CASE DIGEST: BAYAN MUNA v.
ALBERTO HELD: The Agreement does not contravene or
ROMULO. G.R. No. 159618; February 1, 2011.
VELASCO, JR., J.:
FACTS: In 2000, the RP, through Charge
d’Affaires Enrique A. Manalo, signed the Rome
Statute which, by its terms, is “subject to
ratification, acceptance or approval” by the
signatory states. In 2003, via Exchange of Notes
with the US government, the RP, represented by
then DFA Secretary Ople, finalized a non-
surrender agreement which aimed to protect
certain persons of the RP and US from frivolous
and harassment suits that might be brought
against them in international tribunals. Petitioner
imputes grave abuse of discretion to respondents
in concluding and ratifying the Agreement and
prays that it be struck down as unconstitutional,
or at least declared as without force and effect.
ISSUE: [1] Did respondents abuse
their discretion amounting to lack or excess of
jurisdiction in concluding the RP-US Non
Surrender Agreement in contravention of the
Rome Statute?
undermine, nor does it differ from, the Rome
Statute.  Far from going against each other, one
complements the other.  As a matter of fact, the
principle of complementarity underpins the
creation of the ICC. According to Art. 1 of the
Statute, the jurisdiction of the ICC is to “be
complementary to national criminal jurisdictions
[of the signatory states].” the Rome Statute
expressly recognizes the primary jurisdiction of
states, like the RP, over serious crimes committed
within their respective borders, the
complementary jurisdiction of the ICC coming
into play only when the signatory states are
unwilling or unable to prosecute.
IMBONG V. OCHOA (G.R.
NO. 204819)
April 8, 2014
MENDOZA, J.:
Facts:
The increase of the country’s population at
an uncontrollable pace led to the executive
and the legislative’s decision that prior
measures were still not adequate. Thus,
Congress enacted R.A. No. 10354, otherwise
known as the Responsible Parenthood and
Reproductive Health Act of 2012 (RH Law),
to provide Filipinos, especially the poor and
the marginalized, access and information to
the full range of modern family planning
methods, and to ensure that its objective to
provide for the peoples’ right to reproductive
health be achieved. Stated differently, the
RH Law is an enhancement measure to
fortify and make effective the current laws
on contraception, women’s health and
population control.
Shortly after, challengers from various
sectors of society moved to assail the
constitutionality of RH Law. Meanwhile, the
RH-IRR for the enforcement of the assailed
legislation took effect. The Court then issued
a Status Quo Ante Order enjoining the
effects and implementation of the assailed
legislation.
Petitioners question, among others, the
constitutionality of the RH Law, claiming
that it violates Section 26(1), Article VI of the
Constitution, prescribing the one subject-
one title rule. According to them, being one
for reproductive health with responsible
parenthood, the assailed legislation violates
the constitutional standards of due process
by concealing its true intent – to act as a
population control measure. On the other
hand, respondents insist that the RH Law is
not a birth or population control measure,
and that the concepts of “responsible
parenthood” and “reproductive health” are
both interrelated as they are inseparable.
Issue:
Whether or not RH Law violated the one
subject-one title rule under the Constitution
Ruling: NO
Despite efforts to push the RH Law as a
reproductive health law, the Court sees it as
principally a population control measure.
The corpus of the RH Law is geared towards
the reduction of the country’s population.
While it claims to save lives and keep our
women and children healthy, it also
promotes pregnancy-preventing products. As
stated earlier, the RH Law emphasizes the
need to provide Filipinos, especially the poor
and the marginalized, with access to
information on the full range of modem
family planning products and methods.
These family planning methods, natural or
modern, however, are clearly geared towards
the prevention of pregnancy. For said
reason, the manifest underlying objective of
the RH Law is to reduce the number of
births in the country. The Court, thus,
agrees with the petitioners’ contention that
the whole idea of contraception pervades the
entire RH Law.
G. R. No. 161824             March 3, 2004
VICTORINO X. FORNIER, vs. HON. COMMISSION ON
ELECTIONS and FPJ
CARPIO MORALES, J.:
Facts:
Petitioners sought for respondent Poe’s
disqualification in the presidential elections
for having allegedly misrepresented material
facts in his (Poe’s) certificate of candidacy
by claiming that he is a natural Filipino
citizen despite his parents both being
foreigners. Comelec dismissed the petition,
holding that Poe was a Filipino Citizen.
Petitioners assail the jurisdiction of the
Comelec, contending that only the Supreme
Court may resolve the basic issue on the
case under Article VII, Section 4, paragraph 7, of the
1987 Constitution.
Issue:
Whether or not it is the Supreme Court which had
jurisdiction.
Whether or not Comelec committed grave abuse of
discretion in holding that Poe was a Filipino citizen.
Ruling:
1.) The Supreme Court had no jurisdiction on questions
regarding “qualification of a candidate” for the
presidency or vice-presidency before the elections are
held.
Respondent, having been acknowledged as Allan’s son to
Bessie, though an American citizen, was a Filipino citizen by
virtue of paternal filiation as evidenced by the respondent’s
birth certificate. The 1935 Constitution on citizenship did not
make a distinction on the legitimacy or illegitimacy of the
child, thus, the allegation of bigamous marriage and the
allegation that respondent was born only before the assailed
marriage had no bearing on respondent’s citizenship in view
of the established paternal filiation evidenced by the public
documents presented.
But while the totality of the evidence may not establish
conclusively that respondent FPJ is a natural-born citizen of
the Philippines, the evidence on hand still would
preponderate in his favor enough to hold that he cannot be
held guilty of having made a material misrepresentation in
his certificate of candidacy in violation of Section 78, in
relation to Section 74 of the Omnibus Election Code.
Continental Steel
Manufacturing
Corporation vs
Voluntary Arbitrator
Allan Montaño
October 13, 2009
CHICO-NAZARIO, J.:
 
603 SCRA 621 – Labor Law – Labor Standards – Death
Benefits for the Death of a Dependent – A Fetus is a
Dependent
Civil Law – Civil Personality – When does civil personality
start – When does life begin
In January 2006, the wife of Rolando Hortillano had a
miscarriage which caused the death of their unborn child.
Hortillano, in accordance with the collective bargaining
agreement, then filed death benefits claim from his
employer, the Continental Steel Manufacturing
Corporation which denied the claim. Eventually, the issue
was submitted for arbitration and both parties agreed to
have Atty. Allan Montaño act as the arbitrator. Montaño
ruled that Hortillano is entitled to his claims. The Court of
Appeals affirmed the decision of Montaño.
On appeal, Continental Steel insisted that Hortillano is
not entitled because under the CBA, death benefits are
awarded if an employee’s legitimate dependent has died;
but that in this case, no “death” has occurred because the
fetus died inside the womb of the mother, that a fetus has
no juridical personality because it was never born
pursuant to Article 40 of the Civil Code which provides a
conceived child acquires personality only when it is born;
that the fetus was not born hence it is not a legitimate
dependent as contemplated by the CBA nor did it suffer
death as contemplated under civil laws.
ISSUES: 
1. Whether or not the fetus is a legitimate dependent?
2. Whether or not a person has to be born before it could
die?
HELD:  FACTS:
1. Yes. In the first place, the fact of marriage between
Hortillano and his wife was never put in question, hence
they are presumed to be married. Second,
children conceived or born during the marriage of the
parents are legitimate. Hence, the unborn child (fetus) is
already a legitimate dependent the moment it was
conceived (meeting of the sperm and egg cell).
2. No. Death is defined as “cessation of life”. Certainly, a
child in the womb has life. There is no need to discuss
whether or not the unborn child acquired juridical
personality – that is not the issue here. But nevertheless,
life should not be equated to civil personality. Moreover,
while the Civil Code expressly provides that civil
personality may be extinguished by death, it does not
explicitly state that only those who have acquired
juridical personality could die. In this case, Hortillano’s
fetus had had life inside the womb as evidenced by the
fact that it clung to life for 38 weeks before the
unfortunate miscarriage. Thus, death occurred on a
dependent hence Hortillano as an employee is entitled to
death benefit claims as provided for in their CBA.
PT&T vs. NLRC
272 SCRA 596
May 23, 1997
REGALADO, J.:
PT&T (Philippine Telegraph & Telephone Company) initially
hired Grace de Guzman specifically as “Supernumerary
Project Worker”, for a fixed period from November 21, 1990
until April 20, 1991 as reliever for C.F. Tenorio who went on
maternity leave. She was again invited for employment as
replacement of Erlina F. Dizon who went on leave on 2
periods, from June 10, 1991 to July 1, 1991 and July 19,
1991 to August 8, 1991.
On September 2, 1991, de Guzman was again asked to join
PT&T as a probationary employee where probationary period
will cover 150 days. She indicated in the portion of the job
application form under civil status that she was single
although she had contracted marriage a few months earlier.
When petitioner learned later about the marriage, its branch
supervisor, Delia M. Oficial, sent de Guzman a memorandum
requiring her to explain the discrepancy. Included in the
memorandum, was a reminder about the company’s policy of
not accepting married women for employment. She was
dismissed from the company effective January 29, 1992.
Labor Arbiter handed down decision on November 23, 1993
declaring that petitioner illegally dismissed De Guzman, who
had already gained the status of a regular employee.
Furthermore, it was apparent that she had been
discriminated on account of her having contracted marriage
in violation of company policies.
ISSUE: Whether the alleged concealment of civil status can
be grounds to terminate the services of an employee.
HELD:
Article 136 of the Labor Code, one of the protective laws for
women, explicitly prohibits discrimination merely by reason
of marriage of a female employee. It is recognized that
company is free to regulate manpower and employment from
hiring to firing, according to their discretion and best
business judgment, except in those cases of unlawful
discrimination or those provided by law.
PT&T’s policy of not accepting or disqualifying from work any
woman worker who contracts marriage is afoul of the right
against discrimination provided to all women workers by our
labor laws and by our Constitution. The record discloses
clearly that de Guzman’s ties with PT&T were dissolved
principally because of the company’s policy that married
women are not qualified for employment in the company,
and not merely because of her supposed acts of dishonesty.
G.R. No. 207257 February 3, 2015
HON. RAMON JESUS PAJE, in his capacity
as DENR Secretary v. Hon. Teodoro Casino,
et al.
DEL CASTILLO, J.:
Facts
The Department of Environment and Natural Resources,
issued an Environmental Compliance Certificate for a
proposed coal-fired power plant at Subic, Zambales to be
implemented by RP Energy.
Hon. Teodoro Casino and a number of legislators filed a
Petition for Writ of Kalikasan against RP energy, SBMA, and
Hon. Ramon Paje as the DENR secretary on the ground that
actual environmental damage will occur if the power plant
project is implemented and that the respondents failed to
comply with certain laws and rules governing or relating to
the issuance of an ECC and amendments thereto.
The Court of Appeals denied the petition for the Writ of
Kalikasan and invalidated the ECC. Both the DENR and
Casino filed an appeal, the former imputing error in
invalidating the ECC and its amendments, arguing that the
determination of the validity of the ECC as well as its
amendments is beyond the scope of a Petition for a Writ of
kalikasan; while the latter claim that it is entitled to a Writ of
Kalikasan.
Issue
Whether the parties may raise questions of fact on appeal on
the issuance of a writ of Kalikasan;
Ruling
Yes, the parties may raise questions of fact on appeal on the
issuance of a writ of Kalikasan because the Rules on the Writ
of kalikasan (Rule 7, Section 16 of the Rules of Procedure for
Environmental Cases)allow the parties to raise, on appeal,
questions of fact— and, thus, constitutes an exception to
Rule 45 of the Rules of Court— because of the extraordinary
nature of the circumstances surrounding the issuance of a
writ of kalikasan.
Aldrin Jeff Cudia vs The Superintendent of
the Philippine Military
G.R. No. 211362, February 24, 2015
PERALTA, J.:
PMA, as an academic institution, has the right to remove
erring cadets under the principle of academic freedom
But PMA must still observe due process in removing cadets
PMA cadets are entitled to due process
PMA cannot be compelled by mandamus to reinstate cadets
separated therefrom if due process was observed
G.R. No. 211362 – Political Law – Constitutional Law –
Academic Freedom
Remedial Law – Mandamus – Ministrant vs Discretionary
Function
Aldrin Jeff Cudia was a member of the Philippine Military
Academy (PMA) Siklab Diwa Class of 2014. On November 14,
2013, Cudia’s class had a lesson examination in their
Operations Research (OR) subject the schedule of which was
from 1:30pm to 3pm.
However, after he submitted his exam paper, Cudia made a
query to their OR teacher. Said teacher, then asked Cudia to
wait for her. Cudia complied and as a result, he was late for
his next class (English). Later, the English teacher reported
Cudia for being late.
In his explanation, Cudia averred that he was late because
his OR class was dismissed a bit late. The tactical officer (TO)
tasked to look upon the matter concluded that Cudia lied
when he said that their OR class was dismissed late because
the OR teacher said she never dismissed her class late.
Thus, Cudia was meted with demerits and touring hours
because of said infraction.
Cudia did not agree with the penalty hence he asked the TO
about it. Not content with the explanation of the TO, Cudia
said he will be appealing the penalty he incurred to the
senior tactical officer (STO). The TO then asked Cudia to
write his appeal.
People v Judge Ayson; G.R. No. 85215; 07
Jul 1989; 175 SCRA 216
BIDIN, J.:
FACTS:
Felipe Ramos, a ticket freight clerk of the Philippine
Airlines (PAL), was charged with estafa for irregularities
in the sale of plane tickets. Respondent judge admitted
all evidentiary and testamentary evidence offered
against Ramos except for the latter’s handwritten note
expressing his willingness to settle the irregularities
alleged against him as well as his statement during an
administrative investigation where he admitted to the
offense.
ISSUE(S):
Whether or not respondent judge is correct in not
admitting the note and statement in evidence.
RULING:
NO. Felipe Ramos was not in any sense under custodial
interrogation prior to and during the administrative
inquiry into the discovered irregularities in ticket sales
in which he appeared to have had a hand. The
constitutional rights of a person under custodial
interrogation under Section 20, Article IV of the 1973
Constitution did not therefore come into play. He had
voluntarily answered questions posed to him on the
first day of the administrative investigation and agreed
that the proceedings should be recorded. The note that
he sent to his superiors offering to compromise his
liability in the alleged irregularities, was a free and even
spontaneous act on his part.
Petition is GRANTED. Respondent judge ordered to
ADMIT IN EVIDENCE the note and statement.
PRC vs. De Guzman, G. R. No. 144681, June 21,
2004 Constitutional Law: Police Power
June 21, 2004
TINGA, J.:
Facts:
The
respondents are all graduates of the Fatima College of
Medicine
, Valenzuela City, Metro Manila. They
passed the Physician Licensure Examination
conducted in February 1993 by the Board of Medicine
(Board).
Petitioner Professional Regulation Commission (PRC
) then released their names as successful examinees in
the medical licensure examination. Shortly thereafter,
the Board observed that the
grades of the seventy-nine successful examinees from
Fatima College
in the two most difficult subjects in the medical
licensure exam,
Biochemistry (Bio-Chem) and Obstetrics and “the questionable passing rate of Fatima examinees in
Gynecology (OB-Gyne), were unusually and the [1993] Physician Examination
exceptionally high
leads to the conclusion that the
. Eleven Fatima examinees scored 100% in Bio-Chem
and ten got 100% in OB-Gyne, another eleven got 99% Fatima examinees gained early access to the test
in Bio-Chem, and twenty-one scored 99% in OB-Gyne. questions
The
.”
Board also observed that many of those who passed
from Fatima got marks of 95% or better in both
The
subjects

Board issued Resolution No. 26

, and

, dated July 21, 1993,

no one got a mark lower than 90%

charging respondents with "immorality, dishonest

. A comparison of the performances of the candidates
conduct, fraud, and deceit"
from other schools was made. The Board observed that
strangely, the unusually high ratings were true only for
Fatima College examinees. It was a record-breaking in connection with the Bio-Chem and Ob-Gyne
phenomenon in the history of the Physician Licensure examinations. It
Examination. For its part, the
recommended that the test results of the Fatima
NBI found that examinees be nullified

Trial court’s
judgment is rendered
ordering the respondents to allow the petitioners
and intervenors to take the physician’s oath and to
register them as physicians without prejudice to any
administrative
disciplinary action
which may be taken against any of the petitioners for
such causes and in the manner provided by law and
consistent with the requirements of the Constitution as
any other professionals.
Issue:
Whether or not the act pursuant to
R.A. 2382 (prescribes that a person who aspires to
practice medicine in the
Philippines, must have “satisfactorily passed the
corresponding Board Examination)
known as
The Medical Act of 1959
a
valid exercise of police power. Held:
Yes. It is true that this
Court has upheld the constitutional right of every
citizen to select a profession or course of study subject
to a fair, reasonable, and equitable admission and
academic requirements.
But
like all rights and freedoms guaranteed by the Charter,
their exercise may be so regulated pursuant to the
police power of the State
to safeguard
health, morals, peace, education, order, safety, and
general welfare of the people.
Thus, persons who desire to engage in the learned
professions requiring scientific or technical knowledge
may be required to take an examination as a
prerequisite to engaging in their chosen careers. This
regulation takes particular pertinence in the field of
medicine, to protect the public from the potentially
deadly effects of incompetence and ignorance among
those who would practice medicine. *satisfactorily-
defined as “sufficient to meet a condition or obligation”
or “capable of dispelling doubt or ignorance”
It must be stressed, nevertheless, that the power to
regulate the exercise of a profession or pursuit of an
occupation cannot be exercised by the State or its
agents in an arbitrary, despotic, or oppressive manner.
A political body that regulates the exercise of a
particular privilege has the authority to both forbid and
grant such privilege in accordance with certain
conditions. Such
conditions may not, however, require giving up ones
constitutional rights as a condition to acquiring the
license
Ondoy vs. Ignacio et. al. 97 SCRA 252
G.R. No. L-47178 May 16, 1980
FERNANDO, C.J.:
Facts: The petitioner, Estrella Ondoy, is a mother of one Jose
Ondoy, an employee who worked under Virgilio Ignacio.
According to the chief engineer and oiler, Jose Andoy was
aboard the ship of the respondent’s enterprise as part of the
workforce. He was invited by friends to a drinking spree, left
the ship and thereafter was found dead due to drowning.
Thus the petitioner asked for compensation, however, the
testimonies by the chief engineer were dismissed by the
hearing officer due to lack of merit. Afterwards, a motion for
reconsideration was also filed before the Secretary of Labor,
but was denied again due to lack of merit.
Issue: Whether or not the compensation for Jose’s death is
constitutional. Whether or not Social Justice has a role in
this case.
Ruling: The Supreme Court granted the petition, granting
Estrella Ondoy 6,000 pesos as compensation for Jose’s
death, 300 pesos for burial fees and 600 pesos as attorney’s
fee with the costs against respondent, Ignacio.
Ratio Decidendi: The principle of social justice applied in this
case is a matter of protection, and not equality. The Supreme
Court recognized the right of petitioner to claim a
compensation from the respondent, as Jose did drown while
“in the actual performance of his duty.” To fortify this ruling,
the SC cited cases wherein, with accordance to the
constitutional scheme of social justice and protection to
labor, Workmen’s Compensation Act, which dealt with the
right of workers for compensation for personal injury, was
applied.