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Funa vs. Exec. Sec. Ermita, et al.

11th February 2010

ak819913
626 Phil. 218 , G.R. No. 184740
Primary Holding
The designation of a Department Undersecretary (a deputy of a Cabinet Member) to concurrently serve as Officer-in-Charge of an attached agency, such as MARINA, is unconstitutional for violating Section 13, Article VII of the 1987 Constitution, which imposes a stricter prohibition against holding multiple offices on the President, Vice-President, Members of the Cabinet, and their deputies or assistants, allowing exceptions only when expressly provided in the Constitution itself.
Background
The case arose from the President's designation of respondent Maria Elena H. Bautista, then DOTC Undersecretary for Maritime Transport, as Officer-in-Charge (OIC) of the Maritime Industry Authority (MARINA) on September 1, 2008, following the resignation of the MARINA Administrator. This designation was made in a concurrent capacity with her existing role as DOTC Undersecretary.
Constitutional Law I

Soriano vs. People

1st February 2010

ak193031
625 Phil. 33 , G.R. No. 162336
Primary Holding
A bank officer violates the DOSRI law (Section 83 of RA 337) when he acquires bank funds for his personal benefit, even if such acquisition was facilitated by a fraudulent loan application using a third party's name; such fraudulent acquisition does not negate the "indirect borrowing" and can concurrently constitute the crime of estafa through falsification of commercial documents, as the officer holds the funds in a fiduciary capacity and misappropriates them.
Background
The Office of Special Investigation (OSI) of the Bangko Sentral ng Pilipinas (BSP) transmitted a letter with five affidavits to the Department of Justice (DOJ), alleging that Hilario P. Soriano, then president of the Rural Bank of San Miguel (Bulacan), Inc. (RBSM), orchestrated a fraudulent P8 million loan. The loan appeared in the name of spouses Enrico and Amalia Carlos, who denied applying for or receiving it. It was alleged that Soriano ordered, facilitated, and received the loan proceeds without board authorization or proper reporting, using an unsuspecting depositor's name.
Criminal Law II
Estafa

Sps. Tongson vs. Emergency Pawnshop Bula, Inc., et al.

15th January 2010

ak781820
624 Phil. 146 , G.R. No. 167874
Primary Holding
Fraud committed during the consummation stage of a contract of sale, such as the issuance of a worthless check for payment, does not constitute causal fraud (dolo causante) that vitiates consent and annuls the contract; rather, it is incidental fraud (dolo incidente) and a substantial breach of the buyer's obligation to pay, which entitles the seller to rescind the contract under Article 1191 of the Civil Code.
Background
The dispute arose from an agreement for the sale of a 364-square meter parcel of land in Davao City by the Spouses Tongson to Danilo R. Napala for P3,000,000. The transaction involved the execution of a Deed of Absolute Sale indicating a lower consideration, a partial cash payment, and a postdated check for the substantial balance, which was subsequently dishonored.
Obligations and Contracts

Yuchengco vs. Manila Chronicle Publishing Corporation

25th November 2009

ak525473
605 SCRA 684 , G.R. No. 184315
Primary Holding
When actual malice (malice in fact) is proven, the defense that libelous articles are qualifiedly privileged communications becomes futile, as such a defense merely negates the legal presumption of malice (malice in law) but does not overcome proven actual malice.
Background
The case arose from a business rivalry between petitioner Alfonso T. Yuchengco and respondent Roberto Coyiuto, Jr., particularly concerning their competing interests for control over Oriental Petroleum Mineral Corporation. In the months leading up to a crucial stockholders' meeting for Oriental, a series of articles critical of Yuchengco were published in The Manila Chronicle, a newspaper owned and controlled by Coyiuto. These articles formed the basis of Yuchengco's civil complaint for damages due to libel.
Persons and Family Law
Article 33, Civil Code

Office of the Solicitor General vs. Ayala Land

18th September 2009

ak679178
600 SCRA 617 , 616 Phil. 587 , G.R. No. 177056
Primary Holding
Shopping mall operators cannot be legally compelled to provide free parking spaces to their patrons and the general public under the National Building Code and its Implementing Rules and Regulations.
Background
The case arose from a Senate investigation into the legality of shopping malls charging parking fees. The Senate Committees concluded that charging parking fees was contrary to the National Building Code and recommended the Office of the Solicitor General (OSG) to enjoin the practice. Subsequently, the OSG filed a petition seeking to prohibit mall operators from collecting parking fees, arguing that the National Building Code impliedly mandates free parking.
Constitutional Law II

Pundaodaya vs. Commission on Elections, et al.

17th September 2009

ak663988
616 Phil. 167 , G.R. No. 179313
Primary Holding
To successfully effect a change of domicile for election purposes, a candidate must demonstrate by clear and positive proof: (1) an actual removal or an actual change of domicile; (2) a bona fide intention of abandoning the former place of residence and establishing a new one; and (3) definite acts which correspond with that purpose. Mere registration as a voter or voting in a few elections in a locality is not conclusive proof of domicile.
Background
The case arose from the May 14, 2007 Synchronized National and Local Elections. Arsenio Densing Noble filed a Certificate of Candidacy for municipal mayor of Kinoguitan, Misamis Oriental, claiming 15 years of residency. Makil U. Pundaodaya, whose wife Judith Pundaodaya was also a mayoral candidate, filed a petition to disqualify Noble, alleging he lacked the residency qualification as he was actually a resident of Lapasan, Cagayan de Oro City.
Constitutional Law I

Pobre vs. Defensor-Santiago

25th August 2009

ak600796
597 SCRA 1 , A.C. No. 7399
Primary Holding
Statements made by a Senator during a Senate speech, even if offensive and violative of a lawyer's ethical duties towards the courts, are covered by parliamentary immunity under Article VI, Section 11 of the Constitution and cannot be the basis for disciplinary action by the Court, although such immunity is intended for the benefit of the legislative institution and the people, not for personal attacks.
Background
The case arose following Senator Miriam Defensor-Santiago's privilege speech on the Senate floor where she expressed extreme frustration and used insulting language directed at the Supreme Court and its members, particularly then Chief Justice Artemio Panganiban, after the Judicial and Bar Council (JBC) effectively excluded non-incumbent justices, like herself, from nomination for the position of Chief Justice.
Constitutional Law I

Jacinto vs. People

13th July 2009

ak482641
610 Phil. 100 , G.R. No. 162540
Primary Holding
The taking of a worthless check, even with intent to gain and grave abuse of confidence, constitutes an impossible crime under Article 4, paragraph 2, in relation to Article 59 of the Revised Penal Code, because the inherent lack of value in the check at the time of taking makes the consummation of theft factually impossible.
Background
The case originated from an employer-employee relationship where the petitioner, a collector for Mega Foam International Inc., was entrusted with receiving payments from customers. The dispute arose when a check payment collected by the petitioner was not remitted to the company but was instead deposited into an account linked to her family and was subsequently dishonored, leading to accusations of theft with grave abuse of confidence.
Criminal Law II
Impossible Crime

Dreamwork Construction, Inc. vs. Janiola

30th June 2009

ak886351
G.R. No. 184861 , 591 SCRA 466
Primary Holding
For a prejudicial question to exist, Section 7, Rule 111 of the 2000 Rules on Criminal Procedure explicitly requires that the civil action be "previously instituted" before the "subsequent criminal action"; additionally, the resolution of a civil case for rescission of contract is not determinative of guilt in a criminal case for violation of BP 22, as the gravamen of the latter offense is the mere act of issuing a worthless check.
Background
The legal dispute originated from a construction agreement between petitioner Dreamwork Construction, Inc. and private respondent Cleofe S. Janiola. In connection with this agreement, Janiola issued several checks to Dreamwork. When these checks were dishonored, Dreamwork initiated criminal proceedings against Janiola for violation of the Bouncing Checks Law (BP 22). Subsequently, Janiola filed a separate civil action seeking to rescind the construction agreement, which then became the basis for her motion to suspend the ongoing criminal case.
Persons and Family Law
Article 36 of the Civil Code

Matthews vs. Taylor

22nd June 2009

ak576607
590 SCRA 394 , 608 Phil. 193 , G.R. No. 164584
Primary Holding
The Agreement of Lease between Joselyn Taylor and Philip Matthews is valid because Benjamin Taylor, the alien husband, has no legal right to nullify the lease on property exclusively owned by his Filipino wife. Aliens are constitutionally prohibited from owning land in the Philippines, thus Benjamin's claim of ownership or need for consent is without legal basis.
Background
Benjamin Taylor, a British citizen, and Joselyn Taylor, a Filipina, were married. Joselyn purchased a property in Boracay using funds allegedly provided by Benjamin and developed it into a resort. Later, without Benjamin's express consent, Joselyn leased the property to Philip Matthews. Benjamin filed a case to nullify the lease agreement arguing it was void without his consent as the property was community property and his funds were used for its acquisition.
Property and Land Law

Lazatin vs. Desierto

5th June 2009

ak190398
588 SCRA 285 , G.R. No. 147097
Primary Holding
The Ombudsman possesses prosecutorial powers and exercises supervision and control over the Office of the Special Prosecutor (OSP) as constitutionally sanctioned by Congress through Republic Act No. 6770; consequently, the Ombudsman has the authority to approve, disapprove, or overturn any resolution issued by the OSP.
Background
The case originated from a complaint-affidavit filed by the Fact-Finding and Intelligence Bureau of the Office of the Ombudsman against then Congressman Carmelo F. Lazatin and his co-petitioners. The complaint alleged irregularities in the use of Lazatin's Countrywide Development Fund (CDF) for 1996, where he was accused of being both the proponent and implementer of projects, signing disbursement vouchers, and receiving checks as claimant, effectively converting public funds into cash.
Persons and Family Law
Civil Code, Article 8

In Re: Petition for Adoption of Michelle P. Lim, et al.

21st May 2009

ak982276
588 SCRA 98 , 606 Phil. 82 , G.R. Nos. 168992-93
Primary Holding
Married individuals must adopt jointly under RA 8552; exceptions do not apply here, so the petitions were correctly dismissed.
Background
Monina and her late husband Primo Lim raised three abandoned children (including Michelle and Michael) as their own, simulating their births. After Primo’s death, Monina remarried an American citizen, Angel Olario. She later sought to legitimize the children’s status through adoption under RA 8552’s amnesty provision for simulated births.
Statutory Construction

Soriano vs. Laguardia

29th April 2009

ak448960
587 SCRA 79 , 605 Phil. 43 , G.R. No. 164785
Primary Holding
The Movie and Television Review and Classification Board (MTRCB) has the authority, derived from PD 1986, to regulate television program content, including the power to impose preventive suspension and subsequent administrative sanctions like program suspension, when such content is deemed obscene or indecent, especially considering the pervasive nature of television and its accessibility to children; such regulation, when balanced against the State's compelling interest in protecting the youth, does not unconstitutionally abridge freedom of speech.
Background
Petitioner Eliseo F. Soriano, as host of the television program "Ang Dating Daan" aired on UNTV 37, made remarks on August 10, 2004, which included profane and offensive language directed at Michael M. Sandoval, a minister of Iglesia ni Cristo and host of a rival TV program. These utterances prompted complaints filed with the MTRCB by members of the Iglesia ni Cristo, leading to the challenged regulatory actions by the MTRCB.
Constitutional Law I

Barangay Association for National Advancement and Transparency (BANAT) vs. COMELEC

21st April 2009

ak772249
604 Phil. 131 , G.R. No. 179271
Primary Holding
The two percent threshold prescribed in Section 11(b) of R.A. No. 7941 is unconstitutional for the purpose of distributing *additional* party-list seats, as it makes it mathematically impossible to achieve the maximum number of available party-list seats and frustrates the constitutional mandate for proportional representation. A new four-step procedure for allocating party-list seats was established: (1) Rank parties from highest to lowest votes; (2) Parties receiving at least 2% of total votes get one guaranteed seat; (3) Additional seats are distributed proportionally based on total votes until all available seats are filled, disregarding fractional seats; (4) Each party is limited to a maximum of three seats.
Background
The case arose from the May 14, 2007 national elections, specifically concerning the allocation of seats for party-list representatives in the House of Representatives. The COMELEC, acting as the National Board of Canvassers (NBC), applied the formula established in _Veterans Federation Party v. COMELEC_ (the "Panganiban formula" or "Veterans formula") to determine the winners and allocate seats. This application led to dissatisfaction among several party-list groups who believed the formula was unconstitutional and did not allow for the full 20% allocation of seats for party-list representatives as mandated by the Constitution.
Constitutional Law I

Manubay, et al. vs. Sec. Garilao

16th April 2009

ak319606
603 Phil. 135 , G.R. No. 140717
Primary Holding
An application for land conversion can be validly denied if the subject property has already been placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) prior to the application, and a party aggrieved by a DAR Secretary's decision must first exhaust available administrative remedies, such as an appeal to the Office of the President as provided by DAR rules, before resorting to a petition for certiorari in court, unless grave abuse of discretion is clearly shown and no other plain, speedy, and adequate remedy exists.
Background
The case revolves around a 124-hectare parcel of land in Barrio Cadlan, Pili, Camarines Sur, owned by the petitioners. In 1994, this property was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) by the Municipal Agrarian Reform Officer (MARO). Subsequently, the petitioners applied for the conversion of this land from agricultural to residential/commercial use, which was denied by the DAR, leading to this legal dispute.
Constitutional Law I

Deutsche Gesellschaft Für Technische Zusammenarbeit vs. Court of Appeals

16th April 2009

ak268315
585 SCRA 150 , 603 Phil. 150 , G.R. No. 152318
Primary Holding
An entity claiming state immunity from suit, especially one described as a private company organized under foreign law even if state-owned, bears the burden of proving its entitlement to such immunity; failure to adduce evidence of its legal status under its parent country's law consenting to or restricting suit, or to secure an endorsement from the Department of Foreign Affairs, can lead to the denial of the claim for immunity.
Background
The case arose from a technical cooperation agreement between the Federal Republic of Germany and the Republic of the Philippines, initiated in 1971 and extended by subsequent arrangements. One such arrangement in 1999 concerned a project called Social Health Insurance--Networking and Empowerment (SHINE), designed to improve health care for Philippine families. The German government designated GTZ as its implementing agency for its contributions to the SHINE project, while the Philippines designated the Department of Health (DOH) and Philippine Health Insurance Corporation (Philhealth).
Constitutional Law I
State Immunity

Dr. Señeres vs. Commission on Elections, et al.

16th April 2009

ak746986
603 Phil. 552 , G.R. No. 178678
Primary Holding
The House of Representatives Electoral Tribunal (HRET) has sole and exclusive jurisdiction over contests relating to the election, returns, and qualifications of members of the House of Representatives once they have been proclaimed, taken their oath, and assumed office; thus, a petition for certiorari before the Supreme Court is an improper remedy to question the qualifications or authority of those who nominated such members.
Background
The case arose from an intra-party leadership dispute within Buhay Hayaan Yumabong (Buhay), a registered party-list organization, concerning who had the authority to nominate its representatives for the May 2007 party-list elections. This dispute occurred against the backdrop of Buhay's previous participation in the 2001 and 2004 elections with Melquiades Robles as its recognized president, and the upcoming 2007 elections where two conflicting Certificates of Nomination were filed with the COMELEC.
Constitutional Law I

Divinagracia vs. Consolidated Broadcasting System, Inc., et al

7th April 2009

ak738845
602 Phil. 625 , G.R. No. 162272
Primary Holding
The National Telecommunications Commission (NTC) does not have the power to cancel Certificates of Public Convenience (CPCs) or other operating licenses it has issued to broadcast stations based on the ground that the franchisees have violated the terms of their legislative franchises; such cancellation would effectively be a revocation of the legislative franchise itself, a power not delegated to the NTC, and the proper remedy for such violations is a quo warranto proceeding.
Background
The regulation of broadcast media in the Philippines involves a dual requirement: a legislative franchise granted by Congress and a license to operate (such as a CPC) issued by the National Telecommunications Commission (NTC). This system traces back to Act No. 3846 (Radio Control Act of 1931). The case arises from a dispute concerning the alleged failure of broadcast franchisees to comply with a provision in their legislative franchises mandating the public offering of a portion of their common stocks, leading to a complaint filed with the NTC seeking cancellation of their operating licenses.
Constitutional Law I

Geologistic, Inc. vs. Gateway Electronics Corporation

25th March 2009

ak146267
582 SCRA 434 , G.R. Nos. 174256-57
Primary Holding
The Supreme Court ruled that the RTC lacked sufficient justification for ordering execution pending appeal, considering the unresolved issues of liability and the absence of compelling "good reasons."
Background
Geologistics, Inc. sought to recover unpaid fees from Gateway Electronics Corporation for freight forwarding services, amounting to ₱4,769,954.32 plus interest and damages. The RTC ruled in favor of Geologistics, and the petitioner moved for execution pending appeal. Gateway Electronics and its surety, First Lepanto-Taisho Insurance Corp., filed separate petitions to annul the execution orders, which the Court of Appeals granted.
Statutory Construction

Spouses Dela Paz (Ret.) vs. Senate Committee on Foreign Relations, et al.

13th February 2009

ak971434
598 Phil. 981 , G.R. No. 184849
Primary Holding
The Supreme Court held that each House of Congress has full discretionary authority to determine its rules of proceedings, and the exercise of this power is generally exempt from judicial supervision, except on a clear showing of arbitrary and improvident use constituting a denial of due process; the Senate Committee on Foreign Relations acted within its jurisdiction in investigating the "Moscow incident" due to its potential impact on foreign relations and international obligations.
Background
The case arose from the "Moscow incident" where Gen. Eliseo Dela Paz, then PNP comptroller and part of a Philippine delegation to an INTERPOL conference in Russia, was apprehended at the Moscow airport on October 11, 2008, for failing to declare 105,000 euros found in his luggage, with an additional 45,000 euros in his possession. This led to his detention and the confiscation of the money by Russian authorities, prompting a legislative inquiry by the Philippine Senate.
Constitutional Law I

Ngo Te vs. Yu-Te

13th February 2009

ak804453
579 SCRA 193 , G.R. No. 161793
Primary Holding
A marriage is void under Article 36 of the Family Code when expert psychological testimony and the totality of evidence establish that one or both parties suffer from a grave, severe, and incurable personality disorder that renders them truly incapable of assuming the essential obligations of marriage. The strict guidelines established in _Republic v. Molina_ should not be applied as a rigid "strait-jacket" but must be interpreted with a view towards the law's intent for a case-by-case analysis, where the findings of the trial court and the opinion of psychological experts are given decisive weight.
Background
The case arose from the brief and volatile relationship between petitioner Edward Kenneth Ngo Te and respondent Rowena Ong Gutierrez Yu-Te, who were college students when they met in 1996. Their relationship, founded on shared angst towards their families, quickly escalated into an elopement initiated by Rowena. This was followed by a forced marriage under threatening circumstances orchestrated by Rowena's uncle. The marriage lasted only a few months before the couple parted ways, leading Edward to seek a declaration of nullity nearly four years later on the grounds of psychological incapacity.
Persons and Family Law
Article 36 of the Family Code

Ruby Shelter Builders and Realty Development Corporation vs. Formaran III

10th February 2009

ak620041
578 SCRA 283 , 598 Phil. 105 , G.R. No. 175914
Primary Holding
An action, although ostensibly for the annulment of deeds of sale, is considered a real action if its ultimate objective is the recovery of title to or possession of real property, and the docket fees must be computed based on the fair market value of the property as stated in Section 7(a) of Rule 141 of the Rules of Court, as amended.
Background
Petitioner Ruby Shelter Builders and Realty Development Corporation obtained a loan of P95,700,620.00 from respondents Romeo Y. Tan and Roberto L. Obiedo, secured by real estate mortgages over five parcels of land. Upon petitioner's inability to pay, a Memorandum of Agreement (MOA) was executed, granting an extension and providing for the execution of Deeds of Absolute Sale by way of *dacion en pago* for the mortgaged properties if the debt remained unpaid by December 31, 2005. The MOA also included redemption prices for the properties.
Civil Procedure I

Rufloe vs. Burgos

30th January 2009

ak442785
577 SCRA 264 , 597 Phil. 261 , G.R. No. 143573
Primary Holding
The respondents, including the Burgos siblings and Leonarda Burgos, were not innocent purchasers for value. Consequently, they did not acquire a valid title to the property despite relying on Transfer Certificates of Title derived from a forged Deed of Sale. The original title of the Rufloe spouses was reinstated.
Background
The case stems from a property originally owned by the Rufloe spouses. A Deed of Sale was forged, purportedly signed by the Rufloes, transferring the property to Elvira Delos Reyes. Delos Reyes then sold the property to the Burgos siblings, who later sold it to their aunt, Leonarda Burgos. The Rufloes filed a case to nullify these transactions, claiming forgery and asserting their continued ownership.
Property and Land Law

White Light Corporation vs City of Manila

20th January 2009

ak433804
576 SCRA 416 , 596 Phil. 444 , G.R. No. 122846
Primary Holding
Manila City Ordinance No. 7774, which prohibits short-time admission and wash-up rates in hotels and motels, is unconstitutional as it violates the due process clause of the Constitution.
Background
The City of Manila enacted an ordinance seeking to regulate public morals by prohibiting short-time rates in establishments often associated with illicit activities. Several businesses challenged the ordinance, arguing it infringed upon their rights and the rights of their customers. The case highlights the tension between government's power to regulate for public welfare and individual rights to liberty and privacy.
Constitutional Law II
Police Power

Laurel vs. Judge Abrogar

13th January 2009

ak193690
596 Phil. 45 , G.R. No. 155076
Primary Holding
The business of providing telecommunication and the telephone service itself are personal properties capable of appropriation and can be the subject of theft under Article 308 of the Revised Penal Code; the act of International Simple Resale (ISR), which involves unauthorized routing of international calls using a telecommunication company's facilities, constitutes unlawful taking (subtraction) of such business and service.
Background
The case arose from allegations that the petitioner, Luis Marcos P. Laurel, along with others, engaged in International Simple Resale (ISR). ISR is a method of routing and completing international long distance calls using a telecommunication company's lines, cables, antennae, and/or air wave frequency, connecting directly to local or domestic exchange facilities, thereby bypassing the official international gateway of the telecommunication company and depriving it of revenue.
Criminal Law II

Garcillano vs. The House of Representatives Committees on Public Information, et al.

23rd December 2008

ak185298
595 Phil. 775 , G.R. No. 170338 , G.R. No. 179275
Primary Holding
The Senate or its committees may conduct inquiries in aid of legislation only in accordance with duly published rules of procedure; publication of such rules is mandatory for each Congress and failure to do so renders any such inquiry procedurally infirm and unconstitutional.
Background
The "Hello Garci" tapes, allegedly containing a wiretapped conversation between then-President Gloria Macapagal-Arroyo and COMELEC Commissioner Virgilio Garcillano discussing the manipulation of the 2004 presidential election results, surfaced and caused a major political controversy. Both Houses of Congress initiated separate legislative inquiries into the matter, leading to the petitions filed in this case.
Constitutional Law I Constitutional Law II Persons and Family Law
Civil Code, Article 2

Bagabuyo vs. COMELEC

8th December 2008

ak041705
593 Phil. 678 , G.R. No. 176970
Primary Holding
Legislative reapportionment, which involves the creation or realignment of legislative districts for purposes of representation in the legislature, is fundamentally different from the creation, division, merger, abolition, or substantial alteration of boundaries of a local government unit, and thus does not require the conduct of a plebiscite for its validity.
Background
On October 10, 2006, then Congressman Constantino G. Jaraula of Cagayan de Oro City filed House Bill No. 5859, "An Act Providing for the Apportionment of the Lone Legislative District of the City of Cagayan De Oro." This bill was subsequently enacted into Republic Act No. 9371, which increased the city's legislative districts from one to two. The law mandated that for the May 2007 elections, voters in Cagayan de Oro would be classified as belonging to either the first or second legislative district based on their residence, with each district electing its own representative to Congress and eight members to the Sangguniang Panglungsod.
Constitutional Law I

Social Justice Society (SJS) vs. Dangerous Drugs Board, et al

3rd November 2008

ak613538
591 Phil. 393 , G.R. No. 157870
Primary Holding
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.
Background
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.
Constitutional Law I

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
Primary Holding
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.
Background
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.
Constitutional Law I Constitutional Law II Philosophy of Law

Securities and Exchange Commission vs. Interport Resources Corporation

6th October 2008

ak516001
567 SCRA 354 , 588 Phil. 651 , G.R. No. 135808
Primary Holding
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.
Background
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.
Philosophy of Law

Republic vs. Cagandahan

12th September 2008

ak425333
G.R. No. 166676 , 565 SCRA 72
Primary Holding
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.
Background
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.
Persons and Family Law

Neri vs. Senate Committee on Accountability of Public Officers and Investigations, et al.

4th September 2008

ak278418
586 Phil. 135 , G.R. No. 180643
Primary Holding
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.
Background
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.
Constitutional Law I

Abakada Guro Party List vs. Purisima

14th August 2008

ak884230
562 SCRA 251 , 584 Phil. 246 , G.R. No. 166715
Primary Holding
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.
Background
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.
Constitutional Law I Statutory Construction

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
Primary Holding
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.
Background
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.
Philosophy of Law

Mata vs. Agravante

6th August 2008

ak929535
561 SCRA 66 , G.R. No. 147597
Primary Holding
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.
Background
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.
Persons and Family Law
Article 19, 20, and 21, Civil Code

Sema vs. Commission on Elections, et al.

16th July 2008

ak715226
580 Phil. 623 , G.R. No. 177597
Primary Holding
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.
Background
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.
Constitutional Law I

Akbayan Citizens Action Party ("AKBAYAN"), et al. vs. Aquino, et al.

16th July 2008

ak279548
580 Phil. 422 , G.R. No. 170516
Primary Holding
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.
Background
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.
Constitutional Law I

Figueroa vs. People

14th July 2008

ak461685
558 SCRA 63 , 580 Phil. 58 , G.R. No. 147406
Primary Holding
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.
Background
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.
Civil Procedure I

Gobenciong vs. Court of Appeals

31st March 2008

ak728096
550 SCRA 502 , 573 Phil. 613 , G.R. No. 159883
Primary Holding
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.
Background
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.
Constitutional Law II
Due Process

Planters Products, Inc., vs. Fertiphil Corporation

14th March 2008

ak870529
572 Phil. 270 , G.R. No. 166006
Primary Holding
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.
Background
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.
Constitutional Law I

Bier vs. Bier, 547 SCRA 123

27th February 2008

ak808895
547 SCRA 123 , G.R. No. 173294
Primary Holding
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.
Background
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.
Persons and Family Law
Article 36 of the Family Code

Chavez vs. Gonzales, et al.

15th February 2008

ak123614
569 Phil. 155 , G.R. No. 168338
Primary Holding
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.
Background
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.
Constitutional Law II
Freedom of Expression

Trillanes IV vs. Judge Pimentel, Sr., et al.

7th February 2008

ak688993
578 Phil. 1002 , G.R. No. 179817
Primary Holding
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.
Background
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.
Constitutional Law I

Heirs of Marcelino Doronio vs. Heirs of Fortunato Doronio

27th December 2007

ak570269
541 SCRA 479 , 565 Phil. 766 , G.R. No. 169454
Primary Holding
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.
Background
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.
Property and Land Law

Garcia vs. Social Security Commission Legal and Collection

17th December 2007

ak000744
540 SCRA 456 , 565 Phil. 193 , G.R. No. 170735
Primary Holding
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.
Background
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.
Statutory Construction

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
Primary Holding
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.
Background
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.
Property and Land Law

Salvador vs. Mapa

28th November 2007

ak471249
539 SCRA 34 , G.R. No. 135080
Primary Holding
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.
Background
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.
Civil Procedure II
Rule 45 vs. Rule 65

Silverio vs. Republic

19th October 2007

ak402555
537 SCRA 373 , G.R. No. 174689
Primary Holding
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.
Background
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.
Persons and Family Law
Family Code, Articles 1 and 2

Pharmaceutical and Health Care Assoc. of the Phils. vs. Health Sec. Duque III

9th October 2007

ak573831
561 Phil. 386 , G.R. No. 173034
Primary Holding
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.
Background
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.
Constitutional Law I

Heirs of Marcelina Arzadon-Crisologo vs. Rañon

5th September 2007

ak869857
532 SCRA 391 , 559 Phil. 169 , G.R. No. 171068
Primary Holding
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.
Background
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.
Property and Land Law