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Mirasol vs. Court of Appeals

1st February 2001

ak360928
351 SCRA 44 , 403 Phil. 760 , G.R. No. 128448
Primary Holding
The Supreme Court affirmed the Court of Appeals' decision, finding that the trial court improperly ruled on the constitutionality of P.D. No. 579 without proper notice to the Solicitor General, that the doctrine of piercing the corporate veil does not apply, and that the dacion en pago and foreclosure were valid.
Background
The Mirasols, as sugarland owners, had their sugar production financed by PNB. P.D. No. 579 authorized PHILEX to purchase export sugar, with PNB financing the purchases. Disputes arose regarding the accounting of sugar sale proceeds, leading to litigation.
Constitutional Law II

Cruz vs. Secretaryof Environment and Natural Resources

6th December 2000

ak614139
347 SCRA 128 , 400 Phil. 904 , G.R. No. 135385
Primary Holding
The Supreme Court dismissed the petition, ruling that the Indigenous Peoples Rights Act (IPRA) is constitutional by virtue of the tied vote (7-7). Because no majority ruling was reached, the law remained valid.
Background
The case was brought by legal scholars and constitutionalists who questioned whether indigenous groups could hold ownership rights over natural resources traditionally deemed as part of the State’s patrimony under the Regalian Doctrine. The petitioners sought a declaration of unconstitutionality for various provisions of the IPRA, arguing that they violated the 1987 Constitution’s provisions on State ownership of public lands and natural resources.
Philosophy of Law

Del Mar vs. Philippine Amusement and Gaming Corporation

29th November 2000

ak276548
346 SCRA 485 , 400 Phil. 307 , G.R. No. 138298 , G.R. No. 138982
Primary Holding
PAGCOR’s franchise under PD 1869 only covers gambling casinos, not jai-alai. Its operation of jai-alai without a legislative franchise is illegal.
Background
PAGCOR began operating jai-alai in 1999 based on legal opinions from the DOJ, OSG, and OGCC. Petitioners contested this, alleging PAGCOR exceeded its franchise. The cases were consolidated due to overlapping constitutional and statutory issues.
Statutory Construction

Bugatti vs. Court of Appeals

17th October 2000

ak805416
397 Phil. 376 , G.R. No. 138113
Primary Holding
A contract of lease is perfected by the meeting of the minds of the parties upon the thing to be leased and the price certain; where essential terms such as the specific area to be leased, the cost of construction to be offset against rent, and the exact duration remain undetermined or disputed, no perfected contract exists, and a party who proceeds with construction despite objections and without a signed agreement is a builder in bad faith.
Background
The case arose from an action for recovery of possession and damages filed by respondent spouses Ben and Maria Baguilat against petitioner Emilio Bugatti. The dispute centered on an alleged oral agreement for Bugatti to lease a portion of the Baguilats' land, construct a building thereon (with costs to be offset by rent), and then pay a monthly rental, with the building eventually belonging to the Baguilats.
Obligations and Contracts

Veterans Federation Party vs. Commission on Elections

6th October 2000

ak393743
396 Phil. 419 , G.R. No. 136781 , G.R. No. 136786 , G.R. No. 136795
Primary Holding
The allocation of seats for party-list representatives under R.A. No. 7941 must adhere to four inviolable parameters: (1) the twenty percent allocation of the total House membership for party-list representatives is a ceiling, not a mandatory number to be filled at all times; (2) the two percent threshold of total valid votes cast for the party-list system is a valid requirement for a party to qualify for a seat; (3) each qualified party is entitled to a maximum of three seats; and (4) additional seats for qualified parties must be computed based on proportional representation.
Background
The 1987 Constitution introduced the party-list system of representation in the House of Representatives to enable marginalized and underrepresented sectors to participate in lawmaking. Section 5, Article VI of the Constitution mandates that party-list representatives shall constitute twenty percent of the total number of representatives. Congress enacted R.A. No. 7941 (The Party-List System Act) to implement this constitutional provision, outlining the procedure for the election and allocation of seats for party-list representatives. The May 11, 1998 elections were the first time party-list representatives were elected under this system.
Constitutional Law I

People vs. Velasco

13th September 2000

ak988299
340 SCRA 207 , 394 Phil. 517 , G.R. No. 127444
Primary Holding
The Supreme Court dismissed the petition for certiorari, holding that an acquittal based on appreciation of evidence cannot be appealed by the government, as it would violate the constitutional protection against double jeopardy.
Background
In San Ildefonso, Bulacan, a shooting incident resulted in the death of Alex Vinculado and serious injuries to his twin brother Levi and uncle Miguel Vinculado Jr. Honorato Galvez (town mayor) and Godofredo Diego (municipal employee) were charged with murder, frustrated murder, and illegal possession of firearms. After trial, Diego was found guilty while Galvez was acquitted. The government challenged the acquittal.
Philosophy of Law

Integrated Bar of the Philippines vs. Zamora

15th August 2000

ak990550
338 SCRA 81 , G.R. No. 141284 , 392 Phil. 618
Primary Holding
The President's decision to deploy the Marines to assist the PNP in visibility patrols was constitutional; it fell within his powers as Commander-in-Chief and did not violate the principle of civilian supremacy over the military.
Background
Due to rising crime rates in Metro Manila, President Estrada verbally ordered the PNP and Marines to conduct joint patrols. This directive was formalized in a Memorandum and Letter of Instruction (LOI). The IBP then filed a petition questioning the deployment's constitutionality.
Constitutional Law II

International School Alliance of Educators vs. Quisumbing

1st June 2000

ak585504
333 SCRA 13 , 388 Phil. 661 , G.R. No. 128845
Primary Holding
The point-of-hire classification cannot justify a disparity in salary rates between foreign-hired and locally-hired employees performing the same work under similar conditions, as this violates the fundamental principle of "equal pay for equal work" and constitutes discrimination contrary to public policy.
Background
International School, Inc., established under P.D. 732 primarily for dependents of foreign diplomatic personnel, hires both foreign and local teachers. It uses four tests (domicile, home economy, economic allegiance, hiring location/responsibility) to classify faculty as either "foreign-hires" or "local-hires." Foreign-hires received additional benefits (housing, transport, etc.) and a 25% higher salary, which the School justified based on alleged "dislocation" and "limited tenure" disadvantages faced by foreign-hires.
Constitutional Law II
Equal Protection

Heirs of Alberto Suguitan vs. City of Mandaluyong

14th March 2000

ak255645
328 SCRA 137 , 384 Phil. 676 , G.R. No. 135087
Primary Holding
A local government cannot initiate expropriation proceedings without a valid ordinance authorizing it; a resolution is insufficient under Section 19 of RA 7160 (Local Government Code).
Background
The City of Mandaluyong sought to expropriate Alberto Suguitan’s property for expanding the Mandaluyong Medical Center using a 1994 resolution. Suguitan challenged this, arguing it violated procedural requirements under the Local Government Code.
Statutory Construction

Liang vs. People

28th January 2000

ak383066
323 SCRA 692 , G.R. No. 125865
Primary Holding
Immunity under the ADB Headquarters Agreement does not apply to criminal acts like defamation; lower courts must allow both parties to present evidence on whether alleged acts were performed in an official capacity.
Background
Jeffrey Liang, an ADB employee, was charged with defaming a colleague. The MeTC initially dismissed the case based on a DFA protocol letter asserting immunity, but the RTC reversed this decision.
Statutory Construction

Miranda vs. Abaya

28th July 1999

ak165397
311 SCRA 617 , 370 Phil. 642 , G.R. No. 136351
Primary Holding
A candidate whose certificate of candidacy has been denied due course and canceled cannot be substituted under Section 77 of the Omnibus Election Code. As a result, Joel G. Miranda’s substitution was void, and he was not legally elected as mayor.
Background
Jose "Pempe" Miranda, the incumbent mayor of Santiago City, sought reelection despite having already served the maximum of three consecutive terms. Antonio M. Abaya filed a petition to deny due course and/or cancel Jose Miranda’s certificate of candidacy, which the Commission on Elections (COMELEC) granted on May 5, 1998. Despite this, Joel G. Miranda filed a certificate of candidacy on May 6, 1998, claiming to be a substitute candidate for his father.
Philosophy of Law

People vs. Quiñanola

5th May 1999

ak891024
306 SCRA 710 , G.R. No. 126148
Primary Holding
The crime of frustrated rape does not exist in Philippine jurisprudence; any penetration of the female sex organ by the male organ, however slight, including mere entry into the labia or lips of the female organ ("mere touching of the external genitalia"), constitutes consummated rape.
Background
The case arose from the alleged rape of a 15-year-old girl, Catalina Carciller, by two armed men, Agapito Quiñanola and Eduardo Escuadro, in Dumanjug, Cebu, on the night of March 5, 1994. The appellants allegedly accosted the victim and her companions, separated her from them, and took turns sexually assaulting her at gunpoint.
Criminal Law II
Rape

Commissioner of Internal Revenue vs. Court of Appeals

23rd February 1999

ak854014
303 SCRA 508 , 363 Phil. 130 , G.R. No. 107135
Primary Holding
Sales taxes paid on containers and packaging materials are creditable against miller’s tax because such materials are not “raw materials used in the milling process” under the final proviso of Section 168 of the NIRC.
Background
CENVOCO, a manufacturer of coconut oil and related products, paid sales taxes on containers and packaging materials for its edible oil in 1986. The Bureau of Internal Revenue (BIR) later assessed a deficiency miller’s tax and disallowed the sales tax credit, leading CENVOCO to challenge the assessment. The Court of Tax Appeals (CTA) and Court of Appeals (CA) ruled in favor of CENVOCO, prompting the BIR to appeal to the Supreme Court.
Statutory Construction

Echegaray vs. Secretary of Justice

19th January 1999

ak614452
297 SCRA 754 , 361 Phil. 73 , G.R. No. 132601
Primary Holding
The Supreme Court retains jurisdiction to control and supervise the execution of its final and executory judgments to prevent injustice or when supervening events transpire that may render execution unjust or impossible; the issuance of a temporary restraining order on an execution is a valid exercise of judicial power and does not usurp executive or legislative prerogatives, but such a TRO may be lifted when the circumstances justifying its issuance no longer exist.
Background
Petitioner Leo Echegaray was sentenced to death, a conviction affirmed by the Supreme Court in G.R. No. 117472. Subsequently, in G.R. No. 132601, Echegaray challenged the constitutionality of Republic Act No. 8177 (Lethal Injection Law) and its implementing rules. While the Court upheld R.A. No. 8177, it invalidated certain sections of its implementing rules, which were later amended. As Echegaray's execution neared, he filed a Very Urgent Motion for a TRO, citing potential moves in Congress to review or repeal the death penalty law. The Supreme Court, in a Special Session on January 4, 1999, issued a TRO temporarily suspending his execution until June 15, 1999, to allow Congress time to deliberate on the matter. The public respondents then filed an Urgent Motion for Reconsideration of this TRO.
Civil Procedure I Philosophy of Law

People vs. Santiano

3rd December 1998

ak138319
299 SCRA 583 , G.R. No. 123979
Primary Holding
The Court held that when a complex crime has been charged in an information and the evidence fails to support the charge on one of the component offenses, the defendant can still be separately convicted of the other offense when properly established.
Criminal Law II

Defensor-Santiago vs. Guingona, Jr.

18th November 1998

ak966337
359 Phil. 276 , G.R. No. 134577
Primary Holding
The selection of the Senate Minority Leader is an internal matter of the Senate, and courts will not interfere with such internal workings unless a clear violation of the Constitution, laws, or the Senate's own rules, or grave abuse of discretion amounting to lack or excess of jurisdiction, is demonstrated.
Background
The case arose from the organization of the Eleventh Congress of the Philippines in July 1998. Following the election of Senator Marcelo B. Fernan as Senate President, a dispute emerged regarding who should be recognized as the Senate Minority Leader. Senator Tatad, who lost the bid for Senate President, claimed the position, supported by Senator Santiago. Simultaneously, a group of seven senators belonging to the Lakas-NUCD-UMDP party, also a minority bloc, elected Senator Teofisto T. Guingona Jr. as their choice for Minority Leader. Senate President Fernan eventually recognized Senator Guingona.
Constitutional Law I

Municipality of Parañaque vs. V.M. Realty Corporation

20th July 1998

ak525057
292 SCRA 678 , 354 Phil. 684 , G.R. No. 127820
Primary Holding
The exercise of eminent domain by an LGU requires an ordinance, as mandated by Section 19 of RA 7160. A resolution is insufficient for authorizing expropriation. Res judicata does not prevent the State or its agents from initiating new expropriation proceedings when public interest demands and all legal requirements are fulfilled.
Background
The Municipality of Parañaque sought to expropriate private property owned by V.M. Realty Corporation for a socialized housing project. The complaint was filed based on a municipal council resolution, not an ordinance. Previously, a similar expropriation case involving the same property had been dismissed with prejudice.
Statutory Construction

Spouses Guiang vs. Court of Appeals

26th June 1998

ak442488
353 Phil. 578 , G.R. No. 125172
Primary Holding
The sale of conjugal partnership property by one spouse without the consent of the other is null and void under Article 124 of the Family Code; such a void contract cannot be ratified and is not merely voidable.
Background
The dispute arose when Judie Corpuz, without the consent of his wife Gilda Corpuz who was then in Manila seeking employment, sold a one-half portion of their conjugal lot, including their residence, to Spouses Antonio and Luzviminda Guiang. Gilda Corpuz objected to this sale upon her return.
Obligations and Contracts

Heirs of Emiliano Navarro vs. Intermediate Appellate Court

13th October 1997

ak197612
345 Phil. 810 , G.R. No. 68166
Primary Holding
The Supreme Court denied the Motion for Reconsideration and Motion to Remand but granted the Motion for Clarification by rectifying specific typographical and clerical errors within its previous Decision dated February 12, 1997, ultimately granting the Petition for Review and reinstating the decision of the Court of First Instance.
Background
The case involves a land dispute where the Heirs of Navarro originally filed a Petition for Review. The Supreme Court issued a Decision on February 12, 1997, which the Heirs of Pascual found confusing, particularly the dispositive portion in relation to the body of the decision regarding the public domain nature of the land. This confusion led to the Omnibus Motion seeking clarification, reconsideration, and remand.
Property and Land Law

People vs. Catantan

5th September 1997

ak898009
278 SCRA 761 , 344 Phil. 315 , G.R. No. 118075
Primary Holding
The Supreme Court held that the acts of the accused constituted piracy under PD No. 532 and not merely grave coercion under Article 286 of the Revised Penal Code, as the seizure of the vessel through force and intimidation was established.
Background
On June 27, 1993, at around 3:00 AM, the Pilapil brothers were fishing in the seawaters of Tabogon, Cebu, when the accused and his companions approached their boat, boarded it using force and intimidation, and compelled them to ferry them to different locations. The accused later abandoned the victims after transferring to another vessel.
Criminal Law II

Arroyo vs. De Venecia

14th August 1997

ak140457
277 SCRA 268 , 343 Phil. 42 , G.R. No. 127255
Primary Holding
The Supreme Court held that the alleged violations of House rules in the passage of R.A. No. 8240 did not amount to a constitutional violation. The Court also reaffirmed the enrolled bill doctrine, which presumes the validity of a law once it has been duly enacted and certified by the legislative and executive branches.
Background
The case arose from the passage of R.A. No. 8240, which amended the National Internal Revenue Code to impose specific taxes on beer and cigarettes. Petitioners, members of the House of Representatives, claimed that the law was passed in violation of House rules, particularly regarding the approval of the conference committee report and the handling of quorum issues.
Statutory Construction

Nool vs. Court of Appeals

24th July 1997

ak645708
342 Phil. 106 , G.R. No. 116635
Primary Holding
A contract of repurchase arising out of a contract of sale where the seller did not have any title to the property "sold" at the time of the sale is not valid; since nothing was sold, there is nothing to repurchase.
Background
The dispute centers on two parcels of land originally owned by Victorino Nool and Francisco Nool (Conchita Nool's brothers). Petitioners Conchita Nool and Gaudencio Almojera mortgaged these lands to the Development Bank of the Philippines (DBP). Due to non-payment, the mortgage was foreclosed, and DBP consolidated ownership. Subsequently, petitioners entered into an alleged contract of sale (Exhibit C) with respondents Anacleto Nool (Conchita's brother) and Emilia Nebre, with an accompanying agreement for repurchase (Exhibit D). However, respondents later discovered petitioners did not own the land and purchased it directly from DBP.
Obligations and Contracts

Sia vs. Court of Appeals

5th May 1997

ak070235
272 SCRA 141 , 338 Phil. 652 , G.R. No. 108222
Primary Holding
A lessee of land who constructs improvements thereon is not considered a builder in good faith under Articles 448 and 546 of the Civil Code and therefore does not have the right to retain possession until reimbursed for the full value of the improvements. The rights of a lessee regarding improvements are governed by Article 1678 of the Civil Code, which limits reimbursement to one-half of the improvement's value at the lessor's option and does not grant a right of retention.
Background
Atty. Rodolfo N. Pelaez originally owned the land and leased it to Henry L. Sia's parents who built a structure on it with permission in 1970. After Rodolfo Pelaez passed away, the land was inherited by his son, Atty. Pacifico Pelaez, who then sold it to Torre de Oro Development Corporation. Henry L. Sia succeeded his parents as lessee. Torre de Oro Development Corporation and Sia entered into a new one-year lease contract in 1988. Upon expiry, the lessor decided not to renew the lease and sought to eject Sia, leading to this legal dispute concerning Sia's rights as a lessee with improvements on the land.
Property and Land Law

Santiago vs. Commission on Elections

19th March 1997

ak585438
270 SCRA 106 , 336 Phil. 848 , G.R. No. 127325
Primary Holding
Republic Act No. 6735 is incomplete and inadequate to implement the people's initiative to propose amendments to the Constitution as mandated by Article XVII, Section 2 of the 1987 Constitution because it fails to provide a sufficient standard for the delegation of rule-making power to the COMELEC concerning constitutional initiatives. Consequently, COMELEC Resolution No. 2300, insofar as it prescribes rules and regulations for the conduct of initiative on amendments to the Constitution, is void.
Background
The 1987 Philippine Constitution introduced a novel provision in Article XVII, Section 2, allowing amendments to the Constitution to be directly proposed by the people through initiative, upon a petition of at least twelve per centum of the total number of registered voters, with each legislative district represented by at least three per centum of its registered voters. This provision also mandated Congress to provide for its implementation. The case arose from an attempt by private respondent Delfin, representing PIRMA, to utilize this mechanism to propose an amendment lifting the term limits of elective officials, which was met with legal challenges regarding the existence and sufficiency of an enabling law.
Statutory Construction

Apiag vs. Cantero

12th February 1997

ak734101
268 SCRA 47 , 335 Phil. 511 , A.M. No. MTJ-95-1070
Primary Holding
The Supreme Court dismissed the administrative case against Judge Esmeraldo G. Cantero, ruling that his personal misconduct did not directly relate to his judicial duties and therefore did not constitute gross misconduct in office. However, the Court emphasized that his personal behavior fell short of the ethical standards expected of a judge.
Background
The case stems from a failed love affair between Judge Esmeraldo G. Cantero and Maria Apiag, who married in 1947 and had two children. Judge Cantero later abandoned his family and married another woman, Nieves Ygay, without legally annulling his first marriage. The complainants accused him of bigamy and falsification of public documents, as he had listed Nieves Ygay as his spouse in official documents.
Philosophy of Law

Manila Prince Hotel vs. GSIS

3rd February 1997

ak613501
267 SCRA 408 , G.R. No. 122156
Primary Holding
Section 10, second paragraph, Article XII of the 1987 Constitution, which provides that "In the grant of rights, privileges, and concessions covering the national economy and patrimony, the State shall give preference to qualified Filipinos," is a self-executing provision and requires that a qualified Filipino bidder be allowed to match the highest bid of a foreign bidder in transactions involving national patrimony, and upon matching, the award should go to the Filipino bidder.
Background
The case arose from the Philippine Government's privatization program under Proclamation No. 50. Respondent Government Service Insurance System (GSIS) decided to sell 30% to 51% of its shares in respondent Manila Hotel Corporation (MHC), which owns the historic Manila Hotel. The sale was intended to attract a "strategic partner" to provide management expertise, an international marketing/reservation system, and financial support to enhance the Manila Hotel's profitability.
Constitutional Law I Statutory Construction

Republic vs. National Labor Relations Commission

17th October 1996

ak521819
263 SCRA 290 , 331 Phil. 608 , G.R. No. 120385
Primary Holding
While the Asset Privatization Trust (APT) can be sued, its liability for the obligations of a privatized corporation (PNEI) is limited to the assets of that corporation it holds in its capacity as a conservator. APT's own funds, being public funds, are not subject to garnishment or execution to satisfy such obligations, even if a judgment holds APT jointly and solidarily liable with the privatized entity, as such liability only extends to the assets taken over from the privatized firm.
Background
Pantranco North Express, Inc. (PNEI) faced financial difficulties, leading to its ownership transfer to the National Investment Development Corporation (NIDC), a PNB subsidiary, after foreclosure. PNEI was later sequestered by the PCGG and its management transferred to the Asset Privatization Trust (APT) for eventual sale. Due to its deteriorating financial condition, PNEI petitioned for suspension of payments and implemented a retrenchment program, which resulted in numerous labor complaints for unpaid benefits and separation pay filed by its employees against PNEI and APT.
Constitutional Law I

Filoteo, Jr. vs. Sandiganbayan

16th October 1996

ak361388
G.R. No. 79543
Primary Holding
The Supreme Court affirmed the conviction but modified it to robbery under the Revised Penal Code, reducing the penalty, while rejecting retroactive application of 1987 constitutional safeguards on custodial investigations.
Background
Filoteo, accused of leading a syndicate of police and military personnel in hijacking a postal van, challenged his Sandiganbayan conviction. The case centered on constitutional rights during custodial investigations, retroactivity of constitutional guarantees, and the distinction between brigandage and robbery.
Statutory Construction

Regala vs. Sandiganbayan

20th September 1996

ak859521
330 Phil. 678 , 262 SCRA 122 , G.R. No. 105938 , G.R. No. 108113
Primary Holding
The Supreme Court ruled that attorney-client privilege can extend to client identity in exceptional cases where disclosure would implicate the client in the very activity for which legal advice was sought.
Background
The case originated when the Presidential Commission on Good Government (PCGG) filed a complaint on July 31, 1987, before the Sandiganbayan against Eduardo M. Cojuangco Jr. and several others, including lawyers from the ACCRA Law Firm, for the recovery of alleged ill-gotten wealth. The ACCRA lawyers - Teodoro Regala, Edgardo J. Angara, Avelino V. Cruz, Jose C. Concepcion, Rogelio A. Vinluan, Victor P. Lazatin, Eduardo U. Escueta, and Paraja G. Hayudini - had acted as nominal stockholders for various corporations as part of their legal services to clients. When the PCGG filed a Third Amended Complaint in 1991, they excluded one of the ACCRA lawyers, Raul S. Roco, based on his alleged undertaking to reveal the identity of the principals for whom he acted as nominee-stockholder. The remaining ACCRA lawyers sought the same treatment, but the PCGG conditioned their exclusion on three requirements: disclosure of their client's identity, submission of documents proving the lawyer-client relationship, and submission of their deeds of assignment. The lawyers refused, citing attorney-client privilege, leading to a legal battle that ultimately reached the Supreme Court, raising fundamental questions about the scope of attorney-client privilege and the equal protection of law.
Philosophy of Law

Mustang Lumber, Inc. vs. Court of Appeals

18th June 1996

ak227007
257 SCRA 430 , 327 Phil. 214 , G.R. No. 104988 , G.R. No. 106424 , G.R. No. 123784
Primary Holding
The Supreme Court upheld that lumber is included within the term "timber" in P.D. No. 705, as amended, and its possession without appropriate legal documents is a punishable offense. It reversed the lower court’s ruling that dismissed the criminal case, reinstated the information, and directed the trial court to proceed with dispatch. The Court also affirmed the DENR's administrative authority to seize lumber and enforce forest laws.
Background
The case arose from DENR's seizure of lumber stockpiles from Mustang Lumber, Inc., claiming the company failed to present necessary documents proving the legal acquisition and transport of the forest products. The company contested the seizure as illegal and argued that "lumber" does not fall under the punishable scope of P.D. No. 705.
Statutory Construction

Fariñas vs. Barba

19th April 1996

ak562962
256 SCRA 396 , 326 Phil. 416 , G.R. No. 116763
Primary Holding
The Provincial Governor appoints replacements for permanent vacancies in the Sangguniang Bayan caused by non-partisan members, but only upon recommendation of the Sangguniang Bayan.
Background
Carlito Domingo (non-partisan Sangguniang Bayan member) resigned, triggering a dispute over appointment authority between Governor Farinas and Mayor Barba.
Statutory Construction

Eduarte vs. Court of Appeals

9th February 1996

ak813360
253 SCRA 391 , 323 Phil. 462 , G.R. No. 105944
Primary Holding
The Supreme Court held that while the revocation of the donation was valid due to the donee's ingratitude through forgery, the petitioner-spouses were purchasers in good faith. Consequently, the deed of absolute sale to the petitioners and their title were upheld, but the fraudulent donee was held liable for damages to the original donor.
Background
Pedro Calapine donated land to his niece, Helen Doria. Later, he claimed that a second deed of donation conveying the entire property was forged by Doria and sought to revoke the donation due to her ingratitude. Doria then sold the land to Spouses Eduarte. The lower courts sided with Calapine, revoking the donation and declaring the Eduartes buyers in bad faith, leading to this appeal.
Property and Land Law

Romualdez-Marcos vs. Commission on Elections

18th September 1995

ak456788
248 SCRA 300 , 318 Phil. 329 , G.R. No. 119976
Primary Holding
The Supreme Court ruled that Imelda Romualdez-Marcos met the residency requirement to run for Congress in the First District of Leyte, overturning the disqualification issued by the COMELEC.
Background
Imelda Romualdez-Marcos filed her Certificate of Candidacy (COC) for Representative of the First District of Leyte, declaring seven months of residency. Her political opponent, Cirilo Roy Montejo, filed a petition to disqualify her on the grounds of failing to meet the one-year residency requirement. Marcos later amended her COC, stating that she had been a resident "since childhood," but the COMELEC refused to accept this correction and ruled her disqualified. The Supreme Court reviewed the case and reversed the COMELEC's decision.
Philosophy of Law

Philippine Press Institute, Inc. vs. Commission on Elections

22nd May 1995

ak691461
314 Phil. 131 , 244 SCRA 272 , G.R. No. 119694
Primary Holding
Section 2 of COMELEC Resolution No. 2772, which compels newspapers to provide free print space for political candidates, is unconstitutional as it constitutes taking of private property for public use without just compensation and is therefore null and void. Section 8's constitutionality was not ruled upon as it lacked a justiciable controversy.
Background
COMELEC issued Resolution No. 2772 to procure free print space in newspapers for candidates to publicize their qualifications and platforms during the 1995 elections. This was intended to be similar to the voluntary practice by some publishers in the 1992 elections. PPI, representing newspaper publishers, challenged this resolution as an unconstitutional taking of private property.
Constitutional Law II
Eminent Domain

Mariano, Jr. vs. Commission on Elections

7th March 1995

ak024914
312 Phil. 259 , G.R. No. 118577 , G.R. No. 118627
Primary Holding
Republic Act No. 7854, particularly its sections 2 (territorial delineation), 51 (continuity of officials and new corporate existence), and 52 (creation of legislative districts), is constitutional. The delineation of territory by reference to existing boundaries is permissible, especially with pending boundary disputes. Challenges to term limits based on future contingencies are premature. Reapportionment of legislative districts can be done through a special law creating a new city, and the population requirement for an additional district was met.
Background
Republic Act No. 7854 was enacted to convert the Municipality of Makati into a highly urbanized city. This conversion and specific provisions within the Act, such as the definition of its territory, the status of incumbent officials, and the creation of new legislative districts, prompted legal challenges from taxpayers and a senator who questioned their compliance with constitutional and statutory requirements.
Constitutional Law I

Santos vs. Court of Appeals

4th January 1995

ak322702
240 SCRA 20 , 310 Phil. 21 , G.R. No. 112019
Primary Holding
The Supreme Court held that the petitioner failed to prove that the respondent was psychologically incapacitated at the time of the marriage, as required by Article 36 of the Family Code. The Court emphasized that psychological incapacity must be grave, rooted in the party's history, and incurable, and must exist at the time of the marriage.
Background
Leouel Santos and Julia Rosario Bedia-Santos married in 1986. After the birth of their child, marital issues arose, primarily due to interference from Julia's parents. Julia left for the U.S. in 1988 and failed to return or maintain communication with Leouel. Leouel filed for nullity of marriage under Article 36, claiming Julia's behavior demonstrated psychological incapacity. The trial court and Court of Appeals dismissed the petition, leading to this Supreme Court review.
Philosophy of Law

JUSMAG Philippines vs. NLRC

15th December 1994

ak645294
239 SCRA 224 , 309 Phil. 213 , G.R. No. 108813
Primary Holding
The Joint United States Military Assistance Group to the Republic of the Philippines (JUSMAG-Philippines), when performing governmental functions pursuant to the Military Assistance Agreement between the Philippines and the United States, is immune from suit, and such immunity is not waived by entering into employment contracts related to these sovereign functions.
Background
JUSMAG-Philippines was created pursuant to the Military Assistance Agreement of March 21, 1947, between the Philippines and the United States, with the primary task of advising and assisting the Philippines on military matters. Initially, the costs of locally employed personnel were borne by the Republic of the Philippines, but this changed in 1991 when the US Government offered to provide funds for the salaries of security assistance support personnel (SASP) and other operational costs.
Constitutional Law I

Tolentino vs. Secretary of Finance

25th August 1994

ak459748
305 Phil 686 , G.R. No. 115455 , G.R. No. 115525 , G.R. No. 115543 , G.R. No. 115544 , G.R. No. 115754 , G.R. No. 115781 , G.R. No. 115852 , G.R. No. 115873 , G.R. No. 115931
Primary Holding
Republic Act No. 7716, the Expanded Value-Added Tax Law, is constitutional, having been enacted in compliance with the procedural requirements of the Constitution, and its provisions do not, on their face, violate the Bill of Rights or other constitutional mandates concerning taxation, freedom of speech and religion, or impairment of contracts; claims regarding its regressive nature or oppressiveness are considered prematurely raised without a sufficient factual record.
Background
The Philippine government sought to widen the tax base of the existing Value-Added Tax (VAT) system and enhance its administration to address a growing budget deficit and improve revenue collection. This led to the legislative effort to amend the National Internal Revenue Code (NIRC) through what would become Republic Act No. 7716. The law aimed to remove certain VAT exemptions, expand the coverage of VAT to previously exempt goods and services, and restructure its application, sparking widespread opposition from various sectors who feared its economic impact and questioned its legality.
Constitutional Law I

Philippine Constitution Association vs. Enriquez

19th August 1994

ak037325
305 Phil. 546 , G.R. No. 113105 , G.R. No. 113174 , G.R. No. 113766 , G.R. No. 113888
Primary Holding
The President has the power to veto "inappropriate provisions" in a general appropriations bill, treating them as items for veto purposes, even if they are not specific appropriations of money, particularly if such provisions attempt to amend substantive law or encroach on executive functions; however, the President cannot veto a provision that is directly related to an item of appropriation without vetoing the item itself.
Background
The case arose from the enactment of Republic Act No. 7663, the General Appropriations Act (GAA) for 1994. After its passage by both houses of Congress, the President signed it into law but vetoed several provisions and imposed conditions on others through a Presidential Veto Message. Various groups, including the Philippine Constitution Association and several Senators, questioned the constitutionality of certain provisions of the GAA itself (like the Countrywide Development Fund and realignment of operational expenses) and the legality of the President's exercise of the veto power over specific items and special provisions, leading to these consolidated petitions before the Supreme Court.
Constitutional Law I

Kilosbayan, Incorporated vs. Guingona, Jr

5th May 1994

ak025475
232 SCRA 110 , G.R. No. 113375
Primary Holding
The Supreme Court granted the petition and declared the Contract of Lease between PCSO and PGMC invalid, holding that it contravenes Section 1 of R.A. No. 1169, as amended by B.P. Blg. 42.
Background
PCSO decided to establish an on-line lottery system to increase revenue, leading to a Request for Proposal (RFP). PGMC was formed by the Berjaya Group Berhad to bid on the project. The resulting contract was challenged by Kilosbayan, Inc. and others.
Constitutional Law II

Fernandez vs. National Labor Relations Commission

28th February 1994

ak756155
230 SCRA 460 , 300 Phil. 486 , G.R. No. 106090
Primary Holding
Project employees in the construction industry are terminated lawfully upon project completion, even after years of intermittent service. The petition was dismissed for being filed unreasonably late and lacking merit.
Background
Fernandez worked for D.M. Consunji from 1974 to 1986 across multiple projects. The company argued his termination resulted from project completion, while Fernandez alleged indefinite employment. The Labor Arbiter initially ruled for Fernandez, but the NLRC reversed the decision.
Statutory Construction

Republic vs. Court of Appeals

8th November 1993

ak848377
277 SCRA 509 , 298 Phil. 291 , G.R. No. 79732
Primary Holding
The Court held that the judicial declaration of the unconstitutionality of a law should apply retroactively to cases that were still pending at the time of the declaration.
Background
This case involved the expropriation of land for a highway project where the government wanted to use a method of compensation that had been declared unconstitutional in a previous case.
Constitutional Law II
Eminent Domain

Garcia vs. Commission on Audit

14th September 1993

ak053844
297 Phil. 394 , G.R. No. 75025
Primary Holding
A public employee reinstated pursuant to an executive clemency grounded on the employee's innocence is entitled to full back wages from the date of illegal dismissal to the date of reinstatement, as the clemency obliterates the adverse effects of the administrative decision and nullifies the dismissal.
Background
Petitioner Vicente Garcia was a Supervising Lineman summarily dismissed from the Bureau of Telecommunications on April 1, 1975, for alleged dishonesty related to the loss of telegraph poles. A criminal case for qualified theft based on the same facts was filed against him. He was acquitted in the criminal case, with the trial court noting his innocence and commending his dedication. Despite the acquittal, his request for reinstatement was initially denied, leading him to seek executive clemency, which was eventually granted.
Constitutional Law I

Oposa vs. Factoran, Jr.

30th July 1993

ak199582
224 SCRA 792 , 296 Phil. 694 , G.R. No. 101083
Primary Holding
The Supreme Court held that petitioners, including minors representing their generation and generations yet unborn, have the legal standing (locus standi) to sue for the enforcement of their fundamental constitutional right to a balanced and healthful ecology, which is self-executing and judicially enforceable. Furthermore, Timber License Agreements (TLAs) are not contracts but mere privileges granted by the State, which can be amended, modified, replaced, or rescinded when the national interest so requires, and thus are not protected by the non-impairment of contracts clause.
Background
The case arose amidst growing concerns over rapid deforestation in the Philippines and its detrimental environmental consequences. Petitioners highlighted the significant reduction in the country's rainforest cover over 25 years, from approximately 16 million hectares to about 1.2 million hectares by 1987, and further to a mere 850,000 hectares of virgin old-growth rainforests. This deforestation was attributed largely to commercial logging operations sanctioned by Timber License Agreements (TLAs) issued by the Department of Environment and Natural Resources (DENR), leading to severe environmental degradation, including water shortages, soil erosion, loss of biodiversity, and climate change impacts.
Constitutional Law I Philosophy of Law

Philip Morris, Inc. vs. Court of Appeals

16th July 1993

ak115794
296 Phil. 451 , G.R. No. 91332
Primary Holding
A foreign corporation, even if it has registered trademarks in the Philippines and possesses the capacity to sue for infringement under Section 21-A of the Trademark Law, is not automatically entitled to a writ of preliminary injunction unless it can establish actual use of its trademarks in commerce in the Philippines, as required by Sections 2 and 2-A of the Trademark Law, to demonstrate a clear and unmistakable right that is being violated and that would result in irreparable injury.
Background
Petitioners are foreign corporations and registered owners of the trademarks "MARK VII," "MARK TEN," and "LARK" for cigarettes in the Philippines. They alleged that Fortune Tobacco Corporation's manufacture and sale of "MARK" cigarettes infringed their trademarks. Petitioners are not doing business in the Philippines but claimed to be suing on an isolated transaction and under the protection of international conventions and Philippine trademark law. The dispute centered on whether Fortune's use of "MARK" should be preliminarily enjoined pending the outcome of the main infringement case.
Constitutional Law I

Ateneo de Manila University vs. Capulong

27th May 1993

ak203562
222 SCRA 644 , G.R. No. 99327
Primary Holding
The Supreme Court held that the expulsion of the students by Ateneo de Manila University was valid, as the university followed due process in its disciplinary proceedings. The Court emphasized the institution's academic freedom to set and enforce its own rules and standards, including the right to dismiss students for serious violations.
Background
The case arose from a hazing incident during the initiation rites of the Aquila Legis fraternity at Ateneo Law School in February 1991. The hazing resulted in the death of Leonardo Villa and serious injuries to another student, Bienvenido Marquez. The university conducted an investigation and expelled the students involved. The expelled students challenged their dismissal, claiming a violation of due process.
Philosophy of Law

Ebralinag vs. Division of Superintendent of Schools of Cebu

1st March 1993

ak778863
292 Phil. 267 , 321 Phil. 967
Primary Holding
The expulsion of students who are members of Jehovah's Witnesses for their refusal, based on religious convictions, to salute the flag, sing the national anthem, and recite the patriotic pledge during school flag ceremonies is unconstitutional, as it infringes upon their right to freedom of religion and their right to free basic education, provided their non-participation is done respectfully and does not disrupt the ceremony or offend others.
Background
The case arose from the long-standing conflict between state-mandated flag ceremonies in educational institutions, intended to foster patriotism, and the religious beliefs of Jehovah's Witnesses, who consider such acts as forms of worship prohibited by their faith. This issue had previously been decided by the Supreme Court in _Gerona vs. Secretary of Education_ (1959), which upheld the legality of expelling students for non-participation, a ruling that gained legislative endorsement through the Administrative Code of 1987. The present cases challenged the continued application of this policy.
Constitutional Law II
Freedom of Religion

Labo, Jr. vs. Commission on Elections

3rd July 1992

ak581326
286 Phil. 397 , G.R. No. 105111 , G.R. No. 105384
Primary Holding
A candidate previously declared by a final Supreme Court judgment to be a non-Filipino citizen remains disqualified from running for and holding public office unless reacquisition of Philippine citizenship is proven; winning an election does not cure such ineligibility, and the candidate receiving the second-highest number of votes is not entitled to be proclaimed the winner, with the vacancy to be filled by operation of the rule on succession (i.e., by the vice-mayor elect).
Background
This case arose after Ramon L. Labo, Jr., despite a previous Supreme Court ruling in 1989 (_Labo v. Commission on Elections, 176 SCRA 1_) declaring him not a Filipino citizen, filed a certificate of candidacy for Mayor of Baguio City in the May 11, 1992 elections, asserting he was a "natural-born" Filipino. Roberto Ortega, another mayoral candidate, subsequently filed a disqualification case against Labo before the Commission on Elections (Comelec) based on this prior judgment and Labo's alleged false representation of citizenship.
Constitutional Law I

Caltex Philippines, Inc. vs. Commission on Audit

8th May 1992

ak960993
284-A Phil. 233 , G.R. No. 92585
Primary Holding
The Commission on Audit (COA) possesses broad powers under the 1987 Constitution to examine, audit, and settle all government accounts, and to promulgate rules for the prevention and disallowance of irregular, unnecessary, excessive, extravagant, or unconscionable expenditures, which includes the authority to disallow claims not sanctioned by law, such as certain reimbursements from the Oil Price Stabilization Fund (OPSF).
Background
The case revolves around the Oil Price Stabilization Fund (OPSF), created by P.D. No. 1956, as amended by E.O. No. 137. The OPSF was established to minimize frequent price changes of crude oil and petroleum products due to exchange rate adjustments or world market price changes, and to reimburse oil companies for cost increases and certain cost underrecoveries. The Department of Energy (formerly Ministry of Energy/Office of Energy Affairs) administered the OPSF, with the Department of Finance determining specific reimbursable "other factors" leading to cost underrecovery.
Constitutional Law I

Mapulo Mining Corporation vs. Lopez

7th February 1992

ak606231
206 SCRA 9 , 282 Phil. 905 , G.R. No. L-30440
Primary Holding
Strict compliance with the publication requirements under Section 72 of the Mining Act is mandatory and cannot be substituted with "substantial compliance." Failure to publish in local newspapers where the mining claim is located invalidates the lease application process.
Background
The case arose when Project Ventures, Inc. (PROVEN) filed mining lease applications conflicting with prior claims by Mapulo Mining Association and E.V. Chavez & Associates. Petitioners opposed PROVEN’s applications, arguing that the notice's publication did not strictly comply with the Mining Act and that PROVEN’s claims violated sections of the law relating to mining claims on private lands.
Statutory Construction