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Apiag vs. Cantero

12th February 1997

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

Manila Prince Hotel vs. GSIS

3rd February 1997

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

Chi Ming Tsoi vs. Court of Appeals

16th January 1997

ak887142
266 SCRA 324 , G.R. No. 119190
Primary Holding
The persistent and unjustified refusal of a spouse to engage in sexual intercourse, an essential marital obligation, for a prolonged period is equivalent to psychological incapacity under Article 36 of the Family Code, as it demonstrates an utter insensitivity or inability to give meaning and significance to the marriage.
Background
Chi Ming Tsoi and Gina Lao-Tsoi were married on May 22, 1988. Throughout their cohabitation, which lasted until March 15, 1989, they never engaged in sexual intercourse. The wife, Gina, alleged that her husband consistently refused to consummate the marriage, leading her to believe he was either impotent or a closet homosexual who married her merely to maintain his residency status in the Philippines. This complete lack of sexual intimacy and the husband's emotional distance prompted the wife to file a complaint for the annulment of their marriage.
Persons and Family Law
Article 36, Family Code

Republic vs. National Labor Relations Commission

17th October 1996

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

Filoteo, Jr. vs. Sandiganbayan

16th October 1996

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

Regala vs. Sandiganbayan

20th September 1996

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

Mustang Lumber, Inc. vs. Court of Appeals

18th June 1996

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

Fariñas vs. Barba

19th April 1996

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

Eduarte vs. Court of Appeals

9th February 1996

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

Romualdez-Marcos vs. Commission on Elections

18th September 1995

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

Philippine Press Institute, Inc. vs. Commission on Elections

22nd May 1995

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

Apa vs. Fernandez

20th March 1995

ak915647
G.R. No. 112381 , 242 SCRA 509
Primary Holding
A pending civil action that directly questions the ownership of a property constitutes a prejudicial question to a criminal prosecution for squatting on the same property, as the resolution of the ownership issue is determinative of the guilt or innocence of the accused.
Background
Petitioners were criminally charged under the Anti-Squatting Law (P.D. 772) for allegedly occupying a portion of Lot No. 3635-B and constructing their houses thereon without the consent of the registered owner, private respondent Rosita Tigol. However, three years prior to the filing of the criminal case, the petitioners had already initiated a civil action against the private respondents. This civil case sought to annul Rosita Tigol's title (TCT No. 13250) over the same lot and to have the property partitioned among them as co-heirs, asserting that they were co-owners of the land in question.
Persons and Family Law

Mariano, Jr. vs. Commission on Elections

7th March 1995

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

Santos vs. Court of Appeals

4th January 1995

ak322702
240 SCRA 20 , 310 Phil. 21 , G.R. No. 112019
Primary Holding
Psychological incapacity under Article 36 of the Family Code must be characterized by gravity, juridical antecedence, and incurability; it refers to a mental, not physical, incapacity that causes a party to be truly incognitive of the basic marital covenants, and it must be a malady so deep-seated that it renders the person incapable of fulfilling the essential obligations of marriage, which must be proven to have existed at the time of the celebration of the marriage.
Background
The case arose from the application of the then-novel provision of Article 36 of the Family Code, which took effect in 1988. This provision, which introduced "psychological incapacity" as a ground to void a marriage, was adopted from Canon Law but was not defined in the statute itself. This lack of a clear definition led to varying interpretations and necessitated a definitive ruling from the Supreme Court to establish jurisprudential guidelines for its application by the courts.
Persons and Family Law Philosophy of Law
Article 36, Family Code

JUSMAG Philippines vs. NLRC

15th December 1994

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

Tolentino vs. Secretary of Finance

25th August 1994

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

Philippine Constitution Association vs. Enriquez

19th August 1994

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

Kilosbayan, Incorporated vs. Guingona, Jr

5th May 1994

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

Fernandez vs. National Labor Relations Commission

28th February 1994

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

Republic vs. Court of Appeals

8th November 1993

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

Garcia vs. Commission on Audit

14th September 1993

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

Oposa vs. Factoran, Jr.

30th July 1993

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

Philip Morris, Inc. vs. Court of Appeals

16th July 1993

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

Ateneo de Manila University vs. Capulong

27th May 1993

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

Ebralinag vs. Division of Superintendent of Schools of Cebu

1st March 1993

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

Gashem Shookat Baksh vs. Court of Appeals

19th February 1993

ak910606
219 SCRA 115 , G.R. No. 97336
Primary Holding
A breach of promise to marry is not actionable per se, but it can be the basis for recovering damages under Article 21 of the Civil Code if the promise was made in a fraudulent and deceptive manner to entice a woman into sexual congress (moral seduction), thereby causing willful injury to her honor and reputation in a manner contrary to morals, good customs, or public policy.
Background
The case arose from a romantic relationship between Gashem Shookat Baksh, an Iranian medical student residing in Dagupan City, and Marilou T. Gonzales, a 22-year-old Filipina working at a luncheonette. Baksh courted Gonzales and promised to marry her, which led her to live with him with her parents' consent. The dispute began when Baksh later repudiated his promise, prompting Gonzales to file a suit for damages based on the alleged fraudulent promise and the resulting injury to her honor.
Persons and Family Law

Yu vs. Court of Appeals

21st January 1993

ak986897
G.R. No. 86683 , 217 SCRA 328
Primary Holding
A third party or a stranger to an exclusive distributorship contract can be enjoined from interfering with that contract; the right to perform such an agreement and reap the profits therefrom is a proprietary right, and its violation through deceptive means that results in continuous and repeated injury to a party's business and goodwill constitutes irreparable harm warranting the issuance of a writ of preliminary injunction.
Background
Petitioner Philip S. Yu held an exclusive sales agency agreement with the House of Mayfair in England to be the sole distributor of its wallcovering products in the Philippines since 1987. Private respondent Unisia Merchandising Co., Inc., which was previously a dealer for the petitioner, began importing and selling the same Mayfair products in the Philippine market. Unisia sourced the products not directly from House of Mayfair, but through FNF Trading, a firm in West Germany, which allegedly misled House of Mayfair into believing the products were intended for Nigeria. This created direct competition and led the petitioner to seek legal action to protect his exclusive rights.
Persons and Family Law

Albenson Enterprises Corp. vs. Court of Appeals

11th January 1993

ak134873
217 SCRA 16 , G.R. No. 88694
Primary Holding
A party who files a criminal complaint against another based on probable cause and in good faith cannot be held liable for damages under the principle of abuse of rights or for malicious prosecution, even if it is later discovered that the complaint was filed against the wrong person due to an honest mistake of identity. The law does not penalize the right to litigate, and an adverse result of an action does not, by itself, make the act wrongful or subject the actor to payment of damages.
Background
Albenson Enterprises Corporation delivered mild steel plates to Guaranteed Industries, Inc. but was paid with a check that was subsequently dishonored for "Account Closed." The check was drawn against the account of E.L. Woodworks. In an attempt to collect the payment, Albenson conducted inquiries which led them to believe that Eugenio S. Baltao, the president of Guaranteed Industries, was the same "Eugenio Baltao" who owned E.L. Woodworks and issued the check. This belief was based on records from the SEC, the Ministry of Trade and Industry, and the drawee bank. This case of mistaken identity led to the filing of a criminal complaint and the subsequent civil suit for damages.
Persons and Family Law

Labo, Jr. vs. Commission on Elections

3rd July 1992

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

Amelita Constantino and Michael Constantino vs. Ivan Mendez and the Honorable Court of Appeals

14th May 1992

ak349766
G.R. No. 57227
Primary Holding
Paternity and filiation must be established by clear and convincing evidence, and the burden of proof rests on the claimant. Furthermore, moral damages for breach of promise to marry are not recoverable when sexual intercourse is a product of voluntariness and mutual desire, rather than deceit or fraud.
Background
In August 1974, Amelita Constantino, a 28-year-old waitress in Manila, met Ivan Mendez, a prosperous businessman from Davao City. Mendez allegedly professed his love and, through a promise of marriage, convinced Constantino to have sexual intercourse with him in his hotel room. Immediately after, he confessed that he was already married. Despite this revelation, they continued their sexual relationship in the succeeding months. Constantino became pregnant and later gave birth to a son, Michael Constantino. When her pleas for support were ignored, she filed a suit for acknowledgment, support, and damages against Mendez.
Persons and Family Law

Caltex Philippines, Inc. vs. Commission on Audit

8th May 1992

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

Mapulo Mining Corporation vs. Lopez

7th February 1992

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

Bengzon Jr. vs. Senate Blue Ribbon Committee

20th November 1991

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

Ganzon vs. Court of Appeals

5th August 1991

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

Comendador vs. De Villa

2nd August 1991

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

Co vs. Electoral Tribunal of the House of Representatives

30th July 1991

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

People vs. Malmstedt

19th June 1991

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

Solid Manila Corporation vs. Bio Hong Trading Co

8th April 1991

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

Ronquillo vs. Court of Appeals

20th March 1991

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

People vs. Ritter

5th March 1991

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

Jagualing vs. Court of Appeals

4th March 1991

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

Civil Liberties Union vs. Executive Secretary

22nd February 1991

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

Brocka vs. Enrile

10th December 1990

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

Luz Farms vs. Secretary of the Department of Agrarian Reform

4th December 1990

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

Gonzales vs. Macaraig, Jr.

19th November 1990

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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

Valenzuela vs. Court of Appeals

19th October 1990

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G.R. No. 83122 , 191 SCRA 1
Primary Holding
A principal's power to revoke an agency agreement is not absolute and may not be exercised in bad faith or with an abuse of right; a termination tainted with bad faith makes the principal liable for damages. Furthermore, an agency is considered "coupled with an interest" and is not freely revocable by the principal when the agent has been induced to assume a responsibility or incur a liability, such that the agent would be exposed to personal loss if the authority were withdrawn.
Background
Arturo P. Valenzuela had been a General Agent for the Philippine American General Insurance Company, Inc. (Philamgen) since 1965. Over thirteen years, he built a successful insurance agency. The dispute arose from a particularly large marine insurance account he secured from Delta Motors, Inc., which entitled him to a 32.5% commission. In 1977, Philamgen expressed its desire to share in this specific commission on a fifty-fifty basis, which Valenzuela consistently refused, asserting his rights under their existing General Agency Agreement.
Persons and Family Law

Republic vs. Intermediate Appellate Court

4th June 1990

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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

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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