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Ang Nars Party-List v. Executive Secretary

8th October 2019

ak585185
G.R. No. 215746
Primary Holding
The Supreme Court declared Section 32 of Republic Act No. 9173 valid, and voided and declared unconstitutional the provisions of Joint Resolution No. 4 and Executive Order No. 811 that purported to amend or repeal Section 32. However, the Court refused to compel the government to implement Section 32 due to the absence of an appropriation law.
Background
The case arose after the issuance of Executive Order No. 811, which downgraded the entry-level salary of government nurses to Salary Grade 11, contrary to Section 32 of Republic Act No. 9173. Ang Nars Party-List and PSLINK filed the petition, asserting that the downgrade was unconstitutional and beyond the authority of the Executive.
Statutory Construction

Department of Environment and Natural Resources (DENR) vs. United Planners Consultants, Inc

23rd February 2015

ak719310
751 SCRA 389 , 754 Phil. 513 , G.R. No. 212081
Primary Holding
The CA correctly dismissed DENR’s petition for certiorari as it was filed out of time under the Special ADR Rules, and the confirmed arbitral award’s execution remains subject to COA’s approval.
Background
DENR entered a consultancy agreement with UPCI in 1993 but paid only 47% of the contract price. After UPCI sued for non-payment, the case was referred to arbitration, resulting in a monetary award. DENR challenged the award’s confirmation and execution but failed to follow procedural rules.
Statutory Construction

Commissioner of Internal Revenue vs. BASF Coating + Inks Phil., Inc

26th November 2014

ak919594
743 SCRA 113 , 748 Phil. 760 , G.R. No. 198677
Primary Holding
The BIR’s right to assess deficiency taxes against BASF for 1999 prescribed under the three-year statutory period under the National Internal Revenue Code (NIRC). The Formal Assessment Notice (FAN) was invalid because it was sent to BASF’s former address despite the BIR’s documented awareness of its new location.
Background
BASF dissolved on March 31, 2001, and relocated to Calamba, Laguna. The BIR issued a FAN for 1999 tax deficiencies on January 17, 2003, but mailed it to BASF’s old Las Piñas address. BASF protested the assessment, arguing prescription and lack of valid notice. The CTA and CTA En Banc ruled in favor of BASF, prompting the BIR to appeal to the Supreme Court.
Statutory Construction

Araullo vs. Aquino

1st July 2014

ak306263
728 SCRA 1 , 737 Phil. 457 , G.R. No. 209287 , G.R. NO. 209135 , G.R. NO. 209136 , G.R. NO. 209155 , G.R. NO. 209164 , G.R. NO. 209260 , G.R. NO. 209442 , G.R. NO. 209517 , G.R. NO. 209569
Primary Holding
The Supreme Court issued a ruling declaring several aspects of the DAP (Disbursement Acceleration Program) unconstitutional, including: the withdrawal of unobligated allotments and their designation as savings before the fiscal year's end, the cross-border transfers of savings to offices outside the Executive branch, and the use of savings to fund programs, activities, or projects not covered by the GAA (General Appropriations Act). In applying the Operative Fact Doctrine, the Court established that while projects already implemented under the DAP in good faith would remain intact, the officials responsible for these actions could still be held accountable.
Background
The Disbursement Acceleration Program (DAP) was a mechanism introduced by the Department of Budget and Management (DBM) under Secretary Florencio Abad. It allowed the executive branch to pool savings from various government agencies and realign them to other projects to accelerate economic growth. However, petitioners argued that it violated the constitutional power of Congress over appropriations.
Philosophy of Law Statutory Construction

Disini vs. Secretary of Justice

11th February 2014

ak238408
727 Phil. 28 , G.R. No. 203335 , G.R. No. 203299 , G.R. No. 203306 , G.R. No. 203359 , G.R. No. 203378 , G.R. No. 203391 , G.R. No. 203407 , G.R. No. 203440 , G.R. No. 203453 , G.R. No. 203454 , G.R. No. 203469 , G.R. No. 203501 , G.R. No. 203501 , G.R. No. 203515 , G.R. No. 203518
Primary Holding
The Cybercrime Prevention Act of 2012 (R.A. 10175) is constitutional in its general aim to regulate and punish cybercrimes, but specific provisions that unduly curtail fundamental rights, such as certain aspects of online libel, unsolicited commercial communications, real-time collection of traffic data without a warrant, and the power of the Department of Justice to restrict or block access to computer data, are unconstitutional.
Background
The proliferation of internet use and the rise of cyberspace activities brought about new avenues for communication, commerce, and information dissemination, but also new forms of criminal behavior collectively termed "cybercrimes." Recognizing the need to address these emerging threats, the Philippine government enacted Republic Act No. 10175, the Cybercrime Prevention Act of 2012, to define and penalize various offenses committed through or with the use of computer systems, and to provide for their prevention, investigation, and prosecution.
Constitutional Law II Criminal Law II Philosophy of Law Statutory Construction
Police Power; Freedom of Expression, Libel, and Cyberlibel

Belgica vs. Ochoa

19th November 2013

ak249819
710 SCRA 1 , 721 Phil. 416 , G.R. No. 208566 , G.R. No. 208493 , G.R. No. 209251
Primary Holding
The Court held that the post-enactment authority granted to legislators under the PDAF and similar schemes constitutes an impermissible intrusion into the Executive's budget execution domain, and that lump-sum discretionary funds without specific guidelines amount to an undue delegation of legislative power and undermines the President's item-veto power.
Background
The case arose from public outrage and concern over the alleged misuse and corruption associated with the Priority Development Assistance Fund (PDAF) and other lump-sum discretionary funds, particularly in light of the Commission on Audit (CoA) report and the "Napoles controversy."
Constitutional Law I Constitutional Law II Statutory Construction

Commissioner of Internal Revenue vs. San Roque Power Corporation

8th October 2013

ak589834
690 SCRA 336 , 719 Phil. 137 , G.R. No. 187485 , G.R. No. 196113 , G.R. No. 197156
Primary Holding
The 120+30-day periods under Section 112(C) of the Tax Code are mandatory and jurisdictional, except for claims filed between December 10, 2003 (issuance of BIR Ruling DA-489-03) and October 6, 2010 (promulgation of Aichi), where taxpayers could rely on the erroneous ruling in good faith.
Background
San Roque Power Corporation filed a judicial claim for VAT refund 13 days after its administrative claim, violating the 120-day waiting period. The Court of Tax Appeals granted the refund, but the Supreme Court reversed, emphasizing strict compliance with procedural timelines.
Statutory Construction

Dayao vs. Commission on Elections

29th January 2013

ak885502
689 SCRA 412 , 702 Phil. 348 , G.R. No. 193643
Primary Holding
The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing the complaint for cancellation of LPGMA's registration, as the grounds for cancellation were not among those listed in the Party-List System Act, and the complaint was essentially a belated opposition to the registration.
Background
Petitioners, who are dealers of LPG and an association of industries, sought to cancel the registration of LPGMA as a sectoral organization under the Party-List System, arguing that LPGMA did not represent a marginalized sector.
Statutory Construction

Giron vs. Commission on Elections

22nd January 2013

ak774340
689 SCRA 97 , 702 Phil. 30 , G.R. No. 188179
Primary Holding
The Supreme Court upheld the constitutionality of Sections 12 and 14 of RA 9006, finding that they are germane to the general subject of the law, which aims to ensure fair election practices.
Background
The case was a special civil action for certiorari and prohibition filed by Giron against the Commission on Elections (COMELEC) regarding the implementation of the Fair Election Act.
Statutory Construction

Chavez vs. Judicial and Bar Council

17th July 2012

ak960332
676 SCRA 579 , 691 Phil. 173 , G.R. No. 202242
Primary Holding
The JBC’s practice of allowing two congressional representatives (one from the Senate and one from the House) violated Section 8(1), Article VIII of the 1987 Constitution, which mandates only “a representative of Congress” as an ex-officio member.
Background
After Chief Justice Renato Corona’s removal in May 2012, petitioner Francisco Chavez (a nominee for Chief Justice) challenged the JBC’s composition. The JBC had included two congressional representatives since 1994, initially splitting one vote and later granting each a full vote.
Statutory Construction

Liwag vs. Happy Glen Loop Homeowners Association, Inc

4th July 2012

ak931594
675 SCRA 744 , 690 Phil. 321 , G.R. No. 189755
Primary Holding
The Supreme Court affirmed that Lot 11, Block 5, as the site of the subdivision's water facility, is part of the required "open space" under Presidential Decree No. 957 and reserved for public use. The sale of the lot was void, and an easement for the water facility existed for the benefit of the community.
Background
In 1978, F.G.R. Sales, the original subdivision developer, assigned rights to Ernesto Marcelo due to financial obligations. Marcelo assured government agencies that water facilities were available in the subdivision. The water facility on Lot 11, Block 5 became the sole water source for residents for over 30 years. In 1995, Marcelo sold Lot 11, Block 5 to Hermogenes Liwag. After his death, Emeteria Liwag demanded the removal of the water tank, prompting the homeowners' association to file a case before the Housing and Land Use Regulatory Board (HLURB).
Statutory Construction

Commissioner of Customs vs. Hypermix Feeds Corporation

1st February 2012

ak490989
664 SCRA 666 , 680 Phil. 681 , G.R. No. 179579
Primary Holding
CMO No. 27-2003 was declared unconstitutional for violating procedural due process, substantive due process, and the equal protection clause. It also exceeded the Commissioner of Customs' delegated authority.
Background
Hypermix Feeds Corporation challenged CMO No. 27-2003, which classified wheat imports as either food grade (3% tariff) or feed grade (7% tariff) based on factors like importer identity, country of origin, and port of discharge. Hypermix argued that the regulation unfairly classified its wheat as feed grade despite being food grade, subjected it to higher tariffs, and violated constitutional rights.
Statutory Construction

Datu Michael Abas Kida vs. Senate of the Philippines

18th October 2011

ak191813
659 SCRA 270 , 675 Phil. 316 , G.R. No. 196271 , G.R. NO. 196305 , G.R. NO. 197221 , G.R. NO. 197282 , G.R. NO. 197392 , G.R. NO. 197454
Primary Holding
RA No. 10153 is constitutional; the synchronization of ARMM elections with national elections and the President’s power to appoint interim officials (OICs) are valid under the 1987 Constitution.
Background
RA No. 10153 reset the August 2011 ARMM elections to May 2013 to align with national and local polls. Petitioners challenged the law, claiming it violated ARMM’s autonomy, legislative processes, and the constitutional requirement for elective regional positions.
Constitutional Law I Statutory Construction

League of Cities of the Philippines (LCP) vs. Commission on Elections

12th April 2011

ak614037
663 Phil. 496 , G.R. No. 176951 , G.R. No. 177499 , G.R. NO. 178056
Primary Holding
The Court's February 15, 2011 Resolution, upholding the constitutionality of the 16 Cityhood Laws, is affirmed, as the petitioners' procedural arguments regarding finality and jurisdiction, and substantive arguments regarding violations of the Constitution (Art. X, Secs. 6 & 10) and the Equal Protection Clause, are without merit; the prior judgment declaring the laws unconstitutional had not attained finality due to timely filed and entertained motions.
Background
Congress enacted 16 individual Republic Acts ("Cityhood Laws") converting specific municipalities into cities, incorporating exemption clauses that excused them from the P100 million income requirement established by R.A. No. 9009, which had amended the Local Government Code (LGC). These municipalities had cityhood bills pending before R.A. No. 9009's enactment. The League of Cities of the Philippines (LCP), representing existing cities, challenged these laws as unconstitutional for violating the LGC requirement that cityhood criteria be uniform and stated within the LGC itself, and for violating the equal protection clause. This led to a protracted legal battle involving multiple, conflicting Supreme Court rulings on the laws' validity, culminating in the February 15, 2011 Resolution upholding the laws, which petitioners sought to reconsider in the motion addressed by this present Resolution.
Constitutional Law I Constitutional Law II Philosophy of Law Statutory Construction
Equal Protection

Navarro vs. Ermita

12th April 2011

ak213242
648 SCRA 400 , 663 Phil. 546 , G.R. No. 180050
Primary Holding
The Supreme Court ruled RA 9355 constitutional, exempting provinces composed of islands from the land area requirement under the LGC, and validated Dinagat Islands’ status as a province.
Background
Dinagat Islands was created as a province in 2006. Petitioners argued it violated LGC criteria for population (250,000) and land area (2,000 km²). After initial nullification by the Court in 2010, the case was reopened due to post-election implications for local officials, leading to the final validation of the province.
Statutory Construction

Gutierrez vs. The House of Representatives Committee on Justice, Hontiveros-Baraquel, et al.

15th February 2011

ak949647
643 SCRA 198 , 660 Phil. 271 , G.R. No. 193459
Primary Holding
Impeachment proceedings are “initiated” when a complaint is filed and referred to the House Committee on Justice, triggering the constitutional one-year bar against subsequent proceedings.
Background
Gutierrez faced two impeachment complaints filed 11 days apart in 2010. The House referred both to its Committee on Justice. Gutierrez argued this violated the constitutional prohibition against multiple proceedings within one year.
Statutory Construction

Lokin, Jr. vs. Commission on Elections

22nd June 2010

ak434539
621 SCRA 385 , 635 Phil. 372 , G.R. Nos. 179431-32 , G.R. No. 180443
Primary Holding
The Supreme Court ruled that Section 13 of COMELEC Resolution No. 7804 was invalid to the extent it allowed a party to unilaterally change or substitute its nominees after submission of the list to the COMELEC. The statutory grounds for substitution under R.A. No. 7941 are exclusive.
Background
CIBAC submitted its list of nominees for the 2007 elections, which included Lokin as the second nominee. Subsequently, CIBAC's president filed an amended list replacing Lokin and others with new nominees. COMELEC relied on Section 13 of Resolution No. 7804 to approve this substitution. Lokin challenged the substitution and sought to be proclaimed as CIBAC's second nominee.
Statutory Construction

Commissioner of Internal Revenue vs. Kudos Metal Corporation

5th May 2010

ak209769
620 SCRA 232 , 634 Phil. 314 , G.R. No. 178087
Primary Holding
The government’s right to assess taxes prescribed because the waivers executed to extend the three-year assessment period were invalid due to procedural defects.
Background
The BIR issued deficiency tax assessments against Kudos Metal Corporation for 1998 on September 26, 2003, after conducting an audit prompted by suspected tax fraud. The corporation contested these assessments, arguing they were issued beyond the three-year prescriptive period under the Tax Code.
Statutory Construction

Intestate Estate of Manolita Gonzales Vda. De Carungcong vs. People, et al.

11th February 2010

ak055613
612 SCRA 272 , 626 Phil. 177 , G.R. No. 181409
Primary Holding
The Court reversed lower court rulings, holding that while affinity survives death, William Sato was not exempt from criminal liability for the complex crime of estafa through falsification.
Background
Mediatrix Carungcong, administratrix of her mother Manolita’s estate, accused her brother-in-law William Sato of estafa for fraudulently inducing Manolita (blind and elderly) to sign a falsified Special Power of Attorney (SPA) to sell her properties. Lower courts dismissed the case based on Article 332’s exemption for relatives by affinity.
Statutory Construction

In Re: Petition for Adoption of Michelle P. Lim, et al.

21st May 2009

ak982276
588 SCRA 98 , 606 Phil. 82 , G.R. Nos. 168992-93
Primary Holding
Married individuals must adopt jointly under RA 8552; exceptions do not apply here, so the petitions were correctly dismissed.
Background
Monina and her late husband Primo Lim raised three abandoned children (including Michelle and Michael) as their own, simulating their births. After Primo’s death, Monina remarried an American citizen, Angel Olario. She later sought to legitimize the children’s status through adoption under RA 8552’s amnesty provision for simulated births.
Statutory Construction

Geologistic, Inc. vs. Gateway Electronics Corporation

25th March 2009

ak146267
582 SCRA 434 , G.R. Nos. 174256-57
Primary Holding
The Supreme Court ruled that the RTC lacked sufficient justification for ordering execution pending appeal, considering the unresolved issues of liability and the absence of compelling "good reasons."
Background
Geologistics, Inc. sought to recover unpaid fees from Gateway Electronics Corporation for freight forwarding services, amounting to ₱4,769,954.32 plus interest and damages. The RTC ruled in favor of Geologistics, and the petitioner moved for execution pending appeal. Gateway Electronics and its surety, First Lepanto-Taisho Insurance Corp., filed separate petitions to annul the execution orders, which the Court of Appeals granted.
Statutory Construction

Abakada Guro Party List vs. Purisima

14th August 2008

ak884230
562 SCRA 251 , 584 Phil. 246 , G.R. No. 166715
Primary Holding
The Supreme Court upheld the constitutionality of RA 9335, except for Section 12, which created the Joint Congressional Oversight Committee. The Court ruled that the oversight committee violated the separation of powers doctrine.
Background
RA 9335 was enacted to improve the revenue collection performance of the BIR and BOC by creating a rewards and incentives fund and a Revenue Performance Evaluation Board. The law provides rewards for exceeding revenue targets and sanctions for failing to meet them. Petitioners, representing the Abakada Guro Party List, filed a petition challenging the constitutionality of the law, arguing that it violated several constitutional principles.
Statutory Construction

Garcia vs. Social Security Commission Legal and Collection

17th December 2007

ak000744
540 SCRA 456 , 565 Phil. 193 , G.R. No. 170735
Primary Holding
The Supreme Court upheld that as the only surviving director of the now-dissolved Impact Corporation, Immaculada L. Garcia was liable for unpaid Social Security System (SSS) contributions and penalties imposed under the Social Security Law.
Background
Impact Corporation, a manufacturer of aluminum tube containers, experienced financial difficulties in 1978, leading to labor unrest and eventual cessation of operations. Despite collecting SSS contributions from its employees, the company failed to remit them. The SSS pursued legal actions to recover the unremitted contributions.
Statutory Construction

Commissioner of Internal Revenue vs. Primetown Property Group, Inc

28th August 2007

ak667689
531 SCRA 436 , 558 Phil. 182 , G.R. No. 162155
Primary Holding
The two-year prescriptive period under Section 229 of the National Internal Revenue Code (NIRC) must be computed as 24 calendar months under the Administrative Code, not 730 days under the Civil Code.
Background
Primetown Property Group, a real estate company, suffered losses in 1997 due to the Asian Financial Crisis and sought a refund for overpaid quarterly income taxes. The Bureau of Internal Revenue (BIR) delayed acting on the claim, leading to a judicial dispute.
Statutory Construction

Cemco Holdings, Inc. vs. National Life Insurance Company of the Philippines, Inc.

7th August 2007

ak555743
529 SCRA 355 , 556 Phil. 198 , G.R. NO. 171815
Primary Holding
The Supreme Court affirmed that the Mandatory Tender Offer Rule under the Securities Regulation Code applies to indirect acquisitions of shares in a publicly listed company, protecting minority shareholders. The Securities and Exchange Commission (SEC) had jurisdiction to order Cemco Holdings to conduct a tender offer after it acquired indirect control of Union Cement Corporation (UCC) through purchasing shares in its holding company.
Background
Cemco Holdings acquired shares in Union Cement Holdings Corporation (UCHC), a non-listed company holding 60.51% of Union Cement Corporation (UCC), a publicly listed firm. This indirect acquisition increased Cemco’s beneficial ownership in UCC from 17.03% to 53%. National Life Insurance, a minority UCC shareholder, demanded Cemco comply with the Mandatory Tender Offer Rule. After Cemco refused, National Life filed a complaint with the SEC.
Statutory Construction

Adasa vs. Abalos

19th February 2007

ak799445
516 SCRA 261 , 545 Phil. 168 , G.R. No. 168617
Primary Holding
The Supreme Court denied Adasa's petition, affirming the Court of Appeals' decision. The Court held that the DOJ should not have entertained Adasa's petition for review after her arraignment, as it violated DOJ Circular No. 70. The trial court's dismissal of the case was also void as it was based on the DOJ's void resolutions.
Background
The case originated from two complaints filed by Cecille S. Abalos against Bernadette L. Adasa for estafa, alleging that Adasa encashed two checks without her consent. The Office of the City Prosecutor of Iligan City found probable cause and filed criminal cases against Adasa. Adasa sought reinvestigation, and the DOJ later reversed the prosecutor's resolution, leading to the withdrawal of the charges. The trial court dismissed the case based on the DOJ's resolution, but the Court of Appeals reversed this decision, prompting Adasa to file a Petition for Review with the Supreme Court.
Statutory Construction

Balagtas Multi-Purpose Cooperative, Inc. vs. Court of Appeals

27th October 2006

ak270160
505 SCRA 654 , 536 Phil 511 , G.R. No. 159268
Primary Holding
Cooperatives are not exempt from posting an appeal bond under Article 223 of the Labor Code when appealing to the NLRC. The exemption in Article 62(7) of the Cooperative Code applies only to appeals from decisions of inferior courts (e.g., municipal or regional trial courts), not quasi-judicial agencies.
Background
Josefina Hipolito-Herrero was hired by Balagtas Multi-Purpose Cooperative in 1991. After closing a branch office in 1994, she resigned and later filed a complaint for illegal dismissal and unpaid benefits. The Labor Arbiter ruled in her favor, ordering Balagtas to pay backwages, separation pay, and 13th-month pay. Balagtas appealed to the NLRC but refused to post the required bond, citing Article 62(7) of the Cooperative Code. The NLRC and Court of Appeals rejected this argument.
Statutory Construction

Aquino vs. Quezon City

3rd August 2006

ak382783
497 SCRA 497 , 529 Phil. 486 , G.R. No. 137534 , G.R. No. 138624
Primary Holding
The Supreme Court upheld the validity of the auction sales, ruling that the notice requirements under P.D. No. 464 were sufficiently complied with. The Court emphasized that personal service of notice via registered mail satisfies the legal requirements even if the notice was not personally received. Constructive notice through compliance with statutory procedures was deemed adequate.
Background
G.R. No. 137534 (Aquino Case): The Aquino spouses' 612-square meter lot in East Avenue Subdivision, Diliman, Quezon City, was sold in 1984 for non-payment of property taxes from 1975 to 1982. They withheld payment as a protest against the Marcos regime. G.R. No. 138624 (Torrado Case): A 407-square meter property at No. 20 North Road, Cubao, Quezon City, owned by Solomon Torrado, was sold in 1983 due to unpaid property taxes from 1976 to 1982. Notices were sent to an insufficient address, "Butuan City," causing them to be undelivered.
Statutory Construction

Senate of the Philippines vs. Ermita

20th April 2006

ak395231
488 SCRA 1 , 522 Phil. 1 , G.R. No. 169777 , G.R. No. 169659 , G.R. No. 169660 , G.R. No. 169667 , G.R. No. 169834 , G.R. No. 171246
Primary Holding
The Supreme Court ruled that while executive privilege is valid, it cannot be invoked through a blanket requirement of prior presidential consent for all executive officials appearing before Congress. Such privilege must be explicitly claimed on a case-by-case basis with specific grounds stated.
Background
The case arose from several Senate investigations where executive officials failed to appear, citing E.O. 464 which President Gloria Macapagal-Arroyo issued requiring executive department officials to secure presidential consent before appearing in congressional inquiries. This led to multiple petitions challenging the constitutionality of E.O. 464.
Constitutional Law I Philosophy of Law Statutory Construction

Commissioner of Internal Revenue vs. PLDT

15th December 2005

ak383011
478 SCRA 61 , 514 Phil. 255 , G.R. No. 140230
Primary Holding
PLDT’s “in lieu of all taxes” franchise clause exempts only direct taxes on its franchise/earnings, not indirect taxes like VAT; however, advance sales and compensating taxes collected during 1992–1994 were erroneous and refundable.
Background
PLDT sought a tax refund/credit for indirect taxes paid on imported equipment, citing Section 12 of RA 7082. The BIR and lower courts disagreed on whether the franchise’s “in lieu of all taxes” clause covered indirect taxes.
Statutory Construction

Abakada Guro Party List vs. Ermita

1st September 2005

ak134713
469 SCRA 14 , 506 Phil. 1 , G.R. No. 168056 , G.R. No. 168207 , G.R. No. 168461 , G.R. No. 168463 , G.R. No. 168730
Primary Holding
The Supreme Court ruled that Republic Act No. 9337 is constitutional, particularly the provisions granting the President the authority to raise the VAT rate to 12%. The law merely delegates the ascertainment of facts and does not constitute undue delegation of legislative power.
Background
Republic Act No. 9337 (Expanded VAT Law) was enacted to address the Philippines’ fiscal deficit by increasing government revenue through an expanded VAT system. Several petitions challenged its constitutionality, particularly the provisions authorizing the President to increase the VAT rate, arguing that this was an undue delegation of legislative power.
Philosophy of Law Statutory Construction

Coconut Oil Refiners Association, Inc. vs. Torres

29th July 2005

ak371894
465 SCRA 47 , 503 Phil. 42 , G.R. No. 132527
Primary Holding
The Supreme Court ruled that portions of Executive Order No. 97-A and related issuances were unconstitutional for allowing tax-free removal of goods from the Subic Special Economic Zone to other parts of the Philippines and extending incentives to Clark Special Economic Zone without statutory basis.
Background
Republic Act No. 7227 (Bases Conversion and Development Act of 1992) aimed to convert former U.S. military bases into productive economic zones to promote development in Central Luzon. It created the Subic Special Economic Zone (SSEZ) with tax incentives but did not explicitly extend these privileges to other zones like Clark. Several executive issuances, including Executive Orders No. 80 and 97-A, sought to implement these incentives in both SSEZ and CSEZ, prompting legal challenges from businesses outside these zones.
Statutory Construction

City of Manila vs. Laguio, Jr.

12th April 2005

ak416215
455 SCRA 308 , 495 Phil. 289 , G.R. No. 118127
Primary Holding
Ordinance No. 7783 is an invalid exercise of police power because it violates the constitutional rights to due process and equal protection and exceeds the regulatory powers granted to the City of Manila under the Local Government Code.
Background
Malate Tourist Development Corporation (MTDC) questioned the validity of Ordinance No. 7783, which included motels and inns among the prohibited establishments in the Ermita-Malate area, arguing it was unconstitutional and beyond the City Council's powers.
Constitutional Law II Statutory Construction
Police Power

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

15th July 2003

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

Buena Obra vs. Social Security System

9th April 2003

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

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

29th November 2001

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

Estrada vs. Sandiganbayan

19th November 2001

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

Benedicto vs. Court of Appeals

4th September 2001

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

Del Mar vs. Philippine Amusement and Gaming Corporation

29th November 2000

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

Heirs of Alberto Suguitan vs. City of Mandaluyong

14th March 2000

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

Liang vs. People

28th January 2000

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

Commissioner of Internal Revenue vs. Court of Appeals

23rd February 1999

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

Municipality of Parañaque vs. V.M. Realty Corporation

20th July 1998

ak525057
292 SCRA 678 , 354 Phil. 684 , G.R. No. 127820
Primary Holding
The exercise of eminent domain by an LGU requires an ordinance, as mandated by Section 19 of RA 7160. A resolution is insufficient for authorizing expropriation. Res judicata does not prevent the State or its agents from initiating new expropriation proceedings when public interest demands and all legal requirements are fulfilled.
Background
The Municipality of Parañaque sought to expropriate private property owned by V.M. Realty Corporation for a socialized housing project. The complaint was filed based on a municipal council resolution, not an ordinance. Previously, a similar expropriation case involving the same property had been dismissed with prejudice.
Statutory Construction

Arroyo vs. De Venecia

14th August 1997

ak140457
277 SCRA 268 , 343 Phil. 42 , G.R. No. 127255
Primary Holding
The Supreme Court held that the alleged violations of House rules in the passage of R.A. No. 8240 did not amount to a constitutional violation. The Court also reaffirmed the enrolled bill doctrine, which presumes the validity of a law once it has been duly enacted and certified by the legislative and executive branches.
Background
The case arose from the passage of R.A. No. 8240, which amended the National Internal Revenue Code to impose specific taxes on beer and cigarettes. Petitioners, members of the House of Representatives, claimed that the law was passed in violation of House rules, particularly regarding the approval of the conference committee report and the handling of quorum issues.
Statutory Construction

Santiago vs. Commission on Elections

19th March 1997

ak585438
270 SCRA 106 , 336 Phil. 848 , G.R. No. 127325
Primary Holding
Republic Act No. 6735 is incomplete and inadequate to implement the people's initiative to propose amendments to the Constitution as mandated by Article XVII, Section 2 of the 1987 Constitution because it fails to provide a sufficient standard for the delegation of rule-making power to the COMELEC concerning constitutional initiatives. Consequently, COMELEC Resolution No. 2300, insofar as it prescribes rules and regulations for the conduct of initiative on amendments to the Constitution, is void.
Background
The 1987 Philippine Constitution introduced a novel provision in Article XVII, Section 2, allowing amendments to the Constitution to be directly proposed by the people through initiative, upon a petition of at least twelve per centum of the total number of registered voters, with each legislative district represented by at least three per centum of its registered voters. This provision also mandated Congress to provide for its implementation. The case arose from an attempt by private respondent Delfin, representing PIRMA, to utilize this mechanism to propose an amendment lifting the term limits of elective officials, which was met with legal challenges regarding the existence and sufficiency of an enabling law.
Statutory Construction

Manila Prince Hotel vs. GSIS

3rd February 1997

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

Filoteo, Jr. vs. Sandiganbayan

16th October 1996

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

Mustang Lumber, Inc. vs. Court of Appeals

18th June 1996

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

Fariñas vs. Barba

19th April 1996

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

Fernandez vs. National Labor Relations Commission

28th February 1994

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