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Meneses vs.

CA
Parties:

 Complainant: Pablito Meneses


 Respondent: Heirs of Quisimbing
Case no: G.R. No. 82220
Facts: On March 1, 1977, Darum, then the District Land Officer of Los Baños, Laguna, issued to Pablito
Meneses 2 Free Patent and 2 OCT covering lots located in Los Baños, Laguna.

Pablito acquired said property from Bautista through a Deed of Waiver and Transfer of Rights executed in
1975 in consideration of Bautista’s “love and affection” for and “some monetary obligations” in favor of
Meneses. After the execution of said document, Meneses took possession of the land, introduced
improvements thereon, declared the land as his own for tax purposes and paid the corresponding realty
taxes. In turn, Bautista acquired the land from his aunt. He had been occupying the land since 1956.

On the other hand, the Quisumbing family traces ownership of their land as far back as 1919 when their
matriarch was issued an OCT covering a lot. The Quisumbings applied for registration and confirmation of
title over an additional area which had gradually accrued to their property by the natural action of the waters
of Laguna de Bay. The CFI of Biñan confirmed the Quisumbings’ title thereto.

In 1979, the Quisumbings filed a case before the CFI of Calamba against Lorenzo and Pablito Meneses,
Darum and Almendral for nullification of the free patents and titles issued to Pablito Meneses. They alleged
that Lorenzo Menesis, then the Mayor of Los Baños, using his brother Pablito as a “tool and dummy,”
illegally occupied their “private accretion land” and confederating with District Land Officer Darum and
Land Inspector Almendral, obtained free patents and OCTs to the land.

In 1984, the trial court rendered the decision finding that the lands registered by the Meneses brothers are
accretion lands to which the Quisumbings have a valid right as owners of the riparian land to which nature
had gradually deposited the disputed lots. (The lots occupied by Meneses, as found by the court, are to be
accretion lands forming parts of the bigger accretion land owned by the Quisumbings.)

The trial court also found that the free patents issued to Pablito Meneses had been procured through fraud,
deceit and bad faith, citing the following facts as bases for its conclusion:

1. The Deed of Waiver and Transfer of Rights allegedly executed by Silverio Bautista in favor of
Pablito Meneses was a simulated contract for lack of consideration
2. The said instrument was sworn to before Mayor Lorenzo Meneses who had no authority to notarize
deeds of conveyances
3. Land Inspector Cesar Almendral admitted having anomalously prepared the documents to support
the free patent applications of Pablito Meneses and, having personally filled up the blank forms,
signed them in the absence of the persons concerned
4. Darum represented the Bureau of Lands in LRC Case No. B-327 without authority from the
Director of Lands and after he had withdrawn his appearance in said case, persisted in filing a
motion to set aside the order for the issuance of a decree in favor of the Quisumbings
5. Darum and Almendral in bad faith, refused to produce the missing original records of the free patent
applications and their supporting documents

The Quisumbings also filed before the Sandiganbayan a complaint against Pablito Meneses, Silverio
Bautista, Pablo Silva, Virgilio Cruz and Cesar Almendral for violation of paragraphs (e) and (j), Section 3
of Republic Act No. 3019, for conspiring in the approval and grant of the free patents. In due course, the
Sandiganbayan rendered a decision finding the defendants guilty as charged.
Meanwhile, the Meneses brothers and Darum appealed the to the CA, which affirmed in toto the lower
court’s decision.The defendants-appellants filed two MRs of the CA decision but it was denied, hence this
petition for review on certiorari.

Charges: Conspiracy to commit fraud, deceit and bad faith


Issue: Whether or not petitioners are guilty of conspiracy to commit fraud, deceit and bad faith attended
the issuance of the free patent and titles to Pablito Meneses;
Decision of SC: YES. As found by the CA, petitioners conspired in the approval and grant of the free
patents heirs Quisumbing. Such fraud was confirmed by this Court in Meneses v. People, which held the
petitioners therein liable for violation of the Anti-Graft and Corrupt Practices Act in the issuance of the
same free patents and titles. A public official is by law not immune from damages in his personal capacity
for acts done in bad faith which, being outside the scope of his authority, are no longer protected by the
mantle of immunity for official actions. In due course, the Sandiganbayan rendered a decision finding the
defendants guilty as charged. The judgment of conviction was affirmed.
CMV Violated: Respect for authority

Vice: Greed

Virtue lacking: Justice

Republic vs. Sandoval


Parties:

 Complainant: Republic of the Philippines


 Respondent: Hon. Edilberto G. Sandoval
Case no: G.R. No. 84607
Facts: The heirs of the deceased of the January 22, 1987 Mendiola massacre, together with those injured
(Caylao group), instituted the petition seeking the reversal and setting aside of the orders of respondent
Judge Sandoval (May 31 and Aug 8, 1988) in "Erlinda Caylao, et al. vs. Republic of the Philippines, et al."
which dismissed the case against the Republic of the Philippines.

 May 31 Order: Because the impleaded military officers are being charged in their personal and
official capacity, holding them liable, if at all, would not result in financial responsibility of the
government
 August 8 Order: Denied the motions filed by both parties for reconsideration

In January 1987, farmers and their sympathizers presented their demands for what they called "genuine
agrarian reform". The Kilusang Magbubukid ng Pilipinas (KMP), led by Jaime Tadeo, presented their
problems and demands such as:
 giving lands for free to farmers
 zero retention of lands by landlords
 stop amortizations of land payments
Dialogue between the farmers and then Ministry of Agrarian Reform (MAR) began on January 15, 1987
On January 20, 1987, Tadeo met with MAR Minister Heherson Alvarez. Alvarez was only able to promise
to do his best to bring the matter to the attention of then President Cory Aquino during the January 21
Cabinet meeting.

The farmers, on their 7th day of encampment, barricaded the MAR premises and prevented the employees
from going inside their offices/ On January 22, 1987, following a heated discussion between Alvarez and
Tadeo, Tadeo's group decided to march to Malacanang to air their demands. On their march to Malacanang,
they were joined by Kilusang Mayo Uno (KMU), Bagong Alyansang Makabayan (BAYAN), League of
Filipino Students (LFS), and Kongreso ng Pagkakaisa ng Maralitang Lungsod (KPML). Government
intelligent reports were also received that the KMP was heavily infliltrated by CPP/NPA elements, and that
an insurrection was impending Government anti-riot forces assembled at Mendiola.

After the clash, 12 marchers were officially confirmed dead (13 according to Tadeo), 39 were wounded by
gunshots and 12 sustained minor injuries, all belonging to the group of marchers. Of the police and military,
3 sustained gunshot wounds and 20 suffered minor physical injuries.

The "Citizens' Mendiola Commission" submitted its report on the incident on February 27, 1987 as follows:
 The march did not have any permit
 The police and military were armed with handguns prohibited by law
 The security men assigned to protect the government units were in civilian attire (prohibited by
law)
 There was unnecessary firing by the police and military
 The weapons carried by the marchers are prohibited by law
 It is not clear who started the firing
 The water cannons and tear gas were not put into effective use to disperse the crowd; the water
cannons and fire trucks were not put into operation because:
 there was no order to use them
 they were incorrectly prepositioned
 they were out of range of the marchers

The Commission recommended that:


 The criminal prosecution of four unidentified, uniformed individuals shown either on tape or in
pictures, firing at the direction of the marchers.
 All the commissioned officers of both the Western Police District (WPD) and Integrated National
Police (INP) who were armed be prosecuted for violation of par. 4(g) of the Public Assembly Act
of 1985. Prosecution of the marchers was also recommended
 Tadeo be prosecuted both for holding the rally without permit and for inciting sedition
 Administrative sanctions were recommended for the following officers for their failure to make
effective use of their skill and experience in directing the dispersal operations in Mendiola:
o Gen. Ramon E. Montaño
o Police Gen. Alfredo S. Lim
o Police Gen. Edgar Dula Torres
o Police Maj. Demetrio dela Cruz
o Col. Cezar Nazareno
o Maj. Filemon Gasmin
 Last and most important recommendation: for the deceased and wounded victims to be
compensated by the government
It was this portion that petitioners (Caylao group) invoke in their claim for damages from the government.
No concrete form of compensation was received by the victims. On January, 1988, petitioners instituted an
action for damages against the Republic of the Philippines, together with the military officers, and personnel
involved in the Mendiola incident. Solicitor general filed a Motion to Dismiss on the ground that the State
cannot be sued without its consent. Petitioners said that the State has waived its immunity from suit.

Respondent Judge Sandoval, in his first questioned Order, dismissed the complaint as against the Republic
of the Philippines on the ground that there was no waiver by the State. Petitioners (Caylao group) filed a
Motion for Reconsideration therefrom, but the same was denied by respondent judge in his Order dated
August 8, 1988. Consequently, Caylao and her co-petitioners filed the instant petition.

Charges: Grave abuse of discretion by Judge Sandoval


Issue: Whether or not respondent committed grave abuse of discretion
Decision of SC: NO. The case does not qualify as a suit against the State. Some instances when a suit
against the State is proper are:
1. When the Republic is sued by name;
2. When the suit is against an unincorporated government agency;
3. When the, suit is on its face against a government officer but the case is such that ultimate liability
will belong not to the officer but to the government.
While the Republic in this case is sued by name, the ultimate liability does not pertain to the government.
Although the military officers and personnel, then party defendants, were discharging their official
functions when the incident occurred, their functions ceased to be official the moment they exceeded their
authority.
The inescapable conclusion is that the State cannot be held civilly liable for the deaths that followed the
incident. Instead, the liability should fall on the named defendants in the lower court. In line with the ruling
of this court in Shauf vs. Court of Appeals, herein public officials, having been found to have acted beyond
the scope of their authority, may be held liable for damages.
WHEREFORE, finding no reversible error and no grave abuse of discretion committed by respondent Judge
in issuing the questioned orders, the instant petitions are hereby DISMISSED.

Gaspar vs. Bayhon


Parties:

 Complainant: Eleazar Gaspar


 Respondent: Judge William Bayhon
Case no: A.M. No. RTJ-97-1388
Facts: Eleazar B. Gaspar, Court Interpreter of the RTC, is respondent in Remedios Antonio v. Eleazar B.
Gaspar, filed with the Office of the Court Administrator for conduct unbecoming of a government
employee, intriguing against honor, less serious physical injuries, and acts of lasciviousness. Respondent
Judge William H. Bayhon was the fifth of the five (5) Executive Judges of the Regional Trial Court,
National Capital Judicial Region who were tasked, one after another, to investigate such case.
Respondent Judge compulsorily retired on 12 July 1997 but due to his alleged failure to submit his report
on his investigation of the complaint against Gaspar, the former was administratively charged by Gaspar in
an unverified complaint. As a consequence, Judge Bayhon was unable to receive his retirement benefits to
which by law he has otherwise entitled.

Charges: Administrative complaint for malicious delay in the administration of justice and a violation of
Rule 2, Canon 3, of the Code of Judicial Conduct

Issue: Whether or not the delay in the submission of his report constitutes malicious delay in the
administration of justice and a violation of Rule 2, Canon 3, of the Code of Judicial Conduct.
Decision of SC: NO. perusal of the affidavit-complaint of Eleazar B. Gaspar fails to disclose any allegation
that the delay, if any, was borne of malicious intent. Malice connotes that the act complained of must be
the result of a deliberate evil intent and does not cover a mere voluntary act. Further, the delay must be the
result of a deliberate intent to inflict damage on either party to a case before him. Considering that there
was not a single specific act alleged in the complaint imputing malice to respondent Judge resulting in the
delay, thus failing to prove that the delay was malicious, the charge must fail.
As regards the allegation that respondent Judge violated Rule, Canon 3, of the Code of Judicial Conduct, it
appears from the recollection of Gaspar himself that respondent Judge however was the fifth of the five (5)
Executive Judges of the National Capital Judicial Region who were assigned to investigate the
administrative complaint of Remedios Antonio against Eleazar B. Gaspar. They were Judge Job B.
Madayag and Judge Julio Logarta of Makati and now both retired, and Judge Rosalio G, de la Rosa and
Judge Romeo J. Callejo, the former having already retired and the latter now an Associate Justice of the
Court of Appeals. Quite understandably, respondent Judge could not have been familiar with the facts and
the antecedents of the case before it was finally referred to him.
In San Pedro v. Salvador, it was held that a judge should not be blamed for the delay in the disposition of a
case when the delay is beyond his control, specially in the absence of any showing that it was done in bad
faith and intend to prejudice a party to the case or that it was motivated by some ulterior ends. No such ill
motive was even alleged, much less proved, against respondent Judge. Neither is there any allegation of
dishonesty or partiality against him.
WHEREFORE, this administrative case is DISMISSED and, consequently, all the retirement benefits to
which respondent Judge William H. Bayhon is entitled under the law are ordered RELEASED to him.