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People vs. Espinosa

15th August 2003

ak358277
409 SCRA 256 , G.R. Nos. 153714-20
Primary Holding
A waiver of the constitutional right against double jeopardy must be clear, categorical, knowing, and intelligent; any alleged conditions attached to an arraignment must be unmistakable, express, and informed, otherwise, the plea is considered simple and unconditional, and legal jeopardy attaches.
Background
The case originated from initial charges of estafa and attempted corruption filed by the Office of the Ombudsman against Mario K. Espinosa, then the provincial administrator of Masbate. While these cases were pending reinvestigation, Espinosa was arraigned to facilitate a request to travel abroad. The Ombudsman later withdrew these charges and filed new ones for malversation of public funds, prompting Espinosa to raise the defense of double jeopardy.
Civil Procedure II

Allied Domecq Phil., Inc. vs. Villon

12th August 2003

ak813262
439 SCRA 667 , 482 Phil. 894 , G.R. No. 156264
Primary Holding
The Supreme Court held that pursuant to Section 21 of Republic Act No. 7227, only the Supreme Court has the jurisdiction to issue a restraining order or preliminary injunction against the implementation of projects for the conversion of former military reservations into alternative productive uses, which includes the operations of duly registered enterprises within the Clark Special Economic Zone like respondent Clark Liberty.
Background
Petitioner ADPI held an exclusive distributorship agreement for "Fundador" brandy in the Philippines, granted by the Spanish manufacturer Pedro Domecq, S.A. ADPI obtained the necessary Certificate of Registration from the Bureau of Food and Drugs (BFAD) for the product. Subsequently, the Bureau of Customs issued a circular requiring importers of "Fundador" brandy to present a valid BFAD certificate. Respondent Clark Liberty, a duty-free shop in the Clark Special Economic Zone (CSEZ), imported a significant quantity of "Fundador" brandy without such a certificate.
Civil Procedure I

Senate Blue Ribbon Committee vs. Majaducon

29th July 2003

ak802239
455 Phil. 61 , G.R. No. 136760 , G.R. NO. 138378
Primary Holding
A Regional Trial Court has no jurisdiction to prohibit the Senate or its committees from conducting inquiries in aid of legislation, as this would violate the principle of separation of powers; furthermore, the use of terms like "gross ignorance of the law" in pleadings challenging a judge's order, without malice, does not automatically constitute indirect contempt, especially when such terms are descriptive of alleged errors in applying fundamental legal principles.
Background
The case arose from two Senate Resolutions: No. 157, directing an inquiry into alleged coup d'etat plans related to probing AFP fund irregularities, and No. 160, directing an inquiry into alleged mismanagement of AFP-Retirement and Separation Benefits System (AFP-RSBS) funds. These resolutions were referred to the Senate Blue Ribbon Committee and the Committee on National Defense and Security for investigation.
Constitutional Law I

Republic vs. Sandiganbayan

21st July 2003

ak422271
407 SCRA 10 , 454 Phil. 504 , G.R. No. 104768
Primary Holding
The Supreme Court adjudicated that the PCGG lacked the requisite jurisdiction to investigate and prosecute Major General Ramas and Elizabeth Dimaano, as Ramas did not meet the definitional criteria of a "subordinate" of former President Ferdinand Marcos under Executive Orders Nos. 1, 2, 14, and 14-A. The Court affirmed that such jurisdiction rightly resides with the Office of the Ombudsman and the Office of the Solicitor General.
Background
In the aftermath of the 1986 EDSA Revolution, President Corazon Aquino established the PCGG to spearhead the recovery of assets unlawfully acquired during the Marcos regime. The AFP Anti-Graft Board, under the PCGG's directive, initiated an inquiry into the financial dealings of Major General Ramas, uncovering properties and assets allegedly disproportionate to his lawful income. The investigation extended to Elizabeth Dimaano, purportedly Ramas' mistress, in whose possession substantial monetary sums and military-grade equipment were discovered. This led to a forfeiture petition grounded on the Anti-Graft and Corrupt Practices Act and the Forfeiture Law (RA No. 1379).
Philosophy of Law

Commissioner of Internal Revenue vs. Michel J. Lhuillier Pawnshop, Inc

15th July 2003

ak922816
406 SCRA 178 , 453 Phil. 1043 , G.R. No. 150947
Primary Holding
Pawnshops are excluded from the definition of “lending investors” under Section 116 of the NIRC, rendering BIR’s assessment for deficiency percentage tax void.
Background
The BIR sought to impose a 5% lending investor’s tax on pawnshops through administrative issuances (RMO No. 15-91 and RMC No. 43-91). Michel J. Lhuillier Pawnshop challenged the assessment, arguing pawnshops were distinct from lending investors and the BIR overstepped its rulemaking authority.
Statutory Construction

Lawrence vs. Texas

26th June 2003

ak906927
539 U.S. 558
Primary Holding
A Texas statute making it a crime for two persons of the same sex to engage in certain intimate sexual conduct violates the Due Process Clause of the Fourteenth Amendment, as the liberty protected by the Constitution includes the right for adults to engage in private, consensual homosexual activity without government intervention; consequently, _Bowers v. Hardwick_, 478 U.S. 186, is overruled.
Background
The case arose within the legal and social context of state laws criminalizing sodomy, often referred to as "crimes against nature" or "deviate sexual intercourse." Seventeen years prior, in _Bowers v. Hardwick_, the Supreme Court had upheld a Georgia sodomy law applied to homosexual conduct, finding no fundamental right to engage in such activity. Since _Bowers_, legal and social perspectives continued to evolve, with many states repealing their sodomy laws or ceasing enforcement against private, consensual adult conduct, and subsequent Court decisions like _Romer v. Evans_ casting doubt on laws motivated by animus towards homosexuals.
Constitutional Law II
Equal Protection

Ang Bagong Bayani-OFW Labor Party vs. COMELEC

25th June 2003

ak413799
452 Phil. 899 , G.R. No. 147589 , G.R. No. 147613
Primary Holding
In party-list elections, votes cast for organizations that are subsequently disqualified for failing to meet the statutory and jurisprudential requirements must be deducted from the "total votes cast for the party-list system" for the purpose of determining the two-percent threshold required to win a seat in the House of Representatives, as mandated by Section 10 of RA 7941, which states that votes for those "not entitled to be voted for shall not be counted."
Background
The case emerged from the complexities of the 2001 party-list elections, following the Supreme Court's June 26, 2001 Decision that established eight-point guidelines for party-list qualification. Numerous party-list groups participated, leading to disputes over qualification, the computation of votes, the determination of the two-percent threshold, and the allocation of seats, necessitating further clarification from the Court on how to apply the party-list law (RA 7941) and its previous rulings.
Constitutional Law I

Buena Obra vs. Social Security System

9th April 2003

ak528677
401 SCRA206 , 449 Phil. 200 , G.R. No. 147745
Primary Holding
The Court held that (1) the claim was filed within a “reasonable time” due to the SSS’s failure to process her EC claim earlier, and (2) myocardial infarction was work-related under ECC Resolution No. 432 due to job strain.
Background
Juanito Buena Obra, a dump truck driver for 24 years, died of a heart attack at work in 1988. His widow filed for SSS death benefits but learned about EC benefits a decade later. The SSS/ECC rejected her claim, alleging prescription and lack of work connection.
Statutory Construction

Coronel vs. Constantino

7th February 2003

ak326196
445 Phil. 97 , G.R. No. 121069
Primary Holding
A sale by a co-owner of the entire co-owned property is valid only with respect to the seller's pro-indiviso share, and the sale of the shares of other co-owners without their authority or legal representation is unenforceable; mere silence or inaction of such other co-owners, without proof of their awareness of the unauthorized sale and a voluntary, knowing adoption of the act, does not constitute ratification.
Background
The subject property, consisting of two parcels of land (Cadastral Lots Nos. 5737 and 5738) in Sta. Monica, Hagonoy, Bulacan, was originally owned by Honoria Aguinaldo. Upon Honoria's death, one-half (1/2) of the property was inherited by petitioner Emilia Meking Vda. de Coronel together with her sons, petitioner Benjamin, Catalino, and Ceferino, all surnamed Coronel. The other half was inherited by respondents Florentino Constantino and Aurea Buensuceso. The dispute arose from the sale of the portion inherited by Emilia and her sons.
Obligations and Contracts

Dadole vs. Commission on Audit

3rd December 2002

ak714832
441 Phil. 537 , G.R. No. 125350
Primary Holding
Local Budget Circular No. 55, issued by the Department of Budget and Management, is null and void because it overstepped the President's power of general supervision over local government units by imposing a specific monetary limit on additional allowances not found in the enabling law (R.A. 7160), and because it was not published as required for administrative rules intended to enforce or implement existing law.
Background
For several years, RTC and MTC judges in Mandaue City had been receiving monthly additional allowances from the city government through appropriation ordinances. In 1991, this amount was P1,500. In 1994, the Department of Budget and Management (DBM) issued Local Budget Circular No. 55 (LBC 55), which limited such additional allowances from provinces and cities to P1,000.00 per month. This circular led to the Mandaue City Auditor issuing notices of disallowance for the amounts received by the petitioner judges in excess of P1,000 and requiring reimbursement.
Constitutional Law I

Francisco vs. Herrera

21st November 2002

ak748349
440 Phil. 841 , G.R. No. 139982
Primary Holding
A contract entered into by a party whose capacity to consent is vitiated by senile dementia is not void ab initio but merely voidable; such a contract is susceptible to ratification, which can be implied through actions such as accepting and retaining the benefits of the contract, thereby rendering it perfectly valid.
Background
Eligio Herrera, Sr., the father of respondent Pastor Herrera, was the owner of two parcels of land located in Cainta, Rizal. In 1991, Eligio Sr. sold these properties to the petitioner, Julian Francisco, through two separate transactions. Subsequently, the children of Eligio Sr., including the respondent, contested these sales, primarily arguing that the agreed purchase price was grossly inadequate and, more significantly, that Eligio Sr. was suffering from senile dementia at the time of the sales, which allegedly rendered him incapable of giving valid consent to the contracts.
Obligations and Contracts

Carpio vs. Sulu Resources Development Corporation

8th August 2002

ak328564
387 SCRA 128 , G.R. No. 148267
Primary Holding
Decisions and final orders of the Mines Adjudication Board (MAB) are appealable to the Court of Appeals under Rule 43 of the 1997 Rules of Court, as the MAB is a quasi-judicial agency, and Section 79 of RA 7942, which suggests direct appeal to the Supreme Court, is modified by procedural rules and constitutional principles limiting expansions of the Supreme Court's appellate jurisdiction without its consent.
Background
The case arises from a mining dispute under the Philippine Mining Act of 1995 (RA 7942), involving conflicting claims to quarry resources in Antipolo, Rizal, where private landowners like the petitioner assert preferential rights over areas overlapping with corporate mining applications, highlighting tensions between individual property rights and administrative mining allocations by the Department of Environment and Natural Resources (DENR).
Civil Procedure II
Rule 43

Yau vs. Manila Banking Corporation

11th July 2002

ak716089
384 SCRA 340 , 433 Phil. 701 , G.R. No. 126731 , G.R. No. 128623
Primary Holding
A court (RTC Cebu) cannot interfere with property under the *custodia legis* (custody of the law) of a co-equal court (RTC Makati) by ordering the cancellation and transfer of title of such property; however, a judgment creditor who purchases property subject to a prior attachment at an execution sale has a sufficient legal interest to intervene in the action where the attachment was issued to protect their rights.
Background
Esteban Yau obtained a final judgment against Ricardo Silverio, Sr. from RTC Cebu. The only known asset of Silverio was a proprietary share in Manila Golf and Country Club. This share, however, was already subject to preliminary attachments obtained by Manilabank in separate collection cases against Silverio pending before RTC Makati. This created a conflict when Yau, after purchasing the share at the execution sale ordered by RTC Cebu, sought to have the title transferred to his name.
Civil Procedure I
Intervention

Matibag vs. Benipayo

2nd April 2002

ak305174
429 Phil. 554 , G.R. No. 149036
Primary Holding
Ad interim appointments to the Commission on Elections (COMELEC) are permanent appointments that take effect immediately upon qualification and are not considered temporary or acting appointments prohibited by Article IX-C, Section 1(2) of the Constitution; furthermore, the renewal of such ad interim appointments when by-passed by the Commission on Appointments does not violate the constitutional prohibition on reappointment, as this prohibition applies only to appointees who have been previously confirmed by the Commission on Appointments and have served a term or part thereof.
Background
The case arose following changes in the leadership of the Commission on Elections (COMELEC). Petitioner Ma. J. Angelina G. Matibag, who held a temporary appointment as Director IV of the COMELEC's Education and Information Department (EID), was reassigned to the Law Department by newly appointed ad interim COMELEC Chairman Alfredo L. Benipayo. This reassignment, coupled with the ad interim appointments and their subsequent renewals for Chairman Benipayo and Commissioners Borra and Tuason by President Gloria Macapagal Arroyo, prompted Matibag to challenge the constitutionality and legality of these appointments and her reassignment, citing concerns over COMELEC's independence and alleged violations of constitutional prohibitions.
Constitutional Law I

Commission on Audit of the Province of Cebu vs. Province of Cebu

29th November 2001

ak875038
371 SCRA 196 , 422 Phil. 519 , G.R. No. 141386
Primary Holding
The Supreme Court held that salaries and personnel-related benefits of teachers appointed for extension classes may be charged to the SEF, but college scholarship expenses cannot.
Background
The case arose from Notices of Suspension issued by the Commission on Audit (COA) to Cebu Province after it charged teacher salaries and scholarship expenses to its SEF. The province filed a petition for declaratory relief with the Regional Trial Court (RTC), which ruled in favor of Cebu Province. COA elevated the case to the Supreme Court.
Statutory Construction

Estrada vs. Sandiganbayan

19th November 2001

ak529893
369 SCRA 394 , 421 Phil. 290 , G.R. No. 148560
Primary Holding
Republic Act No. 7080, the Plunder Law, as amended by RA 7659, is constitutional and does not suffer from the vice of vagueness, nor does it violate the accused's rights to due process and to be informed of the nature and cause of the accusation. The law provides ascertainable standards and well-defined parameters for the crime of plunder.
Background
Petitioner Joseph Ejercito Estrada, the highest-ranking official to be prosecuted under RA 7080 (Plunder Law), faced charges before the Sandiganbayan for allegedly amassing ill-gotten wealth during his presidency. This case arose from his efforts to quash the Information against him by challenging the constitutionality of the Plunder Law itself, which defines and penalizes the crime of plunder.
Constitutional Law II Philosophy of Law Statutory Construction
Freedom of Expression

Benedicto vs. Court of Appeals

4th September 2001

ak713363
364 SCRA 334 , 416 Phil. 722 , G.R. No. 125359
Primary Holding
The Supreme Court ruled that the repeal of Circular No. 960 did not extinguish petitioners' criminal liability as saving clauses preserved pending cases. It also held that jurisdiction was proper in the Regional Trial Court (RTC), and claims of prescription, exemption, and immunity were unmeritorious.
Background
The case arose from multiple criminal charges filed against Benedicto and Rivera for failing to report foreign exchange earnings as required by Central Bank Circular No. 960. The petitioners argued that their liability was extinguished due to the circular's repeal and other defenses such as prescription and immunity under a compromise agreement with the government.
Statutory Construction

DM. Consunji, Inc. vs. Court of Appeals

20th April 2001

ak928097
357 SCRA 249 , G.R. No. 137873
Primary Holding
An employee's dependent who has claimed and received benefits from the State Insurance Fund under the Labor Code is not barred from subsequently suing the employer for damages under the Civil Code if the initial choice of remedy was made without knowledge of the employer's negligence or of the existence of the alternative remedy, as such ignorance negates a knowing and intelligent waiver.
Background
The case arose from a fatal workplace accident on November 2, 1990, where Jose Juego, a construction worker for petitioner D.M. Consunji, Inc. (DMCI), died after falling 14 floors when the platform he was on collapsed. The incident prompted his widow, Maria Juego, to seek compensation. This led to a legal conflict over whether her initial claim for statutory death benefits under the Labor Code prevented her from later seeking higher damages from the employer through a civil lawsuit based on negligence.
Persons and Family Law

Estrada vs. Desierto

2nd March 2001

ak430917
353 SCRA 452 , 406 Phil. 1 , G.R. Nos. 146710-15 , G.R. No. 146738
Primary Holding
The Supreme Court held that Joseph Ejercito Estrada had effectively resigned as President of the Philippines on January 20, 2001, and that Gloria Macapagal-Arroyo had validly assumed the presidency.
Background
Joseph Estrada’s presidency began in 1998 with broad public support but was marred by corruption allegations, including his involvement in illegal gambling operations (jueteng). A series of political and public upheavals culminated in his impeachment trial, which was aborted after senators voted to suppress key evidence. Massive public protests followed, leading to the withdrawal of military and police support for Estrada and the ascension of Vice President Gloria Macapagal-Arroyo.
Constitutional Law I

De Rama vs. Court of Appeals

28th February 2001

ak337670
405 Phil. 531 , G.R. No. 131136
Primary Holding
The constitutional prohibition against "midnight appointments" found in Article VII, Section 15 of the 1987 Constitution applies only to a President or Acting President and does not extend to appointments made by local elective officials. Furthermore, once an appointment is issued, accepted, and the appointee assumes office, they acquire a legal right to the position, protected by due process, and such appointment cannot be unilaterally revoked by the appointing authority or their successor without just cause and adherence to procedural requirements, with the Civil Service Commission having the authority to review and recall appointments only on specific grounds.
Background
Upon assuming office as Mayor of Pagbilao, Quezon, petitioner Conrado L. de Rama sought to recall the appointments of fourteen municipal employees. These appointments were made by the outgoing mayor, Ma. Evelyn S. Abeja, in the period leading up to the end of her term and after the election of de Rama. The core of the dispute revolved around the petitioner's belief that these were "midnight appointments" and were therefore invalid, leading him to request their recall from the Civil Service Commission.
Constitutional Law I

Mirasol vs. Court of Appeals

1st February 2001

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

Cruz vs. Secretaryof Environment and Natural Resources

6th December 2000

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

Del Mar vs. Philippine Amusement and Gaming Corporation

29th November 2000

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

Marcos vs. Marcos

19th October 2000

ak266337
343 SCRA 755 , G.R. No. 136490
Primary Holding
Psychological incapacity as a ground for nullity of marriage under Article 36 of the Family Code may be established by the totality of evidence presented, and a personal medical or psychological examination of the respondent is not a mandatory requirement or *conditio sine qua non* for such a declaration.
Background
Brenda and Wilson Marcos were married in 1982 and had five children. Both were members of the military assigned to Malacañang Palace. After the 1986 EDSA Revolution, both left the military service. Wilson struggled with unemployment and failed business ventures, leading to frequent quarrels, his failure to provide financial support, and instances of physical abuse against Brenda and their children. The couple eventually separated in 1992, and a series of violent incidents prompted Brenda to file a petition to declare their marriage null and void based on Wilson's alleged psychological incapacity.
Persons and Family Law
Article 36, Family Code

Bugatti vs. Court of Appeals

17th October 2000

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

Veterans Federation Party vs. Commission on Elections

6th October 2000

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

People vs. Velasco

13th September 2000

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

Integrated Bar of the Philippines vs. Zamora

15th August 2000

ak990550
338 SCRA 81 , G.R. No. 141284 , 392 Phil. 618
Primary Holding
The President's exercise of the power to call out the armed forces to prevent or suppress lawless violence is a discretionary power vested by the Constitution, and while subject to judicial review for grave abuse of discretion, the Court will not substitute its judgment for the President's determination of the necessity for such action unless a clear showing of arbitrariness or lack of factual basis is established by the petitioner.
Background
In response to an alarming increase in violent crimes such as robberies, kidnappings, and carnappings in Metro Manila, the President verbally ordered the PNP and the Philippine Marines to conduct joint visibility patrols for crime prevention and suppression. This directive was subsequently formalized through a Memorandum and implemented via Letter of Instruction 02/2000, establishing "Task Force Tulungan."
Constitutional Law I Constitutional Law II

International School Alliance of Educators vs. Quisumbing

1st June 2000

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

Heirs of Alberto Suguitan vs. City of Mandaluyong

14th March 2000

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

University of the East vs. Jader

17th February 2000

ak405597
325 SCRA 804 , G.R. No. 132344
Primary Holding
An educational institution has a contractual obligation to timely inform its students of their academic status and can be held liable for damages if its negligence misleads a student into believing they have completed all graduation requirements, thereby causing injury; this liability is anchored on Articles 19 and 20 of the Civil Code concerning the principle of abuse of rights and liability for negligent acts.
Background
The case arose from the relationship between an educational institution and its student concerning the fulfillment of academic requirements for a law degree. The dispute centered on the university's responsibility to communicate a student's final grade and academic standing, especially when the student's eligibility for graduation and the bar examinations was at stake.
Persons and Family Law

Liang vs. People

28th January 2000

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

Miranda vs. Abaya

28th July 1999

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

People vs. Quiñanola

5th May 1999

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

Commissioner of Internal Revenue vs. Court of Appeals

23rd February 1999

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

Echegaray vs. Secretary of Justice

19th January 1999

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

People vs. Santiano

3rd December 1998

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

Defensor-Santiago vs. Guingona, Jr.

18th November 1998

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

Fabian vs. Desierto

16th September 1998

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295 SCRA 470 , G.R. No. 129742
Primary Holding
Section 27 of Republic Act No. 6770, which authorizes a direct appeal to the Supreme Court from decisions of the Office of the Ombudsman in administrative disciplinary cases, is unconstitutional because it increases the appellate jurisdiction of the Supreme Court without its advice and consent, in violation of Section 30, Article VI of the 1987 Constitution. The correct procedural remedy for such appeals is a petition for review to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure.
Background
The case arose from an administrative complaint filed by petitioner Teresita G. Fabian, a private contractor, against private respondent Nestor V. Agustin, a District Engineer of the Department of Public Works and Highways (DPWH). Fabian alleged that Agustin, taking advantage of his official position, engaged her in an amorous relationship, awarded public works contracts to her company, and later harassed and threatened her when she tried to end the affair. This led to the filing of charges for grave misconduct, oppression, and disgraceful conduct against Agustin before the Office of the Ombudsman.
Civil Procedure II

St. Martin Funeral Home vs. NLRC

16th September 1998

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295 SCRA 494 , G.R. No. 130866
Primary Holding
Petitions for certiorari under Rule 65 seeking judicial review of NLRC decisions must be initially filed with the Court of Appeals, not directly with the Supreme Court, in observance of the doctrine on hierarchy of courts, as all references to "appeals" from NLRC in amended Section 9 of B.P. Blg. 129 are deemed to mean such special civil actions.
Background
The case emerges amid increasing labor disputes reaching the Supreme Court and legislative amendments to the Labor Code (P.D. No. 442) and the Judiciary Reorganization Act (B.P. Blg. 129), particularly R.A. No. 7902, which expanded the Court of Appeals' jurisdiction over quasi-judicial agencies but created ambiguity regarding review of NLRC decisions, prompting the Court to reassess the procedural mode of judicial review to alleviate its workload and ensure efficient adjudication.
Civil Procedure II
Rule 65

Municipality of Parañaque vs. V.M. Realty Corporation

20th July 1998

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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

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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

Palmares vs. Court of Appeals

31st March 1998

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288 SCRA 422 , G.R. No. 126490
Primary Holding
A person who signs a promissory note as a co-maker and explicitly binds herself to be "jointly and severally" or "solidarily" liable with the principal debtor is considered a surety, not a guarantor; as a surety, she is an insurer of the debt itself, directly and primarily liable, and may be sued by the creditor alone for the entire obligation upon the principal debtor's default.
Background
Private respondent M.B. Lending Corporation extended a loan of P30,000.00 to the spouses Osmeña and Merlyn Azarraga. Petitioner Estrella Palmares signed the corresponding promissory note as a co-maker. The terms of the note stipulated that Palmares was "jointly and severally or solidarily liable" with the principal debtors. After partial payments were made, the Azarraga spouses defaulted on the remaining balance, prompting the lending corporation to seek collection.
Persons and Family Law

Heirs of Emiliano Navarro vs. Intermediate Appellate Court

13th October 1997

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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

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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

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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

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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

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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

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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

Republic vs. Court of Appeals (Molina Case)

13th February 1997

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268 SCRA 198 , G.R. No. 108763
Primary Holding
Psychological incapacity under Article 36 of the Family Code must be a medically or clinically identified, grave, and permanent or incurable psychological illness existing at the time of the marriage that renders a spouse truly incapable of knowing and assuming the essential marital obligations; mere refusal, neglect, difficulty, or irreconcilable differences are not sufficient grounds.
Background
The introduction of "psychological incapacity" under Article 36 of the Family Code created a novel ground for declaring a marriage void, leading to a surge in petitions and inconsistent interpretations by lower courts. The Solicitor General expressed concern that the provision was being applied so liberally that it was effectively becoming a "divorce procedure," which is contrary to Philippine law and culture. This case presented the Supreme Court with the opportunity to clarify the provision's meaning and establish uniform standards for its application by the bench and bar.
Persons and Family Law
Article 36, Family Code