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Quizon-Arciga vs. Baluyut

14th June 2023

ak168457
G.R. No. 256612
Primary Holding
A party is barred by estoppel by laches from questioning a court's jurisdiction over the subject matter if they actively participated in all stages of the case before the lower court and only raised the jurisdictional challenge belatedly after an unfavorable judgment, especially after a significant lapse of time.
Background
The case originated from a loan obtained by Relia Arciga from Jaycee P. Baluyut, secured by a Real Estate Mortgage (REM) over a property co-owned by Relia and her mother, Rita Quizon-Arciga. The authority to mortgage was derived from an Extra-Judicial Settlement of Estate/Partition with Special Power of Attorney (EJS-SPA). Upon default, Baluyut initiated judicial foreclosure proceedings.
Civil Procedure I

Odilao vs. Union Bank of the Philippines

26th April 2023

ak759840
G.R. No. 254787
Primary Holding
A restrictive venue stipulation in a contract specifying venue choices (e.g., Place A or Place B) "at the absolute option" of one party (the creditor/mortgagee) does not prevent the other party (debtor/mortgagor) from initiating a lawsuit in *either* of the specified venues; the "absolute option" primarily governs the venue choice when the party granted the option is the one filing the suit and does not serve as a condition precedent restricting the other party's right to file in a contractually permitted location.
Background
Petitioner Lucille Odilao and her husband entered into loan and real estate mortgage agreements with respondent Union Bank of the Philippines. The petitioner later sought judicial reformation of these agreements, contending they were contracts of adhesion and did not accurately reflect the parties' true intentions concerning various terms, including notices, interest, penalties, and venue procedures.
Civil Procedure I
Motion

Go vs. Court of Appeals

29th March 2023

ak010365
G.R. No. 244681
Primary Holding
A prior unregistered sale where ownership has already been vested in the buyer prevails over a subsequent registered levy on execution, as a judgment debtor can only transfer property in which they have an interest at the time of the levy; service of summons by publication is valid when, after diligent efforts to serve personally or by substitution prove futile, particularly due to the defendant's own ambiguous or misleading information regarding their address.
Background
Petitioner Vicente C. Go obtained a favorable judgment in a sum of money case against Setcom Inc. and others (RTC-Manila). To satisfy the judgment, a property registered under the name of Spouses Francisco and Ma. Teresa Bernardo (judgment debtors) was levied upon and sold at an execution sale to Go as the highest bidder. Go, however, failed to consolidate his title. Subsequently, Spouses Rafael and Rosario Colet filed a case to quiet their title over the same property (RTC-Quezon City), claiming they had purchased it from Spouses Bernardo several years prior to Go's levy, although this sale was unregistered. The RTC-QC ruled in favor of Spouses Colet.
Civil Procedure I

Petron Corporation vs. Commissioner of Internal Revenue

20th March 2023

ak403390
G.R. No. 255961
Primary Holding
Alkylate is not subject to excise tax under Section 148(e) of the 1997 NIRC, as amended, because it is not expressly listed therein, nor does it fall under the category of "other similar products of distillation" as it is produced through alkylation (a chemical process) rather than distillation (a physical separation process) and possesses distinct properties and uses compared to naphtha and regular gasoline.
Background
Petron Corporation, a manufacturer of petroleum products, imported alkylate for use as a blending component in gasoline production. Following a Bureau of Internal Revenue (BIR) letter dated June 29, 2012, implemented by Bureau of Customs (BOC) Customs Memorandum Circular (CMC) No. 164-2012 dated July 18, 2012, alkylate was deemed "similar to that of naphtha" and subjected to excise tax under Section 148(e) of the NIRC. Petron paid the taxes but contended they were erroneously imposed.
Civil Procedure I

Monasterial vs. Fontamillas and Kingsville Construction and Development Corporation

13th February 2023

ak472331
G.R. No. 261457
Primary Holding
A Petition for Review on Certiorari under Rule 45 of the Rules of Court is generally confined to questions of law, and factual findings of the trial court that are affirmed by the Court of Appeals are binding upon the Supreme Court unless specific exceptions apply; in actions to recover property, the plaintiff bears the burden of clearly identifying the property claimed and must rely on the strength of their own title, with unapproved survey plans being insufficient to establish property identity against a registered Torrens title, and an action for forcible entry is not the appropriate remedy for resolving what is essentially a boundary dispute.
Background
The case originated from a possessory dispute where petitioner Rosario N. Monasterial filed an action for forcible entry against respondents Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation. Monasterial alleged that respondents unlawfully deprived her of physical possession of a portion of land she claimed, prompting her to seek judicial remedy to recover said possession. The core of the dispute involved Monasterial's claim of prior possession over an unregistered property versus Kingsville's assertion of ownership based on a Torrens title.
Civil Procedure I

Spouses Libiran vs. Elisan Credit Corporation

13th February 2023

ak651801
G.R. No. 255239
Primary Holding
In a judicial foreclosure suit, which is a real action, the assessed value of the subject property must be alleged in the complaint to determine which court has original jurisdiction; failure to do so is fatal to the plaintiff's cause and warrants dismissal.
Background
Spouses Tomas Libiran and Potenciana Feliciano (Spouses Libiran) obtained several loans from Elisan Credit Corporation (Elisan), secured by a real estate mortgage over a parcel of land. The mortgage contract stipulated that the property would secure not only the initial loan but also all other obligations subsequently incurred. Spouses Libiran allegedly failed to pay their total obligation, including interests and penalties, prompting Elisan to file a complaint for judicial foreclosure.
Civil Procedure I

Roa v. Spouses Sy

14th September 2021

ak067727
910 Phil. 219 , G.R. No. 221586
Primary Holding
A court cannot dismiss a complaint _motu proprio_ on a ground not pleaded by the movant, specifically dismissing for "lack of cause of action" when the motion to dismiss alleged "failure to state a cause of action," as these are distinct grounds. Furthermore, when a defendant files a motion for bill of particulars or avails of modes of discovery like written interrogatories, they are deemed to have recognized the existence and sufficiency of the allegations of the adverse party's cause of action in the complaint, thereby barring them from subsequently challenging the complaint for failure to state a cause of action.
Background
Petitioner Zenaida D. Roa and her sister Amelia Roa were co-owners of a property in Makati City. Zenaida discovered that their title was cancelled and a new one was issued to their niece, Marie Antoinette R. Francisco, based on a purportedly forged deed of sale. Zenaida was in Washington D.C. at the time of the alleged execution, and Amelia suffered from Alzheimer's disease. Francisco subsequently sold the property to Spouses Robinson K. and Mary Valerie S. Sy. Zenaida filed a complaint to annul these transactions and recover the property, alleging that Spouses Sy were buyers in bad faith due to suspicious circumstances surrounding the sale.
Civil Procedure I

Gemina v. Heirs of Gerardo V. Espejo, Jr

13th September 2021

ak810334
910 Phil. 48 , G.R. No. 232682
Primary Holding
The mere absence of a defendant's counsel during pre-trial, when the defendant himself is present, does not automatically warrant allowing the plaintiff to present evidence ex parte under the then-applicable Rules of Court (prior to A.M. No. 19-10-20-SC); procedural rules may be relaxed to prevent manifest injustice and uphold the right to due process. Furthermore, in an action to recover possession (accion reivindicatoria), the plaintiff bears the burden of clearly identifying the property sought to be recovered and relying on the strength of their own title, not the weakness of the defendant's claim.
Background
The dispute centers on a parcel of land located at 156 Session Road, Woodcrest Homes, Talanav, Area B, Batasan Hills, Quezon City. Petitioner Gemina claims ownership and possession since 1978 based on a purported purchase, presenting various documents like deeds, tax declarations, and permits. Respondents, the Heirs of Espejo, assert co-ownership based on a Transfer Certificate of Title (TCT No. RIV786U [93809]) in the names of Gerardo V. Espejo, Jr. and Nenafe V. Espejo, and demanded Gemina vacate the property.
Civil Procedure I
Pre-trial

DPWH vs. Manalo

16th November 2020

ak226477
G.R. No. 217656
Primary Holding
The complaint filed by informal settlers whose residential structures are affected by a government infrastructure project sufficiently states a cause of action if it alleges their ownership of the structures, the government agency's obligation to respect their rights to due process (including procedures under R.A. No. 7279 for eviction and demolition), and the agency's violation of these rights. Underprivileged and homeless citizens cannot be summarily evicted or their dwellings demolished without adherence to the legal requirements for notice, consultation, and relocation or financial assistance as mandated by the Constitution and relevant statutes.
Background
Respondents are owners of residential structures located on land owned by the Metropolitan Waterworks and Sewerage System (MWSS) along Luzon Avenue, Quezon City. These structures were directly affected by the Department of Public Works and Highways' (DPWH) C-5 extension project, designed to link the South Luzon Expressway and the North Luzon Expressway. The DPWH sought to clear the area for the project, leading to a dispute over compensation and the process of eviction and demolition.
Civil Procedure I

Trillanes IV vs. Castillo-Marigomen

14th March 2018

ak317975
859 SCRA 271 , 828 Phil. 336 , G.R. No. 223451
Primary Holding
Parliamentary immunity under the "speech or debate" clause (Article VI, Section 11 of the 1987 Constitution) protects only speeches, debates, and utterances made by members of Congress in the performance of their official legislative functions within Congress or its committees, and does not extend to statements made outside of congressional sessions or hearings, such as interviews with the media.
Background
Petitioner, Senator Trillanes, initiated a Senate investigation (P.S. Resolution No. 826) into alleged overpricing of Makati City infrastructure projects involving former VP Binay. During a hearing, former Makati Vice Mayor Mercado testified about the "Hacienda Binay," a large estate in Batangas allegedly owned by VP Binay. Private respondent Antonio Tiu subsequently claimed ownership of a portion of the estate through his company, Sunchamp Real Estate Corporation. Following Tiu's testimony and presentation of an agreement before the Senate Blue Ribbon Sub-Committee, Senator Trillanes made statements to the media describing Tiu as a "front," "nominee," or "dummy" for VP Binay regarding the estate.
Civil Procedure I Constitutional Law I
Motion

Estipona, Jr. vs. Lobrigo

15th August 2017

ak282688
837 SCRA 160 , 816 Phil. 789 , G.R. No. 226679
Primary Holding
Section 23 of Republic Act No. 9165, which prohibits plea bargaining in all cases involving violations of the said Act, is unconstitutional because it contravenes the exclusive power of the Supreme Court to promulgate rules concerning pleading, practice, and procedure in all courts, as mandated by Section 5(5), Article VIII of the 1987 Constitution.
Background
* The case arose within the context of the Philippine government's intensified campaign against illegal drugs, governed by Republic Act No. 9165. * RA 9165 contained a specific provision, Section 23, that explicitly disallowed plea bargaining for any offense under the Act, diverging from the general availability of plea bargaining in other criminal cases under the Rules of Court.
Civil Procedure I Criminal Law I Criminal Procedure
Rule-making power of the SC

National Housing Authority vs. Laurito

31st July 2017

ak182462
833 SCRA 380 , 814 Phil. 1019 , G.R. No. 191657
Primary Holding
Where two certificates of title are issued to different persons covering the same land, the certificate of title issued earlier in date must prevail, and the reconstitution of a title does not determine ownership nor grant priority based merely on the date of reconstitution, especially when the reconstitution itself is dubious and pertains to a title already cancelled prior to the reconstitution.
Background
The case arose from conflicting claims of ownership over Lot F-3 of subdivision plan Psd-12274 in Carmona, Cavite. The heirs of Spouses Laurito based their claim on TCT No. T-9943 registered in 1956 (later reconstituted as RT-8747 in 1962), derived from TCT No. T-8237. Petitioner NHA based its claim on TCT Nos. T-3717 and T-3741, derived through a series of transfers originating from an alleged administrative reconstitution of the same parent title, TCT No. T-8237, in 1960 (as RT 3909) and subsequent subdivisions/transfers starting in 1960.
Civil Procedure I
Intervention

Edron Construction Corporation vs. Provincial Government of Surigao Del Sur

5th June 2017

ak304488
826 SCRA 47 , 810 Phil. 347 , G.R. No. 220211
Primary Holding
Defenses not pleaded in the Answer or in a timely Motion to Dismiss, except for lack of jurisdiction over the subject matter, litis pendentia, res judicata, and prescription, are deemed waived pursuant to Section 1, Rule 9 of the Rules of Court, and a party failing to raise such defenses is estopped from relying on them later in the proceedings.
Background
The dispute originated from three separate construction agreements entered into by petitioners Edron Construction Corporation and Edmer Y. Lim with the respondent, the Provincial Government of Surigao Del Sur, for the construction of the Learning Resource Center of Tandag, Tandag Bus/Jeepney Terminal, and Tandag Public Market.
Civil Procedure I
Motion

Castro vs. Mendoza

26th April 2017

ak470027
809 Phil. 789 , G.R. No. 212778
Primary Holding
An agricultural lessee's right of redemption under Section 12 of RA 3844, as amended, must be validly exercised through timely tender and consignation of the full and reasonable redemption price; failure to do so, coupled with the property's actual conversion and devotion to public use, prevents the lessee from acquiring ownership and possession, although they remain entitled to disturbance compensation.
Background
The case originates from the sale of a portion of agricultural land, tenanted by the petitioners, by one of the co-owning heirs to the respondent Municipality of Bustos for the expansion of its public market. The sale occurred without written notice to the petitioners, triggering their right of redemption under agrarian law. The property had already been classified as commercial, and a public market was constructed and operating on it before the petitioners formally sought redemption.
Civil Procedure I
Intervention

Majestic Plus Holdings International, Inc. vs. Bullion Investment and Development Corporation

5th December 2016

ak807038
812 SCRA 91 , 801 Phil. 883 , G.R. No. 201017 , G.R. No. 215289
Primary Holding
Summary judgment is improper when there are genuine issues of fact that require the presentation of evidence during a full-blown trial, such as disputes over compliance with contractual obligations, the validity of an extrajudicial rescission, and the substantiation of claimed expenses; furthermore, the designation of a Regional Trial Court branch as a Special Commercial Court (SCC) does not divest it of its general jurisdiction over ordinary civil cases.
Background
The City of Manila leased a property to Bullion for development, requiring the construction of a City Hall extension and a commercial building (Meisic Mall). Bullion completed the extension but struggled with the mall construction, prompting it to seek investment from Majestic. This led to a Memorandum of Agreement (MOA) where Majestic agreed to acquire 80% equity in Bullion and infuse capital to complete the mall.
Civil Procedure I

Ursua vs. Republic

5th October 2016

ak913389
805 SCRA 1 , 796 Phil. 439 , G.R. Nos. 177857-58 , G.R. No. 178193
Primary Holding
The Court lacks jurisdiction to order San Miguel Corporation (SMC), a non-party to Civil Case No. 0033-F, to deliver the 25.45 million SMC treasury shares (originating from the 1990 Compromise Agreement) to the Republic, as doing so without impleading SMC violates its constitutional right to due process.
Background
The case originates from the sequestration of assets, including SMC shares held by Coconut Industry Investment Fund (CIIF) Holding Companies, alleged to have been acquired using coco levy funds during the Marcos regime. A 1986 sale of 33.1 million SMC shares by CIIF Holding Companies (administered by UCPB) to the SMC Group was partially rescinded through a 1990 Compromise Agreement between UCPB Group and SMC Group, which required PCGG approval. This agreement recognized SMC's ownership of shares corresponding to its initial P500 million payment (which became 25.45 million shares due to stock dividends/splits) and designated them as SMC treasury shares, while the rest reverted to CIIF Holding Companies. The Republic later sought to include these 25.45 million treasury shares in the assets declared as publicly owned and subject to reconveyance.
Civil Procedure I

Metropolitan Bank and Trust Company vs. Fadcor, Inc

25th January 2016

ak549966
781 SCRA 561 , 779 Phil. 32 , G.R. No. 197970
Primary Holding
In an *ex parte* presentation of evidence resulting from the defendant's failure to appear at pre-trial, documentary evidence formally offered by the plaintiff and subsequently admitted by the trial court is properly considered in rendering judgment, even if the transcript of stenographic notes does not meticulously reflect the identification and marking of each specific exhibit during the witness's testimony; the rules on pre-marking and identification in A.M. No. 03-1-09-SC apply primarily to regular pre-trial proceedings where both parties participate.
Background
Metrobank extended loans totaling P32,950,000.00 to Fadcor, Inc., secured by real estate mortgages over ten parcels of land and continuing surety agreements executed by individual respondents (Fadcor officers). Fadcor defaulted on its loan obligations.
Civil Procedure I
Pre-trial

Gonzales, et al. vs. GJH Land, Inc., et al.

10th November 2015

ak690848
774 SCRA 242 , 772 Phil. 483 , G.R. No. 202664
Primary Holding
The jurisdiction over commercial cases, including intra-corporate disputes, is conferred by Republic Act No. 8799 upon Regional Trial Courts as courts of general jurisdiction, and the Supreme Court's designation of certain RTC branches as Special Commercial Courts is an administrative and procedural measure to promote expediency and efficiency in the exercise of that jurisdiction, not a conferment of jurisdiction itself; therefore, a commercial case erroneously raffled to a regular RTC branch within a station that has a designated Special Commercial Court should be transferred to the latter, not dismissed for lack of jurisdiction.
Background
The case arose from a dispute over shares in S.J. Land, Inc. (later GJH Land, Inc.). Petitioners claimed they had fully paid for their subscribed shares, but these shares were subsequently offered for sale to other stockholders by the corporation, prompting petitioners to seek an injunction. This underlying dispute was recognized as an intra-corporate controversy.
Civil Procedure I

De Leon vs. Chu

2nd September 2015

ak032805
768 SCRA 609 , 768 Phil. 217 , G.R. No. 186522
Primary Holding
A violation of the rule on non-forum shopping, specifically the submission of a false certification or non-compliance with undertakings, does not automatically warrant dismissal; dismissal requires willful and deliberate forum shopping, or must follow a motion and hearing, unless the ground for dismissal (like *litis pendentia*) is evident *motu proprio* from the pleadings or evidence, a ground which became moot here upon case consolidation.
Background
The dispute arose from conflicting claims over a 50-square meter parcel of land, originally part of a 600-square meter property owned by Domingo Delos Santos. Domingo allegedly sold the entire 600 sqm to Lolita Chu in 1990. Lolita entrusted the deed to Rowena De Leon before leaving for Japan. Subsequently, a different Deed of Sale emerged dated March 1993, purportedly showing Domingo sold 50 sqm to Rowena and the remaining 550 sqm to Lolita. Rowena registered the 50 sqm portion in her name, leading Lolita and Domingo to claim forgery and file for annulment, while Rowena sought the surrender of the title she claimed Lolita wrongfully withheld.
Civil Procedure I
Motion

Aquino vs. Quiazon

11th March 2015

ak636229
753 SCRA 98 , 755 PHIL. 793 , G.R. No. 201248
Primary Holding
When a motion to dismiss (or an affirmative defense treated as such) is based on the ground that the complaint states no cause of action, the court must determine the sufficiency of the cause of action based solely on the allegations in the complaint, hypothetically admitting their truth, and cannot consider external facts or evidence presented during a preliminary hearing, except in very limited circumstances not present in this case.
Background
The dispute arose from conflicting claims of ownership over a 557-square meter parcel of land in Magalang, Pampanga. Petitioners, heirs of Epifanio Makam and Severina Bautista, claimed acquisition through a Deed of Sale dated April 20, 1894, and continuous possession. Respondents, heirs of Fausta Baluyut, claimed ownership based on Transfer Certificate of Title (TCT) No. 213777-R, derived from an Original Certificate of Title (OCT) issued pursuant to a Land Registration Decree in 1919. The conflict escalated when respondents sent demand letters to petitioners to vacate the property in June 2005, leading petitioners to file a complaint for Annulment and Quieting of Title.
Civil Procedure I

Zuñiga-Santos vs. Santos-Gran

8th October 2014

ak127777
738 SCRA 33 , 745 Phil. 171 , G.R. No. 197380
Primary Holding
An amended complaint that fails to sufficiently allege ultimate facts establishing the plaintiff's right to the subject properties and the invalidity of their transfer, and which seeks reconveyance based on an implied trust more than ten years after the registration of the disputed titles in the defendant's name, is dismissible for failure to state a cause of action and for prescription.
Background
The case originated from a dispute over three parcels of land allegedly owned by petitioner Eliza Zuñiga-Santos. Petitioner claimed these properties were fraudulently transferred to respondent Maria Divina Gracia Santos-Gran, purportedly the petitioner's daughter through a forged birth certificate, by petitioner's second husband, Lamberto C. Santos, using void and voidable documents, specifically a Deed of Sale that could not initially be located.
Civil Procedure I

Pulgar vs. The Regional Trial Court of Mauban, Quezon, Br. 64, et al.

10th September 2014

ak670551
734 SCRA 527 , 742 Phil. 557 , G.R. No. 157583
Primary Holding
Jurisdiction over an intervention is contingent upon the court's jurisdiction over the main action; an intervention is ancillary and supplemental, not an independent proceeding, and thus ceases to exist when the main case is dismissed, particularly on jurisdictional grounds.
Background
The dispute originated from the Municipal Assessor of Mauban, Quezon's assessment of substantial realty taxes on the Mauban Plant, a power generation facility owned by QPL, based on a market value of approximately P29.6 billion. QPL contested this assessment, declaring a much lower value of about P15 billion, and tendered a significantly smaller amount as its first quarter installment for realty taxes, which was rejected by the Municipal Assessor.
Civil Procedure I
Intervention

SM Land, Inc. vs. Bases Conversion and Development Authority

13th August 2014

ak100107
733 SCRA 68 , 756 PHIL. 354 , G.R. No. 203655
Primary Holding
Administrative issuances duly promulgated pursuant to delegated rule-making power, such as the NEDA JV Guidelines issued under presidential directives (EO 109, EO 109-A, EO 423), have the force and effect of law and are binding on the government agencies covered, which cannot unilaterally deviate from the mandatory procedures therein, like the competitive challenge process following successful negotiation of an unsolicited proposal.
Background
The dispute originated from an unsolicited proposal submitted by SMLI to BCDA for the development of the Bonifacio South Property through a joint venture. After negotiations, BCDA accepted the proposal's terms and conditions and issued a Certification of Successful Negotiations (CSN), agreeing to subject SMLI's proposal to a competitive challenge (Swiss Challenge) as outlined in the NEDA JV Guidelines and the agreed Terms of Reference (TOR). Subsequently, BCDA unilaterally cancelled the competitive challenge process, intending to subject the property to public bidding instead, prompting SMLI to file a petition.
Civil Procedure I
Intervention

Chingkoe vs. Republic

13th July 2013

ak079924
702 SCRA 677 , 715 Phil. 651 , G.R. No. 183608
Primary Holding
An order dismissing a case for the plaintiff's failure to appear at pre-trial under Rule 18, Section 5 of the Rules of Court is a final order, considered an adjudication on the merits and with prejudice unless otherwise stated, and the proper remedy against such dismissal is an ordinary appeal under Rule 41, not a special civil action for certiorari under Rule 65.
Background
The case originated from two separate collection suits filed by the Republic of the Philippines, represented by the Bureau of Customs (BOC), seeking to recover allegedly unpaid customs duties and taxes from Chiat Sing Cardboard Inc. and Filstar Textile Industrial Corporation (Filstar), along with individual defendants including the petitioners Faustino and Gloria Chingkoe. The basis for the collection suits was the alleged use of fake and spurious tax credit certificates originally issued to Filstar and subsequently used by Chiat Sing to settle import duties, and the fraudulent acquisition of tax credit certificates by Filstar itself.
Civil Procedure I
Pre-trial

Eagleridge Development Corporation vs. Cameron Granville 3 Asset Management, Inc.

10th April 2013

ak544596
695 SCRA 714 , 708 Phil. 693 , G.R. No. 204700
Primary Holding
A party defending against a claim based on an assigned credit, especially a credit in litigation, has the right under the rules of discovery (Rule 27) to compel the production of documents like a Loan Sale and Purchase Agreement (LSPA) that are explicitly mentioned in the Deed of Assignment and necessary to determine the consideration paid, particularly when invoking the right of legal redemption under Article 1634 of the Civil Code.
Background
Export and Industry Bank (EIB) initiated a collection suit against Eagleridge Development Corporation (EDC) and its sureties, Marcelo N. Naval and Crispin I. Oben, for an outstanding loan obligation. During the pendency of this suit, EIB assigned EDC's loan obligation to Cameron Granville 3 Asset Management, Inc. (Cameron), a special purpose vehicle, through a Deed of Assignment which referenced an underlying Loan Sale and Purchase Agreement (LSPA). Cameron was subsequently substituted as the plaintiff in the collection case.
Civil Procedure I
Discovery

Alma Jose vs. Javellana

25th January 2012

ak630213
664 SCRA 11 , 680 Phil. 10 , G.R. No. 158239
Primary Holding
An order denying a motion for reconsideration of a final order (such as an order dismissing a case) is itself a final order and thus appealable; the aggrieved party is entitled to a fresh period of 15 days from receipt of the denial order within which to file the notice of appeal, pursuant to the "fresh period rule" established in _Neypes v. Court of Appeals_, which applies retroactively to pending cases.
Background
The dispute originated from a 1979 Deed of Conditional Sale where Margarita Marquez Alma Jose sold two parcels of land to Ramon Javellana. Payment was partially made upfront, with the balance due upon registration under the Torrens System, an obligation Margarita undertook. After Margarita and her son/attorney-in-fact Juvenal died, the obligation fell upon her daughter and sole heir, Priscilla Alma Jose, who allegedly failed to comply and instead started developing the properties, prompting Javellana to sue for specific performance.
Civil Procedure I

Barayuga vs. Adventist University of the Philippines

17th August 2011

ak907241
655 SCRA 640 , G.R. No. 168008
Primary Holding
An injunctive relief protects only a right *in esse*; where the plaintiff fails to demonstrate an existing right to be protected by injunction, the suit for injunction must be dismissed for lack of a cause of action. The petitioner's term of office as President of AUP was for two years as per AUP's amended By-Laws, not five years, and by the time of his removal, he was already serving in a hold-over capacity.
Background
The Adventist University of the Philippines (AUP) is a non-stock, non-profit domestic educational institution. Petitioner Petronilo J. Barayuga was appointed President of AUP by its Board of Trustees. Subsequent external and internal audits revealed alleged irregularities in his management style and financial transactions, leading the Board to consider his removal. The core of the dispute revolved around the validity of his removal and the length of his term as President.
Civil Procedure I

Megan Sugar Corporation vs. Regional Trial Court of Iloilo, Branch 68, Dumangas, Iloilo

1st June 2011

ak127788
650 SCRA 100 , 665 Phil. 245 , G.R. No. 170352
Primary Holding
A party that actively participates in court proceedings through counsel, allows its officer to accompany said counsel, receives court orders and pleadings without repudiating the counsel's authority, and seeks affirmative relief from the court, is estopped from later questioning the counsel's authority and the court's jurisdiction over it, especially after receiving unfavorable rulings.
Background
New Frontier Sugar Corporation (NFSC) defaulted on a loan secured by real estate and chattel mortgages from Equitable PCI Bank (EPCIB). Due to financial difficulties, NFSC entered a Memorandum of Agreement (MOA) allowing Central Iloilo Milling Corporation (CIMICO) to operate its sugar mill. Subsequently, EPCIB foreclosed on the mortgaged properties. CIMICO then entered into another MOA with Megan Sugar Corporation (MEGAN), transferring its operational rights and obligations concerning the sugar mill to MEGAN. This transfer occurred amidst ongoing litigation involving NFSC, CIMICO, and EPCIB.
Civil Procedure I

Mactan-Cebu International Airport Authority vs. Heirs of Estanislao Miñoza

2nd February 2011

ak335523
641 SCRA 520 , 656 Phil. 537 , G.R. No. 186045
Primary Holding
Intervention under Rule 19 requires a legal interest that is actual, substantial, material, direct, and immediate in the matter being litigated; it is not proper when it seeks to inject an independent controversy, would unduly delay or prejudice the adjudication of the original parties' rights, or change the nature of the action, especially when the intervenor's rights can be fully protected in a separate proceeding.
Background
The dispute originated from the sale of two lots (Lots 986 and 991-A) owned by the late Estanislao Miñoza to the National Airports Corporation (NAC), MCIAA's predecessor, in the late 1940s/early 1950s for the Lahug Airport expansion project, which allegedly included an assurance that the original owners' heirs could repurchase the lots if they were no longer needed for that purpose. The airport expansion did not proceed, leading the purported heirs (represented by Leila Hermosisima) to seek reconveyance based on the alleged buy-back option over forty years later.
Civil Procedure I
Intervention

Heirs of Domingo Valientes v. Hon. Reinerio (Abraham) B. Ramas, et al.

15th December 2010

ak555963
653 Phil. 111 , G.R. No. 157852
Primary Holding
An action for reconveyance based on an implied or constructive trust, arising from property acquired through fraud (such as a forged deed leading to the issuance of a Torrens title), prescribes in ten (10) years from the date of the issuance of the certificate of title, if the plaintiff is not in possession of the property.
Background
The dispute originated from a parcel of land initially owned by Domingo Valientes under an Original Certificate of Title (OCT). In 1939, Valientes mortgaged the land to the spouses Belen. Later, the Belens allegedly used a forged "VENTA DEFINITIVA" to obtain a Transfer Certificate of Title (TCT No. T-5,427) in their names in 1969. Valientes' heirs attempted but failed to retrieve the property in the 1950s and filed an adverse claim in 1970. Upon the Belens' death, their heirs sold the property to respondent Vilma Minor, who currently possesses it. This led to conflicting legal actions initiated by both Minor (to cancel the adverse claim) and the Valientes heirs (to cancel the TCT and recover the property).
Civil Procedure I
Motion

Reyes-Mesugas vs. Reyes

22nd March 2010

ak071678
616 SCRA 345 , 630 Phil. 334 , G.R. No. 174835
Primary Holding
A notice of lis pendens annotated in connection with an estate settlement proceeding should be cancelled when the proceeding has terminated by virtue of a judicially approved compromise agreement, and the basis for its continued annotation is an alleged extraneous agreement that falls outside the limited jurisdiction of the probate court.
Background
Petitioner Anita Reyes-Mesugas and respondent Alejandro A. Reyes are siblings and heirs of Lourdes Aquino Reyes, who died intestate leaving several properties, including a lot covered by TCT No. 24475. Respondent initiated proceedings for the settlement of Lourdes' estate, which eventually led to a compromise agreement partitioning the estate among the heirs.
Civil Procedure I

Ruby Shelter Builders and Realty Development Corporation vs. Formaran III

10th February 2009

ak620041
578 SCRA 283 , 598 Phil. 105 , G.R. No. 175914
Primary Holding
An action, although ostensibly for the annulment of deeds of sale, is considered a real action if its ultimate objective is the recovery of title to or possession of real property, and the docket fees must be computed based on the fair market value of the property as stated in Section 7(a) of Rule 141 of the Rules of Court, as amended.
Background
Petitioner Ruby Shelter Builders and Realty Development Corporation obtained a loan of P95,700,620.00 from respondents Romeo Y. Tan and Roberto L. Obiedo, secured by real estate mortgages over five parcels of land. Upon petitioner's inability to pay, a Memorandum of Agreement (MOA) was executed, granting an extension and providing for the execution of Deeds of Absolute Sale by way of *dacion en pago* for the mortgaged properties if the debt remained unpaid by December 31, 2005. The MOA also included redemption prices for the properties.
Civil Procedure I

Figueroa vs. People

14th July 2008

ak461685
558 SCRA 63 , 580 Phil. 58 , G.R. No. 147406
Primary Holding
A litigant is not estopped by laches from assailing the jurisdiction of a trial court over the subject matter for the first time on appeal if the challenge is made without unreasonable delay and the factual circumstances do not mirror the exceptional scenario of _Tijam v. Sibonghanoy_, where the jurisdictional challenge was raised only after almost 15 years. The general rule that a court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal, prevails, as jurisdiction is conferred by law and cannot be vested by consent or waiver of the parties.
Background
The case arose from a criminal information for reckless imprudence resulting in homicide filed against the petitioner, Venancio Figueroa y Cervantes. The core issue that reached the Supreme Court revolved around whether the petitioner was barred by estoppel by laches from questioning the jurisdiction of the Regional Trial Court (RTC) which tried and convicted him, given that he only raised the jurisdictional challenge for the first time during his appeal to the Court of Appeals.
Civil Procedure I

Agulto vs. Tecson

29th November 2005

ak349241
476 SCRA 395 , 512 Phil. 760 , G.R. No. 145276
Primary Holding
Service of notice of pre-trial on the counsel of record (or on the party if they have no counsel) is mandatory under Section 3, Rule 18 of the 1997 Rules of Civil Procedure; failure to serve such notice renders the pre-trial and all subsequent proceedings null and void for violating the party's right to due process, and constitutes grave abuse of discretion correctible by certiorari.
Background
Respondent William Z. Tecson filed an action for damages against petitioners Rolando Agulto, Maxima Agulto, Cecille Tenorio, and Maribel Mallari in the Regional Trial Court (RTC) of Quezon City, alleging malicious prosecution.
Civil Procedure I
Pre-trial

Misamis Occidental II Cooperative, Inc. vs. David

25th August 2005

ak092221
468 SCRA 63 , 505 Phil. 181 , G.R. No. 129928
Primary Holding
A preliminary hearing on affirmative defenses pleaded in an answer, as provided under Section 5, Rule 16 of the old Rules of Court (now Section 6, Rule 16 of the 1997 Rules), is not mandatory but rests upon the sound discretion of the trial court; its denial is not correctible by certiorari absent grave abuse of discretion amounting to lack or excess of jurisdiction.
Background
Respondent Virgilio S. David, a supplier of electrical hardware, entered into a transaction with petitioner Misamis Occidental II Electric Cooperative, Inc. (MOELCI II) concerning the supply of a 10 MVA Power Transformer. A dispute arose regarding the nature of the document governing the transaction and MOELCI II's alleged failure to pay the agreed price, leading David to file a suit for specific performance and damages.
Civil Procedure I
Motion

Ong vs. Mazo

4th June 2004

ak982901
431 SCRA 56 , 474 Phil. 807 , G.R. No. 145542
Primary Holding
A petition for certiorari under Rule 65 filed after the effectivity of A.M. No. 00-2-03-SC benefits from the fresh 60-day period counted from the notice of denial of the motion for reconsideration, even if the original period under the prior rule (Circular No. 39-98) had partially lapsed; furthermore, denying a party the use of written interrogatories based on the outdated notion that it constitutes a "fishing expedition" is a grave abuse of discretion correctible by certiorari, as modes of discovery are liberally granted to enable parties to obtain relevant facts and expedite proceedings.
Background
The case originated from a vehicular accident where a passenger bus owned by petitioner Elena S. Ong and driven by Iluminado J. Caramoan allegedly bumped a jeep owned and driven by respondent Elvira C. Lanuevo, who had respondent Charito A. Tomilloso as a passenger. This incident led respondents Lanuevo and Tomilloso to file a complaint for damages against Ong and Caramoan.
Civil Procedure I
Discovery

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

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

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

Magsaysay-Labrador vs. Court of Appeals

19th December 1989

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

Barde vs. Posiquit

15th August 1988

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

Koh vs. Intermediate Appellate Court

23rd September 1986

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

Sarmiento vs. Juan

28th January 1983

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

Pioneer Insurance & Surety Corp. vs. Hontanosas

31st August 1977

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

Tijam vs. Sibonghanoy

15th April 1968

ak037088
23 SCRA 29 , No. L-21450
Primary Holding
A party is barred by laches from invoking the defense of lack of jurisdiction when they have actively participated in the case proceedings through various stages for an unreasonable and unexplained length of time, sought affirmative relief, and only raised the jurisdictional question after receiving an unfavorable decision on the merits.
Background
The case originated from a simple collection suit for P1,908.00 filed by the spouses Tijam against the spouses Sibonghanoy in the CFI of Cebu shortly after the Judiciary Act of 1948 (RA 296) took effect, which placed such amounts under the exclusive original jurisdiction of inferior courts. A writ of attachment against the Sibonghanoys' property was dissolved upon the posting of a counter-bond by the Manila Surety and Fidelity Co., Inc. (Surety).
Civil Procedure I

Bustos vs. Lucero

20th October 1948

ak135112
81 Phil. 640 , No. L-2068
Primary Holding
An accused person is not entitled, as a matter of fundamental right, to cross-examine the complainant and witnesses during the preliminary investigation stage after the issuance of an arrest warrant; while the investigating judge has the discretion to grant such an opportunity, Section 11 of Rule 108 does not mandate it, and the constitutional right to confront witnesses applies specifically to the trial proper.
Background
The petitioner, Dominador B. Bustos, was accused in a criminal case and underwent a preliminary investigation before the Justice of the Peace (JP) of Masantol, Pampanga. After the JP found probable cause and issued a warrant based on the complainant's and witnesses' initial testimony, the case was set for the second stage of the preliminary investigation where the accused could present evidence.
Civil Procedure I

Herrera vs. Barretto and Joaquin

10th September 1913

ak952887
25 Phil. 245 , No. 8692
Primary Holding
he Supreme Court will not assess damages arising from an injunction issued by it in a certiorari proceeding; such damages, if any, must be claimed and proven in the court trying the main action where the merits of the case are ventilated, as certiorari is limited to reviewing jurisdictional errors and does not involve a "final trial" on the merits for the purpose of assessing damages under Section 170 of the Code of Civil Procedure.
Background
The underlying dispute involved an action for mandamus in the Court of First Instance (CFI) where Constancio Joaquin sought to compel the issuance of a cockpit license and obtained a mandatory injunction. Godofredo B. Herrera, the Municipal President, then filed a petition for a writ of certiorari with the Supreme Court challenging the CFI's jurisdiction. During this certiorari proceeding, a member of the Supreme Court issued an injunction restraining Joaquin from operating his cockpit. The Supreme Court ultimately dismissed Herrera's certiorari petition and dissolved the injunction.
Civil Procedure I