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Te vs COA:

Petitioner Arthur Te and private respondent Liliana Choa were married in civil rites on September 14,
1988. They did not live together after the marriage although they would meet each other regularly. Not
long after, private respondent gave birth to a girl on April 21, 1989, petitioner stopped visiting her. After
a year, while his marriage with private respondent was subsisting, Arthur contracted a second marriage
with Julieta Santella Liliana learned about the marriage and filed a complaint-affidavit, charging Arthur
with Bigamy in the RTC. Meanwhile, months after, petitioner in the RTC of Quezon City an action for
annulment on his message with Liliana on the ground that he was forced to marry her. He alleged that
private respondent concealed her pregnancy to another man at the time of their marriage and she was
psychologically incapacitated to perform her marital obligations. On November 1990, private
respondent filed with PRC an administrative case against petitioner and Santella for revocation of their
respective engineering licenses on the ground that they committed immorality by living together
subsequently marrying each other despite of petitioner being married. In addition, private responded
alleged the petitioner for falsification of marriage contract stating with Santella that he was single.

After the prosecution rested its case Bigamy, petitioner filed a demurrer to evidence with leave of court
and motion to inhibit trial court for showing antagonism and animosity towards the petitioner’s counsel
during the hearings of said case, the trial courts denied. Petitioner also filed with the PRC Board where
the administrative case for the revocation of his license was pending and a motion to suspend the
proceedings therein view of the pendency of the civil case for annulment of his marriage and criminal
case for Bigamy.

The petitions were denied by the lower court. Hence, this appeal:

Issue;
WON the civil case and administrative case were prejudicial question to suspend the criminal case of
Bigamy

Ruling:
No. A prejudicial question has been defined as one based on a fact distinct and separate from the crime
but so intimately connected with it that it determines the guilt or innocence of the accused, and for it to
suspend the criminal action, it must appear not only that said case involves facts intimately related to
those upon which the criminal prosecution would be based but also that in the resolution of the issue or
issues raised in the civil case, the guilt or innocence of the accused would necessarily be determined.

In this case, the court ruled that the outcome of the civil case for annulment of petitioner’s marriage to
private respondent have no bearing upon the determination of petitioner’s innocence or guilt in the
criminal case for bigamy, because all that is required for Bigamy to prosper is that the first marriage is
subsisting at the time of the second marriage; this is given as a fact and could prosper without the
decision from the civil case. Hence, it is deemed that the civil case is not a prejudicial question to the
criminal case as it is independent from the later and can be decided without the former.

With regards to the administrative case, it is clear that a prejudicial question involves a civil and criminal
case. Therefore, a prejudicial question where one case is administrative could not prosper. Furthermore,
it must be noted that the allegations in the administrative complaint before the PRC Board are not
confined to the issue of Bigamy. Hence, the administrative is not deemed as a prejudicial question to the
criminal case.
Marcos vs Manglapus

In view of the recent martial law, Philippine President Cory Aquino has rendered a decision barring the
return of the former President Marcos and his family at the present time, and under the present
circumstance. In her statement, the return of the former President poses a threat to the National
interest, safety and welfare of the country.

On October 1989, the petitioners filed a motion for reconsideration, however was denied by the court.

Issue: WON President Cory Aquino acted arbitrarily or with grave abuse of discretion in determining the
return of the former President Marcos in the Philippines.

Ruling: NO. Considering the death of Mr Marcos, the threats to the government, to which the return of
the Marcoses has been viewed to provide a catalytic effect and have not been shown to have ceased. It
cannot be denied that the President, upon whom executive power is vested, has unstated residual
powers which are implied from the grant of executive power and which are necessary for her to comply
with her duties under the Constitution. Among her duties is to protect and promote the interest and
welfare of the people. Her decision to bar the return of the Marcoses and subsequently, the remains of
Mr. Marcos at the present time and under present circumstances is in compliance with this bounden
duty. Hence, there is no clear showing that the president acted arbitrarily and with grave abuse of
discretion.

De Jesus v Syquia

Cesar Syquia was 23 years old, born in a prominent family. He used to go to a barber shop owned by his
brother-in-law, where he met Antonia Loanca, 23 years old, unmarried. Not long enough, the two
become acquaintance and developed relationship. As a consequence, Antonia becomes pregnant with a
baby boy who was born on June 17 2931. The defendant became a constant visitor at the home of
Antonia. During the early months of her pregnancy, the defendant wrote a letter directed to a priest
who is expected to baptize the baby acknowledging the unborn child as his own and giving him the
name of Cesar Syquia Jr. This was written prior his departure on a trip to China and Japan.

While he was away, he wrote several letters to Antionia, showing a parental interest to their baby.
When the baby was born, Cesar arranged all the hospitalizations, and leaved together with Antonia and
her mother in law in Camarines St. Manila. As time passed, the defendant become uninterested and
when Antonia started showing signs of her 2nd pregnancy, the defendant decamped and married
another woman. It was also been noted that during the christening of their child, the defendant changed
it’s name to Ismael Loanco instead of Cesar Syquia Jr.

ISSUE: WON Ismael Loanco obtains the status of a natural child, justified by the conduct of the father
himself, and that as a consequence, the defendant in this case should be compelled to acknowledge the
said Ismael Loanco

RULING:
YES. The letters presented as evidence proved that the defendant acknowledge the child as his own.
It is also undeniable that from the birth of this child the defendant supplied a home for it and the
mother, in which they lived together with the defendant. This situation continued for about a year, and
until Antonia became pregnant the second time, when the idea entered the defendant's head of
abandoning her. The law fixes no period during which a child must be in the continuous possession of
the status of a natural child; and the period in this case was long enough to evince the father's
resolution to concede the status.

Rallos vs Gochan

Concepcion and Gerundia Rallos were sisters and registered co-owners of a parcel of land in Cebu. On
April 21, 1954, the sisters executed a special power of attorney in favor of their brother, Simeon Rallos,
authorizing him to sell for and in their behalf lot. On March 3, 1955, Concepcion Rallos died. On
September 12, 1955, Simeon Rallos sold the undivided shares of his sisters Concepcion and Gerundia to
Felix Go Chan & Sons Realty Corporation for the sum of P10,686.90. The deed of sale registered in the
Registry of Deeds of Cebu, was cancelled, and a new transfer certificate of Title No. 12989 was issued in
the named of the vendee.

On May 18, 1956 Ramon Rallos as administrator of the Intestate Estate of Concepcion Rallos filed a
complaint against Simon Rallos, Felix Go Chan & Sons Realty corporation and Registry deeds of Cebu,,
praying (1) that the sale of the undivided share of the deceased Concepcion Rallos in be unenforceable,
and said share be reconveyed to her estate; (2) that the Certificate of 'title issued in the name of Felix
Go Chan & Sons Realty Corporation be cancelled and another title be issued in the names of the
corporation and the "Intestate estate of Concepcion Rallos" in equal undivided and (3) that plaintiff be
indemnified by way of attorney's fees and payment of costs of suit. The complaint was amended twice;
defendant Corporation's Answer contained a crossclaim against its co-defendant, Simon Rallos while the
latter filed third-party complaint against his sister, Gerundia Rallos. During the pendency of the case,
both Simon and his sister Gerundia died and they were substituted by the respective administrators of
their estates.

ISSUE: WON there is a legal effect of an act performed by an agent after the death of his principal. We
have the query.

RULING:
No, the sale is void because Simeon’s authority as an agent of Concepcion was extinguished upon her
death.
Article 1317 provides that no one may contract in the name of another without being authorized or
unless he has, by law, a right to represent him. Article 1919 furthers that the death of the principal
terminates the agency.
The case at bar is also not among the exceptions whereby an agent’s acts bind the principal even after
the latter’s death because of Simeon’s knowledge of Concepion’s death is material. Hence, the sale was
null and void.

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