Reset

There are 47 results on the current subject filter

Quizon-Arciga vs. Baluyut

14th June 2023

G.R. No. 256612
Summary
The Supreme Court denied the petition for review on certiorari filed by Rita Quizon-Arciga and Relia Q. Arciga challenging the Court of Appeals' dismissal of their petition for annulment of judgment. The Court ruled that while the RTC lacked jurisdiction due to the complaint's failure to state the property's assessed value, petitioners were estopped from questioning jurisdiction after actively participating in the proceedings.
Background
The case stemmed from a loan agreement where Relia Arciga borrowed P500,000 from Jaycee Baluyut, secured by a real estate mortgage on property she co-owned with her mother Rita. When Relia defaulted, Baluyut filed for judicial foreclosure.
Civil Procedure I

Odilao vs. Union Bank of the Philippines

26th April 2023

G.R. No. 254787
Summary
This case involves a petition challenging the dismissal of a complaint for reformation of loan and mortgage agreements due to improper venue. The petitioner filed the suit in Davao City, where the mortgaged property was located, consistent with one of the locations specified in the mortgage contract's venue clause. However, the clause also granted the respondent bank the "absolute option" to choose between Davao City and Pasig City. The lower courts dismissed the case, interpreting the "option" clause as requiring the bank's prior selection. The Supreme Court reversed, holding that the petitioner correctly filed the case in one of the stipulated venues and that the bank's "option" does not preclude the mortgagor from initiating suit in either location; the option is primarily for the bank's use when it is the plaintiff. The complaint was reinstated in the Davao City RTC.
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

G.R. No. 244681
Summary
This case involves a dispute over a property subject to execution in favor of Vicente C. Go following a judgment in a breach of contract and sum of money case. However, the property was previously sold to Spouses Colet, leading to a subsequent case for quieting of title. The Supreme Court ultimately upheld the Court of Appeals' dismissal of Go's Petition for Annulment of Judgment, ruling that the RTC-Quezon City validly acquired jurisdiction and that Spouses Colet's prior unregistered sale took precedence over Go's registered levy.
Background
Vicente C. Go filed a Complaint against Setcom Inc. and several individuals for recovery of money, breach of contract, and damages (Civil Case No. 06-115453, RTC-Manila). The RTC-Manila ruled in Go's favor, ordering the defendants to pay Go P1.7 million with interest and damages. The property owned by Spouses Bernardo was levied and sold in execution to Go in 2011. Spouses Colet, who had purchased the property from Spouses Bernardo in 2005, later discovered the levy and filed a case for quieting of title in RTC-Quezon City. RTC-Quezon City ruled in favor of Spouses Colet, canceling Go’s encumbrances. Go filed a Petition for Annulment of Judgment before the Court of Appeals, which was dismissed. The Supreme Court affirmed the CA’s decision.
Civil Procedure I

Petron Corporation vs. Commissioner of Internal Revenue

20th March 2023

G.R. No. 255961
Summary
Petron Corporation sought a refund for excise taxes paid under protest on its importations of alkylate between July and November 2012, arguing that alkylate is not subject to excise tax under Section 148(e) of the National Internal Revenue Code (NIRC) of 1997, as amended. The Court of Tax Appeals (CTA) Special Second Division and later the CTA En Banc denied the refund, holding that alkylate falls under "other similar products of distillation" because its raw materials are products of distillation. The Supreme Court reversed the CTA, ruling that alkylate, being produced through alkylation and not distillation, and differing significantly from naphtha and regular gasoline, is not among the items subject to excise tax under the plain language of Section 148(e); therefore, the taxes were erroneously collected and must be refunded.
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

G.R. No. 261457
Summary
The Supreme Court denied the petition for review on certiorari filed by Rosario Monasterial challenging the Court of Appeals' decision that affirmed the dismissal of her forcible entry case. The Court ruled that a boundary dispute cannot be settled through an ejectment case and that unregistered sketch plans without proper government approval have no evidentiary value.
Background
Rosario Monasterial filed a case for forcible entry against Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation regarding a property dispute. She presented sketch plans and a deed of sale to support her claim, while Kingsville presented a Torrens title.
Civil Procedure I

Spouses Libiran vs. Elisan Credit Corporation

13th February 2023

G.R. No. 255239
Summary
This case clarifies that while a judicial foreclosure of mortgage is an action incapable of pecuniary estimation, it is also a real action requiring the allegation of the property's assessed value to determine the proper court's jurisdiction. The failure to include this assessed value in the complaint is a fatal flaw, warranting dismissal without prejudice.
Background
Spouses Libiran obtained loans from Elisan Credit Corporation, secured by a real estate mortgage. When they defaulted, Elisan filed a judicial foreclosure complaint. The case reached the Supreme Court concerning jurisdictional issues.
Civil Procedure I

Roa v. Spouses Sy

14th September 2021

910 Phil. 219, G.R. No. 221586
Summary
This case addresses the distinction between "failure to state a cause of action" and "lack of cause of action" as grounds for dismissal of a complaint, and the impact of filing a motion for a bill of particulars (treated as a request for written interrogatories) on a defendant's ability to challenge the sufficiency of the complaint. The Supreme Court found that the Court of Appeals erred in dismissing the complaint based on a ground not originally invoked by the respondents.
Background
The dispute involves a property initially co-owned by Zenaida Roa and her sister Amelia. Their niece, Marie Antoinette Francisco, allegedly fraudulently acquired title and then sold the property to Spouses Sy. Zenaida Roa filed a complaint seeking to nullify the deeds of sale and titles.
Civil Procedure I

Patricio G. Gemina, et al. v. Heirs of Gerardo V. Espejo, Jr., et al.

13th September 2021

910 Phil. 48, G.R. No. 232682
Summary
This case involves a petition for review challenging the Court of Appeals' decision which affirmed the Regional Trial Court's ruling in favor of the respondents (Heirs of Espejo) in an action for recovery of possession of property. The Supreme Court reversed the lower courts' decisions, finding that the petitioner (Gemina) was denied due process when the trial court allowed the respondents to present evidence ex parte solely due to the absence of Gemina's counsel during pre-trial, despite Gemina himself being present. The Court also highlighted issues regarding the sufficient identification of the disputed property and ultimately remanded the case to the trial court for further proceedings, allowing Gemina to present his evidence.
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

G.R. No. 217656
Summary
This case concerns the rights of informal settlers facing eviction due to a government infrastructure project. The Supreme Court affirmed the lower courts' decisions, holding that the Department of Public Works and Highways (DPWH) must comply with due process and the requirements of existing laws before evicting the respondents and demolishing their structures.
Background
The DPWH initiated a C-5 extension project that affected the residential structures of the respondents, who are informal settlers. Instead of initiating expropriation proceedings, the DPWH offered financial assistance, which the respondents deemed insufficient. The respondents filed a complaint seeking just compensation.
Civil Procedure I

Trillanes IV vs. Castillo-Marigomen

14th March 2018

859 SCRA 271, 828 Phil. 336, G.R. No. 223451
Summary
This case involves a Petition for Certiorari filed by Senator Antonio F. Trillanes IV challenging the Regional Trial Court's (RTC) denial of his motion to dismiss a defamation complaint filed against him by businessman Antonio L. Tiu. Trillanes argued his statements calling Tiu a "dummy" for former Vice President Binay concerning the "Hacienda Binay" were covered by parliamentary immunity and failed to state a cause of action. The Supreme Court dismissed Trillanes' petition, holding that his statements to the media were not covered by parliamentary immunity as they were not made during Senate sessions or committee hearings nor in the performance of his official legislative duties, affirmed the RTC's finding that the complaint sufficiently stated a cause of action, and ruled that Trillanes violated the doctrine of hierarchy of courts by filing directly with the Supreme Court without exceptionally compelling reasons.
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

837 SCRA 160, 816 Phil. 789, G.R. No. 226679
Summary
This case challenged the constitutionality of Section 23 of Republic Act No. 9165, which prohibits plea bargaining in all drug-related offenses. The Supreme Court ruled that the provision encroached upon the judiciary's exclusive power to promulgate procedural rules, thereby declaring it unconstitutional.
Background
Petitioner Salvador Estipona, Jr. was charged with possession of dangerous drugs under Section 11, Article II of R.A. No. 9165. He attempted to enter into a plea bargaining agreement, which was denied based on the statutory prohibition under Section 23 of the law. He then filed a petition questioning the constitutionality of the prohibition, arguing that it violated the judiciary’s rule-making power.
Civil Procedure I Criminal Law I Criminal Procedure

National Housing Authority vs. Laurito

31st July 2017

833 SCRA 380, 814 Phil. 1019, G.R. No. 191657
Summary
This case involves a dispute between the National Housing Authority (NHA) and the heirs of Spouses Laurito over ownership of a parcel of land in Carmona, Cavite, with both parties presenting different Transfer Certificates of Title (TCTs) derived ultimately from the same parent title but registered at different times and through different processes (transfer vs. administrative reconstitution). The Supreme Court affirmed the lower courts' decisions upholding the title of the Spouses Laurito's heirs, ruling that their title, registered earlier in time (1956), prevails over NHA's titles which originated from a later, dubious administrative reconstitution (1960) of an already cancelled parent title. The Court also denied a late petition-in-intervention filed by the heirs of Rufina Manarin.
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

826 SCRA 47, 810 Phil. 347, G.R. No. 220211
Summary
This case involves a petition for review challenging the Court of Appeals' reversal of a Regional Trial Court decision. Petitioners Edron Construction Corporation and Edmer Y. Lim sued the Provincial Government of Surigao Del Sur for specific performance and damages to collect unpaid amounts under three construction contracts. The Court of Appeals dismissed the complaint for lack of cause of action due to the petitioners' failure to submit a contractually required sworn statement. The Supreme Court reversed the Court of Appeals, reinstated the RTC decision with modifications on interest rates, and held that the respondent had waived the defense regarding the sworn statement by failing to raise it in its Answer or in a timely Motion to Dismiss, as mandated by the Rules of Court.
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

809 Phil. 789, G.R. No. 212778
Summary
This case involves a dispute over a parcel of land originally owned by the Santos heirs and tenanted by petitioners Castro and Sebastian. An heir sold a portion to the Municipality of Bustos, which built a public market on it. Although the Provincial Agrarian Reform Adjudicator (PARAD) initially recognized the petitioners' right of redemption as tenants, subsequent execution proceedings led to the PARAD ordering the transfer of ownership despite the petitioners' failure to timely and validly redeem the property. The Court of Appeals reversed the PARAD's execution orders. The Supreme Court affirmed the Court of Appeals, holding that while petitioners were tenants with a right of redemption, their failure to validly exercise this right (by timely consigning the full redemption price) and the property's conversion to public use precluded them from acquiring ownership or possession, though they are 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

812 SCRA 91, 801 Phil. 883, G.R. No. 201017, G.R. No. 215289
Summary
A case involving a dispute over a Memorandum of Agreement (MOA) between two corporations regarding the acquisition of shares and development of a commercial property (Meisic Mall), where issues of summary judgment and execution pending appeal were central to the Supreme Court's decision.
Background
The case arose from a contract between the City of Manila and Bullion for the lease and development of a 4,808.40-square-meter property. Bullion won the bidding but needed additional funding to complete the commercial building (Meisic Mall). They entered into a MOA with Majestic Plus Holdings International, Inc. for 80% equity interest in exchange for funding.
Civil Procedure I

Ursua vs. Republic

5th October 2016

805 SCRA 1, 796 Phil. 439, G.R. Nos. 177857-58, G.R. No. 178193
Summary
This case involves consolidated petitions for review challenging various rulings of the Sandiganbayan regarding the ownership and disposition of coconut levy funds and assets, including shares in United Coconut Planters Bank (UCPB) and San Miguel Corporation (SMC). The petitioners, including COCOFED and individual coconut farmers, sought to reverse the rulings that declared the assets to be public funds held in trust for all coconut farmers, while the respondents, including the Republic, argued for the recovery of allegedly ill-gotten wealth.
Background
The case arose from a broader legal battle over the alleged misuse of coconut levy funds collected from coconut farmers during the Marcos regime. These funds were purportedly used to acquire shares in UCPB and SMC, among other assets. The Presidential Commission on Good Government (PCGG) filed several cases to recover these assets as part of the government's efforts to reclaim ill-gotten wealth.
Civil Procedure I

Metropolitan Bank and Trust Company vs. Fadcor, Inc

25th January 2016

781 SCRA 561, 779 Phil. 32, G.R. No. 197970
Summary
This case involves a petition for review on certiorari filed by Metropolitan Bank and Trust Company (Metrobank) challenging the Court of Appeals' (CA) decision which reversed the Regional Trial Court's (RTC) ruling. The RTC had ordered Fadcor, Inc. and its officers (respondents) to pay Metrobank a deficiency obligation arising from an extra-judicial foreclosure sale. The CA reversed the RTC, finding that certain exhibits supporting the deficiency claim were improperly admitted because they were not explicitly identified piece-by-piece in the transcript of stenographic notes (TSN) of the *ex parte* hearing, allegedly violating A.M. No. 03-1-09-SC. The Supreme Court granted Metrobank's petition, reversed the CA, and reinstated the RTC decision, holding that the formal offer and admission of evidence by the RTC were sufficient, especially since the presentation was *ex parte* due to respondents' failure to appear at pre-trial, and that A.M. No. 03-1-09-SC primarily applies to regular pre-trial proceedings, not *ex parte* hearings resulting from a defendant's default.
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 vs. GJH Land, Inc. (formerly S.J. Land, Inc.)

10th November 2015

774 SCRA 242, 772 Phil. 483, G.R. No. 202664
Summary
This case resolves whether a regular branch of the Regional Trial Court (RTC) lacking designation as a Special Commercial Court can dismiss an intra-corporate case for lack of jurisdiction, or should instead transfer it to the designated Special Commercial Court branch.
Background
The case arose from a dispute over corporate shares in S.J. Land, Inc. (later GJH Land, Inc.) where the petitioners claimed full payment of their share subscriptions while the company attempted to sell these allegedly unpaid shares.
Civil Procedure I

De Leon vs. Chu

2nd September 2015

768 SCRA 609, 768 Phil. 217, G.R. No. 186522
Summary
This case involves a dispute over ownership of a 50-square meter portion of land, originating from alleged forgery of a deed of sale. Petitioner Rowena De Leon filed a case to compel Respondent Lolita Chu to surrender the title (LRC Case No. 1322), while Respondents Lolita Chu and Domingo Delos Santos filed a separate case to annul the deed and cancel the title (Civil Case No. 2257), alleging forgery. The RTC consolidated the cases, found forgery by Rowena, annulled the deed/title, and dismissed Rowena's petition. The Court of Appeals affirmed the RTC decision. The Supreme Court denied Rowena's petition for review, finding no merit in her arguments regarding forum shopping, indispensable parties, and issues raised for the first time on appeal, ultimately upholding the lower courts' findings.
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

753 SCRA 98, 755 PHIL. 793, G.R. No. 201248
Summary
This case involves a dispute over land ownership between the Naguit family (petitioners), claiming ownership through a deed of sale from 1894 and long-term possession, and the Quiazon family (respondents), asserting ownership based on a Torrens title derived from a 1919 land registration decree. The Supreme Court addressed whether the lower courts erred in dismissing the petitioners' complaint for quieting of title based on a lack of cause of action, considering evidence beyond the allegations in the complaint.
Background
The Naguit family filed a complaint seeking to annul the Quiazon family's title and quiet title in their favor, asserting a prior claim based on a deed of sale and continuous possession. The Quiazons countered that their Torrens title, derived from a land registration decree, was superior. The trial court conducted a preliminary hearing and dismissed the case, a decision affirmed by the Court of Appeals.
Civil Procedure I

Zuñiga-Santos vs. Santos-Gran

8th October 2014

738 SCRA 33, 745 Phil. 171, G.R. No. 197380
Summary
The Supreme Court affirmed the dismissal of a complaint seeking to annul a sale and revoke a title, but modified the grounds for dismissal, holding that the amended complaint failed to state a cause of action and that the action had prescribed.
Background
The case concerns a dispute over the ownership of properties transferred from the petitioner's name to the respondent's name, where the petitioner claims the transfer was based on void or voidable documents.
Civil Procedure I

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

10th September 2014

734 SCRA 527, 742 Phil. 557, G.R. No. 157583
Summary
This case involves a petition directly filed with the Supreme Court challenging the Regional Trial Court's (RTC) dismissal of petitioner Frumencio Pulgar's motion for intervention in Civil Case No. 0587-M. The RTC dismissed the main case, originally filed by Quezon Power (Philippines) Limited, Co. (QPL) as a consignation and damages complaint protesting a realty tax assessment, for lack of jurisdiction, ruling it should have been filed with the Local Board of Assessment Appeals. Consequently, the RTC also dismissed Pulgar's intervention. The Supreme Court affirmed the RTC's decision, holding that since intervention is merely ancillary, the dismissal of the main case due to lack of jurisdiction necessarily results in the dismissal of the intervention.
Background
The underlying dispute concerned the Municipal Assessor of Mauban, Quezon's 1999 assessment of significant realty taxes on the Mauban Power Plant owned by Quezon Power (Philippines) Limited, Co. (QPL), based on a market value far exceeding QPL's own declared value. QPL contested the assessment's validity and the assessor's authority.
Civil Procedure I
Intervention

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

13th August 2014

733 SCRA 68, 756 PHIL. 354, G.R. No. 203655
Summary
This case involves a Resolution denying the Motion for Reconsideration filed by the Bases Conversion and Development Authority (BCDA) and its President. The Court affirmed its earlier Decision which granted SM Land Inc.'s (SMLI) petition for certiorari and directed BCDA to proceed with the competitive challenge for SMLI's unsolicited proposal for the Bonifacio South Property. The Court reiterated that a perfected contract existed between SMLI and BCDA (the Certification of Successful Negotiations), mandating the competitive challenge process under the NEDA JV Guidelines, which have the force of law, and that BCDA was estopped from unilaterally cancelling the process.
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

702 SCRA 677, 715 Phil. 651, G.R. No. 183608
Summary
This case involves a Petition for Review on Certiorari challenging the Court of Appeals' decision which reversed the Regional Trial Court's dismissal of two consolidated collection cases filed by the Bureau of Customs (BOC). The RTC dismissed the cases due to the repeated failure of the BOC and the Office of the Solicitor General (OSG) to appear at pre-trial hearings. The CA granted the BOC's Petition for Certiorari, finding grave abuse of discretion by the RTC and ordered the remand of the cases. The Supreme Court reversed the CA, ruling that certiorari was the wrong remedy (appeal should have been filed) and that the RTC's dismissal was justified, but modified the dismissal to be without prejudice due to the public interest involved in the collection of taxes.
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

695 SCRA 714, 708 Phil. 693, G.R. No. 204700
Summary
This case involves a petition seeking the reversal of the Court of Appeals' dismissal of a certiorari petition, which had challenged the Regional Trial Court's denial of the petitioners' motion for the production and inspection of a Loan Sale and Purchase Agreement (LSPA). The petitioners, defendants in a collection suit where the plaintiff's credit was assigned to the respondent, argued the LSPA was crucial to determine the assignment price for exercising their right of redemption under Article 1634 of the Civil Code. The Supreme Court granted the petition, ruling that the LSPA was relevant and material, and its production was necessary for fair litigation and the petitioners' right to discovery, ordering the respondent to produce the document.
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

664 SCRA 11, 680 Phil. 10, G.R. No. 158239
Summary
The Supreme Court affirmed that the denial of a motion for reconsideration of an order granting a motion to dismiss is a final, not interlocutory order, as it conclusively terminates the matter. Under the "fresh period rule," a party has 15 days from notice of denial to appeal.
Background
In 1979, Margarita Marquez Alma Jose sold two parcels of land to Ramon Javellana through a deed of conditional sale for ₱160,000. The agreement required Margarita to register the land under the Torrens System, with her children (Juvenal and Priscilla) authorized to receive the balance payment and proceed with registration if she became incapacitated.
Civil Procedure I

Barayuga vs. Adventist University of the Philippines

17th August 2011

655 SCRA 640, G.R. No. 168008
Summary
A case concerning the validity of removing a university president and determining his proper term length, where the Supreme Court affirmed that an injunctive relief only protects existing rights and dismissed the petition for lack of merit due to the petitioner's inability to prove a clear legal right to the position.
Background
The dispute arose when Petronilo Barayuga, President of Adventist University of the Philippines (AUP), was removed from his position on January 27, 2003 following audit findings of financial irregularities and management issues. He filed a suit for injunction and damages, claiming he had a five-year term and was illegally removed. While the Regional Trial Court granted him a preliminary injunction, the Court of Appeals reversed this decision. The case reached the Supreme Court to determine whether he had any legal right to the position that could be protected by an injunctive writ.
Civil Procedure I

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

1st June 2011

650 SCRA 100, 665 Phil. 245, G.R. No. 170352
Summary
The case revolves around the authority of Atty. Reuben Mikhail Sabig to represent Megan Sugar Corporation (MEGAN) in proceedings before the Regional Trial Court (RTC) and whether MEGAN is estopped from questioning the RTC's jurisdiction after its counsel actively participated in the proceedings and sought affirmative relief from the court.
Background
The case originated from a loan obtained by New Frontier Sugar Corporation (NFSC) from Equitable PCI Bank (EPCIB), secured by mortgages over NFSC's land and sugar mill. Due to liquidity problems, NFSC entered into agreements with various parties, leading to complex legal proceedings involving multiple corporations and their interests in the sugar mill operations.
Civil Procedure I

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

2nd February 2011

641 SCRA 520, 656 Phil. 537, G.R. No. 186045
Summary
This case involves a petition by Mactan-Cebu International Airport Authority (MCIAA) challenging the Court of Appeals' decision allowing intervention by the respondents (Heirs of Filomeno, Pedro, and Florencia Miñoza) in a reconveyance case originally filed by another set of heirs (represented by Leila Hermosisima) against MCIAA. The respondents claimed to be the true heirs of the original landowner, Estanislao Miñoza, and alleged fraud by the original plaintiffs' predecessors. The Supreme Court reversed the Court of Appeals and reinstated the Regional Trial Court's denial of intervention, holding that the respondents' claims constituted an independent controversy that would unduly delay and complicate the main action, and their interest, while potentially valid, was not sufficiently direct and immediate to the specific issue of the reconveyance based on the alleged buy-back option.
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

653 Phil. 111, G.R. No. 157852
Summary
This case involves a petition for certiorari challenging the Court of Appeals' decision which affirmed the dismissal of the petitioners' complaint for cancellation of title and reconveyance. Petitioners, heirs of Domingo Valientes, claimed their ancestor's land was fraudulently transferred to the predecessors of respondent Minor, who obtained a Transfer Certificate of Title (TCT). Although the Court of Appeals disagreed with the trial court's dismissal ground (forum shopping), it upheld the dismissal based on prescription and laches, finding that the action for reconveyance based on an implied trust, filed over 28 years after the TCT issuance, was time-barred as petitioners were not in possession of the property. The Supreme Court affirmed the Court of Appeals, holding that prescription applies and the appellate court could dismiss the case *motu proprio* on this ground.
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

616 SCRA 345, 630 Phil. 334, G.R. No. 174835
Summary
This case involves a dispute over the cancellation of a notice of lis pendens on a property that was part of an inheritance settlement. The Supreme Court ruled that once a compromise agreement in an estate settlement is approved by the court, the notice of lis pendens should be cancelled as the probate proceedings have ended.
Background
The case arose from the settlement of the estate of Lourdes Aquino Reyes. The property in question was covered by Transfer Certificate of Title (TCT) No. 24475, which had a notice of lis pendens annotated on it during the estate proceedings. After a compromise agreement was reached and approved by the court, the petitioner sought to cancel the lis pendens annotation, which the respondent opposed due to an alleged unfulfilled side agreement regarding a right of way.
Civil Procedure I

Ruby Shelter Builders and Realty Development Corporation vs. Formaran III

10th February 2009

578 SCRA 283, 598 Phil. 105, G.R. No. 175914
Summary
A case involving the determination of proper docket fees in a real action for recovery of real property, where the Supreme Court affirmed that such cases must be computed based on the fair market value of the property rather than treating them as actions incapable of pecuniary estimation.
Background
Ruby Shelter obtained a loan of P95,700,620.00 from respondents Tan and Obiedo, secured by real estate mortgages over five parcels of land. After defaulting, they entered into a Memorandum of Agreement allowing extension of payment and requiring execution of Deeds of Absolute Sale. When Ruby Shelter failed to pay, the respondents registered the properties in their names.
Civil Procedure I

Figueroa vs. People

14th July 2008

558 SCRA 63, 580 Phil. 58, G.R. No. 147406
Summary
This case revolves around the issue of whether a litigant may be estopped by laches from questioning the jurisdiction of a tribunal. Petitioner Venancio Figueroa was convicted by the RTC for reckless imprudence resulting in homicide. He later raised the lack of jurisdiction of the RTC only on appeal. The Supreme Court ruled that jurisdiction can be questioned at any stage and granted the petition, dismissing the criminal case.
Background
Figueroa was accused of reckless imprudence resulting in homicide after a bus he was driving struck and killed a pedestrian. He was convicted by the RTC of Bulacan and sentenced to imprisonment. On appeal, he questioned the trial court's jurisdiction, arguing that the MTC, not the RTC, had jurisdiction over the case based on the imposable penalty.
Civil Procedure I

Agulto vs. Tecson

29th November 2005

476 SCRA 395, 512 Phil. 760, G.R. No. 145276
Summary
This case involves a petition for review on certiorari challenging the Court of Appeals' dismissal of a petition for certiorari, which questioned the Regional Trial Court's (RTC) order allowing respondent to present evidence ex parte and the subsequent judgment against petitioners due to their failure to appear at a pre-trial hearing. The Supreme Court granted the petition, ruling that the RTC committed grave abuse of discretion because petitioners' counsel was not served with a formal notice of the pre-trial as required by the Rules of Court, rendering the subsequent proceedings void for violation of due process, and held that certiorari was the appropriate remedy given the patent nullity of the RTC's orders.
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

468 SCRA 63, 505 Phil. 181, G.R. No. 129928
Summary
This case involves a petition for review seeking the reversal of a Court of Appeals decision which upheld a trial court's denial of petitioner MOELCI II's motion for a preliminary hearing on its affirmative defenses, particularly the defense of failure to state a cause of action. Respondent David sued MOELCI II for specific performance and damages based on an alleged contract (Annex "A") for the sale of a transformer, which MOELCI II claimed was merely a quotation letter. The Supreme Court affirmed the lower courts' decisions, holding that preliminary hearings on affirmative defenses are discretionary and that the determination of whether a complaint states a cause of action must be based solely on the allegations within the complaint and its annexes, hypothetically admitting their truth.
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

431 SCRA 56, 474 Phil. 807, G.R. No. 145542
Summary
This case involves a petition for review challenging the Court of Appeals' dismissal of a petition for certiorari on procedural grounds (timeliness) and, ultimately, addresses the propriety of the trial court's denial of the petitioner's motion to compel respondents to answer written interrogatories in a damages suit arising from a vehicular accident. The Supreme Court reversed the Court of Appeals, ruling that the certiorari petition was timely filed based on the retroactive application of A.M. No. 00-2-03-SC, and further held that the trial court committed grave abuse of discretion in disallowing the written interrogatories, emphasizing the importance and liberal use of discovery mechanisms under the Rules of Court.
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

439 SCRA 667, 482 Phil. 894, G.R. No. 156264
Summary
A case involving jurisdiction over injunctive relief regarding operations within the Clark Special Economic Zone, where the Supreme Court affirmed that under Republic Act No. 7227, only it has the authority to issue injunctions concerning projects for the conversion of military reservations into alternative productive uses.
Background
This case originated from a distributorship agreement between Allied Domecq Philippines Inc. (ADPI) and Pedro Domecq, S.A. of Spain for the exclusive distribution of "Fundador" brandy in the Philippines. When Clark Liberty Warehouse imported the brandy without BFAD certification, ADPI sought injunctive relief, leading to a jurisdictional dispute that reached the Supreme Court.
Civil Procedure I

Yau vs. Manila Banking Corporation

11th July 2002

384 SCRA 340, 433 Phil. 701, G.R. No. 126731, G.R. No. 128623
Summary
This consolidated case involves twin petitions questioning separate Court of Appeals decisions concerning a proprietary share in Manila Golf and Country Club owned by Ricardo Silverio, Sr. Esteban Yau, a judgment creditor of Silverio, purchased the share at an execution sale but faced challenges because the share was already under preliminary attachment by The Manila Banking Corporation (Manilabank) in cases pending before the RTC Makati. The Supreme Court ultimately affirmed the Court of Appeals' decisions, holding that the RTC Cebu City lacked jurisdiction to order the cancellation and issuance of a new certificate for the share already under *custodia legis* of RTC Makati, but upheld Yau's right to intervene in the RTC Makati case to protect his interest as purchaser of the attached share.
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

297 SCRA 754, 361 Phil. 73, G.R. No. 132601
Summary
A landmark case addressing the Supreme Court's jurisdiction to temporarily restrain the execution of a death convict and the constitutional limitations on Congress's power to impose the death penalty.
Background
Leo Echegaray was sentenced to death under R.A. 7659. The Supreme Court issued a Temporary Restraining Order (TRO) on his execution to give Congress time to review the death penalty law. Public respondents challenged the Court's jurisdiction to issue such TRO.
Civil Procedure I Philosophy of Law

Magsaysay-Labrador vs. Court of Appeals

19th December 1989

180 SCRA 266, 259 Phil. 748, G.R. No. 58168
Summary
This case involves a petition for review challenging the Court of Appeals' denial of the petitioners' motion to intervene in an annulment suit filed by the respondent, Adelaida Rodriguez-Magsaysay. The respondent sought to nullify a Deed of Assignment transferring property (allegedly conjugal) from her late husband, Senator Genaro Magsaysay, to SUBIC Land Corporation (SUBIC), and a subsequent mortgage by SUBIC. The petitioners, sisters of the late Senator, claimed a right to intervene based on an alleged assignment of SUBIC shares to them by their brother. The Supreme Court affirmed the denial of intervention, ruling that the petitioners, as shareholders, lacked the direct legal interest required under the Rules of Court, emphasizing the separate legal personality of the corporation and the fact that the share transfer was not registered in the corporate books.
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

164 SCRA 304, 247 Phil. 268, G.R. No. L-29445
Summary
This case involves an appeal from a Court of First Instance order denying a Petition for Relief from Judgment. The appellants (heirs of Pedro Barde) were declared in default, and judgment was rendered against them in a case for reconveyance and partition after notice of pre-trial was sent only to their counsel and returned unclaimed, without notice being served upon the appellants themselves. The Supreme Court set aside the trial court's decision, holding that notice of pre-trial must be served on both the parties and their counsel, and the lack of notice to the parties rendered the subsequent proceedings, including the judgment, null and void for violating procedural 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

144 SCRA 259, 228 Phil. 258, G.R. NO. 71388
Summary
This case involves a petition to review the Intermediate Appellate Court's decision which dismissed a certiorari petition seeking to annul the Regional Trial Court's denial of a motion to dismiss based on res adjudicata. The respondent bank had mistakenly overpaid the petitioner due to a computer error, filed a collection suit which was dismissed for non-compliance with a "Notice of Case Status" issued by an officer-in-charge, and then refiled the complaint. The Supreme Court affirmed the lower courts' rulings, holding that the initial dismissal was null and void because the notice was not a valid court order, and therefore, the dismissal did not constitute res adjudicata barring the second complaint.
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

120 SCRA 403, 205 Phil. 335, No. L-56605
Summary
This case involves a petition for review on certiorari challenging the Court of Appeals' decision which upheld the trial court's orders denying petitioner's motion to postpone pre-trial due to illness, declaring him "as in default," and denying his motion for reconsideration. The Supreme Court reversed the lower courts, finding that the trial court committed grave abuse of discretion by prioritizing procedural rules over substantial justice, particularly since the petitioner presented a valid reason for his absence and the respondent also failed to make a valid appearance at the 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

168 Phil. 608, G.R. No. L-35951
Summary
This case involves a petition for certiorari challenging the Court of Appeals' decision which upheld the Court of First Instance (CFI) of Cebu's order declaring petitioners in default for failing to attend a second pre-trial and the subsequent judgment awarding damages to respondents. The Supreme Court reversed the Court of Appeals, nullified the CFI's default order and decision, holding that the second pre-trial was improperly called, notice was insufficient as the party itself was not notified, the case was prematurely set for pre-trial as the last pleading had not been filed, the denial of the motion for postponement constituted grave abuse of discretion, appeal was not an adequate remedy under the circumstances, and the CFI of Cebu lacked jurisdiction over the claim for damages arising from an attachment issued by the CFI of Manila.
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

23 SCRA 29, No. L-21450
Summary
A landmark case establishing the doctrine of laches in Philippine jurisprudence, where a party was barred from questioning the court's jurisdiction after actively participating in proceedings for an extended period. The case emphasizes that jurisdiction questions must be raised at the earliest opportunity.
Background
The case originated from a civil suit to recover money where attachment was issued but later discharged upon posting of a counter-bond by defendants through Manila Surety and Fidelity Co., Inc. After judgment and failed execution against defendants, plaintiffs sought to execute against the surety bond. The surety company raised jurisdictional questions only after adverse decisions and nearly 15 years of proceedings
Civil Procedure I

Bustos vs. Lucero

20th October 1948

81 Phil. 640, No. L-2068
Summary
A landmark case addressing the scope of an accused's right to cross-examine witnesses during preliminary investigation, where the Supreme Court upheld the discretionary nature of this right rather than treating it as an absolute constitutional guarantee.
Background
The case arose from a criminal proceeding where the accused sought to cross-examine witnesses during preliminary investigation. After being denied this opportunity, he attempted to have the case remanded back to the justice of the peace court to exercise this right.
Civil Procedure I

Herrera vs. Barretto and Joaquin

10th September 1913

25 Phil. 245, No. 8692
Summary
A case concerning the scope and limitations of certiorari, where the Supreme Court established that certiorari cannot be used to review decisions that are merely erroneous when the court has jurisdiction over the subject matter and parties - such errors must be corrected through appeal.
Background
The case arose from a dispute over a cockpit license in Caloocan, where the municipal president refused to issue a license to Constancio Joaquin. The Court of First Instance issued an ex parte mandatory injunction requiring the issuance of a provisional license during the pendency of the action.
Civil Procedure I