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Gonzales vs. Macaraig, Jr.

19th November 1990

ak708936
269 Phil. 472 , G.R. No. 87636
Primary Holding
The President's item-veto power extends to "inappropriate provisions" in an appropriations bill that are essentially general law measures and do not relate specifically to a particular appropriation, and such provisions can be treated as "items" for the purpose of the veto.
Background
The controversy arose from the President's exercise of the veto power over specific provisions in the General Appropriations Acts for Fiscal Years 1989 and 1990. Congress, in these acts, included provisions (Section 55 for FY 1989 and Section 16 for FY 1990) that aimed to prohibit the President and other designated officials from using savings to augment items of appropriation that Congress had disapproved or reduced from the President's original budget proposal. The President vetoed these provisions, citing them as unconstitutional infringements on the executive's power of augmentation and as violations of the constitutional provision allowing augmentation from savings.
Constitutional Law I

Republic vs. Intermediate Appellate Court

4th June 1990

ak579538
186 SCRA 88 , 264 Phil. 450 , G.R. No. 73085
Primary Holding
Forest lands and national parks are not subject to private appropriation; Spanish titles are not valid proof of ownership for unregistered lands after Presidential Decree No. 892.
Background
Private respondents filed a complaint for quieting of title, asserting ownership over land based on a Spanish title. The Republic of the Philippines argued that the land was part of a forest reserve and national park, making it inalienable public land not subject to private ownership. The trial court and the Intermediate Appellate Court initially ruled in favor of the private respondents.
Property and Land Law

Department of Education, Culture and Sports vs. San Diego

21st December 1989

ak022039
180 SCRA 533 , 259 Phil. 1016 , G.R. No. 89572
Primary Holding
The State, in the exercise of its police power, can validly regulate admission to medical schools, including imposing a limit on the number of times an individual can take the National Medical Admission Test (NMAT), to ensure that only qualified individuals enter the medical profession and to protect public health and safety.
Background
The case arose from the implementation of MECS Order No. 12, Series of 1972, specifically rule h) which states: "A student shall be allowed only three (3) chances to take the NMAT. After three (3) successive failures, a student shall not be allowed to take the NMAT for the fourth time." This rule was part of the government's effort to upgrade the quality of medical education and ensure that only competent individuals are admitted to medical schools, thereby safeguarding public health. The NMAT itself was established as a qualifying examination for admission to medical schools.
Constitutional Law I Constitutional Law II

Magsaysay-Labrador vs. Court of Appeals

19th December 1989

ak001133
180 SCRA 266 , 259 Phil. 748 , G.R. No. 58168
Primary Holding
Shareholders do not possess the direct and immediate legal interest in suits involving corporate property necessary to entitle them to intervene as parties, as the corporation has a distinct legal personality and owns the property itself; an interest as a shareholder is merely indirect, contingent, and inchoate.
Background
The case arose from a dispute over a parcel of land ("Pequeña Island") acquired during the marriage of the late Senator Genaro Magsaysay and respondent Adelaida Rodriguez-Magsaysay. After the Senator's death, Adelaida discovered annotations on the title suggesting the property was his separate capital, a Deed of Assignment transferring the land to SUBIC Land Corporation (SUBIC), and a subsequent mortgage on the property executed by SUBIC. Adelaida filed suit to annul these transactions, claiming the land was conjugal, the transactions were fraudulent, and her consent was not obtained.
Civil Procedure I
Intervention

Pita vs. Court of Appeals

5th October 1989

ak292021
258-A Phil. 134 , G.R. No. 80806
Primary Holding
The seizure of allegedly obscene materials, even under the guise of an anti-smut campaign and police power, requires a prior judicial determination of obscenity and the issuance of a valid search warrant; law enforcement authorities cannot unilaterally determine obscenity and confiscate materials without violating constitutional guarantees of due process and freedom from unreasonable searches and seizures.
Background
The case arose from an "Anti-Smut Campaign" initiated by then-Mayor of Manila, Ramon D. Bagatsing. As part of this campaign, various publications, including the petitioner's "Pinoy Playboy" magazines, were seized from vendors and publicly burned based on the authorities' belief that they were obscene, pornographic, and indecent.
Constitutional Law II
Freedom of Expression

Marcos vs. Manglapus

15th September 1989

ak357065
177 SCRA 668 , 258 Phil. 479 , G.R. No. 88211
Primary Holding
The President of the Philippines possesses unenumerated residual powers, implicit in the grant of executive power, which include the authority to bar the return of a citizen to the country if deemed necessary for the paramount interests of national security and public welfare, subject only to judicial review for grave abuse of discretion.
Background
Following the "People Power" Revolution in February 1986, Ferdinand E. Marcos was deposed as President and forced into exile in Hawaii. Corazon C. Aquino assumed the presidency amidst significant political instability, including coup attempts by Marcos loyalists and military factions, communist insurgency, secessionist movements, and severe economic difficulties attributed to the previous regime. As Marcos lay dying in Hawaii, he expressed his wish to return to the Philippines, a prospect President Aquino firmly opposed due to perceived threats to national stability and recovery efforts.
Constitutional Law I Constitutional Law II
Liberty of Abode

Dario vs. Mison

8th August 1989

ak848552
257 Phil. 84 , G.R. No. 81954 , G.R. No. 81967 , G.R. No. 82023 , G.R. No. 83737 , G.R. No. 85310 , G.R. No. 85335 , G. R. No. 81954
Primary Holding
Government reorganization after the effectivity of the 1987 Constitution, while permissible under its transitory provisions (Article XVIII, Section 16), must be carried out in good faith; separations of career civil service employees resulting therefrom are valid only if they are due to bona fide reasons such as the abolition of an office, redundancy of functions, or the need to merge, divide, or consolidate positions to meet service exigencies, and not as a means to arbitrarily remove employees whose security of tenure is protected by the Constitution.
Background
* Following the 1986 People Power Revolution, President Corazon Aquino promulgated Proclamation No. 3, "DECLARING A NATIONAL POLICY TO IMPLEMENT THE REFORMS MANDATED BY THE PEOPLE," which also served as a provisional "Freedom Constitution." * Proclamation No. 3 mandated, among other things, the complete reorganization of the government to eradicate unjust and oppressive structures, vestiges of the previous regime, and to promote economy, efficiency, and the eradication of graft and corruption. * This proclamation empowered the President to undertake this reorganization, during which appointive officials could be separated from service under specified conditions.
Constitutional Law I

Association of Small Landowners in the Philippines, Inc. vs. Secretary of Agrarian Reform

14th July 1989

ak989617
175 SCRA 343 , 256 Phil. 777 , G.R. No. 78742 , G.R. No. 79310 , G.R. No. 79744 , G.R. No. 79777
Primary Holding
The Supreme Court upheld the constitutionality of R.A. No. 6657 (CARP), P.D. No. 27, Proc. No. 131, and E.O. Nos. 228 and 229, subject to the condition that title to expropriated properties only transfers to the State upon full payment of just compensation to the landowners.
Background
The case arose from the government's efforts to implement agrarian reform, aimed at redistributing agricultural lands to landless farmers. Landowners challenged the legal basis and specific provisions of the agrarian reform laws, arguing that they violated constitutional rights.
Constitutional Law II
Police Power

Monsanto vs. Factoran Jr.

9th February 1989

ak622137
252 Phil. 192 , G.R. No. 78239
Primary Holding
An absolute pardon granted to a convicted public officer removes the penal consequences of the crime, including accessory penalties like disqualification from public office, thereby restoring eligibility for public employment; however, it does not _ipso facto_ restore the officer to the specific public office forfeited by reason of the conviction, nor does it extinguish civil liability arising from the offense or entitle the pardonee to back salaries for the period of suspension or non-employment.
Background
Petitioner Salvacion A. Monsanto was the assistant treasurer of Calbayog City. She was convicted by the Sandiganbayan for the complex crime of estafa thru falsification of public documents. This conviction, if finalized, carried with it accessory penalties including disqualification from public office. The core of the dispute arose after she received an absolute pardon from the President while her case was technically still pending (motion for reconsideration before the Supreme Court), leading her to believe she was entitled to automatic reinstatement and other benefits.
Constitutional Law I

Lazatin vs. House Electoral Tribunal

8th December 1988

ak403328
168 SCRA 391 , 250 Phil. 390 , No. L-84297
Primary Holding
The HRET’s rules, not the Omnibus Election Code, govern the filing period for congressional election protests; Timbol’s protest was timely filed under HRET’s 15-day rule.
Background
The case arose from the 1987 congressional election in Pampanga, where Timbol contested Lazatin’s proclamation due to alleged irregularities. After prolonged COMELEC proceedings, the Supreme Court reinstated Lazatin’s proclamation, prompting Timbol to file a protest with the HRET.
Statutory Construction

PLDT vs. NLRC and Abucay

23rd August 1988

ak716437
247 Phil. 641 , G.R. No. 80609
Primary Holding
An employee dismissed for serious misconduct or for causes reflecting on their moral character (e.g., dishonesty, theft, illicit sexual relations with a fellow worker) is not entitled to separation pay or financial assistance on the grounds of social justice or equity; such an award would effectively reward wrongdoing.
Background
Marilyn Abucay, a traffic operator at PLDT, was accused by two complainants of demanding and receiving P3,800.00 in exchange for a promise to facilitate the approval of their telephone installation applications. Following an investigation, PLDT found her guilty and terminated her employment.
Constitutional Law I

Barde vs. Posiquit

15th August 1988

ak212779
164 SCRA 304 , 247 Phil. 268 , G.R. No. L-29445
Primary Holding
Notice of the pre-trial conference under the Revised Rules of Court must be served not only upon the counsel but also directly upon the parties, and failure to notify the parties themselves renders the pre-trial and all subsequent proceedings and judgments null and void for violation of due process.
Background
The case originated from a dispute over the inheritance of a 173 square meter residential land originally owned by spouses Claro Barde and Juana Cordial. After their deaths, their son Pedro Barde registered the property exclusively in his name, excluding his sister Brigida and the heirs of his deceased brother Rafael. This led Brigida and Rafael's heirs to file a suit for reconveyance and partition against Pedro's heirs.
Civil Procedure I
Pre-trial

Spouses Del Campo vs. Abesia

15th April 1988

ak305738
160 SCRA 379 , 243 Phil. 532 , No. L-49219
Primary Holding
Article 448 of the Civil Code can apply to resolve disputes between former co-owners after partition, concerning constructions made in good faith that encroach on another co-owner's allocated portion.
Background
Spouses Del Campo and Bernarda Abesia were co-owners of a small parcel of land. During a partition action, it was discovered that Abesia's house slightly encroached onto the portion allocated to the Del Campos. The core issue was whether Abesia, as a co-owner builder, could invoke the rights of a builder in good faith under Article 448.
Property and Land Law

Aberca vs. Ver

15th April 1988

ak165028
160 SCRA 590 , 243 Phil. 735 , G.R. No. 69866 , No. L-69866
Primary Holding
The suspension of the privilege of habeas corpus does not bar a civil action for damages resulting from illegal arrests, searches, and other violations of constitutional rights. Superior officers can be held liable for such violations if they are found to be directly or indirectly responsible.
Background
The case arose from alleged illegal searches, seizures, arrests, and torture committed by the Armed Forces of the Philippines' Task Force Makabansa (TFM) under the command of General Fabian Ver, purportedly targeting communist-terrorist underground houses.
Constitutional Law II

Hustler Magazine, Inc. vs. Falwell

24th February 1988

ak337881
485 U.S. 4
Primary Holding
Public figures and public officials may not recover damages for the tort of intentional infliction of emotional distress by reason of the publication of a caricature or parody without showing that the publication contains a false statement of fact which was made with "actual malice"—that is, with knowledge that the statement was false or with reckless disregard as to whether or not it was true.
Background
Respondent Jerry Falwell, a nationally recognized minister and political commentator, was the subject of an advertisement "parody" published in petitioner Hustler Magazine, a nationally circulated publication known for its often-offensive content. The parody was modeled on a popular Campari Liqueur ad campaign that featured celebrities discussing their "first time." This case arose from Falwell's lawsuit against Hustler Magazine and its publisher, Larry Flynt, seeking damages for the distress caused by this publication.
Constitutional Law II
Freedom of Expression

Escritor, Jr. vs. Intermediate Appellate Court

12th November 1987

ak429625
239 Phil. 563 , 155 SCRA 577 , No. L-71283
Primary Holding
A possessor who initially acquired property based on a court decision, even if later reversed, is considered a possessor in good faith until they are actually aware of a defect in their title. Bad faith is personal and not transmissible to heirs unless they have personal knowledge of the flaw. Good faith is presumed, and the burden of proving bad faith lies with the one alleging it.
Background
The case originates from a cadastral proceeding where Miguel Escritor claimed ownership of a land lot based on inheritance. The Court of First Instance initially adjudicated the land to Escritor. Years later, Simeon Acuna filed a petition for review alleging fraud and misrepresentation in Escritor's acquisition. This petition was eventually granted, and the land was adjudicated to Acuna. Acuna then sued Escritor's heirs for damages for unlawful possession of the land during the period between the initial adjudication and its reversal.
Property and Land Law

Negros Oriental II Electric Cooperative, Inc. vs. Sangguniang Panlungsod of Dumaguete

5th November 1987

ak236019
239 Phil. 403 , G.R. No. 72492
Primary Holding
Local legislative bodies, such as a Sangguniang Panlungsod, do not possess the inherent power to compel the attendance of witnesses who are not their members through subpoena, nor the power to punish such non-members for contempt, as these powers are judicial in nature and must be expressly granted by statute or the Constitution; such powers cannot be implied from the delegation of legislative functions.
Background
The Ad Hoc Committee of the Sangguniang Panlungsod of Dumaguete initiated an investigation "in connection with pending legislation related to the operations of public utilities," specifically focusing on the alleged use of inefficient power lines by Negros Oriental II Electric Cooperative, Inc. (NORECO II) in Dumaguete City. This led to the issuance of a subpoena to NORECO II's officials and a subsequent order for them to show cause for contempt due to non-appearance, prompting the legal challenge.
Constitutional Law I

People vs. Abarca

14th September 1987

ak372672
153 SCRA 735 , 237 Phil. 718 , No. L-74433
Primary Holding
Article 247 of the Revised Penal Code, which imposes the penalty of *destierro* on a legally married person who kills their spouse or the spouse's paramour immediately after surprising them in the act of sexual intercourse, does not define a crime but grants a special privilege or benefit, negating conviction for homicide or murder; consequently, the act cannot be qualified by circumstances like treachery, nor can it form part of a complex crime.
Background
The case arose from an illicit relationship between Khingsley Paul Koh and Jenny Abarca, the wife of accused-appellant Francisco Abarca. This relationship began while Francisco Abarca was away in Manila reviewing for the 1983 bar examinations, leaving his wife behind in Tacloban, Leyte.
Criminal Law II
Death or physical injuries inflicted under exceptional circumstances

De Leon vs. Esguerra

31st August 1987

ak434466
153 SCRA 602 , 237 Phil. 582 , No. L-78059
Primary Holding
The Supreme Court declared the replacements void, holding that the 1987 Constitution superseded the Provisional Constitution on February 2, 1987, and barred the OIC Governor’s post-ratification designations.
Background
Petitioners, elected barangay officials in 1982, faced replacement through memoranda issued by the OIC Governor in February 1987. The Court determined the memoranda were antedated and issued after the 1987 Constitution’s ratification.
Statutory Construction

Export Processing Zone Authority vs. Dulay

29th April 1987

ak477243
149 SCRA 305 , 233 Phil. 313 , No. L-59603
Primary Holding
Presidential Decrees No. 76, 464, 794, and 1533, which limit just compensation to the lower of the owner’s declared value or the assessor’s value, are unconstitutional and void as they encroach upon the judiciary’s inherent power to determine just compensation in expropriation cases.
Background
The Export Processing Zone Authority (EPZA) sought to expropriate private land owned by San Antonio Development Corporation for the Mactan Export Processing Zone. EPZA attempted to base just compensation on valuations stipulated in Presidential Decrees, which were significantly lower than the market value. The trial court appointed commissioners to determine just compensation under Rule 67 of the Rules of Court, prompting EPZA to file this petition questioning the court's authority to do so.
Constitutional Law II
Eminent Domain

Ynot vs. Intermediate Appellate Court

20th March 1987

ak605477
148 SCRA 659 , 232 Phil. 615 , G.R. No. 74457
Primary Holding
Executive Order No. 626-A is unconstitutional because it violated due process by allowing confiscation of property without prior hearing, employed means not reasonably necessary to achieve its purpose, conferred judicial functions on administrative authorities, and contained an invalid delegation of legislative powers.
Background
The case arose during the Marcos regime when the government sought to protect carabaos (water buffalos) as essential farm animals by prohibiting their transportation across provincial boundaries, with the aim of preventing their indiscriminate slaughter.
Constitutional Law I Constitutional Law II
Police Power

Teja Marketing vs. Intermediate Appellate Court

9th March 1987

ak520987
232 Phil. 321 , G.R. No. 65510
Primary Holding
Parties involved in an illegal "kabit system," an arrangement contrary to public policy, are deemed *in pari delicto*, and courts will not aid either party in enforcing their illicit agreement or recovering what has been given thereunder.
Background
The case arose from a transaction involving the sale of a motorcycle intended for use as a trimobile under the seller's existing franchise, an arrangement commonly known as the "kabit system." This system involves a person who has been granted a certificate of public convenience allowing another person who owns motor vehicles to operate under such franchise for a fee, which is considered contrary to public policy.
Obligations and Contracts

Demetria vs. Alba

27th February 1987

ak192412
232 Phil. 222 , G.R. No. 71977
Primary Holding
The first paragraph of Section 44 of Presidential Decree No. 1177 is unconstitutional because it empowers the President to indiscriminately transfer funds without regard to whether the funds are savings or whether the transfer is for augmenting an item, thereby over-extending the privilege granted by Section 16(5), Article VIII of the 1973 Constitution and constituting an undue delegation of legislative power.
Background
The case arose from the petitioners' challenge to Presidential Decree No. 1177, specifically Section 44, which granted the President broad authority to transfer appropriated funds within the Executive Department. This decree was issued during a period when the President exercised legislative powers. Petitioners, concerned about potential abuse and the circumvention of constitutional safeguards on public funds, questioned the legality of this provision.
Constitutional Law I

Director of Lands vs. Intermediate Appellate Court

29th December 1986

ak048318
146 SCRA 509 , 230 Phil. 590 , No. L-73002
Primary Holding
The Supreme Court held that the land acquired by Acme Plywood from the Infiels in 1962 was already private land by operation of law due to the Infiels' immemorial possession, and thus Acme Plywood, as a successor-in-interest, had a registrable title despite being a corporation and despite the 1973 Constitution’s restrictions, because the right vested prior to the 1973 Constitution.
Background
Acme Plywood & Veneer Co., Inc. sought to register five parcels of land acquired from Mariano and Acer Infiel, members of the Dumagat tribe, through land registration proceedings under Section 48 of the Public Land Act. The Director of Lands opposed the registration, arguing that because the proceedings started after the 1973 Constitution came into effect, the corporation was disqualified from owning public land according to the new constitution.
Property and Land Law

Koh vs. Intermediate Appellate Court

23rd September 1986

ak423446
144 SCRA 259 , 228 Phil. 258 , G.R. NO. 71388
Primary Holding
A dismissal of a case based on non-compliance with a "Notice of Case Status" issued by a court's officer-in-charge, which requires parties to manifest their intent regarding modes of discovery, is null and void and does not constitute res adjudicata, as such notice is not a lawful order of the court contemplated under Rule 17, Section 3 of the Rules of Court.
Background
The dispute originated from an erroneous bank transaction where respondent First Interstate Bank of California, due to a computer mistake, issued a cashier's check for US-$8,500.00 to petitioner Maria Monserrat R. Kor, instead of the US-$500.00 actually remitted by her father.
Civil Procedure I
Discovery

Javier vs. Commission on Elections

22nd September 1986

ak367573
144 SCRA 194 , 228 Phil. 193 , G.R. Nos. L-68379-81
Primary Holding
The COMELEC Second Division lacked jurisdiction to decide pre-proclamation controversies involving Batasang Pambansa members, as such cases must be heard en banc under the 1973 Constitution.
Background
The 1984 Antique elections were marred by violence, including the killing of petitioner Evelio Javier’s supporters. Javier challenged irregularities in the canvass, but COMELEC’s Second Division dismissed his claims and proclaimed Arturo Pacificador winner. Javier’s assassination in 1986 and the Batasang’s abolition under the post-Marcos Freedom Constitution rendered the case moot.
Constitutional Law II

Galman vs. Pamaran

30th August 1985

ak797659
138 SCRA 294 , Nos, L-71208-09 , Nos. L-71212-13
Primary Holding
This case arises from the assassination of former Senator Benigno S. Aquino Jr. in 1983 at Manila International Airport. The primary issue concerns the admissibility of testimonies and evidence provided by suspects before the Agrava Fact-Finding Board, especially in light of their constitutional right against self-incrimination and the immunity granted under Presidential Decree No. 1886. The Supreme Court upheld the exclusion of the testimonies and evidence submitted to the Agrava Board, reinforcing constitutional protections against self-incrimination.
Background
The assassination of Senator Benigno S. Aquino Jr. on August 21, 1983, led to the creation of the Agrava Fact-Finding Board under P.D. 1886. The Board investigated the incident and gathered testimonies, including those from suspects. Legal questions arose during subsequent trials regarding the admissibility of evidence obtained under mandatory compulsion by the Board.
Statutory Construction

Jain vs. Intermediate Appellate Court and People

28th September 1984

ak063159
132 SCRA 359 , 217 Phil. 347 , No. L-63129
Primary Holding
The crime of theft, under Philippine law, requires physical taking or apoderamiento of the personal property of another; substituting train receipts to fraudulently claim ownership of sugar canes does not constitute theft because there was no physical taking of the canes themselves.
Background
Wayne Jain was accused of theft based on informations filed by the City Fiscal for allegedly stealing sugar canes. The prosecution argued that Jain, in conspiracy with a watchman, fraudulently substituted train receipts to misrepresent ownership and claim proceeds from sugar canes owned by Tomasa Bermejo.
Philosophy of Law

Heirs of Jose Amunategui vs. Director of Forestry

29th November 1983

ak724137
126 SCRA 69 , 211 Phil. 260 , No. L-27873 , No. L-30035
Primary Holding
Possession of forest lands, regardless of duration, cannot ripen into private ownership. Forest lands remain in the public domain and are not subject to registration for private individuals unless there is a positive act from the government declassifying them as agricultural or disposable land.
Background
The case originated from an application for land registration filed in the Court of First Instance of Capiz for Lot No. 885. Several oppositions were filed, including one from the Director of Forestry, who argued the land was forest land. The Court of First Instance partially granted the application to private litigants, but this was appealed.
Property and Land Law

City Government of Quezon City vs. Ericta

24th June 1983

ak611870
207 Phil. 648 , 122 SCRA 759 , No. L-34915
Primary Holding
Section 9 of Ordinance No. 6118, S-64 of Quezon City is unconstitutional and void as it constitutes an invalid exercise of police power amounting to confiscation of property without due process or just compensation, rather than a valid regulation.
Background
Quezon City enacted an ordinance regulating private cemeteries, including a provision (Section 9) requiring a 6% set-aside for pauper burials. This provision was not initially enforced, but seven years later, the City Council resolved to enforce it, directing the City Engineer to stop land transactions in cemeteries not complying with the 6% requirement. Himlayang Pilipino, Inc., a cemetery operator, challenged the ordinance in court.
Constitutional Law II
Police Power

People vs. Narvaez

20th April 1983

ak862181
121 SCRA 389 , 206 Phil. 314 , Nos. L-33466-67
Primary Holding
Narvaez is guilty of two counts of homicide, not murder, due to incomplete self-defense and mitigating circumstances. His sentence is reduced to four months of arresto mayor, and he is ordered to indemnify the heirs of the deceased with a reduced amount of damages, leading to his immediate release given his lengthy pre-trial detention.
Background
Narvaez, a settler in South Cotabato, was embroiled in a land dispute with Fleischer and Company. He had been leasing a portion of the land in contention, but the company sought to remove him and other settlers. The deceased victims, Davis Fleischer and Flaviano Rubia, were secretary-treasurer and assistant manager of Fleischer & Co. respectively, and were fencing the land when Narvaez shot them.
Property and Land Law

Garcia-Padilla vs. Enrile

20th April 1983

ak516942
206 Phil. 392 , G.R. No. 61388
Primary Holding
The President's decision to suspend the privilege of the writ of habeas corpus in cases of invasion, insurrection, rebellion, or imminent danger thereof, when public safety requires it, is a political question beyond judicial inquiry; consequently, a Presidential Commitment Order (PCO) issued for offenses covered by such suspension renders the detention legal and valid, and the right to bail is deemed suspended for the duration of the emergency for those detained for such offenses.
Background
The case arose following the official lifting of Martial Law in the Philippines via Proclamation No. 2045 on January 17, 1981. However, this same proclamation continued the suspension of the privilege of the writ of habeas corpus with respect to persons detained for crimes of insurrection, rebellion, subversion, conspiracy or proposal to commit such crimes, and for all other crimes committed in furtherance thereof. The arrests and detentions in this case occurred under this legal framework, amidst ongoing government efforts to suppress perceived threats to national security.
Constitutional Law I

Sarmiento vs. Juan

28th January 1983

ak679362
120 SCRA 403 , 205 Phil. 335 , No. L-56605
Primary Holding
A trial court commits grave abuse of discretion when it denies a motion for postponement of pre-trial based on a party's sudden illness (even if initially lacking a medical certificate but later substantiated under oath) and declares that party in default, especially when the opposing party also failed to make a valid appearance (i.e., counsel appeared without special authority); the requirement for pre-trial to be held "after the last pleading has been filed" can be interpreted to mean after the period for filing the last pleading has expired, and failure to answer a compulsory counterclaim does not necessarily prevent pre-trial.
Background
The underlying case (Civil Case No. 126113 in the Court of First Instance of Manila) was initiated by private respondent Belfast Surety & Insurance Co., Inc. against petitioner Andres C. Sarmiento and his father, Benjamin R. Sarmiento, Sr., seeking indemnification under an Indemnity Agreement related to a bail bond.
Civil Procedure I
Pre-trial

Macias vs. Araula

20th July 1982

ak051208
115 SCRA 135 , 200 Phil. 524 , A.M. No. 1895-CFI
Primary Holding
While the evidence presented was insufficient to establish prohibited partisan political activity (electioneering) or grave misconduct/oppression under the high standard of proof required in administrative cases against judges, a judge's conduct must nonetheless be free from the appearance of impropriety, and actions that could be misinterpreted as partisan, even if well-intentioned (like explaining election mechanics at a political rally), warrant admonishment under the Canons of Judicial Ethics.
Background
The case arose in the context of intense local political rivalry in Dauin, Negros Oriental, following the April 7, 1978 elections. Respondent Judge Araula's wife was the incumbent Mayor and KBL Chairman in Dauin, while the complainant and his witnesses were associated with the opposing Pusyon Bisaya party. The charges stemmed from incidents occurring shortly before and after these elections, reflecting the bitter political division and personal animosity between the factions, particularly involving the Judge's family and Atty. Rudy Enriquez, a relative and political opponent.
Constitutional Law I

Puyat vs. De Guzman, Jr.

25th March 1982

ak217409
198 Phil. 420 , G.R. No. 51122
Primary Holding
A Member of the Batasang Pambansa is prohibited from appearing as counsel before any administrative body, and this prohibition extends to indirect appearances, such as intervening in a case under the guise of protecting a minimal stockholding acquired shortly before and for the purpose of such intervention, when the true intent is to participate in the proceedings in a capacity akin to counsel.
Background
The case arose from a contested election of the Board of Directors of International Pipe Industries Corporation (IPI) on May 14, 1979, which led to a quo warranto proceeding (SEC Case No. 1747) filed by the "Acero Group" against the "Puyat Group" before the Securities and Exchange Commission (SEC). Assemblyman Estanislao A. Fernandez, after initially attempting to appear as counsel for the Acero Group and facing objection, purchased a nominal number of IPI shares and then sought to intervene in the SEC case as a stockholder.
Constitutional Law I

Yuvienco vs. Dacuycuy

27th May 1981

ak311310
192 Phil. 183 , G.R. No. 55048
Primary Holding
For a contract of sale of real property to be enforceable under the Statute of Frauds, particularly when payment is to be made in installments, the note or memorandum must contain all essential elements of the contract, including the specific terms of payment; a mere indication of the total price without the agreed manner of payment is insufficient if the intent is not a cash sale. Furthermore, an acceptance of an offer that includes a call to "negotiate details" is not an absolute acceptance required for the perfection of a contract under Article 1319 of the Civil Code.
Background
Petitioners expressed willingness to sell a property in Tacloban City to private respondents (occupants of the property) for P6,500,000, provided respondents decided by July 31, 1978. Respondents replied, agreeing to buy and asking petitioners' representative to "proceed Tacloban to negotiate details." A subsequent meeting occurred where petitioners' representative presented a prepared contract with payment terms (balance within 30 days) that differed from what respondents allegedly expected (balance within 90 days), leading to the non-signing of the contract and the present suit for specific performance.
Obligations and Contracts

Azarcon vs. Vallarta

28th October 1980

ak487327
100 SCRA 450 , 188 Phil. 481 , No. L-43679
Primary Holding
The Original Certificate of Title held by the Vallartas is valid and superior, while the Free Patent Title held by the Azarcons is declared null and void and ordered cancelled.
Background
The contested land was originally owned by Dr. Jose V. Cajucom, who sold it in two separate transactions. First, to the Vallartas' predecessors in 1932, and later to the Azarcons in 1959. Both parties subsequently obtained titles, leading to conflicting claims of ownership over the same property.
Property and Land Law

Ceniza vs. COMELEC

28th January 1980

ak528318
95 SCRA 763 , 180 Phil. 597 , G.R. No. 52304
Primary Holding
The classification of cities into highly urbanized and component cities based on annual income under Batas Pambansa Blg. 51, which determines whether their residents can vote for provincial officials, is based on substantial distinctions germane to the constitutional mandate of promoting local autonomy and does not violate the equal protection clause or the right of suffrage.
Background
Following the enactment of the 1973 Constitution emphasizing local government autonomy, the Interim Batasan Pambansa passed Batas Blg. 51 in preparation for the January 30, 1980 local elections. This law introduced a classification system for cities based on annual income (P40 million threshold) into "highly urbanized" and "component" cities. This classification determined whether the registered voters of a city could participate in the election of officials of the province where the city is geographically located, leading to challenges from voters in affected cities like Cebu and Mandaue.
Constitutional Law II
Equal Protection

Arenas vs. City of San Carlos (Pangasinan)

5th April 1978

ak735400
82 SCRA 318 , 172 Phil. 306 , No. L-34024
Primary Holding
The Supreme Court held that the proviso in Republic Act No. 5967, which states that a city judge's salary must be at least P100 less than that of the city mayor, qualifies the general provision establishing city judges' salaries.
Background
Isidro G. Arenas, serving as City Judge of San Carlos City, claimed entitlement to a higher salary based on Republic Act No. 5967. The city government refused to pay the differential, citing that the law mandates the judge's salary to be lower than the mayor's. Arenas filed a mandamus petition, which was dismissed by the Court of First Instance.
Statutory Construction

Arianza vs. Workmen’s Compensation Commission

28th February 1978

ak230860
81 SCRA 698 , 171 Phil. 616 , No. L-43352
Primary Holding
The Supreme Court held that Arianza’s liver cirrhosis, though not directly caused by his employment, was aggravated by his working conditions, making it compensable under the Workmen’s Compensation Act.
Background
Arianza worked for Central Azucarera de la Carlota, Inc. from 1960, performing various physically demanding tasks, including packing and piling bagasse and working as a water tender in the fire-room. He developed liver cirrhosis, which he claimed was aggravated by his work conditions. His claim was initially dismissed by the Workmen’s Compensation Commission but was later reversed by the Supreme Court.
Philosophy of Law

Pioneer Insurance & Surety Corp. vs. Hontanosas

31st August 1977

ak095815
168 Phil. 608 , G.R. No. L-35951
Primary Holding
A claim for damages arising from a wrongful preliminary attachment must be prosecuted in the same court where the attachment bond was filed and the writ of attachment was issued, pursuant to Rule 57, Section 20 of the Rules of Court; prosecuting such a claim in a separate action before a different court is improper and that court lacks jurisdiction.
Background
The dispute originated from a collection suit filed by Allied Overseas Commercial Co., Ltd. (Allied) against Ben Uy Rodriguez in the CFI of Manila, where Allied obtained a writ of preliminary attachment secured by a bond from Pioneer Insurance & Surety Corp. (Pioneer). Although the Manila case was dismissed for improper venue, Rodriguez subsequently filed a separate action in the CFI of Cebu against Pioneer and Allied (later including Allied's assignee, Hadji Esmayaten Lucman) to claim damages for the alleged wrongful and malicious attachment.
Civil Procedure I
Pre-trial

Cruz vs. J. M. Tuason and Co., Inc.

29th April 1977

ak142238
167 Phil. 261 , G.R. No. L-23749
Primary Holding
A motion for reconsideration that merely reiterates arguments already considered and resolved by the court is pro-forma and does not suspend the reglementary period for filing an appeal; consequently, an appeal filed beyond this period must be dismissed as the assailed order has become final and executory.
Background
The case arose from claims over a large tract of land. The Deudor family, asserting rights based on an "informacion posesoria," allegedly engaged Faustino Cruz to make improvements on a portion of this land. Subsequently, J.M. Tuason & Co., Inc. and Gregorio Araneta, Inc. (defendants-appellees), who were the registered owners, purportedly engaged Cruz to act as an intermediary to settle a civil case (Civil Case No. Q-135) with the Deudors concerning 50 quiñones of land, promising him 3,000 square meters as compensation. A compromise agreement was indeed reached between the Deudors and the defendants.
Obligations and Contracts

Bagatsing vs. Ramirez

17th December 1976

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74 SCRA 306 , 165 Phil. 909 , G.R. No. L-41631
Primary Holding
Tax ordinances are governed by the Local Tax Code’s publication requirements (post-approval only), overriding the Revised City Charter’s stricter pre- and post-enactment rules.
Background
June 12–15, 1974: Manila’s Municipal Board enacted and Mayor Bagatsing approved Ordinance No. 7522, imposing fees on public market stalls. February 17, 1975: The Federation of Manila Market Vendors sued to invalidate the ordinance, claiming non-compliance with the City Charter’s publication rules. August 29, 1975: The Court of First Instance (Manila) nullified the ordinance for lacking pre-enactment publication.
Statutory Construction

Purugganan vs. Paredes

21st January 1976

ak605464
69 SCRA 69 , 161 Phil. 91 , No. L-23818
Primary Holding
A summary judgment was correctly rendered because the defendants-appellants violated the conditions of a registered easement of drainage and failed to demonstrate a genuine issue of material fact that would necessitate a full trial. Furthermore, any prescriptive easement of light and view was extinguished by the registration of the servient estate under the Torrens System without such easement being annotated.
Background
Plaintiff Purugganan owned lots burdened by a registered easement of drainage in favor of Defendant Paredes' adjacent property. Paredes constructed a house that exceeded the easement's specifications, causing rainwater to improperly drain onto Purugganan's property. Purugganan sued to enforce the easement, while Paredes claimed her house was pre-existing and not in violation.
Property and Land Law

Padua vs. Robles

29th August 1975

ak406269
66 SCRA 485 , No. L-40486
Primary Holding
The Supreme Court ruled that Robles, as the employer of the negligent driver Punzalan, was subsidiarily liable for the civil indemnity awarded to the Paduas under the judgment in the criminal case, in accordance with Article 103 of the Revised Penal Code. The dismissal by the lower court was set aside, and the case was remanded for further proceedings.
Background
On January 1, 1969, a taxi owned by Bay Taxi Cab, driven by Romeo Punzalan, hit and killed 10-year-old Normandy Padua in Olongapo City. The victim's parents (Paulino and Lucena Padua) filed a civil case against Punzalan and the Bay Taxi Cab (Civil Case No. 427-O), while Punzalan faced criminal charges for reckless imprudence resulting in homicide (Criminal Case No. 1158-O). The civil court ruled in favor of the Paduas, ordering Punzalan to pay damages but absolving Bay Taxi Cab. The criminal court later convicted Punzalan and sentenced him to imprisonment, stating that his civil liability had already been determined in Civil Case No. 427-O. However, when the Paduas attempted to execute the civil judgment, Punzalan was found to be insolvent. They then filed a separate action (Civil Case No. 1079-O) to enforce Robles’ subsidiary liability. The lower court dismissed the case, ruling that there was no cause of action. The Paduas appealed, and the Court of Appeals referred the case to the Supreme Court due to the legal question involved.
Philosophy of Law

Aquino, Jr. vs. Enrile

17th September 1974

ak831150
59 SCRA 183 , 158-A Phil. 1 , No. L-35546 , No. L-35538 , No. L-35539 , No. L-35540 , No. L-35547 , No. L-35556 , No. L-35567 , No. L-35571 , No. L-35573
Background
The case primarily revolved around the legality of arresting individuals without a court order, based solely on martial law powers. The petitioners argued that the martial law proclamation was unconstitutional, and that the arrests violated due process. The respondents maintained that the arrests were necessary for national security given the ongoing rebellion.
Constitutional Law I

Victoriano vs. Elizalde Rope Workers' Union

12th September 1974

ak917809
158 Phil. 60 , G.R. No. L-2524
Primary Holding
Republic Act No. 3350, which amends Section 4(a)(4) of the Industrial Peace Act (R.A. No. 875) by exempting members of religious sects prohibiting affiliation with labor organizations from the coverage of closed shop agreements, is constitutional. It validly protects the fundamental right to freedom of religion without unduly infringing upon other constitutional rights or established legal principles.
Background
The case arose from a conflict between an employee's religious beliefs prohibiting labor union membership and a collective bargaining agreement's closed shop provision. Benjamin Victoriano, an employee of Elizalde Rope Factory Inc. and a member of the Iglesia ni Cristo, a religious sect prohibiting its members from joining labor organizations, was compelled by a closed shop agreement between his employer and the Elizalde Rope Workers' Union to be a member of the Union. Following the enactment of R.A. No. 3350, which exempts such individuals from closed shop provisions, Victoriano resigned from the Union. The Union then demanded his dismissal from the company, leading to the legal challenge.
Constitutional Law II
Freedom of Religion

Republic vs, Vda. de Castellvi

15th August 1974

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58 SCRA 336 , 157 Phil. 329 , No. L-20620
Primary Holding
The Supreme Court held that the "taking" of the properties occurred upon the filing of the expropriation complaint in 1959, not in 1947 when the Republic initially leased Castellvi's land. The just compensation for the expropriated lands, classified as residential, was fixed at P5.00 per square meter. The Republic was ordered to pay interest on the compensation from the time of deposit of provisional value and from the actual taking in possession.
Background
The Republic needed to expand the Basa Air Base and initiated expropriation proceedings against Carmen M. Vda. de Castellvi and Maria Nieves Toledo-Gozun, landowners of adjacent properties. The Republic had previously leased Castellvi’s land since 1947. Disagreement arose over the just compensation, with landowners claiming a much higher value (P15.00 per square meter) compared to the Republic's initial valuation (P0.20 per square meter).
Constitutional Law II
Eminent Domain

Cabanas vs. Pilapil

25th July 1974

ak516159
58 SCRA 94 , 157 Phil. 97 , No. L-25843
Background
The case arose from a dispute over the custody of insurance proceeds intended for a minor beneficiary. The deceased, Florentino Pilapil, had named his brother Francisco as the trustee for his daughter Millian's insurance benefits. However, Millian's mother, Melchora Cabanas, sought to obtain the proceeds, arguing that as the child's mother and guardian, she was entitled to administer the funds.
Constitutional Law I

Astorga vs. Villegas

30th April 1974

ak503127
56 SCRA 714 , No. L-23475
Primary Holding
The Supreme Court declared Republic Act 4065 invalid as it was not properly enacted into law, ruling that when there is a conflict between the enrolled bill and the legislative journal records, the latter may be consulted to determine whether a bill was duly enacted.
Background
The case originated from the passage of House Bill No. 9266, which sought to define the powers of the Manila Vice-Mayor. After its passage, controversy erupted when it was discovered that the version signed into law did not include substantial amendments made by Senator Tolentino on the Senate floor.
Statutory Construction