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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

Bengzon Jr. vs. Senate Blue Ribbon Committee

20th November 1991

ak129190
280 Phil. 829 , G.R. No. 89914
Primary Holding
The Senate Blue Ribbon Committee is enjoined from compelling the petitioners to testify and produce evidence because its contemplated inquiry is not in aid of legislation and, if pursued, would violate the principle of separation of powers by encroaching upon matters already within the jurisdiction of the Sandiganbayan, and would disregard the petitioners' constitutional rights, particularly the right against self-incrimination, given the pending judicial case involving the same issues.
Background
Following the 1986 People's Revolution, the Presidential Commission on Good Government (PCGG) was tasked with recovering alleged ill-gotten wealth accumulated by former President Ferdinand E. Marcos, his family, and close associates. One such associate was Benjamin "Kokoy" Romualdez. The PCGG filed Civil Case No. 0035 before the Sandiganbayan against Romualdez and others, including the petitioners, for reconveyance, reversion, accounting, restitution, and damages related to numerous corporations allegedly acquired through illicit means. The Senate Blue Ribbon Committee subsequently initiated an inquiry into the purported sale of these Romualdez corporations to the Lopa Group, a transaction also central to the PCGG's case.
Constitutional Law I

Ganzon vs. Court of Appeals

5th August 1991

ak696650
277 Phil. 311 , G.R. No. 93252 , G.R. NO. 93746 , G.R. NO. 95245
Primary Holding
The President of the Philippines, through the Secretary of Local Government, possesses the authority to investigate and impose preventive suspensions on elective local officials in accordance with the procedures and limitations set forth in the Local Government Code (Batas Blg. 337), as this power is a component of the President's general supervision over local governments and was not abrogated by the 1987 Constitution; however, such power must not be exercised oppressively, and successive suspensions for numerous charges arising from acts committed prior to the first suspension may be curtailed to prevent what amounts to a de facto removal from office.
Background
The cases arose from a series of administrative complaints filed in 1988 against Mayor Rodolfo Ganzon of Iloilo City and Sangguniang Panglunsod member Mary Ann Rivera Artieda. The complaints, lodged by various city officials, alleged offenses such as abuse of authority, oppression, grave misconduct, and culpable violation of the Constitution. These complaints led to investigations by the Department of Local Government and the imposition of preventive suspensions by the Secretary of Local Government, prompting the petitioners to question the Secretary's authority under the new constitutional framework emphasizing local autonomy.
Constitutional Law I

Comendador vs. De Villa

2nd August 1991

ak165261
200 SCRA 80 , 277 Phil. 93 , G.R. No. 93177 , G.R. No. 95020 , G.R. No. 96948 , G.R. No. 97454
Primary Holding
The pre-trial investigation substantially complied with legal requirements despite petitioners’ procedural delays. The right to peremptory challenge under the Articles of War was revived after PD 39 became ineffective post-martial law. Regional Trial Courts (RTCs) lack jurisdiction to interfere in military court-martial proceedings or grant bail to military personnel.
Background
Following a failed December 1989 coup, AFP officers were charged with mutiny, murder, and related offenses under the Articles of War. They contested the legality of the Pre-Trial Investigation (PTI) Panel, the General Court-Martial (GCM) No. 14’s composition, and the denial of peremptory challenges. Civilian RTCs granted provisional liberty to some officers via certiorari and habeas corpus, prompting appeals to the Supreme Court.
Statutory Construction

Co vs. Electoral Tribunal of the House of Representatives

30th July 1991

ak810844
199 SCRA 692 , 276 Phil. 758 , G.R. Nos. 92191-92 , G.R. Nos. 92202-03
Primary Holding
The Supreme Court affirmed HRET’s decision, declaring Jose Ong, Jr. a natural-born Filipino citizen and resident of Laoang, Northern Samar, dismissing the petitions for lack of grave abuse of discretion by HRET.
Background
Jose Ong, Jr. won the 1987 congressional election for Northern Samar’s second district. Petitioners Co and Balanquit filed protests with HRET, contesting Ong’s citizenship and residency. HRET ruled in Ong’s favor, prompting petitioners to seek certiorari before the Supreme Court.
Statutory Construction

People vs. Malmstedt

19th June 1991

ak473261
198 SCRA 401 , 275 Phil. 447 , G.R. No. 91107
Primary Holding
A warrantless search of a moving vehicle and its passengers is valid when based on probable cause, which can arise from specific intelligence reports combined with the suspicious conduct of the person being searched, even without a warrant obtained beforehand due to the exigencies of the situation.
Background
The case arose amidst persistent reports received by the First Regional Command (NARCOM) of the Philippine Constabulary that vehicles originating from Sagada were being used to transport marijuana and other prohibited drugs through the Cordillera Region.
Constitutional Law II
Searches and Seizures

Solid Manila Corporation vs. Bio Hong Trading Co

8th April 1991

ak658021
195 SCRA 748 , 273 Phil. 115 , G.R. No. 90596
Primary Holding
The easement of right-of-way in favor of the public was validly constituted and was not extinguished by merger when Bio Hong Trading Co., Inc. acquired the property; therefore, Bio Hong must respect and maintain the easement, removing any obstructions.
Background
Solid Manila Corporation claimed a right-of-way over a private alley located on property owned by Bio Hong Trading Co., Inc. This alley was established by a prior owner and annotated on Bio Hong's title. Bio Hong constructed steel gates obstructing the alley, leading Solid Manila to file for injunction to remove the gates and enforce the easement.
Property and Land Law

Ronquillo vs. Court of Appeals

20th March 1991

ak198213
195 SCRA 433 , 272-A Phil. 412 , G.R. No. 43346
Primary Holding
The dried-up portion of Estero Calubcub is public land, not private property of the riparian owners, because its drying up was caused by human intervention and not a natural change in the course of the waters.
Background
Rosendo del Rosario and his daughters claimed ownership of a dried-up estero portion adjacent to their titled land, asserting riparian rights. Mario Ronquillo occupied this portion and claimed it was public land. The Director of Lands and Development Bank of the Philippines were later impleaded as respondents.
Property and Land Law

People vs. Ritter

5th March 1991

ak344111
272 Phil. 532 , G.R. No. 88582
Primary Holding
An accused cannot be convicted of Rape with Homicide if the prosecution fails to prove beyond reasonable doubt the victim's age (for statutory rape) and the direct causal link between the accused's actions and the victim's death, especially when significant time has elapsed and other intervening causes are plausible; however, acquittal from criminal liability does not necessarily extinguish civil liability if the acquittal is based on reasonable doubt and facts supporting civil liability for acts contrary to morals, good customs, public order or public policy are established by a preponderance of evidence.
Background
The case arose from the death of Rosario Baluyot, an approximately 12-year-old street child, who died from septicemia and peritonitis caused by a foreign object (a portion of a sexual vibrator) lodged in her vaginal canal. The accused, Heinrich Stefan Ritter, a foreign national, was alleged to have brought Rosario and another child, Jessie Ramirez, to his hotel room, where the alleged rape and insertion of the object occurred. The incident gained public attention due to the victim's vulnerability and the nature of the crime, highlighting the plight of street children.
Constitutional Law I

Jagualing vs. Court of Appeals

4th March 1991

ak813608
194 SCRA 607 , 272 Phil. 439 , G.R. No. 94283
Primary Holding
The owner of the land along the margin nearest to an island formed in a non-navigable and non-floatable river has a better right to the island than those in actual possession of it, based on the principle of riparian ownership and accretion as provided in Article 465 of the Civil Code.
Background
The Eduaves, private respondents, filed an action to quiet title over a parcel of land that had become an island in the Tagoloan River against the Jagualings, petitioners, who were in possession of the island. The Eduaves claimed ownership through inheritance and presented evidence of tax declarations and acts of ownership on the land prior to its becoming an island. The Jagualings claimed ownership through adverse possession.
Property and Land Law

Civil Liberties Union vs. Executive Secretary

22nd February 1991

ak233934
194 SCRA 317 , 272 Phil. 147 , G.R. No. 83896 , G.R. No. 83815
Primary Holding
Executive Order No. 284 is unconstitutional because it allows members of the Cabinet, their undersecretaries, and assistant secretaries to hold multiple offices or employment in contravention of the express prohibition in Section 13, Article VII of the 1987 Constitution, which provides a stricter rule for these officials compared to the general rule for other appointive officials in Section 7, Article IX-B. The only exceptions to this prohibition are those expressly provided in the Constitution itself, or positions held in an *ex-officio* capacity without additional compensation and as required by the primary functions of their office.
Background
The case arose from the issuance of Executive Order No. 284 by President Corazon C. Aquino on July 25, 1987. This E.O. allowed members of the Cabinet, undersecretaries, assistant secretaries, and other appointive officials of the Executive Department to hold, in addition to their primary positions, not more than two positions in the government and government corporations and receive corresponding compensation. This was issued following DOJ Opinion No. 73, s. 1987, which interpreted Section 13, Article VII in relation to Section 7, par. (2), Article IX-B of the Constitution. The practice of high-ranking executive officials holding multiple government posts, often with substantial emoluments, had been a contentious issue, particularly during the Marcos regime, and the 1987 Constitution sought to address this.
Constitutional Law I Statutory Construction

Brocka vs. Enrile

10th December 1990

ak940091
192 SCRA 183 , 270 Phil. 271 , G.R. Nos. 69863-65
Primary Holding
The Supreme Court ruled in favor of the petitioners, granting the petition and permanently enjoining the trial court from proceeding with the cases. The Court held that criminal prosecution may be enjoined in cases of manifest bad faith, as demonstrated by the state officials' actions in this case.
Background
The case arose during a period of political unrest in the Philippines, marked by demonstrations and strikes against the government. Petitioners, including prominent filmmakers and activists, were arrested during a jeepney strike and subsequently charged with Illegal Assembly and Inciting to Sedition. The case highlights the tension between the government's authority to maintain order and the protection of individual rights and freedoms.
Constitutional Law II

Luz Farms vs. Secretary of the Department of Agrarian Reform

4th December 1990

ak615135
192 SCRA 51 , 270 Phil. 151 , G.R. No. 86889
Primary Holding
Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. No. 6657 were declared unconstitutional to the extent that they included livestock, poultry, and swine raising within the agrarian reform program, as such activities are not consistent with the constitutional intent of agrarian reform.
Background
Luz Farms, a corporation engaged in livestock and poultry raising, challenged certain provisions of R.A. No. 6657 arguing that livestock and poultry operations shouldn't be considered agricultural lands under agrarian reform laws. The petitioner claimed that the application of these provisions violated its property rights and due process.
Statutory Construction