No. L-65505.

October 12, 1987

GABRIEL ABAD, PIO AGANON, MARIO ALARCIO, JOSE AQUINO, CESAR ATANACIO,
LEONARDO AURELIO, SOTERO BERNARDO, AURELIO CABRAL, JESUS CARREON,
ABELARDO CARILLO, ET AL., petitioners,
vs.
REGIONAL TRIAL COURT OF MANILA, BRANCH LII-HON. DAVID G. NITAFAN and
THE PHILIPPINE AMERICAN GENERAL INSURANCE COMPANY, INC., respondents

This is a Petition to review the ruling of the Regional Trial Court of Manila, Br. 52.

Facts:
On August 18, 1978, petitioners filed a complaint against respondent Philippine American
General Insurance Company, Inc. (PHILAMGEN, for brevity) for the enforcement of contract
and pay the monetary value of the accumulated sick leave with pay of its separated employees of

On February 16, 1979, the trial court granted PHILAMGEN’s moved to dismiss the complaint
instead of answering.

On May 2, 1979, petitioners filed a petition for Certiorari and on October 30, 1981this Court
ordered to reinstate the dismissal and said court is directed to conduct further proceedings for the
disposition of the case. The case was remanded to the trial court for further proceedings.

On January, 1983, judicial reorganization took place by virtue of EO No. 864 and declared that
the case lacked jurisdiction over the subject. A motion for reconsideration was filed by the
petitioners but was denied.

Issues:
Whether or not the Respondent Court erred in reversing motu proprio this Honorable Supreme
Court's decision by dismissing once again petitioners' action on the erroneous ground of lack of
jurisdiction; and whether or not Respondent Court erred in holding itself a totally different court
from the Court of First Instance whose cases were merely taken over by Respondent Court.

Ruling:
No and no. Jurisdiction over money claims of laborers and employees appertained to Courts of
First Instance, the same are now to be taken cognizance of by proper entities in the Department
of Labor and Employment.
G.R. No. 132601. January 19, 1999
LEO ECHEGARAY, petitioner,
vs.
SECRETARY OF JUSTICE, ET AL., respondents

FACTS:
On June 25, 1996, this Court affirmed the conviction of petitioner Leo Echegaray y Pilo for the
crime of rape of the 10 year-old daughter of his common-law spouse and the imposition upon
him of the death penalty for the said crime. Petitioner filed a Motion for Reconsideration with a
supplemental motion for reconsideration, raising for the first time the issue of the
constitutionality of Republic Act No. 7659 (the death penalty law) and the imposition of the
death penalty for the crime of rape; but the court denied such motion. In the meantime, Congress
had seen it fit to change the mode of execution of the death penalty from electrocution to lethal
injection, and passed Republic Act No. 8177. Pursuant to the provisions of said law, the
Secretary of Justice promulgated the Rules and Regulations to Implement Republic Act No. 8177
and directed the Director of the Bureau of Corrections to prepare the Lethal Injection Manual.
Petitioner filed a Petition for Prohibition, Injunction and/or Temporary Restraining Order to
enjoin respondents Secretary of Justice and Director of the Bureau of Prisons from carrying out
the execution by lethal injection of petitioner as these are unconstitutional and void.

On March 3, 1998, petitioner, through counsel, filed a Motion for Leave of Court to
Amend and Supplement Petition with the Amended and Supplemental Petition attached thereto.
The Court resolved to require the respondents to COMMENT thereon within a nonextendible
period of ten (10) days from notice, and directed the parties "to MAINTAIN the status quo
prevailing at the time of the filing of this petition." Petitioner then filed a Very Urgent Motion (1)
To clarify Status Quo Order, and (2) For the Issuance of a Temporary Restraining Order.

On March 16, 1998, the Office of the Solicitor General filed a Comment (On the Petition and the
Amended Supplemental Petition). The Court required the petitioner to file a REPLY thereto
within a non-extendible period of ten days from notice.Subsequently, the Commission on Human
Rights filed a Motion for Leave of Court to Intervene and/or Appear as Amicus Curiae alleging
that the death penalty imposed under R.A. No. 7659 which is to be implemented by R.A. No.
8177 is cruel, degrading and outside the limits of civil society standards, and further invoking (a)
Article II, Section 11 of the Constitution. After deliberating on the pleadings, the Court gave due
course to the petition, which it now resolves on the merits. In the Amended and Supplemental
Petition, petitioner assails the constitutionality of the mode of carrying out his death sentence by
lethal INJECTION.

Issue:
Whether or not there is an undue delegation of legislative power to the secretary of justice and
the director of bureau of corrections, in RA8177; and thus, makes the regulation invalid.
Ruling:
Empowering the Secretary of Justice in conjunction with the Secretary of Health and the
Director of the Bureau of Corrections, to promulgate rules and regulations on the subject of
lethal injection is a form of delegation of legislative authority to administrative bodies. The
reason for delegation of authority to administrative agencies is the increasing complexity of the
task of government requiring expertise as well as the growing inability of the legislature to cope
directly with the myriad problems demanding its attention. Although Congress may delegate to
another branch of the Government the power to fill in the details in the execution, enforcement
or administration of a law, it is essential, to forestall a violation of the principle of separation of
powers, that said law: (a) be complete in itself - it must set forth therein the policy to be
executed, carried out or implemented by the delegate - and (b) fix a standard - the limits of which
are sufficiently determinate or determinable - to which the delegate must conform in the
performance of his functions. Considering the scope and the definiteness of R.A. No. 8177, the
Court finds that the law sufficiently describes what job must be done, who is to do it, and what is
the scope of his authority. R.A. No. 8177 specifically requires that the death sentence shall be
executed under the authority of the Director of the Bureau of Corrections, endeavoring so far as
possible to mitigate the sufferings of the person under the sentence during the lethal injection as
well as during the proceedings prior to the execution." Further, the Director of the Bureau of
Corrections shall take steps to ensure that the lethal injection to be administered is sufficient to
cause the instantaneous death of the convict." The legislature also mandated that "all personnel
involved in the administration of lethal injection shall be trained prior to the performance of such
task." In this sense, R.A. No. 8177 is sufficiently definite and the exercise of discretion by the
administrative officials concerned is, to use the words of Justice Benjamin Cardozo, canalized
within banks that keep it from overflowing. THUS, there is no undue delegation of legislative
power.
G.R. No. 167891. January 15, 2010
SPOUSES JESUS FAJARDO and EMER FAJARDO, petitioners,
vs.
ANITA R. FLORES, assisted by her husband, BIENVENIDO FLORES, respondent.

Facts:
Leopoldo delos Reyes owned a parcel of land. In 1963, he allowed petitioner Jesus Fajardo to
cultivate said land and the net harvests were divided equally between them.

In 1975 when the relationship was converted to leasehold tenancy. Per Order from the
Department of Agrarian Reform (DAR), rent was provisionally fixed at 27.42 cavans per year,
which Jesus Fajardo religiously complied with. From the time petitioner cultivated the land, he
was allowed by Leopoldo delos Reyes to erect a house for his family on the stony part of the
land, which is the subject of controversy.

On January 26, 1988, Leopoldo delos Reyes died. His daughter and sole heir, herein respondent
Anita Flores, inherited the property. On June 28, 1991, Anita Flores and Jesus Fajardo executed
agreements, “Kasunduan”. Apparently, there was a conflict of claims in the interpretation of the
Kasunduan between Anita Flores and Jesus Fajardo, which was referred to the DAR, Provincial
Agrarian Reform Office, Baliuag, Bulacan. In the Report and Recommendation dated May 3,
2000, the Legal Officer advised the parties to ventilate their claims and counterclaims with the
Department of Agrarian Reform Adjudication Board (DARAB), Malolos, Bulacan.

On December 22, 2000, a complaint for ejectment was filed by herein respondent Anita Flores,
assisted by her husband Bienvenido Flores, against petitioners. In the complaint, she alleged that,
as the sole heir of the late Leopoldo delos Reyes, she inherited a parcel of land consisting of
stony land, not devoted to agriculture, and land suitable and devoted to agriculture.

On February 1999, Flores approached Fajardo and verbally informed them of her intention to
repossess the stony portion, but Fajardo refused to heed the request.

Fajardo filed a Motion to Dismiss, alleging that the subjected lot was agricultural land; that they
had been continuously, uninterruptedly, and personally cultivating the same since 1960 up to the
present; that the MTC had no jurisdiction over the case, considering that the dispute between the
parties, regarding the Kasunduan, was referred to the DARAB; and that the assumption by the
DARAB of jurisdiction over the controversy involving the lot in question therefore precluded the
MTC from exercising jurisdiction over the case.

Resolving the Motion to Dismiss, the MTC ruled that, while at first glance, the court did not
have jurisdiction over the case, considering that it was admitted that Fajardo was allowed to
cultivate the land, a closer look at the Kasunduan, however, revealed that what was divided was
only the portion being tilled. By contrast, the subject matter of the complaint was the stony
portion where Fajardo's house was erected. Thus, the court ruled that it had jurisdiction over the
subject matter. On April 25, 2001, the MTC rendered judgment in favor of Flores.

On appeal, the Regional Trial Court (RTC), Branch 16, Third Judicial Region, Malolos, Bulacan,
affirmed the MTC Decision in toto upon a finding that no reversible error was committed by the
court a quo in its Decision.

On motion for reconsideration, however, the RTC issued an Order on December 10, 2002,
reversing its decision dated August 29, 2002. The RTC found that the issue involved appeared to
be an agrarian dispute, which fell within the contemplation of Republic Act (R.A.) No. 6657,
otherwise known as the Comprehensive Agrarian Reform Law of 1988, and thus ordered the
dismissal of the case for lack of jurisdiction. A petition for review was then filed by Flores with
the CA to annul the Order of the RTC. On October 28, 2004, the CA rendered the assailed
decision, which reinstated the MTC decision. The subsequent motion for reconsideration was
denied; hence, this petition.

Issue:
Whether or not MTC has jurisdiction over the case.

Ruling:
No. As long as the subject matter of the dispute is the legality of the termination of the
relationship, or if the dispute originates from such relationship, the case is cognizable by the
DAR, through the DARAB. The severance of the tenurial arrangement will not render the action
beyond the ambit of an agrarian dispute

The doctrine of primary jurisdiction precludes the courts from resolving a controversy over
which jurisdiction has initially been lodged with an administrative body of special competence.
For agrarian reform cases, jurisdiction is vested in the Department of Agrarian Reform (DAR);
more specifically, in the Department of Agrarian Reform Adjudication Board (DARAB).
G.R. No. 181517. July 6, 2015
GREEN STAR EXPRESS, INC. and FRUTO SAYSON, JR., petitioners,
vs.
NISSIN-UNIVERSAL ROBINA CORPORATION, respondent.

Facts:
On February 25, 2003, a Mitsubishi L-300 van which Universal Robina Corporation ( URC)
owned figured in a vehicular accident with petitioner Green Star Express, Inc.’ s (Green Star)
passenger bus, resulting in the death of the van’s driver. Thus, the bus driver, petitioner Fruto
Sayson, Jr., was charged with the crime of reckless imprudence resulting in homicide. Thereafter,
Green Star sent a demand letter to respondent Nissin Universal Robina Corporation (NURC) for
the repair of its passenger bus. NURC denied any liability therefore and argued that the criminal
case shall determine the ultimate liabilities of the parties. Then criminal case was dismissed
without prejudice, due to insufficiency of evidence. Sayson and Green Star then filed a complaint
for damages against NURC before the R TC of San Pedro, Laguna. Francis Tinio, one of
NURC’s employees, was the one who received the summons. On February 6, 2004, NURC filed
a Motion to Dismiss claiming lack of jurisdiction due to improper service.

Issue:
Whether or not there is valid service of summons.

Ruling:
No. It is a well-established rule that the rules on service of summons upon a domestic private
juridical entity must be strictly complied with. Otherwise, the court cannot be said to have
acquired jurisdiction over the person of the defendant. NURC maintains that the RTC did not
acquire jurisdiction over it as the summons was received by its cost accountant, Francis Tinio. It
argues that under Section 11, Rule 14 of the 1997 Rules of Court, which provides the rule on
service of summons upon a juridical entity, in cases where the defendant is a domestic
corporation like NURC, summons may be served only through its officers. Thus:
Section 11. Service upon domestic private juridical entity. – When the defendant is a corporation,
partnership or association organized under the laws of the Philippines with a juridical
personality, service may be made on the president, managing partner, general manager, corporate
secretary, treasurer, or in-house counsel.

The Court considered said persons as “agent” within the contemplation of the old rule. Notably,
under the new Rules, service of summons upon an agent of the corporation is no longer
authorized, The rule now likewise states “general manager” instead of “manager”; “corporate
secretary” instead of merely “secretary”; and “treasure” instead of “cashier.” It has now become
restricted, limited, and exclusive only to the persons enumerated in the aforementioned
provision, following the rule in statutory construction that the express mention of one person
excludes all others, or expression unions est exclusion alterius. Service must, therefore, be made
only on the person expressly listed in the rules. If the revision committee intended to liberalize
the rule on service of summons, it could have easily done so by clear and concise language.