prior the said date because it occupied the property in good faith,
A. Sagrada v National Coconut Corporation under no obligation to pay rentals for the use and occupation of the
Facts: ​The land belongs to Sagrada, in whose name the title was
registered before the war. On January 4, 1943, during the Japanese
military occupation, the land was acquired by a Japanese
corporation Taiwan Tekkosho for 140,000 pesos and issued the title
in its name. After liberation, the Alien Property Custodian of the
United States of America took possession, control, and custody
thereof under Section 12 of the Trading with the Enemy Act because
it belonged to an enemy national.
The respondent, while occupying the property, was authorized to
repair the warehouse on the land where it spent P26,898.27.
Afterwards, in 1948, it leased one-third of the warehouse to one
Dioscoro Sarile at a monthly rental of P500, which was later raised to
P1,000 a month.
The case was brought to the CFI. by Sagrada, claiming ownership of
the property. Petitioner was praying for the annulment of the sale of
the property to Taiwan Tekkosho and to recover its possession. The
parties presented a joint petition claiming that the sale in favor of
Taiwan Tekkosho was null and void because it was executed under
threats, duress, and intimidation, and it was agreed that the title
issued in the name of Taiwan Tekkosho be cancelled and for Nacoco
to recover its equipment and to pay the Philippine Alien Property
Admin 140,000.
The court rendered judgment releasing the defendant and the
intervenor from liability, but reserving to the plaintiff the right to
recover from the National Coconut Corporation reasonable rentals
for the use and occupation of the premises. However, although the
respondents did not deny its liabilities but only agreed to pay rentals
from Feb. 28, 1949 onwards, it argued that it should not pay rentals
warehouse.
The court declared that the plaintiff has always been the owner, and
the sale to the Japanese purchase was void ab initio, that the Alien
Property Adminsitration never acquired the right to the property, and
that as defendant has used the property and had subleased portion
thereof, it must pay reasonable rentals for its occupation.
Issue: ​Whether or not NACOCO should be held liable for rentals
Held: ​No.
SC held that the decision of the RTC that was based on the fact that
plaintiff was the owner, easily jumped to the conclusion that the
occupant is liable for the value of such use and occupation. SC held
that if the defendant is liable at all, its obligations must arise from any
of the 4 sources law, custom, contract or quasi-contract, crime, or
negligence.
Defendant-appellant is not guilty of any offense at all, because it
entered the premises and occupied it with the permission of the
entity which had the legal control and administration thereof, the
Alien Property Administration. Neither was there any negligence on
its part.
In addition, another ground why the claim for rentals can not be
made against defendant-appellant. There was no express agreement
between the Alien Property Custodian and the defendant-appellant
for the latter to pay rentals on the property.
Costs of this appeal shall be against the plaintiff-appellee.
ALACALA_ERA_LEE_OMOROG_SALVADOR 1

Doctrine: ​Obligations must arise from any of the 4 sources law,
custom, contract or quasi-contract, crime, or negligence.
B. METROPOLITAN BANK v. ROSALES
FACTS​: Rosales is the owner of China Golden Bridge Travel Agency
and one of her clients is Liu Chu Fang who was applying for a
retiree’s visa from Philippine Leisure and Retirement Authority
(PLRA) one of the requirements for such is to open a savings
account, so they did in the petitioner’s Escolta branch. Petitioner
however, issued a “Hold Out” order against respondents’ accounts in
their Pritil-Tondo branch (Joint Dollar Account ito with her mother Yo
Yuk To). Petitioner filed with Prosecutor charges of Estafa against
Rosales for the alleged unauthorized withdrawal of 75,000 US
dollars from Liu Chu Fang’s account using an impostor.
Respondents filed with RTC Breach of Contract With Damages
against petitioner, they argue that no explanation whatsoever was
given by the bank as to why there was a Hold Out Order. RTC ruled
in favor of Rosales, petitioners appealed to CA, CA affirmed RTC
decision deleting award for exemplary damages. Petitioner Contends
that the Hold Out clause in the Application and Agreement for
Deposit Accounts applies to all kinds of obligation.
ISSUE​: WON petitioner breached its contract with respondents and if
so are they liable for damages.
HELD: ​Petitioners reliance to the Hold Out clause is misplaced. This
only applies if there is a valid and existing obligation enumerated in
Art. 1157 of the Civil Code: law, contracts, quasi contracts, delicts,
and quasi-delict. Petitioner failed to show this. More so, the criminal
complaint is not enough reason to issue said order when in fact the
order was issued even before the complaint was filed. The Court
held further that there was no legal basis for petitioner to issue such
order because Rosales is not responsible in any of the five
aforementioned sources of obligation. Lastly, respondents are
entitled to exemplary damages because the bank acted in bad faith
by refusing to let them withdraw their deposits without any legal
basis and notice. Hence, the exemplary damages must be awarded
to set as an example or correction for the public good, due to the
fiduciary nature of the bank it must treat its documents and deal with
clients with meticulous care.
DOCTRINE: ​There are five sources of obligation namely: Law,
Contracts, Quasi-Contracts, Delicts, Quasi-Delicts. (Art. 1157)
C. OFFICE OF THE SOLICITOR GENERAL vs. AYALA LAND
INCORPORATED, ROBINSON’S LAND CORPORATION, et al
FACTS: The Office of the Solicitor General (OSG) instituted an
action to enjoin Ayala Land, Robinsons, Shangri-La and SM Prime
and similar establishments from collecting parking fees based on the
findings and recommendation of the Senate Committee on Trade
and Commerce and on Justice and Human Rights in their joint
investigation. The Committees found that the collection of parking
fees by shopping malls is contrary to the national Building Code and
is illegal. While the Code only states that the mall are required to
provide parking spaces, without expressly stating that it should be
free, both Committees believed that the reasonable interpretation of
the Code is that parking spaces are for free.
OSG further argued the requirement of free-of-charge parking greatly
contributes to the aim of safeguarding “life, health, property, and
public welfare…..” as stated in the declaration of policy in Section
102 of the National Building Code..
ISSUE:​W/N Ayala Land, Robinsons, Shangri-La and SM Prime are
obligated to provide free parking spaces in their mall for the use of
patrons or the public in general, free of charge, pursuant to Section
803 of the National Building Code and Rule XIX of the IRR
ALACALA_ERA_LEE_OMOROG_SALVADOR 2
 In order for the law to be a source of obligation, the law must
HELD/RULING:​NO. The Court finds no merit in the petition because expressly provide so. Obligation from the law cannot be presumed.
the explicit and clear directive of the afore-quoted statutory and
regulatory provisions, is that respondents, as operators/lessors of D. PEOPLE’S CAR INC. V. COMMANDO SECURITY SERVICE
neighborhood shopping centers, should provide parking and loading AGENCY
spaces, in accordance with the minimum ration provided in the Code. FACTS: ​On April 5, 1970, a security guard of the defendant while
The term “parking fees” cannot be found at all in the Code. assigned and on duty at plaintiff’s premises, without any consent,
approval or knowledge or orders of plaintiff or defendant brought out
Moreover, the Court said the RTC and CA correctly applied Article of the compound of the plaintiff a car belonging to a customer,
1158 of the New Civil Code, which states: Joseph Luy, and drove said car from place to place, abandoning his
post as a security guard, and while driving lost control of the car
“Section 1158. Obligations causing it to fall into a ditch.
derived from law are not
presumed. ​Only those The total cost or actual damages incurred by the plaintiff as a result
expressly determined in of the incident amounted to P8,489.10. Plaintiff claims that defendant
this Code of in special laws is liable for damages under paragraph 5 of their contract which
are demandable,​ and shall stipulates that the defendant would shoulder sole responsibility for all
be regulated by the precepts acts done by their guards while on duty. Defendant claims that it is
of the law which establishes liable only under paragraph 4 which stipulates that it shall assume
the; and as to what has not full responsibility for any loss or damage that may occur to any
been foreseen, by the property of the client provided that the amount lost shall not exceed
provisions this Book.” P1,000 per guard post.

The provision on ratios of parking slots in the Rule XIX of the IRR
cannot be construed as a directive to provide free parking spaces
because the enabling law, the Building Code does not so provide. To
compel respondents to provide parking spaces for free can be
considered as unlawful taking of property without just compensation.
While they still retain ownership of the land and building used for
such parking spaces, the public use of said facilities with prohibition
against their collection of parking fees is tantamount to a taking or
confiscation of their properties.
DOCTRINE​:
ISSUE: ​Whether defendant is liable under paragraph 5 or paragraph
4 of their contract.
HELD: It was held that defendant is liable to indemnify the plaintiff
for the entire damages incurred since paragraph 5 stated that it
would assume the responsibility for the proper performance by the
guards employed of their duties and be solely responsible for all acts
done during their watch hours and it would specifically release
plaintiff from any and all liabilities to third parties arising from such
acts or omissions by their guards.

ALACALA_ERA_LEE_OMOROG_SALVADOR 3
Plaintiff was in law liable to its customer for the damages caused the
customer’s car, which had been entrusted into its custody. Plaintiff
therefore was in law justified in making good such damages and
relying in turn on defendant to honor its contract and indemnify it for
such undisputed damages, which had been caused directly by the
unlawful and wrongful acts of defendant’s security guard in breach of
their contract. As ordained in Article 1159, Civil Code, "obligations
arising from contracts have the force of law between the contracting
parties and should be complied with in good faith.
E. CBK POWER COMPANY LIMITED vs. COMMISSIONER OF
INTERNAL REVENUE
FACTS: ​present case is a Petition for Review on Certiorari filed by
CBK Power Company Limited which assails a CTA decision which
partly granted the claim of petitioner for the issuance of a tax credit
certificate representing the latter’s alleged unutilized input taxes on
local purchases of goods and services attributable to effectively
zero-rated sales to National Power Corporation (NPC) for the second
and third quarters of 2005. CBK filed for tax refund on the 3 quarters
of 2005. CTA granted the claim and ordered the issuance of tax
certificates for the 2​nd​ and 3​rd​ quarter but denied the claim of the first
since it was filed out of time (or after the period to file has lapsed).
Both parties filed their respective motions for Partial Reconsideration
but were denied by the CTA Division. On appeal, the CTA En Banc
ruled that the petitioner’s judicial claim for the first, second, third
quarters of 2005 were belatedly filed. Hence, this petition. The issue
in the case (pero not really related to obli) is whether the applicable
prescriptive period on its claim for refund of unutilized input VAT
have lapsed.
ISSUE: ​Whether or not the prescriptive period has passed for all 3
quarters for CBK to be entitled for the VAT-zero rate certificate
HELD: ​The SC ruled that CBK is not entitled to any of the refund for
the three quarters since they filed out of time. Section 112 of the
NIRC provides that after the close of the taxable quarter when the
sales are made, there is a two-year prescriptive period within which
they can file for a tax refund. Plaintiff applied Mirant case stating that
they are allowed to apply for tax refund prematurely without following
the 120+30 day rule, however, the SC emphasized that this is not a
case of premature filing of a judicial claim but a late filing by CBK.
They had 30 days after the 120-day period to file a case with the CIR
but filed almost 2 years after.
WHEREFORE, the Instant Petition is DENIED.
DOCTRINE: (ok di to main issue ng case pero parang opinion
lang sa origs pero eto lang ung obli-related)
The court held also that ​solutio indebiti ​is not applicable in this case
for three reasons. First, there is a BINDING RELATION between
petitioner and CIR since the former is obligated to pay VAT. Second,
the payment of input tax was not made through mistake. They were
still obligated to pay VAT but had the privilege of filing for a tax
refund. They failed to file before the prescriptive period had lapsed
so it is still lawful to deny their claim. Finally, equity, it is not unfair to
deny since section 112 of the NIRC is a positive rule that should
preempt and prevail over all abstract arguments based only on
equity. Well-settled is the rule that tax refunds or credits, just like tax
exemptions, are strictly construed against the TAXPAYER. Since
they did not file on time, they are not entitled to the tax refund.
F. Jose Cangco v Manila Railroad Co.
Facts: ​Jose Cangco was in the employment of the Manila Railroad
Company as clerk with a monthly wage of 25 pesos. He lived in San
Mateo, Rizal, which is located iupon the line of the defendant’s
company. In order to go to work, he used a pass supplied by the
company. On January 20, 1915, the plaintiff was returning home by
rail, and as the train approached the station, the plaintiff arose from
his seat in the 2nd class-car, and making his exit, took his position
ALACALA_ERA_LEE_OMOROG_SALVADOR 4
upon the steps of the coach, seizing the upright guardrail with his
right hand for support.
When he was stepping off the train, his feet came in contact with a
sack of watermelons which resuled to his feet slipping from under
him and then he fell violently on the platform. His body rolled from
the platform and was drawn uner the moving car where his righs arm
was badly crushed and lacerated. It appears that after the plaintiff
alighted from the train the car moved forward possibly six meters
before it came to a full stop.
The testimony shows that this row of sacks was so placed that there
was a space of only about two feet between the sacks of melons and
the edge of the platform; and it is clear that the fall of the plaintiff was
due to the fact that his foot alighted upon one of these melons at the
moment he stepped upon the platform.
Plaintiff was brought to the hospital but his operation was
unsatisfactory, and a second operation had to be done. He spent a
total of 790.25 for medical fees.
He instituted this case in the CFI to recover damages form the
company, stating that the company’s servants and employees were
negligent in placing the sacks of melons upon the platform and in
leaving them so places as to be a menace to the security of the
passengers.
CFI ruled in favor of the company, stating that the plaintiff failed to
use due caution alighting from the coach.
Plaintiff appealed.
Issue: Whether or not Manila Railroad Co. is liable for damages for
alleged negligence of its employees
Ruling​: Yes.
The Supreme Court held that the explanation of cases as such is to
be found in the spehres of contractual and extra-contractual
obligations. The field of NON-CONTRACTUAL obligation is broader
than that of contractual obligations, comprising the whole extent of
juridical human relations.
This means that the mere fact that a person is ound to another by
contract does not relieve him from extra-contractial liability to such
person.
SC held that the contract of defendant to transport plaintiff carried
with it, by implication, the duty to carry him IN SAFETY and to
provide safe means of entering and leaving its trains. That duty is
contractual, which means that its non-performance cannot be
excused by proof that the dault was morally imputable to defendant’s
servants.
Judgement is rendered plaintiff 3,290 pesos.
G. LIGHT RAIL TRANSIT AUTHORITY V. NAVIDAD
FACTS​: Nicanor Navidad was drunk when he entered the station
and had an altercation with a security guard where he fell on the
tracks of the LRT. At the exact moment Navidad fell an LRT came
and hit him causing his instantaneous death. His heirs filed damages
against Prudent Security, LRTA, the security guard and the driver of
the LRT that hit Navidad. LRTA and Roman were dismissed by the
trial court, upon appeal CA exonerated Prudent due to the fact that
Navidad failed to prove that the security guard hit first.
ISSUE​: WON there was a contract of carriage between Navidad and
LRT
ALACALA_ERA_LEE_OMOROG_SALVADOR 5
HELD​: According to the Civil Code common carriers are bound to
carry passengers as safely as far as human care would provide,
using the utmost diligence of very cautious persons with due regard
for all circumstances. Such obligation arises not only during the trip
but for so long as the passengers are within its premises and where
they ought to be in pursuance to the contract of carriage. The
foundation of LRTA’s liability, therefore, is the contract of carriage
and its obligation to indemnify the victim arises from the breach of
that contract by reason of its failure to exercise the high diligence
required of the common carrier. Carrier may choose to hire its own
employees or seek a service provider in ensuring safety, in either
case the carrier is not relieved of its responsibilities under the
contract of carriage.
H. L.G. FOODS CORPORATION AND VICTORINO GABOR vs
HON. PHILADELFA PAGAPONG-AGRAVIADOR AND SPOUSES
VALLEJERA
FACTS: ​Charles Vallejera, 7 year old son of spouses Vallejera died
after being hit by a van owned by LG Foods Corporation and was
driven at that time by their employee, Vincent Yeneza. Information
for Reckless Imprudence Resulting to Homicide was filed but before
the trial could be concluded, Yeneza, the driver and employee of LG
Foods Corp committed suicide.
The spouses Vallejera filed a complaint for damages against the
petitioners as employers of the deceased driver basicially alleging
that as such employers, they failed to exercise due diligence in the
selection and supervision of their employees. Petitioners denied
liability and filed a motion to dismiss, principally arguing that the
complaint is a claim for subsidiary liability against an employer under
the provision of Article 103 of the Revised Penal Code.
ISSUE: ​W/N the complaint for damages filed by spouses Vallejera
against LG Foods Corporation is an action to enforce civil liability
arising from culpa criminal (criminal negligence) under Article 100 of
the Revised Penal Code.
HELD/RULING: ​NO. The complaint for damages filed by spouses
Vallejera against LG Foods Corp is an action for quasi-delict or culpa
aquiliana under Article 2176 to 2194 of the Civil Code.
In the case, the complaint sufficiently alleged that the death of the
couple’s minor son was caused by the negligent act of the
petitioners’ driver; and the petitioners themselves were civilly liable
for the negligence of their driver for failing “to exercise the necessary
diligence required of a good father of the family in the selection and
supervision of their employee, the driver, which diligence, if exercise
would have prevented said accident.” Had the respondents elected
to sue the petitioners based on Article 103 of the Revised Penal
Code, they would have alleged that the guilt of the driver had been
proven beyond reasonable doubt; that such driver is insolvent; that it
is the subsidiary liability of the defendant petitioners as employers to
pay for the damage done by their driver.
DOCTRINE: Under 2180 of the Civil Code, the liability of the
employer is direct or immediate. It is not conditioned upon prior
recourse against the negligent employee and a prior showing of
insolvency of such employee. On the other hand, in an action for
culpa criminal, governed by the Revised Penal Code, the plaintiff can
hold the employer subsidiarily liable only upon proof of conviction of
its employee.
ALACALA_ERA_LEE_OMOROG_SALVADOR 6