Santiago v Bautista

Facts: Petitioner is a sixth grader graduating with the honor rank of third place. His parents
thereafter filed a suit against the screening committee of said school claiming that their son
should have been ranked first place.
Issue: W/N the said screening committee is one of the quasi-judicial bodies that the Court has
jurisdiction over.
Held: no, the so called committee on the rating of students for honor whose actions are
questioned in this case exercised neither judicial nor quasi judicial functions in the performance
of its assigned task. From the above-quoted portions of the decision cited, it will be gleaned that
before tribunal board, or officer may exercise judicial or quasi judicial acts, it is necessary that
there be a law that give rise to some specific rights of persons or property under which
adverse claims to such rights are made, and the controversy ensuing therefrom is brought, in
turn, before the tribunal, board or officer clothed with power and authority to determine what
that law is and thereupon adjudicate the respective rights of the contending parties. As pointed
out by appellees, however, there is nothing on record about any rule of law that provides that
when teachers sit down to assess the individual merits of their pupils for purposes of rating
them for honors, such function involves the determination of what the law is and that they are
therefore automatically vested with judicial or quasi judicial functions. Worse still, this Court has
not even been appraised by appellant of the pertinent provisions of the Service Manual of
Teachers for Public Schools appellees allegedly violated in the composition of the committee
they constituted thereunder, and, in the performance of that committee's duties.

Noblejas v Teehankee

Facts: Noblejas was the Commissioner of Land Registration, after being suspended by the
Executive Secretary, petitioner now alleges that it is only the Supreme Court who will be able to
investigate and penalize him as the Commissioner of Land Registration due to the fact that he
exercises Judicial Functions and can be considered as a judge of First Instance.
Issue: whether the Commissioner of Land Registration may only be investigated by the Supreme
Court
Held: No. First to militate against petitioner's stand is the fact that section 67 of the Judiciary Act
providing for investigation, suspension or removal of Judges, specifically recites that "No District
Judge shall be separated or removed from office by the President of the Philippines unless
sufficient cause shall exist in the judgment of the Supreme Court . . ." and it is nowhere claimed,
much less shown, that the Commissioner of Land Registration is a District Judge, or in fact a
member of the Judiciary at all.
If the Legislature had really intended to include in the general grant of "privileges" or
"rank and privileges of Judges of the Court of First Instance" the right to be investigated by the
Supreme Court, and to be suspended or removed only upon recommendation of that Court,
then such grant of privileges would be unconstitutional, since it would violate the fundamental
doctrine of separation of powers, by charging this court with the administrative function of
supervisory control over executive officials, and simultaneously reducing pro tanto the control
of the Chief Executive over such officials.
Manila Electric Company v. Pasay Transportation Company
Facts: the Manila Electric Company, requesting the members of the Supreme Court,
sitting as a board of arbitrators, to fix the terms upon which certain transportation companies
shall be permitted to use the Pasig bridge of the Manila Electric Company and the compensation
to be paid to the Manila Electric Company by such transportation companies, relates to the
validity of section 11 of Act No. 1446 and to the legal right of the members of the Supreme
Court, sitting as a board of arbitrators, to act on the petition.
Section 11 of the Act provides: "Whenever any franchise or right of way is
granted to any other person or corporation, now or hereafter in existence, over portions of the
lines and tracks of the grantee herein, the terms on which said other person or corporation shall
use such right of way, and the compensation to be paid to the grantee herein by such other
person or corporation for said use, shall be fixed by the members of the Supreme Court, sitting
as a board of arbitrators, the decision of a majority of whom shall be final."
Issue: W/N the ourt may sit as Board of arbritrators
Held:No. We run counter to this dilemma. Either the members of the Supreme Court,
sitting as a board of arbitrators, exercise judicial functions, or the members of the Supreme
Court, sitting as board of arbitrators, exercise administrative or quasi judicial functions. The first
case would appear not to fall within the jurisdiction granted the Supreme Court. Even conceding
that it does, it would presuppose the right to bring the matter in dispute before the courts, for
any other construction would tend to oust the courts of jurisdiction and render the award a
nullity. But if this be the proper construction, we would then have the anomaly of a decision by
the members of the Supreme Court, sitting as a board of arbitrators, taken therefrom to the
courts and eventually coming before the Supreme Court, where the Supreme Court would
review the decision of its members acting as arbitrators. Or in the second case, if the functions
performed by the members of the Supreme Court, sitting as a board of arbitrators, be
considered as administrative or quasi judicial in nature, that would result in the performance of
duties which the members of the Supreme Court could not lawfully take it upon themselves to
perform. The present petition also furnishes an apt illustration of another anomaly, for we find
the Supreme Court as a court asked to determine if the members of the court may be
constituted a board of arbitrators, which is not a court at all.
Just as the Supreme Court, as the guardian of constitutional rights, should not sanction
usurpations by any other department of the government, so should it as strictly confine its own
sphere of influence to the powers expressly or by implication conferred on it by the Organic Act.
The Supreme Court and its members should not and cannot be required to exercise any power
or to perform any trust or to assume any duty not pertaining to or connected with the
administering of judicial functions.
Director of Prisons v. Ang Cho Kio
Respondent was a convicted felon in the Philippines who was granted provisional
pardon by the President with a condition of never coming back to the country, on a connecting
flight from Taiwan to the United States Respondents route included the Philippines. Upon
arriving here he decided to stay longer with some of his friends, while seeking for the extension
of his stay in the Philippines from the bureau of Immigration he was arrested and immediately
recommitted to prison by the secretary of justice for violation of his pardon, respondent then
filed for petition for habeas corpus which was dismissed by the CFI, at the CA affirmed the
decision of the CFI but contained a recommendation to allow him to leave the country.
Issue: W/N the CA may make a recommendation in its decision.
Held: No. The case before the Court of Appeals was for habeas corpus. The only
question to be resolved by the Court of Appeals was whether, or not, the Court of First Instance
of Rizal, had rightly dismissed the petition of Ang Cho Kio for habeas corpus. The Court of
Appeals was not called upon to review any sentence imposed upon Ang Cho Kio.
" When the Chief Executive, exercising his powers pursuant to Section 64(i) of the
Revised Administrative Code, ordered Ang Cho Kio recommitted to prison, it is assumed that the
Chief Executive had decided that Ang Cho Kio should be dealt with that way under the
circumstances. For the court to suggest to the Chief Executive to modify his decision to
recommit Ang Cho Kio to prison by allowing him to leave the country instead is indeed to
interfere with the functions of the Chief Executive. Under the principle of separation of powers,
it is not within the province of the judiciary to express an opinion, or express a suggestion, that
would reflect on the wisdom or propriety of the action of the Chief Executive on matters purely
political in nature.
In Re Laureta
Facts: Atty. Laureta was suspended by the Court for having contemptuous statements
against the Court. He now alleges of violation of his right and due process of law for not having
conducted a hearing to hear his side.
Issue: W/N rights of the petitioner was violated.
Held:No. The word "hearing" does not necessarily connote a "trial-type" proceeding. In
the show-cause Resolution of this Court, dated January 29, 1987, Atty. Laureta was given
sufficient opportunity to inform this Court of the reasons why he should not be subjected to
dispose action. His Answer, wherein he prayed that the action against him be dismissed,
contained twenty-two (22) pages, double spaced.
Marcos v. Manglapus
FACTS: This case involves a petition of mandamus and prohibition asking the court to order the
respondents Secretary of Foreign Affairs, etc. To issue travel documents to former Pres. Marcos
and the immediate members of his family and to enjoin the implementation of the President's
decision to bar their return to the Philippines. Petitioners assert that the right of the Marcoses
to return in the Philippines is guaranteed by the Bill of Rights, specifically Sections 1 and 6. They
contended that Pres. Aquino is without power to impair the liberty of abode of the Marcoses
because only a court may do so within the limits prescribed by law. Nor the President impair
their right to travel because no law has authorized her to do so.
They further assert that under international law, their right to return to the Philippines is
guaranteed particularly by the Universal Declaration of Human Rights and the International
Covenant on Civil and Political Rights, which has been ratified by the Philippines.
ISSUE: Whether or not, in the exercise of the powers granted by the constitution, the President
(Aquino) may prohibit the Marcoses from returning to the Philippines.
HELD: "It must be emphasized that the individual right involved is not the right to travel from
the Philippines to other countries or within the Philippines. These are what the right to travel
would normally connote. Essentially, the right involved in this case at bar is the right to return to
one's country, a distinct right under international law, independent from although related to the
right to travel. Thus, the Universal Declaration of Human Rights and the International Covenant
on Civil and Political Rights treat the right to freedom of movement and abode within the
territory of a state, the right to leave the country, and the right to enter one's country as
separate and distinct rights. What the Declaration speaks of is the "right to freedom of
movement and residence within the borders of each state". On the other hand, the Covenant
guarantees the right to liberty of movement and freedom to choose his residence and the right
to be free to leave any country, including his own. Such rights may only be restricted by laws
protecting the national security, public order, public health or morals or the separate rights of
others. However, right to enter one's country cannot be arbitrarily deprived. It would be
therefore inappropriate to construe the limitations to the right to return to ones country in the
same context as those pertaining to the liberty of abode and the right to travel.
The Bill of rights treats only the liberty of abode and the right to travel, but it is a well
considered view that the right to return may be considered, as a generally accepted principle of
International Law and under our Constitution as part of the law of the land.
The court held that President did not act arbitrarily or with grave abuse of discretion in
determining that the return of the Former Pres. Marcos and his family poses a serious threat to
national interest and welfare. President Aquino has determined that the destabilization caused
by the return of the Marcoses would wipe away the gains achieved during the past few years
after the Marcos regime.
The return of the Marcoses poses a serious threat and therefore prohibiting their return to the
Philippines, the instant petition is hereby DISMISSED
US vs. Nixon
Facts: This case occurred in the midst of the Nixon Watergate scandal. The prosecutor assigned
to the case had subpoenaed the Presidents recordings of his office visits/conversations/phone
conversations. The attorney for the President argued that the tapes should not be subpoenaed
because they were granted executive privilege. Furthermore, the Presidents attorney argued to
the court that the issue was not a matter for the Supreme Court because it was a dispute within
the executive branch; the Supreme Court can only properly hear cases where there is a dispute
between branches.
Issue: Whether the President can quash a subpoena via executive privilege under any condition.
Held: No, held. Citizens have the right under Amendments 4 and 5 of the constitution to face
their accusers and have fair and speedy trials, even when bringing claims against the President
of the United States. While the President is not any other citizen, the court must balance the
executive privilege interest with the interest of the individual citizen under Amendments 4 and
5. In so doing, the court should review the privileged material the tapes in this case in their
private chambers and balance such interests. In the instant case, interest claimed by the
President was not sufficient to outweigh that of the individual citizens. Therefore, the tapes
were subpoenaed.
Rule: Balancing test weighs the importance of the general privilege of confidentiality of
Presidential communications in performance of the President's responsibilities against the
inroads of such a privilege on the fair administration of criminal justice.
Salud v. Alumbres
Facts: Pastor Salud filed a Letter Complaint with the OCA praying that the respondent judge be
found administratively liable for delay in rendering judgment in Civil Case No. LP-96-300. The
Salud spouses claimed that the RTC had the period from May 1997 to August 1997 to decide
Civil Case No. LP-96-300, but had not resolved the matter. They likewise pointed to another case
pending before the respondent, where the litigants had been waiting at least six (6) months for
the courts judgment. The complainants herein asked the OCA to look closely at the docket of
respondent judges sala, as they were of the belief that several cases ripe for decision remained
unacted upon. Respondent points out that despite the pendency of the administrative case
against him, he was nevertheless able to render a decision, albeit delayed by 16 months. He
now submits that given this development, he should be exempted from and relieved of any
liability. In addition, Judge Alumbres submits that more than one (1) year has lapsed since the
case was decided and he no longer has any jurisdiction over Civil Case No. LP-96-300. Hence, he
should not be ordered to explain matters no longer within his jurisdiction and competence.[19]
Lastly, Judge Alumbres attributes the filing of the administrative case against him to the
unfavorable decision he rendered against complainant in the unlawful detainer case. He cites
complainant as a classic example of a disgruntled litigant.
Issue: W/N there was delay in rendering the decision.
Held: Yes. It is not disputed that it took respondent judge over 16 months to render his decision
in Civil Case No. LP-96-300 after it was submitted for decision. The Constitution mandates lower
court judges to decide a case within ninety (90) days from its submission. Likewise, the Code of
Judicial Conduct mandates judges to administer justice without delay and directs every judge to
dispose of the courts business promptly within the period prescribed by the law and the rules.
We have emphasized strict observance of this duty in order to minimize, if not totally eradicate,
the twin problems of congestion and delay that have long plagued our courts. It is an oft-
repeated maxim that justice delayed is often justice denied. Thus, any delay in the
administration of justice, no matter how brief, may result in depriving the litigant of his right to
a speedy disposition of his case. Delay ultimately affects the image of the judiciary. Failure to
comply with the mandate of the Constitution and of the Code of Judicial Conduct constitutes
serious misconduct, which is detrimental to the honor and integrity of a judicial office. Inability
to decide a case despite the ample time prescribed is inexcusable, constitutes gross inefficiency,
and warrants administrative sanction of the defaulting judge.
Samson v. Mejia
Facts: Complainant alleged that she is the defendant in Civil Case No. A-2274, entitled Dorothy
M. Cabal, et al. vs. Dominador Cabal and Evangeline C. Samson for annulment of contracts,
pending before respondents court. On April 26, 2000, the case was deemed submitted for
decision. Four months passed and still, respondent had not rendered his decision, prompting
her to file three motions for resolution dated August 18, 2000, November 3, 2000 and January 9,
2001.
Three months later, complainant, dismayed by respondents inaction, went to his office and
pleaded for the early disposition of the case. However, respondent ignored her plea and even
suggested that she settle the case amicably with the plaintiffs. This convinced complainant that
respondent purposely withheld his decision in the subject case to pressure her to enter into a
compromise agreement with the plaintiffs. Further He also explained that he was then suffering
from the untimely demise of his daughter.
Issue: W/N respondent had valid reason to delay in giving the resolution
Held: No. Article VIII, Section 15 (2) of the Constitution requires judges of lower courts to decide
cases or resolve matters within three months from the date they are submitted for decision or
resolution. Under Administrative Circular No. 28, a case is considered submitted for decision
upon the admission of the evidence of the parties at the termination of the trial. The ninety-
day period for deciding the case shall commence to run from submission of the case for decision
without memoranda; in case the court requires or allows its filing, the case shall be considered
submitted for decision upon the filing of the last memorandum or upon the expiration of the
period to do so, whichever is earlier.
While we commiserate with respondent for the untimely death of his daughter, such fact, while
mitigating, cannot completely exculpate him from liability. He could have asked the Court for an
extension of the period within which to decide Civil Case No. A-2274 instead of allowing the 90-
day period to expire. Or, as complainant aptly suggested, he could have gone on leave during
the time of his mourning if he could not effectively discharge his duties as a judge. We likewise
cannot understand why a letter-request from one of the plaintiffs could cause delay. Nor can
we accept his excuse that his designation as Acting Presiding Judge of another Branch
contributed to the delay in the disposition of the case.
The Code of Judicial Conduct mandates judges to dispose of the courts business promptly and
to decide cases within the required periods. Failure to do so violates a litigants right to speedy
disposition of his case. Moreover, delay in the disposition of cases undermines the peoples faith
and confidence in the judiciary.
Sibayan-Joaquin v. Judge Javellana
FACTS:In a complaint-affidavit, dated 17 September 1999, Eliezer A. Sibayan-Joaquin charged
Judge Roberto S. Javellana, acting presiding judge of the Regional Trial Court (RTC) of San Carlos
City, Branch 57, with grave misconduct in the performance of official duties, graft and gross
ignorance of the law. The complaint was an offshoot of a case for estafa, docketed Criminal Case
No. RTC 1150, entitled "People of the Philippines vs. Romeo Tan y Salazar," filed by Sibayan-
Joaquin for and in behalf of Andersons Group, Inc., against Romeo Tan before the San Carlos
City RTC. Complainant averred that there was an undue delay in the rendition of judgment in
the afore numbered criminal case, the decision, dated 16 July 1999, that had acquitted the
accused Romeo Tan, having been rendered only on the tenth month after the case was
submitted for decision. The matter was referred to the Office of the Court Administrator (OCA)
for evaluation. The Investigating Justice ended his report to the Court by recommending
respondent judge beheld administratively liable for failure to render judgment in Criminal Case
No. RTC-1150 within the period prescribed by law (in violation of 15, ARTICLE VIII OF THE
PHILIPPINECONSTITUTION, CANON 1, RULE 1.02, and CANON 3, RULE 3.05 OF THE Code of
Judicial Conduct).
ISSUE:Whether or not a judge may be held administratively liable for failure to render judgment
within the period prescribe by law.

HELD: YES. Section 15, Article XVIII, of the Constitution provides that lower courts have three
months within which to decide cases or matters pending before them from the date of
submission of such cases or matters for decision or resolution. Canon 3 of the Code of Judicial
Conduct holds similarly by mandating that the disposition of cases must be done promptly and
seasonably. Admittedly, respondent judge has taken ten months to finally decide Criminal Case
No. RTC-1150 from its submission for decision, a period clearly beyond the ninety-day
reglementary period. He could have asked for an extension of time to decide the case and
explain why, but he did not. Any undue delay in the resolution of cases often amounts to a
denial of justice and can easily undermine the people's faith and confidence in the judiciary.
Aware of the heavy caseload of judges, the Court has continued to act with great understanding
on requests for extension of time to decide cases.