There are 599 results on the current subject filter
| Title | IDs & Reference #s | Background | Primary Holding | Subject Matter |
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Social Justice Society (SJS) vs. Dangerous Drugs Board, et al (3rd November 2008) |
AK613538 591 Phil. 393 , G.R. No. 157870 |
Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, was enacted to intensify the government's campaign against dangerous drugs. Section 36 of this Act mandated drug testing for various sectors of society. These provisions prompted challenges from different petitioners, questioning their validity on several constitutional grounds, leading to these consolidated petitions before the Supreme Court. | The mandatory drug testing requirement for candidates for public office (Sec. 36(g) of RA 9165) is unconstitutional because it imposes an additional qualification not found in the Constitution. Mandatory drug testing for persons accused of crimes (Sec. 36(f)) is also unconstitutional as it violates the right to privacy and the right against self-incrimination. However, mandatory random drug testing for students (Sec. 36(c)) and employees (Sec. 36(d)) is constitutional, being a reasonable exercise of the State's police power and, in the case of students, within the schools' _in loco parentis_ authority, and for employees, a reasonable regulation for workplace safety. |
Constitutional Law I |
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Province of North Cotabato vs. Government of the Republic of the Philippines Peace Panel on Ancestral Domain (GRP) (14th October 2008) |
AK025291 568 SCRA 402 , 589 Phil. 387 , G.R. No. 183591 , G.R. No. 183752 , G.R. No. 183893 , G.R. No. 183951 , G.R. No. 183962 |
The case arose from the long-standing armed conflict between the Philippine government and the Moro Islamic Liberation Front (MILF) in Mindanao. Decades of negotiations aimed at achieving peace led to various agreements, including the 2001 GRP-MILF Tripoli Agreement on Peace, which outlined security, rehabilitation, and ancestral domain aspects for further discussion. The MOA-AD represented the culmination of negotiations specifically on the Ancestral Domain aspect, intended to address historical grievances and establish a framework for Bangsamoro self-governance. | The Memorandum of Agreement on the Ancestral Domain (MOA-AD) is unconstitutional and contrary to law because its provisions, particularly the creation of the Bangsamoro Juridical Entity (BJE) under an "associative" relationship, violate the sovereignty and territorial integrity of the Republic of the Philippines, and the process of its negotiation failed to comply with the constitutional and statutory requirements for public consultation and the right to information. Furthermore, the Executive branch exceeded its authority by guaranteeing constitutional and legal amendments necessary for the MOA-AD's implementation, as such power rests solely with Congress and the sovereign people. |
Constitutional Law I Constitutional Law II Philosophy of Law |
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Securities and Exchange Commission vs. Interport Resources Corporation (6th October 2008) |
AK516001 567 SCRA 354 , 588 Phil. 651 , G.R. No. 135808 |
In 1994, IRC entered into a Memorandum of Agreement with Ganda Holdings Berhad (GHB) to acquire 100% of Ganda Energy Holdings, Inc. (GEHI). IRC also planned to acquire 67% of Philippine Racing Club, Inc. (PRCI). The SEC alleged that IRC failed to disclose these negotiations promptly and that some directors traded IRC shares using insider information. The SEC initiated an investigation, but the Court of Appeals issued an injunction, halting the SEC's actions. | The Supreme Court held that the SEC has the authority to investigate violations of the Revised Securities Act, and the absence of implementing rules does not render the provisions of the Act ineffective. The Court also ruled that the SEC's investigation interrupted the prescription period for filing charges. |
Philosophy of Law |
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Republic vs. Cagandahan (12th September 2008) |
AK425333 G.R. No. 166676 , 565 SCRA 72 |
The case arose from the unique situation of Jennifer Cagandahan, who was born with Congenital Adrenal Hyperplasia (CAH), a condition that causes a person with female chromosomes (XX) to develop ambiguous genitalia and secondary male characteristics due to excessive production of male hormones. Despite being registered as female at birth, Cagandahan's physical development and self-perception aligned with the male gender, prompting her to seek legal recognition of her identity by petitioning to correct her birth certificate. | Where a person is biologically or naturally intersex, the determining factor in their gender classification for legal and civil registry purposes is what the individual, having reached the age of majority, reasonably thinks of their own sex, supported by medical evidence of their condition. |
Persons and Family Law |
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Neri vs. Senate Committee on Accountability of Public Officers and Investigations, et al. (4th September 2008) |
AK278418 586 Phil. 135 , G.R. No. 180643 |
The case arose from a legislative inquiry conducted by respondent Senate Committees into the National Broadband Network (NBN) project, a government project awarded to Zhong Xing Telecommunications Equipment (ZTE). Petitioner Romulo L. Neri, then Director-General of the National Economic and Development Authority (NEDA), was a key figure in the evaluation of this project. During his testimony, he disclosed an alleged bribery attempt but invoked executive privilege when asked about his conversations with President Gloria Macapagal Arroyo regarding the NBN project, specifically on three questions. | The claim of presidential communications privilege, when properly invoked by the President or through the Executive Secretary concerning communications with close advisors on matters quintessential to the President's duties and responsibilities, is presumptively valid and can only be overcome by a specific, demonstrated, and compelling need by the investigating legislative body that is critical to the exercise of its legislative functions, a burden which the respondent Senate Committees failed to discharge in this case. |
Constitutional Law I |
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Abakada Guro Party List vs. Purisima (14th August 2008) |
AK884230 562 SCRA 251 , 584 Phil. 246 , G.R. No. 166715 |
Republic Act No. 9335, the Attrition Act of 2005, was enacted to improve the revenue-generation capabilities of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). The law established a system of rewards for officials and employees who exceed revenue targets and sanctions for those who fall short, funded by a Rewards and Incentives Fund and overseen by a Revenue Performance Evaluation Board for each agency. This legislative measure was part of broader tax reform efforts aimed at enhancing government revenue collection. | Section 12 of Republic Act No. 9335, creating a Joint Congressional Oversight Committee with the power to approve the Implementing Rules and Regulations (IRR) of the law, is unconstitutional as it constitutes an encroachment on executive power (implementation of laws) and violates the principles of separation of powers, bicameralism, and the presentment clause. However, the remainder of RA 9335 is constitutional and remains in force and effect due to the law's separability clause. |
Constitutional Law I Statutory Construction |
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In the Matter of the Allegations Contained in the Columns of Mr. Amado P. Macasaet Published in Malaya Dated September 18, 19, 20 and 21, 2007 (8th August 2008) |
AK206148 583 Phil. 391 , A.M. No. 07-09-13-SC |
Amado Macasaet, a columnist for the newspaper Malaya, published a series of articles in September 2007 alleging that a Supreme Court Justice had received bribes in connection with a case involving a Filipino-Chinese businessman. The articles were based on information from confidential sources and claimed that five boxes containing ₱10 million were delivered to the Court. The Court initiated contempt proceedings against Macasaet for publishing unverified allegations that damaged the Court's reputation. | The Supreme Court held that Amado Macasaet was guilty of indirect contempt for publishing false and baseless allegations of bribery within the Court, which tended to degrade the administration of justice. |
Philosophy of Law |
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Mata vs. Agravante (6th August 2008) |
AK929535 561 SCRA 66 , G.R. No. 147597 |
The dispute originated from a labor issue where former security guards of the Bessang Pass Security Agency, the respondents, filed complaints against their employer, the petitioner, for non-payment of salaries and other benefits. To pursue their claims, they not only filed a case with the National Labor Relations Commission (NLRC) but also sought the cancellation of the agency's license from the Philippine National Police (PNP), sending copies of their complaint to multiple government bodies. | The exercise of a legal right, such as filing complaints with appropriate government agencies to seek redress for grievances, does not give rise to liability for damages unless it is proven that such an act was done with malice or bad faith and with the intent to injure another, in violation of the principle of abuse of rights under Articles 19 and 21 of the Civil Code. |
Persons and Family Law Article 19, 20, and 21, Civil Code |
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Akbayan Citizens Action Party ("AKBAYAN"), et al. vs. Aquino, et al. (16th July 2008) |
AK279548 580 Phil. 422 , G.R. No. 170516 |
The case arose from the negotiation of the Japan-Philippines Economic Partnership Agreement (JPEPA), a comprehensive bilateral free trade agreement between the Philippines and Japan. Amidst concerns about transparency and the potential impact of the agreement on various national interests, petitioners sought access to the complete JPEPA documents, including the initial offers exchanged between the two countries during the negotiation phase, which the government had kept confidential. | Offers exchanged by parties during diplomatic negotiations for a treaty, such as the JPEPA, are covered by executive privilege, specifically the diplomatic negotiations privilege, and remain confidential even after the main treaty text is published, unless a sufficient showing of public interest or need to overcome the privilege is demonstrated by the requesting party. |
Constitutional Law I |
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Sema vs. Commission on Elections, et al. (16th July 2008) |
AK715226 580 Phil. 623 , G.R. No. 177597 |
The 1987 Constitution apportioned two legislative districts for Maguindanao, with the first district including Cotabato City and eight municipalities. Maguindanao is part of the Autonomous Region in Muslim Mindanao (ARMM), but Cotabato City, despite being in its first legislative district, is not part of ARMM, having voted against inclusion. Republic Act No. 9054, amending the ARMM Organic Act, granted the ARMM Regional Assembly the power to create provinces. This grant of power and its subsequent exercise led to the legal disputes in this case. | The power to create provinces and cities, which inherently includes the power to create legislative districts, is vested exclusively in Congress and cannot be delegated to the ARMM Regional Assembly; therefore, any province or city created by the ARMM Regional Assembly under such delegated authority is void. |
Constitutional Law I |
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Figueroa vs. People (14th July 2008) |
AK461685 558 SCRA 63 , 580 Phil. 58 , G.R. No. 147406 |
The case arose from a criminal information for reckless imprudence resulting in homicide filed against the petitioner, Venancio Figueroa y Cervantes. The core issue that reached the Supreme Court revolved around whether the petitioner was barred by estoppel by laches from questioning the jurisdiction of the Regional Trial Court (RTC) which tried and convicted him, given that he only raised the jurisdictional challenge for the first time during his appeal to the Court of Appeals. | A litigant is not estopped by laches from assailing the jurisdiction of a trial court over the subject matter for the first time on appeal if the challenge is made without unreasonable delay and the factual circumstances do not mirror the exceptional scenario of _Tijam v. Sibonghanoy_, where the jurisdictional challenge was raised only after almost 15 years. The general rule that a court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal, prevails, as jurisdiction is conferred by law and cannot be vested by consent or waiver of the parties. |
Civil Procedure I |
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Gobenciong vs. Court of Appeals (31st March 2008) |
AK728096 550 SCRA 502 , 573 Phil. 613 , G.R. No. 159883 |
Dr. Pedro Gobenciong, an administrative officer at a regional hospital, was administratively charged for falsification of public documents and misconduct related to the allegedly anomalous purchase of a hemoanalyzer, leading to preventive suspension and subsequent disciplinary action by the Ombudsman. | The Supreme Court held that the Ombudsman's preventive suspension orders are immediately executory, the Ombudsman's disciplinary authority is not merely recommendatory but includes ensuring compliance, and RA 6770 does not constitute an unconstitutional delegation of authority or violate the equal protection clause. |
Constitutional Law II Due Process |
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Planters Products, Inc., vs. Fertiphil Corporation (14th March 2008) |
AK870529 572 Phil. 270 , G.R. No. 166006 |
The case arose from the issuance of LOI No. 1465 by then-President Ferdinand Marcos, which mandated the Fertilizer and Pesticide Authority (FPA) to include a P10 capital recovery component (CRC) per bag in its fertilizer pricing formula. This CRC was to be collected until adequate capital was raised to make Planters Products, Inc. (PPI), a private corporation, financially viable. Fertiphil Corporation, another private entity engaged in the fertilizer business, paid these levies and, after the 1986 EDSA Revolution, sought a refund from PPI, contending the LOI was unconstitutional. | Letter of Instruction (LOI) No. 1465, which imposed a capital recovery component on the sale of fertilizers to benefit Planters Products, Inc. (PPI), is unconstitutional because it violates the public purpose requirement inherent in the power of taxation, as the levy was designed to aid a private enterprise rather than serve a public interest. |
Constitutional Law I |
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Bier vs. Bier, 547 SCRA 123 (27th February 2008) |
AK808895 547 SCRA 123 , G.R. No. 173294 |
Petitioner Renne Enrique Bier, an electronics technician based in Saudi Arabia, and respondent Ma. Lourdes A. Bier married after a six-month long-distance courtship. For the first three years of their marriage, the relationship was positive, with the respondent described as a sweet, loving, and caring wife. The couple maintained residences in both the Philippines and Saudi Arabia, shuttling between the two countries to spend time together. However, after three years, the respondent's behavior allegedly changed drastically, leading to the eventual breakdown of the marriage and her departure for the United States, prompting the petitioner to file for nullity. | A petition for declaration of nullity of marriage based on psychological incapacity under Article 36 of the Family Code requires clear and convincing proof of the gravity, juridical antecedence, and incurability of the alleged incapacity; failure to establish these three essential characteristics, especially the root cause of the disorder and its existence at the inception of the marriage, is fatal to the petition, even if the party's post-marital behavior is shown to be irresponsible or neglectful. |
Persons and Family Law Article 36 of the Family Code |
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Chavez vs. Gonzales, et al. (15th February 2008) |
AK123614 569 Phil. 155 , G.R. No. 168338 |
The case arose from the political controversy surrounding the "Hello Garci" tapes, which allegedly contained a wiretapped phone conversation between then-President Gloria Macapagal Arroyo and a high-ranking COMELEC official, purportedly discussing the rigging of the 2004 national election results. Following the public emergence of these tapes, the Secretary of Justice and the NTC issued warnings to the media against their dissemination, citing potential violations of the Anti-Wiretapping Act and program standards for broadcast media. | Governmental warnings or press statements made by officials in their official capacity that threaten sanctions for the publication or broadcast of specific content, without satisfying the clear and present danger test, constitute an unconstitutional prior restraint on freedom of speech and of the press. |
Constitutional Law II Freedom of Expression |
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Trillanes IV vs. Judge Pimentel, Sr., et al. (7th February 2008) |
AK688993 578 Phil. 1002 , G.R. No. 179817 |
The case arose after the "Oakwood Incident" on July 27, 2003, where over 300 armed soldiers, led by junior AFP officers including petitioner Antonio F. Trillanes IV, took over the Oakwood Premier Apartments in Makati City, demanding the resignation of the President and other key officials. Following their surrender, Trillanes was charged with coup d'etat and remained in detention. While detained, he ran for and won a seat in the Senate in the May 2007 elections. | A detention prisoner, even if an elected public official like a Senator, cannot be allowed to leave detention to attend legislative sessions or perform other official functions outside their place of confinement, as the fact of lawful detention inherently curtails rights and privileges, including the full exercise of civil and political rights associated with public office, especially when bail has been denied due to strong evidence of guilt for a non-bailable offense. |
Constitutional Law I |
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Heirs of Marcelino Doronio vs. Heirs of Fortunato Doronio (27th December 2007) |
AK570269 541 SCRA 479 , 565 Phil. 766 , G.R. No. 169454 |
Spouses Simeon Doronio and Cornelia Gante owned a parcel of land covered by Original Certificate of Title No. 352. They had children, including Marcelino and Fortunato Doronio. Simeon and Cornelia executed a private deed of donation propter nuptias in favor of Marcelino and his wife Veronica Pico. The description in the deed of donation differed slightly from OCT No. 352 regarding adjacent property owners. Petitioners, heirs of Marcelino, registered the deed through a petition case without naming respondents, heirs of Fortunato, leading to a new TCT in their predecessor's name, covering the entire property. Respondents contested this, claiming only half was intended for donation and the donation was invalid. | The private deed of donation propter nuptias of real property executed in 1919 under the Old Civil Code is void for not being in a public instrument; therefore, it conveyed no title. |
Property and Land Law |
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Garcia vs. Social Security Commission Legal and Collection (17th December 2007) |
AK000744 540 SCRA 456 , 565 Phil. 193 , G.R. No. 170735 |
Impact Corporation, a manufacturer of aluminum tube containers, experienced financial difficulties in 1978, leading to labor unrest and eventual cessation of operations. Despite collecting SSS contributions from its employees, the company failed to remit them. The SSS pursued legal actions to recover the unremitted contributions. | The Supreme Court upheld that as the only surviving director of the now-dissolved Impact Corporation, Immaculada L. Garcia was liable for unpaid Social Security System (SSS) contributions and penalties imposed under the Social Security Law. |
Statutory Construction |
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Manotok Realty, Inc. vs. CLT Realty Development Corporation (14th December 2007) |
AK258876 540 SCRA 304 , 565 Phil. 59 , G.R. No. 123346 , G.R. No. 134385 |
The dispute centers on ownership claims over portions of the vast Maysilo Estate, all purportedly originating from OCT No. 994. Conflicting claims arose between Manotok Realty and Manotok Estate Corporation versus CLT Realty Development Corporation in one case, and Araneta Institute of Agriculture, Inc. versus the Heirs of Jose B. Dimson in the other. These cases reached the Supreme Court after conflicting decisions in the lower courts and the Court of Appeals concerning the validity of the parties' titles. Prior Supreme Court decisions in MWSS v. Court of Appeals and Gonzaga v. Court of Appeals had previously addressed claims emanating from OCT No. 994, but inconsistencies and new factual evidence necessitated a re-examination. | The Supreme Court remanded the consolidated cases to a Special Division of the Court of Appeals to conduct further proceedings and factually determine which of the contending parties' titles, if any, are validly derived from the genuine Original Certificate of Title No. 994 registered on May 3, 1917, and to resolve other factual issues crucial to determining rightful land ownership. Titles purportedly derived from a non-existent OCT No. 994 dated April 19, 1917 are declared void. |
Property and Land Law |
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Salvador vs. Mapa (28th November 2007) |
AK471249 539 SCRA 34 , G.R. No. 135080 |
During the Marcos administration, government financial institutions granted loans at the behest of high officials to cronies, often under-collateralized and to undercapitalized entities, leading to significant losses for the government; post-1986 EDSA Revolution, efforts to recover such ill-gotten wealth prompted the creation of investigative bodies, including the Presidential Ad Hoc Fact-Finding Committee on Behest Loans under Administrative Order No. 13 in 1992 to inventory and recommend recovery actions for these loans. | The prescriptive period for violations of Republic Act No. 3019 in behest loan cases commences from the date of discovery by the Presidential Ad Hoc Fact-Finding Committee on Behest Loans in 1992, not from the commission of the acts, and Administrative Order No. 13 and Memorandum Order No. 61 are not ex post facto laws as they are not penal in nature. |
Civil Procedure II Rule 45 vs. Rule 65 |
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Silverio vs. Republic (19th October 2007) |
AK402555 537 SCRA 373 , G.R. No. 174689 |
Petitioner Rommel Silverio, born anatomically male, identified as a female from childhood and felt "trapped in a man's body." After consulting with doctors, he underwent hormone therapy, breast augmentation, and ultimately, a sex reassignment surgery in Thailand. Living as a female and engaged to be married to a man, he sought to have his public records, specifically his birth certificate, reflect his new identity and physical state by changing his first name and sex entry. | Philippine law does not permit a person who has undergone sex reassignment surgery to change their name and sex as recorded in their birth certificate to align with their new physical characteristics, as there is no statute that recognizes or governs the effects of such a procedure. |
Persons and Family Law Family Code, Articles 1 and 2 |
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Pharmaceutical and Health Care Assoc. of the Phils. vs. Health Sec. Duque III (9th October 2007) |
AK573831 561 Phil. 386 , G.R. No. 173034 |
Executive Order No. 51, "The Milk Code," was issued in 1986 to give effect to Article 11 of the International Code of Marketing of Breastmilk Substitutes (ICMBS), aiming to protect and promote breastfeeding. Over the years, the World Health Assembly (WHA) adopted various resolutions recommending stricter measures for marketing breastmilk substitutes, including absolute bans on advertising and promotion for certain age groups. The Department of Health (DOH), citing these international instruments and its mandate under the Milk Code and the Administrative Code, issued A.O. No. 2006-0012 (RIRR) to update the implementing rules of the Milk Code, leading to this legal challenge by manufacturers of breastmilk substitutes. | The Department of Health (DOH) exceeded its rule-making authority when it issued RIRR provisions (Sections 4(f), 11, and 46) that absolutely prohibited advertising, promotions, and sponsorships of breastmilk substitutes for infants and young children up to 24 months and imposed administrative fines not authorized by the Milk Code (E.O. No. 51). While the DOH has the power to issue rules to implement the Milk Code, these rules cannot expand, modify, or contradict the parent statute; international instruments like World Health Assembly (WHA) Resolutions, unless transformed into domestic law through legislation or qualifying as customary international law, cannot be implemented by executive agencies as if they were binding domestic law. |
Constitutional Law I |
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Heirs of Marcelina Arzadon-Crisologo vs. Rañon (5th September 2007) |
AK869857 532 SCRA 391 , 559 Phil. 169 , G.R. No. 171068 |
Agrifina Rañon filed a complaint against spouses Montemayor to quiet title over a residential lot, claiming ownership based on long and continuous possession since 1962. The Heirs of Arzadon-Crisologo intervened, asserting their rights as successors-in-interest of the original owners and claiming that Rañon's possession was not in good faith and did not ripen into ownership. The spouses Montemayor were later dropped as parties as they had repurchased the property from the Arzadons. The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the Arzadon heirs, but the Regional Trial Court (RTC) reversed this decision, favoring the Rañons through acquisitive prescription. The Court of Appeals affirmed the RTC’s decision. | The respondents, Heirs of Agrifina Rañon, validly acquired ownership of the subject property through extraordinary acquisitive prescription because they demonstrated continuous, peaceful, public, notorious, uninterrupted, and adverse possession in the concept of an owner for over thirty years. |
Property and Land Law |
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Commissioner of Internal Revenue vs. Primetown Property Group, Inc. (28th August 2007) |
AK150634 531 SCRA 436 , G.R. No. 162155 |
The case originated from a claim for a tax refund by Primetown Property Group, Inc. (Primetown) for taxes paid in 1997. Due to the Asian Financial Crisis, the real estate industry slowed down, causing Primetown to suffer significant losses for that year. Despite these losses, the company had paid quarterly corporate income taxes and remitted creditable withholding taxes. Believing it was not liable for income tax due to its net loss, Primetown filed an administrative claim for a refund with the Bureau of Internal Revenue (BIR), which was not acted upon, prompting the company to seek judicial relief. | A "year" for the purpose of computing legal periods is understood to be twelve calendar months, as provided in Section 31, Chapter VIII, Book I of the Administrative Code of 1987, which has impliedly repealed the definition of a "year" as 365 days under Article 13 of the Civil Code. |
Persons and Family Law Statutory Construction Article 13, Civil Code |
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Cemco Holdings, Inc. vs. National Life Insurance Company of the Philippines, Inc. (7th August 2007) |
AK555743 529 SCRA 355 , 556 Phil. 198 , G.R. NO. 171815 |
Cemco Holdings acquired shares in Union Cement Holdings Corporation (UCHC), a non-listed company holding 60.51% of Union Cement Corporation (UCC), a publicly listed firm. This indirect acquisition increased Cemco’s beneficial ownership in UCC from 17.03% to 53%. National Life Insurance, a minority UCC shareholder, demanded Cemco comply with the Mandatory Tender Offer Rule. After Cemco refused, National Life filed a complaint with the SEC. | The Supreme Court affirmed that the Mandatory Tender Offer Rule under the Securities Regulation Code applies to indirect acquisitions of shares in a publicly listed company, protecting minority shareholders. The Securities and Exchange Commission (SEC) had jurisdiction to order Cemco Holdings to conduct a tender offer after it acquired indirect control of Union Cement Corporation (UCC) through purchasing shares in its holding company. |
Statutory Construction |
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National Electrification Administration vs. Morales (24th July 2007) |
AK115653 528 SCRA 79 , 555 Phil. 74 , G.R. No. 154200 |
Danilo Morales and other employees of the National Electrification Administration (NEA) filed a class suit against NEA for the payment of various allowances and longevity pay purportedly authorized under Republic Act No. 6758 (Compensation and Classification Act of 1989). The RTC granted their petition, ordering NEA to settle their claims. | A judgment directing a government-owned or controlled corporation (GOCC) to "settle the claims" of its employees is a special judgment for the performance of an act other than the payment of a specific sum of money, and its execution cannot be enforced through garnishment; furthermore, even if a GOCC's funds can generally be garnished, a claim for payment of a judgment award against it must first be filed with the Commission on Audit (COA) before execution can proceed. |
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 |
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Bantay Republic Act or BA-RA 7941 vs. COMELEC (4th May 2007) |
AK522247 551 Phil. 1 , G.R. No. 177271 , G.R. NO. 177314 |
The case arose from the upcoming May 14, 2007 party-list elections. Various groups filed manifestations of intent to participate, and some were accredited by the COMELEC. Public perception grew that some individuals behind these accredited party-list groups did not genuinely represent marginalized and underrepresented sectors. Petitioners, concerned about the qualifications and sectoral representation of these nominees, sought the disclosure of their names from the COMELEC, which the latter refused, leading to these petitions. | The Commission on Elections has a constitutional duty to disclose to the public the names of party-list nominees, as this is a matter of public concern falling under the people's right to information; Section 7 of R.A. No. 7941, which states that "The names of the party-list nominees shall not be shown on the certified list," only prohibits the inclusion of such names on the certified list posted in polling places on election day and does not constitute an absolute bar to their disclosure through other means before the election. |
Constitutional Law I |
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Rev. Fr. Cayat vs. COMELEC (1st Div.) (24th April 2007) |
AK957651 550 Phil. 209 , G.R. No. 163776 , G.R. No. 165736 |
Rev. Fr. Nardo B. Cayat and Thomas R. Palileng, Sr. were candidates for Mayor of Buguias, Benguet in the May 10, 2004 local elections. Cayat had been previously convicted by final judgment for Forcible Acts of Lasciviousness, a crime involving moral turpitude, and was under probation when he filed his certificate of candidacy. This conviction became the basis for Palileng's petition to disqualify Cayat. | A candidate disqualified by final judgment before an election cannot be voted for, and votes cast for him shall not be counted; consequently, the candidate who is the sole remaining qualified candidate does not merely take second place but is the only placer and is entitled to be proclaimed. |
Constitutional Law I |
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Citizen’s Battle Against Corruption (CIBAC) vs. COMELEC (13th April 2007) |
AK084300 549 Phil. 76 , G.R. No. 172103 |
The dispute arose from the allocation of party-list seats in the House of Representatives following the May 2004 National and Local Elections. After petitioner CIBAC was proclaimed as having qualified for one seat by receiving the required two percent (2%) of the total votes cast for party-list representatives, a controversy emerged regarding its entitlement to an additional seat, hinging on the correct formula for computation to be used by the COMELEC. | The correct and prevailing formula for computing additional seats for qualified party-list groups is the one established in *Veterans Federation Party v. COMELEC*, which is: (Number of votes of concerned party / Number of votes of first party) x Number of *additional* seats allocated to the first party. A party-list group must obtain an exact whole number in this computation to be entitled to an additional seat; fractions are not rounded up. |
Constitutional Law I |
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Republic vs. Lacap (2nd March 2007) |
AK609364 G.R. No. 158253 , 517 SCRA 255 |
The District Engineer of Pampanga initiated a public bidding for the concreting of Sitio 5 Bahay Pare. Carlito Lacap, doing business as Carwin Construction and Construction Supply, was one of three pre-qualified contractors. After submitting the lowest bid, Lacap was awarded the contract by the Department of Public Works and Highways (DPWH). A formal Contract Agreement was executed, and Lacap proceeded with and completed the project. The dispute arose when the government, through the DPWH, refused to release the payment for the completed project upon the disapproval of the District Auditor of the Commission on Audit (COA). | A contractor with an expired license who fully completes a government project is entitled to payment, as the Contractor's License Law (R.A. No. 4566) does not declare contracts entered into under such circumstances as void. The government cannot refuse payment and retain the benefits of the completed work, as this would constitute unjust enrichment under Article 22 of the Civil Code. |
Persons and Family Law Article 22 of the Civil Code |
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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 |
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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 |
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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 |
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Golangco vs. Fung (16th October 2006) |
AK531157 504 SCRA 321 , G.R. No. 147640 , G.R. No. 147762 |
The case arises from complaints about excessive placement fees charged by recruitment agencies for overseas employment, leading to investigations by the Philippine Overseas Employment Administration (POEA) under the Department of Labor and Employment (DOLE) to enforce labor laws against illegal recruitment practices, including non-transferability of recruitment licenses. | A public officer's warrantless arrest during a legitimate entrapment operation, based on reasonable belief of violation of labor laws prohibiting unauthorized recruitment activities, does not constitute administrative offenses like oppression or grave misconduct when performed in good faith, though courts lack jurisdiction to review Ombudsman findings of probable cause in criminal cases. |
Civil Procedure II Rule 43 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
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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 |
On February 24, 2006, amidst alleged conspiracies by political opposition, leftist insurgents (NDF-CPP-NPA), and military adventurists to overthrow the government, President Gloria Macapagal-Arroyo issued PP 1017, declaring a state of national emergency. This declaration cited threats to the democratic Philippine State, including plots to unseat or assassinate the President, magnified by certain media segments, and actions adversely affecting the economy and national security. On the same day, G.O. No. 5 was issued to implement PP 1017, directing the AFP and PNP to suppress acts of terrorism and lawless violence. These issuances followed a series of events, including the escape of Magdalo Group members, discovery of "Oplan Hackle I" (a plot for bombings and assassinations), recapture of Lt. San Juan with subversive documents, alleged defection plans within the PNP-SAF, and confessions by military officers about plans to join anti-Arroyo protests. | The President has the constitutional power to declare a state of national emergency and call out the Armed Forces to prevent or suppress lawless violence under Section 18, Article VII of the Constitution. However, such a declaration does not authorize the President to (1) issue decrees, (2) direct the AFP to enforce laws unrelated to suppressing lawless violence, (3) impose prior restraint on the press, or (4) take over privately-owned public utilities or businesses affected with public interest without legislative authority under Section 17, Article XII of the Constitution. General Order No. 5 is constitutional in providing a standard for the AFP and PNP to implement PP 1017, but its reference to undefined "acts of terrorism" is unconstitutional. |
Constitutional Law I Constitutional Law II Philosophy of Law |
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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 various Senate inquiries into matters of public concern, including the North Luzon Railways (NorthRail) Project, the "Gloriagate Scandal" involving alleged electoral fraud and wiretapping, and the fertilizer fund scam. Several executive officials invited to these hearings declined to attend, citing E.O. 464, which President Gloria Macapagal-Arroyo issued on September 28, 2005. This prompted multiple petitioners, including the Senate, legislators, and public interest groups, to challenge the constitutionality of E.O. 464 before the Supreme Court. | Executive Order No. 464 is unconstitutional in part: Sections 2(b) and 3 are void because they allow executive officials to evade congressional inquiries without a specific and properly invoked claim of executive privilege by the President or the Executive Secretary (by order of the President), thereby unduly infringing upon the legislative power of inquiry. Section 1 is valid when construed to apply only to the Question Hour (Art. VI, Sec. 22, Constitution), and Section 2(a) is valid as an internal guideline for the executive department concerning information that may be considered privileged. |
Constitutional Law I Philosophy of Law Statutory Construction |
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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 |
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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 |
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Antonio vs. Reyes (10th March 2006) |
AK471421 484 SCRA 353 , G.R. No. 155800 |
Petitioner Leonilo Antonio and respondent Marie Ivonne Reyes met in August 1989 and married in 1990. Their union produced a child who died five months after birth. The couple's relationship quickly deteriorated due to what the petitioner described as the respondent's unusual and deceitful behavior. After a brief separation and a failed attempt at reconciliation, the petitioner left the respondent for good in November 1991. This led him to file a petition for nullity of marriage, claiming that the respondent's constant and elaborate fabrications about her life were manifestations of a deep-seated psychological incapacity to assume the fundamental duties of marriage. | A party's pathological inability to abide by the truth, manifesting as a persistent and constant pattern of fabricating stories about one's self, occupation, and background, is a psychological incapacity that renders one incognitive of the essential marital obligations of mutual trust, respect, and fidelity, and thus constitutes a valid ground for the declaration of nullity of marriage under Article 36 of the Family Code. |
Persons and Family Law Article 36, Family Code |
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Executive Secretary vs. Southwing Industries, Inc. (20th February 2006) |
AK861204 518 Phil. 103 , G.R. No. 164171 , G.R. No. 164172 , G.R. No. 168741 |
On December 12, 2002, President Gloria Macapagal-Arroyo issued Executive Order No. 156, "Providing for a Comprehensive Industrial Policy and Directions for the Motor Vehicle Development Program and its Implementing Guidelines." Article 2, Section 3.1 of EO 156 prohibited the importation into the country, inclusive of the Subic Bay Freeport, of all types of used motor vehicles, subject to limited exceptions. This was intended to rationalize the importation of used motor vehicles and enhance the competitiveness of the domestic motor vehicle manufacturing industry. Respondents, entities operating within the Subic Bay Freeport and engaged in the business of importing and trading used motor vehicles, challenged this provision. | Article 2, Section 3.1 of Executive Order No. 156, prohibiting the importation of used motor vehicles, is valid and constitutional in its application to the Philippine territory outside the secured area of the Subic Bay Freeport, but it is ultra vires and void in its application to the presently secured fenced-in former Subic Naval Base area (the "Secured Area" of the Subic Bay Freeport as defined in EO 97-A), because such application exceeds the President's delegated authority and unreasonably modifies the freeport status established by RA 7227. |
Constitutional Law I |
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Radio Communications of the Philippines, Inc. vs. Verchez (31st January 2006) |
AK180962 481 SCRA 384 , G.R. No. 164349 |
On January 21, 1991, Editha Hebron Verchez was confined at the Sorsogon Provincial Hospital. Her daughter, Grace Verchez-Infante, sent an urgent telegram through RCPI to her sister, Zenaida Verchez-Catibog, in Quezon City, with the message "Send check money Mommy hospital." The purpose was to secure immediate financial aid for their mother's medical needs. The failure to receive a timely response caused distress and confusion within the family, leading them to believe Zenaida was ignoring their plea for help. | A telecommunications company that fails to deliver a telegram promptly due to its own negligence is liable for damages; its liability is based on _culpa contractual_ to the sender and quasi-delict to the intended recipient and other affected family members. Gross negligence in the performance of its contractual obligation, such as an inordinate delay without notifying the sender, amounts to bad faith and justifies the award of moral damages. |
Persons and Family Law Article 26, New Civil Code |
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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 |
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