Enriquez vs. Sun Life Assurance Co. of Canada.

November 29, 1920.

[GRN 15895 November 29, 1920.]

RAFAEL ENRIQUEZ, as administrator of the estate of the late Joaquin Ma. Herrer, plaintiff and appellant, VS. SUN LIFE ASSURANCE COMPANY OF CANADA, defendant and appellee.
1. INSURANCE; PHILIPPINE LAW.-The law of insurance is now found in the Insurance Act and the Civil Code. 2. ID.; OFFER AND ACCEPTANCE.-The Civil Code rule, that an acceptance made by letter shall bind the person making the offer only from the date it came to his knowledge, is controlling. 3. ID.; ID.-On September 24, 1917, H made application to an insurance company through its office in Manila for a life annuity. Two days later he paid the sum of P6,000 to the manager of the company's Manila office and was given a receipt therefor. On November 26, 1917, the head office gave notice of acceptance by cable to Manila. On the same date the Manila office prepared a letter notifying H that his application had been accepted and this was placed in the ordinary channels for transmission, but as far as known, was never actually mailed and was never received by the applicant. H died on December 20, 1917. Held: That the contract for a life annuity was not perfected because it had not been proved satisfactorily that the acceptance of the application ever came to the knowledge of the applicant. 4. ID.; ID.-An acceptance of an offer of insurance not actually or constructively communicated to the proposer does not make a contract. Only the mailing of acceptance completes the contract of insurance, as the locus poenitentiæ ended when the acceptance has passed beyond the control of the party. 5. ID.; ID.; MAILING AND DELIVERY OF MAIL MATTER, PRESUMPTION.When a letter or other mail matter is addressed and mailed with postage prepaid there is a rebuttable presumption of fact that it was received by the addressee as soon as it could have been transmitted to him in the ordinary course of the mails. But if any one of these elemental facts fails to appear, it is fatal to the presumption.

APPEAL from a judgment of the Court of First Instance of Manila. V. del Rosario, J. The facts are stated in the opinion of the court. Jose A. Espiritu for appellant.

Cohn, Fisher & DeWitt for appellee. MALCOLM, J.: This is an action brought by the plaintiff as administrator of the estate of the late Joaquin Ma. Herrer to recover from the defendant life insurance company the sum of P6,000 paid by the deceased for a life annuity. The trial court gave judgment for the defendant. Plaintiff appeals. The undisputed facts are these: On September 24, 1917, Joaquin Herrer made application to the Sun Life Assurance Company of Canada through its office in Manila for a life annuity. Two days later he paid the sum of P6,000 to the manager of the company's Manila office and was given a receipt reading as follows: "MANILA, I. F., 26 de septiembre, 1917. "PROVISIONAL RECEIPT "P6,000 "Recibí la suma de seis mil pesos de Don Joaquin Herrer de Manila como prima de la Renta Vitalicia solicitada por dicho Don Joaquin Herrer hoy, sujeta al examen médico y aprobación de la Oficina Central de la Compañia." The application was immediately forwarded to the head office of the company at Montreal, Canada. On November 26, 1917, the head office gave notice of acceptance by cable to Manila. (Whether on the same day the cable was received notice was sent by the Manila office to Herrer that the application had been accepted, is a disputed point, which will be discussed later.) On December 4, 1917, the policy was issued at Montreal. On December 18, 1917, attorney Aurelio A. Torres wrote to the Manila office of the company stating that Herrer desired to withdraw his application. The following day the local office replied to Mr. Torres, stating that the policy had been issued, and called attention to the notification of November 26, 1917. This letter was received by Mr. Torres on the morning of December 21, 1917. Mr. Herrer died on December 20, 1917. As above suggested, the issue of fact raised by the evidence is whether Herrer received notice of acceptance of his application. To resolve this question, we propose to go directly to the evidence of record. The chief clerk of the Manila office of the Sun Life Assurance Company of Canada at the time of the trial testified that he prepared the letter introduced in evidence as Exhibit 3, of date November 26, 1917, and handed it to the local manager, Mr. E. E. White, for signature. The witness admitted on cross-examination that after preparing the letter and

giving it to the manager, he knew nothing of what became of it. The local manager, Mr. White, testified to having received the cablegram accepting the application of Mr. Herrer from the home office on November 26, 1917. He said that on the same day he signed a letter notifying Mr. Herrer of this acceptance. The witness further said that letters, after being signed, were sent to the chief clerk and placed on the mailing desk for transmission. The witness could not tell if the letter had ever actually been placed in the mails. Mr. Tuason, who was the chief clerk, on November 26, 1917, was not called as a witness. For the defense, attorney Manuel Torres testified to having prepared the will of Joaquin Ma. Herrer, that on this occasion, Mr. Herrer mentioned his application for a life annuity, and that he said that the only document relating to the transaction in his possession was the provisional receipt. Rafael Enriquez, the administrator of the estate, testified that he had gone through the effects of the deceased and had found no letter of notification from the insurance company to Mr. Herrer. Our deduction from the evidence on this issue must be that the letter of November 26, 1917, notifying Mr. Herrer that his application had been accepted, was prepared and signed in the local office of the insurance company, was placed in the ordinary channels for transmission, but as far as we know, was never actually mailed and thus was never received by the applicant. Not forgetting our conclusion of fact, it next becomes necessary to determine the law which should be applied to the facts. In order to reach our legal goal, the obvious signposts along the way must be noticed. Until quite recently, all of the provisions concerning life insurance in the Philippines were found in the Code of Commerce and the Civil Code. In the Code of Commerce, there formerly existed Title VIII of Book II and Section III of Title III of Book III, which dealt with insurance contracts. In the Civil Code there formerly existed and presumably still exist, Chapters II and IV, entitled insurance contracts and life annuities, respectively, of Title X11 of Book IV. On and after July 1, 1915, there was, however, in force the Insurance Act, No. 2427. Chapter IV of this Act concerns life and health insurance. The Act expressly repealed Title VIII of Book II and Section III of Title III of 'Book III of the Code of Commerce. The law of insurance is consequently now found in the Insurance Act and the Civil Code. While, as just noticed, the Insurance Act deals with life insurance, it is silent as to the methods to be followed in order that there may be a contract of insurance. On the other hand, the Civil Code, in article 1802, not only describes a contract of life annuity markedly similar to the one we are considering, but in two other articles, gives strong clues as to the proper disposition of the case. For instance, article 16 of the Civil Code

The contract. that an acceptance made by letter shall bind the person making the offer only from the date it came to his knowledge. closely related to the chapter concerning life annuities. would be controlling. the subject-matter of the Civil Code. completes the contract of insurance. pp. three things had to be accomplished by the insurance company before there was a contract: (1) There bad to be a medical examination of the applicant. Still it must be admitted that its enforcement avoids uncertainty and tends to security. and having thus left a void in the commercial law. then the only duty remaining is for the court to apply the law as it is found. may not be the best expression of modern commercial usage. The Civil Code rule.) In résumé. is presumed to have been entered into at the place where the offer was made. The legislature in its wisdom having enacted a new law on insurance. and (3) this approval had in some way to be 12 . The Law of Insurance. An acceptance made by letter shall not bind the person making the offer except from the time it came to his knowledge." This latter article is in opposition to the provisions of article 54 of the Code of Commerce. If no mistake has been made in announcing the successive steps by which we reach a conclusion. in such case. let it be 'noticed that it is identical with the principles announced by a considerable number of respectable courts in the United States. as the locus poenitentiæ is ended when the acceptance has passed beyond the control of the party. (2) there had to be approval of the application by the head office of the company. that according to the provisional receipt. Not only this. and expressly repealed the provisions in the Code of Commerce on the same subject. Only the mailing of acceptance. the law applicable to the case is found to be the second paragraph of article 1262 of the Civil Code providing that an acceptance made by letter shall not bind the person making the offer except from the time it came to his knowledge. that the special law on the subject of insurance is deficient in enunciating the principles governing acceptance. 235. therefore. The courts who take this view have expressly held that an acceptance of an offer of insurance not actually or constructively communicated to the proposer does not make a contract. which is incontestable. 244. therefore. but in order that the principle may not be taken too lightly. (I Joyce." On the supposition. if there be any. it has been said. In the Civil Code is found article 1262 providing that "Consent is shown by the concurrence of offer and acceptance with respect to the thing and the consideration which are to constitute the contract. The pertinent fact is. it would seem logical to make use of the only pertinent provision of law found in the Civil Code. any deficiency of the latter shall be supplied by the provisions of this Code.provides that "In matters which are governed by special laws.

properly addresse and stamped. as it could have been transmitted to him in the ordinary course of the mails. Moral turpitude. Attorney-General Feria for the Government. concur. received by the addressee as soon. J.-" Moral turpitude" includes everything which is done contrary to justice. DISBARMENT OR SUSPENSION .-The crime of abduction with consent. Johnson. 12 . The fact as to the letter of notification thus fails to concur with the essential elements of the general rule pertaining to the mailing and delivery of mail matter as announced by the American courts.communicated by the company to the applicant. J. honesty. 1920. and 49 L. pp. as punished by article 446 of the Penal Code.. ID. 2... modesty. C. or good morals. ORIGINAL ACTION in the Supreme Court. JJ. without special finding as to costs in either instance. But if any one of these elemental facts fails to appear. In re CARLOS S. did actually issue the policy and did.. A. 96. 458. when a letter or other mail matter is addressed and mailed with postage prepaid there is a rebuttable presumption of fact that it was. 1918. Araullo. and Villamor. S. [N.) We hold that the contract for a life annuity in the case at bar was not perfected because it has not been proved satisfactorily that the acceptance of the application ever came to the knowledge of the applicant.000 with legal interest from November 20. et seq. ID.]. December 7. So ordered. ATTORNEYS-AT-LAW. Judgment is reversed. R. namely. ID.. until paid. 1. BASA. through its agent in Manila. (See 22 C. it is fatal to the presumption. and the plaintiff shall have and recover from the defendant the sum of P6. involves moral turpitude. actually write the letter of notification and place it in the usual channels for transmission to the addressee. For instance. Mapa. notes. Pedro Guevara for respondent. Judgment reversed.CONVICTION OF A CRIME INVOLVING MORAL TURPITUDE. Avanceña. The further admitted facts are that the head office in Montreal did accept the application. dissents. a letter will not be presumed to have been received by the addressee unless it is shown that it was deposited in the post-office.. did cable the Manila office to that effect. J.

569." it has been said.. "includes everything which is done contrary to justice. J. 12 . admitted to the bars of California and the Philippine Islands.. therefore. Lyon [1875]. 1876 and June 15. provides that "A member of the bar may be removed or suspended from his office of lawyer by the Supreme Court by reason of his conviction of a crime involving moral turpitude The sole question presented. Araullo.. or good morals. concur. 185. The inherent nature of the act is such that it is against good morals and the accepted rule of right conduct. (In re Hopkins [1909]. he be suspended from his office of lawyer for one year. 225. honesty. section 21. it cannot admit of doubt that crimes of this character involve moral turpitude. is whether the crime of abduction with consent. 54 Wash. 91 U. J.) Although no decision can be found which has decided the exact question. to determine the exact action which should be taken by the court. del Rosario. P. involves moral turpitude. 1 The Code of Civil Procedure. cited by numerous courts. Avanceña. we do so regretfully and reluctantly. modesty. Mapa. this decision was affirmed in a judgment handed down by the second division of the Supreme Court.. I." (Bouvier's Law Dictionary. the violation of the criminal law by the respondent attorney cannot be lightly passed over. 1895. was found guilty in a decision rendered by the Honorable M. and Villamor. Atty. Judge of First Instance. decisions of the Supreme Court of Spain of November 30.. as punished by article 446 of the Penal Code. S. V. 5 Ops. C.: The Attorney-General asks that an order issue for the disbarment of Attorney Carlos S. as we must. On appeal. eleven months and eleven days of prisión correecional. Recently he was charged in the Court of First Instance of the city of Manila with the crime of abduction with consent. Carlos S. On the one hand. Basa. On the other hand.MALCOLM. and was sentenced to be imprisoned for a period of two years. So ordered. Pollard vs. It is the order of the court that beginning with the day when Carlos S. 46. Basa is a young man about 29 years of age. Respondent suspended. Basa shall be discharged from prison. "Moral turpitude. Street. JJ.) When we come next.-Gen. we are willing to strain the limits of our compassion to the uttermost in order that so promising a career may not be utterly ruined.

De Jesus-Paras vs.. Butte. ORIGINAL ACTION in the Supreme Court. R.. Isada. C. It is held that the crime of concubinage involves moral turpitude. and Diaz. was convicted of the crime of concubinage and is now serving his sentence in Bilibid Prison. Avanceña. No. Mariano Ezpeleta for respondent. Disbarment proceedings. and a member of the Philippine bar may be disbarred or suspended for conviction of this crime.1. not published.: Juan C. Vailoces April 12. Abad Santos. (In re Basa [1920]. The Code of Civil Procedure. Solicitor-General Hilado for the Government. J. MALCOLM. 275. August 10. 1934] In re JUAN C. Respondent suspended. The facts are stated in the opinion of the court. Isada November 16. Vickers. Goddard. G. J. Street.) It is the order of the court that beginning with the day when Juan C. he be suspended from his office of lawyer for one year. 41 Phil. provides that a member of the bar may be removed or suspended from his office of lawyer by the Supreme Court by reason of his conviction of a crime involving moral turpitude. Isada shall be discharged from prison.. Imperial. Hull.1961 [Adm. 439 April 12. a member of the Philippine bar. 1934 [GRN November 16. 15398. CRIMES INVOLVING MORAL TURPITUDE. ISADA ATTORNEYS-AT-LAW. JJ. SUSPENSION OR DISBARMENT. concur.-The crime of concubinage involves moral turpitude. Case No. Villa-Real. In re Juan C. in its section 21.1961] 12 . 1920.

respondent not only disputes the judgment of conviction rendered against him in the criminal case but contends that the same is based on insufficient. Ocampo & Salazar for respondent. In his answer. Vailoces was found guilty beyond reasonable doubt of the crime of falsified of public document defined and penalized. On appeal. This decision became final. with the accessories of the law. they were found gui1ty and convicted. respondent. Vailoces began serving it in the insular penitentiary. It appears that as member of the bar and in his capacity as a notary public. to 8 years 1 day of prision mayor. J. and inconclusive evidence. the charge being merely motivated by sheer vindictiveness. rendered decision denying probate to the will. Vailoces. As finally adjudged. As a consequence. malice and spite on the part of herein complainant. Disbarment. Agustin J. finding that the will was a forgery. The facts are stated in the opinion of the Court. petitioner vs. on December 14. as maximum. the will was impugned by her surviving spouse and daughter. Presented for probate before the Court of First Instance of Negros Oriental. BAUTISTA ANGELO. the Court of Appeals affirmed the decision with regard to Vailoces but modified it with regard to his co-accused. On the basis of this decision a criminal action for falsification of public document was filed against Vailoces and the three attesting witnesses to the will before the Court of First Instance of Negros Oriental where. ORIGINAL ACTION in the Supreme Court. Debuque for petitioner. acknowledged the execution of a document purporting to be the last will and testament of one Tarcila Visitacion de Jesus. This sentence having become final. Consequently. the probate court. the offended party instituted the present disbarment proceedings.: This concerns the disbarment of Quinciano Vailoces as member of the Philippine bar. QUINCIANO VAILOCES. as minimum. after trial. fine and costs. 1950. in Article 171 of the Revised Penal Code and was sentenced to suffer an indeterminate penalty ranging from 2 years 4 months and 1 day of prision correccional.LEDESMA DE JESUS-PARAS. and that to give course to this proceeding would be tantamount to placing him in double jeopardy. He pleads that the complaint be 12 .

1 Among the examples given of crimes of this nature by former Chief Justice Moran are the crime of seduction and the crime of concubinage 2 .J. Under Section 25. April 30. That is now a closed chapter insofar as this proceeding is concerned. as used in this section. for such defense can only be availed of when he is placed in the predicament of being prosecuted for the same offense. for the act is clearly contrary to justice. a member of the bar may be removed or suspended from his office as attorney if it appears that he has been convicted of a crime involving moral turpitude. all crimes of which fraud is an element are looked on as involving moral turpitude" (53 C.S. by his conviction. honesty or good morals. includes any act deemed contrary to justice. 3 Phil. of the Rules of Court. of our Rules of Court. Jaramillo. honorable and reliable. The judgment not only has become final but has been executed. Negros Oriental would be tantamount to placing him in double jeopardy is untenable. Such is not the case here." (In the Matter of Disbarment Proceedings against Narciso N. himself unfit to protect the administration of justice. As this Court well said: "The review of respondent's conviction no longer rests upon us. or for any offense necessarily included therein. Rather. swindling are crimes. which is indeed of this nature. Adm. Rule 127.. for this is a matter which we cannot now look into. the respondent has proved. The disbarment of an attorney does not partake of a criminal proceeding. 229. It is futile on his part much as we sympathize with him to dispute now the sufficiency of his conviction. Moral turpitude. honesty and good morals. Case No. Hence such crime involves moral turpitude. The crime of which respondent was convicted is falsification of public document. forgery. it is intended "to protect the court and the public from the misconduct of officers. as a general rule.dismissed. robbery. or for any attempt to commit the same or frustration thereof. The only issue with which we are concerned is that he was found guilty and convicted by a final judgment of a crime involving moral turpitude. which denote moral turpitude and. No elaborate argument is necessary to hold the respondent unworthy of the privilege bestowed on him as a member of the bar. and its purpose is "to protect the administration of justice by requiring that those who exercise this important function shall be competent. of the court" (In re Montagre and Dominguez. 1206). 1957) The plea of respondent that to disbar him now after his conviction of a crime which resulted in the deprivation of his liberty and of his office as Justice of the Peace of Bais. Rule 113. men in whom courts 12 . Rule 127. Indeed it is well-settled that "embezzlement. 588). It appearing that respondent has been found guilty and convicted of a crime involving moral turpitude it is clear that he rendered himself amenable to disbarment under Section 25. within the meaning of Section 9. Suffice it to say that..

Padilla. Acting C. G. J..R..and clients may repose confidence" (In re McDougall. Reyes. 60 Phil. L. our Clerk of Court is enjoined to erase his name from the roll of attorneys. Barrera. respondent is hereby removed from his office as attorney and.. 915. 180363 12 . B. 3 Phil. to this effect. concur. 77). 41 Phil. 1. In re Basa. Concepcion. No. Wherefore.. JJ.. J.. 275. Respondent disbarred. In re Isada. Labrador. 2. Bengzon. and Dizon.

the term “moral turpitude” first appeared in the . Justice Consuelo Ynares-Santiago. in response to the British government’s policy of sending convicts to the colonies. versus THE COMMISSION ON ELECTIONS and HERMINIO G. Promulgated: April 28.2(2) 12 In the U. petitioner. while carrying far-reaching effects. Historical Roots The term “moral turpitude” first took root under the United States (U. J.S. I. I add these views to further explore the term “moral turpitude” – a term that. embodies a concept that to date has not been given much jurisprudential focus. I fully concur with the ponencia of my esteemed colleague. respondents. State legislators at that time strongly suspected that Europe was deliberately exporting its human liabilities.. No.1(1) Its history can be traced back as far as the 17th century when the States of Virginia and Pennsylvania enacted the earliest immigration resolutions excluding criminals from America. 180363 – EDGAR Y.) immigration laws.x CONCURRING OPINION BRION. TEVES.R.S. TEVES. 2009 x ---------------------------------------------------------------------------------------.G.

the Board of Immigration Appeals ordered De George’s deportation on the basis of the Immigration Act provision that allows the deportation of aliens who commit multiple crimes involving moral turpitude. an Italian immigrant was convicted twice of conspiracy to defraud the U. De George.S.S. through Chief Justice Vinzon.S. of taxes on distilled spirits is a crime involving moral turpitude within the meaning of Section 19 (a) of the Immigration Act of 1919 (Immigration Act). De George argued that he should not be deported because his tax evasion crimes did not involve moral turpitude. in determining the measure of contribution between joint tortfeasors. 1891. Congress used the term “moral turpitude” in immigration laws. Sam De George. Supreme Court ruled on the constitutionality of the term “moral turpitude” in Jordan v. which directed the exclusion of persons who have been convicted of a felony or other infamous crime or misdemeanor involving moral turpitude. the presence of moral turpitude has been used as a test in a variety of situations.4(4) In 1951. and in deciding whether a certain language is slanderous.5(5) The case presented only one question: whether conspiracy to defraud the U.S. this marked the first time the U. the U. Subsequently.Immigration Act of March 3. Supreme Court. including legislation governing the disbarment of attorneys and the revocation of medical licenses.S.3(3) Since then. Moral turpitude also has been judicially used as a criterion in disqualifying and impeaching witnesses. government of taxes on distilled spirits. finding that “under an unbroken course of judicial 12 . The U. disagreed.

”6(6) Notably. is a crime involving moral turpitude. the crime of conspiring to defraud the U.” The legislative history of statutes containing the moral turpitude standard indicates that Congress left the interpretation of the term to U. vileness.S. xxx Act or behavior that gravely violates moral sentiment or accepted moral standards of community and is a morally culpable quality held to be present in some criminal offenses as distinguished from others. the U. or the depravity in private and social duties which man owes to his fellow man. courts and administrative agencies.S.xxx We therefore decide that Congress sufficiently forewarned respondent that the statutory consequence of twice conspiring to defraud the United States is deportation.”9(9) The most common definition of moral turpitude is similar to one found in the early editions of Black’s Law Dictionary: [An] act of baseness.8(8) In the absence of legislative history as interpretative aid. or to society in general.decisions. American courts have resorted to the dictionary definition – “the last resort of the baffled judge. 7(7) Significantly. contrary to the accepted and customary rule of right and duty between man and man.S. the term moral turpitude was first introduced in 1901 in 12 .10(10) In the Philippines.xxx Fraud is the touchstone by which this case should be judged. the Court determined that fraudulent conduct involved moral turpitude without exception: Whatever the phrase “involving moral turpitude” may mean in peripheral cases. Congress has never exactly defined what amounts to a “crime involving moral turpitude. the decided cases make it plain that crimes in which fraud was an ingredient have always been regarded as involving moral turpitude. xxx The quality of a crime involving grave infringement of the moral sentiment of the community as distinguished from statutory mala prohibita.

as punished by Article 446 of the Penal Code of 1887.20(20) and disqualification of persons from running for any elective local position. cited by numerous courts. otherwise known as the Code of Civil Actions and Special Proceedings. a lawyer.11(11) The Act provided that a member of the bar may be removed or suspended from his office as lawyer by the Supreme Court upon conviction of a crime involving moral turpitude. Basa. provided the first instance for the Court to define the term moral turpitude in the context of Section 21 of the Code of Civil Procedure on the disbarment of a lawyer for conviction of a crime involving moral turpitude. "includes everything which is done contrary to justice. Carlos S.15(15) exclusion16(16) and naturalization of aliens. The Court. 190. or good morals.17(17) discharge of the accused to be a state witness. The sole question presented was whether the crime of abduction with consent. turned to Bouvier’s Law Dictionary for guidance and held: "Moral turpitude. 12 . honesty. was convicted of the crime of abduction with consent. modesty. involved moral turpitude.19(19) suspension and removal of elective local officials. it cannot admit of doubt that crimes of this character involve moral turpitude.14(14) registration to military service.22(22) a 1920 case. the term “moral turpitude” has been employed in statutes governing disqualifications of notaries public.18(18) admission to the bar. The inherent nature of the act is such that it is against good morals and the accepted rule of right conduct.12(12) Subsequently." it has been said.13(13) priests and ministers in solemnizing marriages." (Bouvier's Law Dictionary.21(21) In Re Basa.) Although no decision can be found which has decided the exact question. finding no exact definition in the statutes.Act No.

” “nebulous. or good morals. early on. honesty. or to society in general. contrary to the accepted and customary rule of right and duty between man and woman. Problems with the Definition of Moral Turpitude Through the years. the Court has never significantly deviated from the Black’s Law Dictionary definition of moral turpitude as “an act of baseness.”25(25) In the U. II.” 28(28) 12 . the phrase “crimes involving moral turpitude” has been described as “vague. the Philippines followed the American lead and adopted a general dictionary definition.” “most unfortunate.Thus. there appears to be a universal recognition that we have here an undefined and undefinable standard. or depravity in the private duties which a man owes his fellow men.S. these same definitions have been highly criticized for their vagueness and ambiguity.. opening the way for a case-to-case approach in determining whether a crime involves moral turpitude. or conduct contrary to justice. honesty.26(26) In Jordan.” and even “bewildering. vileness. Justice Jackson noted that “except for the Court’s [majority opinion].”27(27) Thus. modesty. or good morals.”23(23) This definition is more specific than that used in In re Vinzon24(24) where the term moral turpitude was considered as encompassing “everything which is done contrary to justice.

NLRC29(29) that moral turpitude “is somewhat a vague and indefinite term. our case-by-case approach in determining the crimes involving moral turpitude. in terms of 12 . This Court itself concluded in IRRI v. it provides terms such as “baseness. Thus. or to society in general”. as the term “moral turpitude” contains the word “moral” and its direct connotation of right and wrong. the use of morality as a norm cannot be avoided. In essence. “Turpitude. directly means “depravity” which cannot be appreciated without considering an act’s degree of being right or wrong. Second. as late as 1993 in IRRI. First. moral turpitude is an act violating these duties.” “vileness.the “private and social duties which man owes to his fellow man.” and “depravity. Instead. the definition also assumes the existence of a universally recognized code for socially acceptable behavior -.” on the other hand. they are “conclusory but non-descriptive.a result that the Legislature could not have intended. or provide examples of acts which violate them. in adopting the term “moral turpitude.” necessarily adopted a concept involving notions of morality – standards that involve a good measure of subjective consideration and. the meaning of which must be left to the process of judicial inclusion or exclusion as the cases are reached” – once again confirming. the current definition of the term is broad.”30(30) To be sure. the law.” which better describe moral reactions to an act than the act itself.Criticisms of moral turpitude as an inexactly defined concept are not unwarranted. It can be stretched to include most kinds of wrongs in society -. The problem is that the definition does not state what these duties are.

given that the consequences of committing a crime involving moral turpitude can be severe. Abduction with consent37(37) 2. however. of the crimes adjudged to involve moral turpitude: 1.31(31) Third. Concubinage39(39) 4.36(36) the Court has maintained its case-by-case categorization of crimes on the basis of moral turpitude and has labeled specific crimes as necessarily involving moral turpitude. cannot be taken lightly. as a legal standard. Bigamy38(38) 3. inviting them to condemn all that we personally disapprove and for no better reason than that we disapprove it. Smuggling40(40) 12 . are far from the usual measures used in law. The following is a list. moral turpitude fails to inform anyone of what it requires.certainty and fixity.32(32) It has been said that the loose terminology of moral turpitude hampers uniformity since … [i]t is hardly to be expected that a word which baffle judges will be more easily interpreted by laymen. Crimes Categorized as Crimes Involving Moral Turpitude35(35) Since the early 1920 case of In re Basa.”34(34) This trait.33(33) This led Justice Jackson to conclude in Jordan that “moral turpitude offered judges no clearer guideline than their own consciences. not necessarily complete.

Robbery45(45) 10. Estafa through falsification of a document42(42) 7. Murder. whether consummated or attempted46(46) 11. 2250(50) 12 . Illicit Sexual Relations with a Fellow Worker49(49) 14. Rape41(41) 6. Attempted Bribery43(43) 8. Theft48(48) 13. Estafa47(47) 12. Violation of BP Bldg. Profiteering44(44) 9.5.

criminal conspiracy to smuggle opium. murder. bribery. seduction under the promise of marriage. Falsification of Document51(51) 16. estafa. Perjury55(55) 20. forgery. bigamy. rape. Violation of the Anti-Fencing Law53(53) 18. Flores59(59) is one case that has provided jurisprudence its own list of crimes involving moral turpitude. perjury. dueling. offenses against pension laws. libel. concubinage.15. mutilation of public records. Intriguing against Honor52(52) 17. and estafa thru falsification of public document. namely: 12 . blackmail.60(60) Crimes Categorized as Crimes Not Involving Moral Turpitude61(61) The Court. extortion. has also had the occasion to categorically rule that certain crimes do not involve moral turpitude. Direct Bribery57(57) 22. making fraudulent proof of loss on insurance contract. embezzlement. Frustrated Homicide58(58) Zari v. barratry. namely: adultery. arson. falsification of public document. evasion of income tax. Forgery56(56) 21. fabrication of evidence. Violation of Dangerous Drugs Act of 1972 (Drug-pushing)54(54) 19. on the other hand.

Flores66(66) where the Court saw the involvement of moral turpitude where an act is intrinsically 12 . Even a cursory examination of the above lists readily reveals that while the concept of “moral turpitude” does not have one specific definition that lends itself to easy and ready application. Indirect Contempt65(65) Approaches and Standards. conviction for speeding)62(62) Illegal recruitment63(63) Slight physical injuries and carrying of deadly weapon (Illegal possession of firearms)64(64) 4.e. The Court best expressed the first approach in Zari v. namely: from the objective perspective of the act itself.. irrespective of whether or not the act is a crime.” is the standard of depravity viewed from a scale of right and wrong. The application of this depravity standard can be made from at least three perspectives or approaches. The key element. 3.1. 2. Minor transgressions of the law (i. III. as defined through its elements. the Court has been fairly consistent in its understanding and application of the term and has not significantly deviated from what it laid down in In re Basa. directly derived from the word “turpitude. and from the subjective perspective that takes into account the perpetrator’s level of depravity when he committed the crime. from the perspective of the crime itself.

It would appear that statutes permitting gambling. this approach requires that the committed act itself be examined. the Court went on to conclude that gambling is a 12 . small bets on horse racing and the “policy or numbers games” are diversions of the masses. Thus. In established societies more or less serious attempts are everywhere made. A ruling that exemplifies this approach is that made in the U. almost inevitable.S. case In The Matter of G---67(67) where. to obviate cheating and other corrupt practices that may result if uncontrolled. regardless of whether it is punishable by law or not. however. That such enterprises exist surreptitiously is a matter of common knowledge. highly reputable according to prevailing social standards. Present-day movements to suppress gambling are also tinged with other considerations. divorced from its characterization as a crime. rest primarily on the theory that they are in the interest of public policy: that is to regulate and restrict any possible abuse. The Court emphasized that moral turpitude goes beyond being merely mala prohibita. and at later dates antigambling laws were aimed especially at the activity as practiced by the working classes. Many countries permit it under a license system. From this discussion. in considering gambling. Card playing for small stakes is a common accompaniment of social life. with sharp practice. it was held that: Gambling has been in existence since time immemorial. the act itself must be inherently immoral. Prohibition against gambling has had something of a police rather than a truly penal character. to prohibit or to regulate gambling in its more notorious forms. such as those under discussion. At all times an important fact in arousing antagonism in gambling has been the association. have come more and more to resemble it.immoral. In ancient times laws were enacted to discourage people from gambling on the theory that the State had first claim upon their time and energy. In urban communities in the past few decades the purely religious opposition to gambling has tended to become less violent because certain activities.

In his subsequent plea for reinstatement. apparently drawing on what society deems important. the Court strongly denounced drug possession as an “especially vicious crime. held that the use of drugs amounted to an act so inherently evil that no law was needed to deem it as such.malum prohibitum that is not intrinsically evil and.” The Court. Likewise. a Deputy Sheriff in MTCC Iligan City was convicted of possession of “shabu.”70(70) In People v. but with a different result. Librado. they become a grave menace to the safety of law abiding members of society. The Office of the Court Administrator commenced an administrative case against him and he was subsequently suspended from office. what is worse. it is an evil without need for a law to call it evil69(69) .68(68) a case involving drug possession. is Office of the Court Administrator v. Yambot. one of the most pernicious evils that has ever crept into our society… For those who become addicted to it not only slide into the ranks of the living dead. Librado.“an immoral act in itself regardless of whether it is punishable or not.71(71) the Court categorically ruled that the possession of a deadly weapon does not involve moral turpitude since the act of carrying a weapon by itself is not inherently wrong in the absence of a law punishing it. With the same approach. is not a crime involving moral turpitude. thus. the Court acknowledged in Court Administrator v. San Andres72(72) that illegal recruitment does not involve moral turpitude since it is not in itself an evil act – being 12 .” a prohibited drug.

i..” This is the same conclusion that the U. Laguna on the basis of his conviction for violation of Presidential Decree No.S. The Court ruled that moral turpitude is deducible from the third element. In Paras v. Dela Torre was disqualified by the Comelec from running as Mayor of Cavinti. that crimes requiring fraud or intent to defraud always involve moral turpitude. Supreme Court made in Jordan. are crimes of moral turpitude. Dela Torre appealed to this Court to overturn his disqualification on the ground that the crime of fencing is not a crime involving moral turpitude. otherwise known as the Anti-Fencing Law.74(74) Dela Torre v.73(73) the Court recognized that as a “general rule. all crimes of which fraud is an element are looked on as involving moral turpitude. Vailoces. Actual knowledge by the fence of the fact that property received is stolen displays the same degree of malicious deprivation of one’s rightful property as that which animated the robbery or theft which. by their very nature. To be sure.e. the elements of the crime can be a critical factor in determining 12 . The second approach is to look at the act committed through its elements as a crime.ordinarily an act in the ordinary course of business – in the absence of the a law prohibiting it. 1612. Commission on Elections75(75) is a case in point that uses the second approach and is one case where the Court even dispensed with the review of facts and circumstances surrounding the commission of the crime since Dela Torre did not assail his conviction.

denotes a malicious intent on the part of the offender to renege on the duties which he owes his fellowmen and society in general. held that the “presence of the second element manifest moral turpitude” in that “a drawer who issues an unfunded check deliberately reneges on his private duties he owes his fellow men or society in a manner contrary to accepted and customary rule of right and duty. justice. essentially takes the offender and his acts into account in light of the attendant circumstances of the crime: was he motivated by ill will indicating depravity? The Court apparently used this approach in Ao Lin v.78(78) a 1964 case. thus: Moral turpitude can be inferred from the third element. the fact that the offender takes advantage of his office and position is a betrayal of the trust reposed on him by the public. the subjective approach. In Villaber v. by analyzing the elements alone of the offense under Batas Pambansa Blg.moral turpitude if the second approach is used in the crimes listed above as involving moral turpitude. Commission on Elections. justice. 22.77(77) when it ruled that direct bribery involves moral turpitude. when it held “that the use of a meter stick without the corresponding seal of the Internal Revenue Office by one who has been engaged in business for a long time. not necessarily because the 12 . honesty and good morals. Commission on Elections. The fact that the offender agrees to accept a promise or gift and deliberately commits an unjust act or refrains from performing an official duty in exchange for some favors. Republic. It is a conduct clearly contrary to the accepted rules of right and duty. direct bribery is a crime involving moral turpitude. In all respects. [Emphasis supplied] The third approach. involves moral turpitude because it involves a fraudulent use of a meter stick. honesty or good morals.” The same conclusion was reached by the Court in Magno v. Also.76(76) the Court.

immoral or unjust. Moral turpitude is not involved in every criminal act and is not shown by every known and intentional violation of statute. plus the total absence of any aggravating circumstances demonstrate that Micosa’s character and intentions were not inherently vile. but the need for the appreciation of facts in considering whether moral turpitude exists – an unavoidable step under the third approach. The Court refused to characterize the crime of homicide as one of moral turpitude in light of the circumstances of its commission. not only the subjective element. The Court stressed. but because it manifests an evil intent on the part of the petitioner to defraud customers purchasing from him in respect to the measurement of the goods purchased. too. but whether any particular conviction involves moral turpitude may be a question of fact and frequently depends on all the surrounding circumstances. NLRC. The Court ruled: These facts show that Micosa’s intention was not to slay the victim but only to defend his person.” In IRRI v. The appreciation in his favor of the mitigating circumstances of self-defense and voluntary surrender. Homicide may or may not involve moral turpitude depending on the degree of the crime.Government is cheated of the revenue involved in the sealing of the meter stick. the Court explained: This is not to say that all convictions of the crime of homicide do not involve moral turpitude. [italics supllied]. Thus. [Emphasis supplied] 12 .79(79) the International Rice Research Institute terminated the employment contract of Nestor Micosa on the ground that he has been convicted of the crime of homicide – a a crime involving moral turpitude.

the circumstances clearly evince the moral turpitude of respondent and his unworthiness to practice law. Manuel Dizon alleging that the crime of frustrated homicide involves moral turpitude under the circumstances surrounding its commission. he acted like a god on the road. while IRRI refused to characterize the crime of homicide as one of moral turpitude. the crime of frustrated homicide committed by the respondent involved moral turpitude. Dizon80(80) held that based on the circumstances. In the tenacity with which he pursued complainant. Clearly. respondent wrapped the handle of his gun with a handkerchief so as not to leave fingerprints. Dizon when the latter unexpectedly shot him. the recent case of Soriano v. respondent revealed his extreme arrogance and feeling of self-importance. As it were. The Court after noting the factual antecedents of IRRI held that – The present case is totally different. those were reasonable actions clearly intended to fend off the lawyer’s assault. the unarmed complainant was merely returning the eyeglasses of Atty. Dizon was definitely the aggressor. The act of aggression shown by respondent will not be mitigated by the fact that he was hit once and his arm twisted by complainant. who deserved to be venerated and never to be slighted. under the impression that the assault was already over. his inordinate reaction to a simple traffic incident reflected poorly on his fitness to be a member of the legal profession. By his conduct.In contrast. His overreaction also evinced vindictiveness. As the IBP correctly found. complainant Soriano filed a disbarment case against respondent Atty. To make matters worse. In Soriano. In so doing. Under the circumstances. as he pursued and shot complainant when the latter least expected it. and was a sufficient ground for his disbarment under Section 27 of Rule 138 of the Rules of Court. more so in a lawyer. The totality of the facts unmistakably bears the earmarks of moral turpitude. he betrayed his sly intention to escape punishment for his crime. In fact. Atty. He shot the victim when the latter was not in a position to defend himself. we see not the persistence of a 12 . which was definitely an undesirable trait in any individual. We also consider the trial court’s finding of treachery as a further indication of the skewed morals of respondent.

We are not in a position to say whether or not the previous conviction of malicious mischief proves that accused had displayed the baseness.85(85) [Emphasis supplied] Thus.person who has been grievously wronged. since he has been previously convicted of the crime of malicious mischief – a crime involving moral turpitude. Jamero84(84) where the Court disregarded the appellants’ argument that the trial court erred in ordering the discharge of Inocencio Retirado from the Information in order to make him a state witness. Tinio. We should not make haste in declaring that such crime involves moral turpitude without determining. but the obstinacy of one trying to assert a false sense of superiority and to exact revenge. Another subjective element case.82(82) expressed in terms of the protection of the sanctity of marriage.81(81)[Emphasis supplied] Laguitan v. any deliberate act (not constituting arson or other crimes involving destruction) causing damage in the property of another. And considering that under paragraph 3 of Article 329 of the Revised Penal Code. In sum. again. the need for a factual determination was considered necessary. a survey of jurisprudence from the earliest case of In Re Basa86(86) to 12 . The Court said: In the absence of any evidence to show the gravity and the nature of the malicious mischief committed. is People v.83(83) also necessarily looked at the subjective element because the offender’s concubinage involved an assault on the basic social institution of marriage. in terms of looking at the damage wrought by the offender’s act. the vileness and the depravity which constitute moral turpitude. the value of the property destroyed and/or the circumstances under which the act of destroying was committed. at least. may constitute the crime of malicious mischief.

mere possession by a public officer of pecuniary interest in a cockpit was not expressly prohibited. at its core. if possible. IV. objectively. This bit of history alone is an indicator that. . although not without controversy. but used the same standard or measure – the degree of attendant depravity. The Approaches Applied to TEVES The Objective Approach The crime for which petitioner Teves was convicted (possession of pecuniary or financial interest in a cockpit) is. and to evaluate the results from each of the approaches. . is generally regarded to be within acceptable moral limits.88(88) judicial notice can be taken of state-sponsored gambling activities in the country that. The safest approach to avoid being misled in one’s conclusion is to apply all three approaches. The ponencia correctly noted that prior to the enactment of the Local Government Code of 1991. makes such possession of interest 12 . as a conclusion of moral turpitude invariably signifies a worse consequence for him or her. related to gambling – an act that by contemporary community standards is not per se immoral. A useful caveat in the evaluation is to resolve any doubt in favor of the perpetrator. This reasoning led the ponencia to conclude that “its illegality does not mean that violation thereof . Dizon 87(87) shows that the Court has used varying approaches. Other than the ruling heretofore cited on this point.the recent case of Soriano v. no essential depravity is involved even from the standards of a holder of a public office.

inherently immoral.”89(89) From the Perspective of the Elements of the Crime Under this approach. contract or transaction. and 3. The Subjective Approach 12 . honesty and good morals. justice. 2. This element shows that the holding of interest that the law covers is not a conduct clearly contrary to the accepted rules of right and duty. He is prohibited from having such interest by the Constitution or any law. The essential elements of the offense of possession of prohibited interest (Section 3(h) of the Anti-Graft Law) for which the petitioner was convicted are: 1. He has a direct or indirect financial or pecuniary interest in any business. Thus. it is illegal solely because of the prohibition that exists in law or in the Constitution. From the perspective of moral turpitude. no depravity immediately leaps up or suggests itself based on the elements of the crime committed. The accused is a public officer. we determine whether a crime involves moral turpitude based solely on our analysis of the elements of the crime alone. the third element is the critical element.

all three approaches point to the conclusion that no moral turpitude was involved in the crime Teves committed. results in clear and easily appreciated conclusions. is the clinching argument that no moral turpitude can be involved as no depravity can be gleaned where intent is clearly absent. not that he hid this interest by transferring it to his wife. The ponencia significantly noted. with the predominant reasons being the first (or objective) and the third (or subjective) approaches. but due simply to Teves’ lack of awareness or ignorance of the prohibition. the ponencia firstly considered that the petitioner did not use his official capacity in connection with the interest in the cockpit. as it expressly stated that “a determination of all surrounding circumstances of the violation of the statute must be considered. with one approach reinforcing another. ARTURO D. BRION Associate Justice 12 . Conclusion To recapitulate. Analysis in this manner. that the violation was not intentionally committed in a manner contrary to justice. or good morals. as the transfer took effect before the effectivity of the law prohibiting the possession of interest. in my view. modesty.This approach is largely the ponencia’s approach. This.”90(90) In doing this. too.

12 .

12 (Popup . 3613. Rule 138. 813. Section 27.Popup) Id. Rule 138. 11 (Popup . 227 (1951).Popup) Id. 5 (Popup .Popup) 12 . 341 U. Harms. 337.J.Popup) ACT NO. Rule 119. 7160.Popup) Id.Popup) Id. 16 (Popup . Section 29. 8 (Popup . December 21. 3 (Popup . Section 4. 1983. 14 (Popup . 15 GEO. 2 (Popup .Popup) Id. 15 (Popup . 259. 7 (Popup . 10 (Popup . 229. 261 (2001). March 10. De George.Popup) RULES OF COURT.J. 816 (2008). Section 60. June 17. L.Popup) COMMONWEALTH ACT No.Popup) Now RULES OF COURT. Section 2..Popup) Brian C. p. January 1. 1929. 1. 9 (Popup . 1939. 41 CORNELL INT’L L. p. Section 17. August 26.Popup) COMMONWEALTH ACT No.Popup) Derrick Moore. 1940. 20 (Popup . December 4.Endnotes 1 (Popup . 1992. Section 60. 223. Section 45.Popup) BATAS PAMBANSA BLG.S. 1935. 17 (Popup . 1901.Popup) Effective September 1.. 19 (Popup . 4 (Popup . Redefining “Crimes of Moral Turpitude”: A Proposal to Congress. 2711. “Crimes Involving Moral Turpitude”: Why the Void-For-Vagueness Argument is Still Available and Meritorious.Popup) COMMONWEALTH ACT No. 1917. 18 (Popup .Popup) REVISED RULES OF CRIMINAL PROCEDURE. 6 (Popup . 21 (Popup . Section 234. 13 (Popup .Popup) ACT NO. IMMIGR. 227. p.Popup) Jordan v. REPUBLIC ACT NO. 232. February 10.Popup) Id.Popup) Supra note 1. 473. Section 57. 613.

1992.Popup) 12 . 24 (Popup . 561. No.Popup) Supra note 8. April 27.) citing Interstate Circuit.Popup) 41 Phil. 476 (1957).” Geoffrey R.Popup) Supra note 1. Miller v. p. 35 (Popup . 10 LEWIS & CLARK L. 676.S. p. p. 235.Popup) Cited in Rafael Christopher Yap. No. 816.Popup) G. L. REPUBLIC ACT NO. citing Zari v. 323 (1979).Popup) Nate Carter. 27 (Popup . 881. 390 U. p. Dallas. Section 12. 22 (Popup .Popup) Supra note 30. Supreme Court rulings. 34 (Popup .S. 1967. July 5. Inc. p. 19 SCRA 815. 813. v. 20-21. 94 SCRA 317. Slaton. 275.Popup) G.” whose standards have been in continuous development in U.S.R.S. pp. 258 SCRA 483. 31 (Popup . 22 as a Crime of Moral Turpitude (2006). 705 n. 487.1 (1968) (Harlan. 121 (1930). Ateneo de Manila University).R. 97239. p..D. 13 (unpublished J. 959 (2006). 121592. Bouncing Doctrine: Re-Examining the Supreme Court’s Pronouncements of Batas Pambansa Blg. No. United States.Popup) Dela Torre v. California. 1985. 955. 276 (1920). 704-705.R. 413 U. 36 (Popup . Commission on Elections. 242. J. on file with the Professional Schools Library. 37 (Popup .Popup) A similar concept is “obscenity. 32 (Popup . 117.Popup) Supra note 25. 33 (Popup .Popup) Supra note 22. 1255. 26 (Popup . California.. REV. Albert v. January 1. Flores. 814. 15 (1973) and Paris Adult Theatre I v. Constitutional Law.Popup) Supra note 8. Justice Harlan observed that “[t]he subject of obscenity has produced a variety of views among the members of the Court unmatched in any other course of constitutional adjudication. 49 (1973). G. REV. Justice Harlan noted that in the thirteen obscenity cases decided in the decade after Roth. 221 SCRA 760. 354 U.S. 1993. Ateneo de Manila University. 43 HARV. 959.Popup) Supra note 8. dissenting). Stone et al. May 12. See Roth v. Only a decade after Roth. Crimes Involving Moral Turpitude.BATAS PAMBANSA BLG.” As evidence. 413 U. Section 40. 23 (Popup . 7160. thesis. December 3. 30 (Popup . there were “a total of 55 separate opinions among the Justices. 1996. (1996 ed. p. 29 (Popup .Popup) Supra note 1. Shocking The Conscience of Mankind: Using International Law To Define “Crimes Involving Moral Turpitude” In Immigration Law. citing Note. 28 (Popup . 25 (Popup .

C. July 31. 106 Phil. 424 SCRA 42 citing Laguitan v. A. 1996. April 24. Librado. 119332. April 12.Popup) Betguen v. 208 SCRA 174. 369 SCRA 126. 1994. Silvosa. 56 (Popup . A. 106 Phil 1 (1959).148326.Popup) 12 .M. Robert W. Macarrubo v. 260 SCRA 624. Case No. No.. April 20.Popup) Philippine Long Distance Telephone Company v.Popup) Id.Popup) In Re Marcelino Lontok. 89454. 2001. August 22.Popup) In Re Dalmacio De Los Angeles. 48 (Popup . Villaber v. Campilan Jr.Popup) In Re Atty. Tuanda. 1997. G. No. Adm. 19 SCRA 815. 278 SCRA 368. No. No. 1992.Popup) Tak Ng v. 3049.C. 1967. Vinzon. 439. Civil Service Commission. Paolo C. A. 238 SCRA 475. November 27. 57 (Popup . National Labor Relations Commission.R. 166 SCRA 422. 39 (Popup .R. No. December 1. 1962.Popup) Can v. G. No. 6148. No. 40 (Popup . Commission on Elections. Atty. 51 (Popup . 92 Phil. 43 Phil. 381 SCRA 494. 5916.C.Popup) People v.Id. No.M. 60 Phil 915 (1934). 155 SCRA 663 citing In Re Gutierrez. MTJ-96-1100.Popup) Supra note 23 at 483. Macarrubo. 97 Phil.Popup) People v. L-363. 50 (Popup . Galing. L-54258. Tranquilino Rovero. 2003.R. December 4. Vailoces. 128 (1952). 41 (Popup .Popup) In Re: Atty. No. Case No. Selwyn F. 1989. A. 53 (Popup .Popup) In Re Juan C. 49 (Popup . 2002. Admin.M. February 27. November 15. Adm. Lao v. 1961. 43 (Popup . 3360. 2004. P-93-822. Isidro P. Medel. 52 (Popup .R.Popup) In the Matter of Eduardo A. July 1.Popup) Campilan v.1182 (1958). Abesamis. 54 (Popup . Isada. G. No. 561. 727 (1959). April 27. Case No. No. 179 SCRA 837. 47 (Popup . 1990. 38 (Popup . 45 (Popup . 42 (Popup .R. No.Popup) University of the Philippines v. 102 Phil. Sorrel. 1988. 5 SCRA 661.M. January 30. 55 (Popup .Popup) Office of the Court Administrator v. 1 SCRA 954. L-63652 October 18. Masangcay. P-94-1089. 46 (Popup .Popup) Mondano v. 44 (Popup . 1987. G. 405 SCRA 227. G. A. A. Republic of the Philippines. 181 SCRA 692. August 29. 143 (1955). 293 (1922).Popup) Paras v. A. Tinio.

147904. 197 SCRA 704. No. 343 SCRA 20. 63 (Popup . San Andres. G. p. De Vera.Popup) Garcia v. A. 75 (Popup . 1979. 12 . p.Popup) Soriano v. 70 (Popup .Popup) Supra note 64. November 21. 61 (Popup . 78 (Popup . 66 (Popup . A. January 30. 418 SCRA 27.Popup) People v. Dizon. 2002. 484 (1959). 64 (Popup . p. 60 (Popup . 58 (Popup . 323. May 31. 2003.Popup) 1 I.C. No. 6792. 62 (Popup .M.Magno v. 59 (Popup .R. 2000. Republic. 73 (Popup . 74 (Popup . 23. 67 (Popup . 390 SCRA 495. No. 103 Phil.Popup) Supra note 57.Popup) Supra note 25. 69 (Popup . January 25. December 11. 72 (Popup . 1964.Popup) Supra note 1. 120350.Popup) Supra note 59. p. No. A. 228. October 13.Popup) Supra note 45.Popup) Id. 94 SCRA 317. 59.Popup) Supra note 54.Popup) Ng Teng Lin v. No. L-18506. G.Popup) Court Administrator v.Popup) Adm.Popup) Supra note 59. No. 323. 1941 WL 7913 (BIA). Yambot. 79 (Popup .Popup) Supra note 50. Dec. 77 (Popup . & N.R. 76 (Popup . (2170-MC) P-1356. Commission on Elections. 1991. October 4. 2006.Popup) G.C.Popup) Supra note 29. 71 (Popup . 134.Popup) Supra note 23. 6052. 65 (Popup .R. P-89-345.Popup) Supra note 25 at 21. No. 480 SCRA 1. 68 (Popup . 10 SCRA 27.Popup) Supra note 63.

Popup) G. 89 (Popup . 81 (Popup ..Popup) Supra note 58. p.Popup) Supra note 39. 88 (Popup . No.R.Popup) Supra note 25. 87 (Popup . 24 SCRA 206. pp.Popup) Supra note 58. p. pp. July 29. p. 1968.Popup) Id. 245-246. L-19852. 7.. 10-11.Popup) Supra note 22.Popup) Id.Popup) Supra note 67. 83 (Popup . 9. 90 (Popup .Popup) Supra note 58. 85 (Popup . 24. 12 .Popup) Ponencia. 82 (Popup . 86 (Popup . 84 (Popup .80 (Popup .

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