employees for dismissal are not fair, reasonable, and applied in good faith. |
Civil Procedure II |
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Luz vs. People (29th February 2012) |
AK520853 683 Phil. 399 , G.R. No. 197788 |
The case arose from a routine traffic stop where a police officer flagged down the petitioner for driving a motorcycle without a helmet, a violation of a Naga City ordinance. | A stop for a minor traffic violation, particularly one punishable only by a fine like failing to wear a motorcycle helmet under a city ordinance, does not inherently constitute a lawful custodial arrest that justifies a subsequent warrantless search incidental to arrest; evidence obtained from such an illegal search is inadmissible. |
Constitutional Law II Searches and Seizures |
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China National Machinery & Equipment Corp. (Group) vs. Santamaria (7th February 2012) |
AK339749 665 SCRA 189 , 681 Phil. 198 , G.R. No. 185572 |
The case arose from the North Luzon Railways Project (Northrail Project), a large-scale infrastructure project involving the construction of a railway line from Caloocan to Malolos. This project involved agreements between Philippine government entities, Chinese government entities, and petitioner CNMEG, a Chinese state-owned corporation designated as the prime contractor. The project was financed through a Preferential Buyer's Credit extended by the Export Import Bank of China (EXIM Bank) to the Philippine government. | A state-owned corporation engaging in proprietary or commercial activities (acts jure gestionis) is not entitled to sovereign immunity from suit, and a contract entered into by such an entity for a commercial venture, governed by domestic law, does not constitute an executive agreement immune from judicial review. |
Constitutional Law I |
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Dela Llana vs. The Chairperson, Commission on Audit, et al (7th February 2012) |
AK783122 681 Phil. 186 , G.R. No. 180989 |
The COA's approach to pre-audit has evolved over time. In 1982, COA Circular No. 82-195 lifted the pre-audit system with exceptions, emphasizing agency head responsibility. Following the 1986 EDSA Revolution and the discovery of financial anomalies, COA Circular No. 86-257 reinstated selective pre-audit. With political and governmental stabilization, COA Circular No. 89-299 was issued, again lifting the pre-audit for national government agencies (NGAs) and government-owned or -controlled corporations (GOCCs) to reaffirm managerial fiscal responsibility and accelerate public service delivery. Subsequent circulars (94-006 and 95-006) expanded the lifting of pre-audit to local government units (LGUs). COA Circular No. 89-299A allowed for the reinstitution of pre-audit under certain circumstances. Later, COA Circular No. 2009-002 reinstated selective pre-audit due to rising irregularities, which was then lifted again by COA Circular No. 2011-002. | The Commission on Audit (COA) is not constitutionally mandated to conduct a pre-audit of all government transactions; the COA has the exclusive authority to define the scope of its audit and examination, and the conduct of pre-audit is discretionary, to be implemented when, for example, an agency's internal control system is inadequate. |
Constitutional Law I |
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Villareal vs. People (1st February 2012) |
AK884025 664 SCRA 519 , 680 Phil. 527 , G.R. No. 151258 , G.R. No. 154954 , G.R. No. 155101 , G.R. No. 178057 , G.R. No. 178080 |
Lenny Villa, a law student at Ateneo de Manila University, died during the initiation rites of the Aquila Legis Juris Fraternity in February 1991. The initiation involved physical beatings and psychological pressure, leading to Villa's death from cardiac failure due to multiple traumatic injuries. The case led to the enactment of the Anti-Hazing Law in 1995. | The Supreme Court found the accused fraternity members guilty of reckless imprudence resulting in homicide, emphasizing that the death of Lenny Villa was the cumulative effect of the physical injuries inflicted during the initiation rites. The Court also dismissed the case against Artemio Villareal due to his death, extinguishing his criminal liability. |
Philosophy of Law |
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Commissioner of Customs vs. Hypermix Feeds Corporation (1st February 2012) |
AK490989 664 SCRA 666 , 680 Phil. 681 , G.R. No. 179579 |
Hypermix Feeds Corporation challenged CMO No. 27-2003, which classified wheat imports as either food grade (3% tariff) or feed grade (7% tariff) based on factors like importer identity, country of origin, and port of discharge. Hypermix argued that the regulation unfairly classified its wheat as feed grade despite being food grade, subjected it to higher tariffs, and violated constitutional rights. | CMO No. 27-2003 was declared unconstitutional for violating procedural due process, substantive due process, and the equal protection clause. It also exceeded the Commissioner of Customs' delegated authority. |
Statutory Construction |
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Fontana Resort and Country Club, Inc. vs. Spouses Tan (30th January 2012) |
AK756215 680 Phil. 395 , G.R. No. 154670 |
Respondent spouses purchased two class "D" shares of stock in petitioner Fontana Resort and Country Club, Inc. (FRCCI) from petitioner RN Development Corporation (RNDC), allegedly enticed by promises of first-class leisure facilities at Fontana Leisure Park (FLP) to be fully operational by the first quarter of 1998, and specific accommodation privileges. Disputes arose when respondents experienced difficulties in availing their free accommodations and perceived the FLP development as incomplete and the club rules as obscure and changing. | A contract of sale cannot be annulled or rescinded for alleged fraud or default if the party seeking such relief fails to establish by full, clear, and convincing evidence the existence of dolo causante or a substantial and fundamental breach that defeats the object of the parties in making the agreement; mere negligence, while not justifying rescission, may entitle the aggrieved party to nominal damages. |
Obligations and Contracts |
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Alma Jose vs. Javellana (25th January 2012) |
AK630213 664 SCRA 11 , 680 Phil. 10 , G.R. No. 158239 |
The dispute originated from a 1979 Deed of Conditional Sale where Margarita Marquez Alma Jose sold two parcels of land to Ramon Javellana. Payment was partially made upfront, with the balance due upon registration under the Torrens System, an obligation Margarita undertook. After Margarita and her son/attorney-in-fact Juvenal died, the obligation fell upon her daughter and sole heir, Priscilla Alma Jose, who allegedly failed to comply and instead started developing the properties, prompting Javellana to sue for specific performance. | An order denying a motion for reconsideration of a final order (such as an order dismissing a case) is itself a final order and thus appealable; the aggrieved party is entitled to a fresh period of 15 days from receipt of the denial order within which to file the notice of appeal, pursuant to the "fresh period rule" established in _Neypes v. Court of Appeals_, which applies retroactively to pending cases. |
Civil Procedure I |
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Balao, et al. vs. Macapagal-Arroyo, et al (13th December 2011) |
AK153249 678 Phil. 532 , G.R. No. 186050 , G.R. No. 186059 |
James M. Balao, a co-founder of the Cordillera Peoples Alliance (CPA), an organization advocating for indigenous peoples' rights, was abducted on September 17, 2008. Prior to his abduction, James had reported surveillance activities against him to his family and CPA colleagues, allegedly by state agents. The CPA had been linked by military sources to the Communist Party of the Philippines-New People's Army (CPP-NPA), and petitioners cited a pattern of harassment and violence against CPA members and other activists, suggesting James's abduction was politically motivated and part of a counter-insurgency campaign. | The privilege of the writ of amparo shall be denied if the allegations of an enforced disappearance are not proven by substantial evidence establishing state participation or acquiescence; however, government officials remain accountable for failing to conduct an investigation with extraordinary diligence, and the case may be remanded for continued investigation and monitoring by the trial court. Presidential immunity from suit is applicable in amparo proceedings for an incumbent president, and the doctrine of command responsibility, while not a basis for criminal liability in amparo, can be used to determine accountability for failure to investigate or prevent violations. |
Constitutional Law I |
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Bureau of Customs Employees Association (BOCEA) vs. Hon Teves, et al. (6th December 2011) |
AK564613 677 Phil. 636 , G.R. No. 181704 |
Republic Act No. 9335, the Attrition Act of 2005, was enacted to optimize the revenue-generation capability and collection of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). It aimed to encourage BIR and BOC officials and employees to exceed their revenue targets by establishing a system of rewards and sanctions, including a Rewards and Incentives Fund and a Revenue Performance Evaluation Board. The law covered all officials and employees of the BIR and BOC with at least six months of service. | Republic Act No. 9335 (Attrition Act of 2005) and its Implementing Rules and Regulations are constitutional, do not constitute an undue delegation of legislative power, do not violate the rights to equal protection, security of tenure, or due process of covered employees, and do not constitute a bill of attainder. |
Constitutional Law I |
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People vs. Trestiza (16th November 2011) |
AK906974 660 SCRA 407 , 676 Phil. 420 , G.R. No. 193833 |
The Supreme Court affirmed that police officers can be held liable for kidnapping when they act in their private capacity rather than in furtherance of official functions, upholding the conviction of PO1 Trestiza and his co-accused for kidnapping for ransom. |
Criminal Law II |
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Datu Michael Abas Kida vs. Senate of the Philippines (18th October 2011) |
AK191813 659 SCRA 270 , 675 Phil. 316 , G.R. No. 196271 , G.R. NO. 196305 , G.R. NO. 197221 , G.R. NO. 197282 , G.R. NO. 197392 , G.R. NO. 197454 |
RA No. 10153 reset the August 2011 ARMM elections to May 2013 to align with national and local polls. Petitioners challenged the law, claiming it violated ARMM’s autonomy, legislative processes, and the constitutional requirement for elective regional positions. | RA No. 10153 is constitutional; the synchronization of ARMM elections with national elections and the President’s power to appoint interim officials (OICs) are valid under the 1987 Constitution. |
Constitutional Law I Statutory Construction |
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Barayuga vs. Adventist University of the Philippines (17th August 2011) |
AK907241 655 SCRA 640 , G.R. No. 168008 |
The Adventist University of the Philippines (AUP) is a non-stock, non-profit domestic educational institution. Petitioner Petronilo J. Barayuga was appointed President of AUP by its Board of Trustees. Subsequent external and internal audits revealed alleged irregularities in his management style and financial transactions, leading the Board to consider his removal. The core of the dispute revolved around the validity of his removal and the length of his term as President. | An injunctive relief protects only a right *in esse*; where the plaintiff fails to demonstrate an existing right to be protected by injunction, the suit for injunction must be dismissed for lack of a cause of action. The petitioner's term of office as President of AUP was for two years as per AUP's amended By-Laws, not five years, and by the time of his removal, he was already serving in a hold-over capacity. |
Civil Procedure I |
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Magallona vs. Ermita (16th August 2011) |
AK124720 655 SCRA 476 , 671 Phil. 243 , G.R. No. 187167 |
The Philippines, an archipelagic state, enacted Republic Act No. 3046 in 1961 to define its maritime baselines. Following its ratification of the United Nations Convention on the Law of the Sea (UNCLOS III) in 1984, there arose a need to align domestic law with the Convention's specific requirements for archipelagic baselines, such as water-land ratio, maximum length of baselines, and conformity to the general configuration of the archipelago. UNCLOS III also established a deadline for coastal states to submit claims for an extended continental shelf. Consequently, Congress enacted RA 9522 in March 2009, amending RA 3046 to comply with UNCLOS III by optimizing basepoints, adjusting baseline lengths, and classifying the Kalayaan Island Group (KIG) and Scarborough Shoal as "regimes of islands" under the Republic, whose islands would generate their own maritime zones distinct from the main archipelago's baselines. | Republic Act No. 9522, which adjusts the Philippines' archipelagic baselines and classifies the Kalayaan Island Group and Scarborough Shoal as "regimes of islands" in accordance with UNCLOS III, is constitutional; it serves as a statutory mechanism for demarcating the country's maritime zones and does not result in the diminution of Philippine territory or sovereignty. |
Constitutional Law I |
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Gamboa vs. Finance Secretary Teves, et al. (28th June 2011) |
AK128498 668 Phil. 1 , G.R. No. 176579 |
The Philippine government, through the Presidential Commission on Good Government (PCGG), decided to privatize its shares in Philippine Telecommunications Investment Corporation (PTIC). PTIC was a significant shareholder in Philippine Long Distance Telephone Company (PLDT), a public utility. First Pacific Company Limited, a foreign entity, through its subsidiary Metro Pacific Assets Holdings, Inc. (MPAH), sought to acquire these government shares in PTIC. This impending acquisition raised concerns about potentially breaching the constitutional 60-40 Filipino-foreign ownership requirement in PLDT, as First Pacific already had substantial interests in PTIC, and consequently, in PLDT. | The term "capital" in Section 11, Article XII of the 1987 Constitution, pertaining to the 60% Filipino ownership requirement for public utilities, refers only to shares of stock that are entitled to vote in the election of directors, not the total outstanding capital stock which includes non-voting preferred shares. |
Constitutional Law I |
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Megan Sugar Corporation vs. Regional Trial Court of Iloilo, Branch 68, Dumangas, Iloilo (1st June 2011) |
AK127788 650 SCRA 100 , 665 Phil. 245 , G.R. No. 170352 |
New Frontier Sugar Corporation (NFSC) defaulted on a loan secured by real estate and chattel mortgages from Equitable PCI Bank (EPCIB). Due to financial difficulties, NFSC entered a Memorandum of Agreement (MOA) allowing Central Iloilo Milling Corporation (CIMICO) to operate its sugar mill. Subsequently, EPCIB foreclosed on the mortgaged properties. CIMICO then entered into another MOA with Megan Sugar Corporation (MEGAN), transferring its operational rights and obligations concerning the sugar mill to MEGAN. This transfer occurred amidst ongoing litigation involving NFSC, CIMICO, and EPCIB. | A party that actively participates in court proceedings through counsel, allows its officer to accompany said counsel, receives court orders and pleadings without repudiating the counsel's authority, and seeks affirmative relief from the court, is estopped from later questioning the counsel's authority and the court's jurisdiction over it, especially after receiving unfavorable rulings. |
Civil Procedure I |
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Navarro vs. Ermita (12th April 2011) |
AK213242 648 SCRA 400 , 663 Phil. 546 , G.R. No. 180050 |
Dinagat Islands was created as a province in 2006. Petitioners argued it violated LGC criteria for population (250,000) and land area (2,000 km²). After initial nullification by the Court in 2010, the case was reopened due to post-election implications for local officials, leading to the final validation of the province. | The Supreme Court ruled RA 9355 constitutional, exempting provinces composed of islands from the land area requirement under the LGC, and validated Dinagat Islands’ status as a province. |
Statutory Construction |
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League of Cities of the Philippines (LCP) vs. Commission on Elections (12th April 2011) |
AK614037 663 Phil. 496 , G.R. No. 176951 , G.R. No. 177499 , G.R. NO. 178056 |
Congress enacted 16 individual Republic Acts ("Cityhood Laws") converting specific municipalities into cities, incorporating exemption clauses that excused them from the P100 million income requirement established by R.A. No. 9009, which had amended the Local Government Code (LGC). These municipalities had cityhood bills pending before R.A. No. 9009's enactment. The League of Cities of the Philippines (LCP), representing existing cities, challenged these laws as unconstitutional for violating the LGC requirement that cityhood criteria be uniform and stated within the LGC itself, and for violating the equal protection clause. This led to a protracted legal battle involving multiple, conflicting Supreme Court rulings on the laws' validity, culminating in the February 15, 2011 Resolution upholding the laws, which petitioners sought to reconsider in the motion addressed by this present Resolution. | The Court's February 15, 2011 Resolution, upholding the constitutionality of the 16 Cityhood Laws, is affirmed, as the petitioners' procedural arguments regarding finality and jurisdiction, and substantive arguments regarding violations of the Constitution (Art. X, Secs. 6 & 10) and the Equal Protection Clause, are without merit; the prior judgment declaring the laws unconstitutional had not attained finality due to timely filed and entertained motions. |
Constitutional Law I Constitutional Law II Philosophy of Law Statutory Construction Equal Protection |
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Yusay vs. Court of Appeals (6th April 2011) |
AK797825 647 SCRA 269 , 662 Phil. 634 , G.R. No. 156684 |
Spouses Yusay owned land in Mandaluyong City, part of which they rented out. The City Council passed a resolution authorizing the City Mayor to initiate expropriation of the land for low-cost housing. The Yusays, fearing immediate action, filed certiorari and prohibition to annul the resolution. | Certiorari and prohibition do not lie to assail the issuance of a resolution by the Sanggunian Panglungsod authorizing expropriation because a resolution is a legislative act, not a judicial or quasi-judicial one. Furthermore, initiating expropriation requires an ordinance, not a resolution, under the Local Government Code. |
Constitutional Law II |
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General vs. Urro (29th March 2011) |
AK549891 646 SCRA 567 , 662 Phil. 132 , G.R. No. 191560 |
Then President Gloria Macapagal-Arroyo appointed several individuals to the NAPOLCOM, including General as an acting commissioner. Near the end of her term, she appointed Urro, de Guzman, and Escueta as permanent commissioners. General questioned these appointments, claiming they violated the ban on midnight appointments. | An acting appointee to a public office does not have the legal standing (cause of action) to file a quo warranto petition against a newly appointed individual to that same office. The court did not rule on the constitutionality of the new appointments. |
Constitutional Law II |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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Belongilot vs. Cua (24th November 2010) |
AK244573 636 SCRA 34 , G.R. No. 160933 |
The dispute arose from a long-standing agrarian reform case involving parcels of land in Bulacan owned by the petitioner's wife, which were forcibly occupied and converted into a fishpond by Juanito Constantino in 1979, leading to an ejectment suit under the Department of Agrarian Reform framework and subsequent procedural maneuvers that culminated in the petitioner's loss of possession despite a favorable final decision. | The Supreme Court held that the Ombudsman committed grave abuse of discretion by dismissing the complaint without properly assessing probable cause for violation of Section 3(e) of R.A. No. 3019, as the DARAB respondents' issuance of a TRO and injunction after the final and executed PARAD decision evidenced manifest partiality, evident bad faith, or gross inexcusable negligence, warranting the filing of criminal charges. |
Civil Procedure II Rule 45 vs Rule 65 |
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Land Bank of the Philippines vs. Ong (24th November 2010) |
AK275684 636 SCRA 266 , G.R. No. 190755 |
On March 18, 1996, the Spouses Johnson and Evangeline Sy obtained a PhP 16 million loan from Land Bank, secured by three residential lots, five cargo trucks, and a warehouse. The loan agreement included an acceleration clause. When the Spouses Sy found themselves unable to service the loan, they sought to transfer their obligation. | A bank that accepts a conditional payment from a third person for the assumption of a mortgage, and subsequently disapproves the application without notice while retaining the payment, is obligated to return the amount under the principle of unjust enrichment, as it has no legal ground to keep the money. |
Persons and Family Law Article 19 and 22 of the Civil Code |
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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 |
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Mitra vs. Commission on Elections (19th October 2010) |
AK877231 633 SCRA 580 , G.R. No. 191938 |
Abraham Kahlil Mitra, a three-term congressman whose district included Puerto Princesa City, intended to run for Governor of Palawan in the May 2010 elections. Due to the reclassification of Puerto Princesa City as a highly urbanized city, its residents became ineligible to vote for or be elected to provincial offices. To qualify for the gubernatorial race, Mitra needed to establish residence in a municipality within the province of Palawan for at least one year prior to the election. He declared Aborlan, Palawan as his new residence in his Certificate of Candidacy, which prompted private respondents to file a petition for its cancellation, alleging material misrepresentation. | The Supreme Court is constitutionally bound to exercise its certiorari jurisdiction to review and correct actions of the COMELEC when the latter commits grave abuse of discretion, such as when its appreciation of evidence is grossly unreasonable or when it uses subjective, non-legal standards in its evaluation, thereby transforming an error of judgment into a reviewable error of jurisdiction. |
Civil Procedure II Rule 64 and 65 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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