Land Bank of the Ph v Yatco Agricultural Enterprises (2014, Brion)

- Property: 27.58 ha land, Laguna

- Yatco owner of property
- Property placed under CARP by gov’t
- LBP: value of property at 1.1M
o Yatco: unacceptable, went to
- DAR: summary admin proceedings to determine just compensation
o Value: 16.5M
o LBP without verified or authentic doc to back up computation
- RTC as Special Agrarian Court: 22/sq m value || RTC Calamba, Branch 35 valuation
- CA: dismissed LBP appeal
o Parcels of land same case in agrarian case. Valuation OK
 Based on report of duly appointed commissioners
 Determination of value judicial function
- SC:
o LBP: property expropriated || CARP v civil cases: NAPOCOR exprop for insutrial purposes
 Valuation disregarded enumartions in RA 6657, DAR AO
o Yatco: valuations based on market value; considered all factors in law; issues raised factual
o Not a factual issue
 Resolution can be made by mere inquiry into law and jurisprudence
 No need to review evidence
o RTC SAC has power to decide value
 As long as according to RA
 But need not follow law to its minute detail, esp when faced with situtations that do not warrant
strict application
 Formula may be relaxed and such must be explained
o BUT valuation erroneous
 Courts may take judicial notice of certain facts
 For expediency and convenience; equivalent to proof
 G: no JN of contents of records of ther cases even when said case tried or pending in
same court before same judge
o X: if parties present them in evidence; or if court resolves to do so || Rule 129,
Sec 3
 RTC fully disregarded Sec 17 of RA 6657
 Simply relied on other branch’s valuation; no independent assessment
 Valuation by other branch inapplicable
 Purposes different; easement fee v CARP
 + time of taking diff (1997 v 2004 values)
o GRANTED. Reversed, set aside; remanded
Elsa Degayo v Cecila Dinglasan, et al (2015, Brion)

- Property: northeastern bank of Jalaud; 3.7 ha

o Registered in name of Degayo’s parents; used to be bounded on southwest by Jalaud that serves to
separate Dingle from Pototan, Iloilo
- Jalaud changed course, moved towards Pototan where another lot (7328, 15.3ha)
o 7328 decreased; property increased (now 5.5ha)
- Degayo and Jarencios, et al: accretion to lot; tenants cultivated area with corn, tobacco
- Dinglasan: abandoned riverbed; theirs
- RTC1: Dinglasan and Magbanuas v Jarencios, et al (tenants)
o Degayo not allowed to intervene but was able to participate as defense witness
o In favor of Dinglasan; final and executory
- RTC2: Degayo v Dinglasan et al
o In favor of Degayo
- CA: reversed
o Property abandoned riverbeds therefore belonging to Dinglasans and Ms, owners of property now
occupied by Jalaud
- SC:
o Res judicata
 Matter adjudged
 Parties should not be permitted to litgate same issue more than once
 Ownership settled in RTC1 case
o CA may take judicial notice of RTC1
 Courts have taken JN of proceedings because of their close connection with the matter in
controversy
 Whether or not case pending moot
 + Degayo herself repeatedly referred to RTC1 in pleadings in RTC2
 || Republic v CA: court will take judicial notice of
 own acts and records in same case,
 of facts est in prior proceedings in same cause,
 of authenticity of its records of another case bet same parties,
 of files of related cases in same court, and
 of public records on file in same court
o Degayo should have filed certiorari with CA
o DENIED. Costs against Degayo
People v Cristina Hernandez, ant (1996, Francisco)

- Hernandez introduced self as gen mgr of Ph-Thai Assn, Inc

o Recruited workers for placement abroad and asked if complainants wanted to work as factory workers in
Taipeh eh eh
- Complainants paid placement and passport fees but were unable to leave
- Hernandez refused to give back monies
- RTC: Hernandez: never met any but admitted she was pres of Ph-Thai only in nominal capacity; did not participate
in transxns since only in nominal capacity; Ph-Thai engaged in barong biz
o Hernandez guilty of illegal recruitment
o Already charged another ill recruitment case = evidence of scheme and strategy adopted by Hernandez
o Defense of denial cannot prevail over positive and clear testimonies of witnesses
- SC:
o Hernandez:
 distinguish bet admission that a particular witness if presented would testify to certain facts and
admission of facts themselves
 What was stipulated at hearing was merely that testimony of Chief Licensing Officer of
POEA would be to the effect that Hernandez not licensed nor auth
 No judicial admission
 Cannot stipulate facts in crim case
o Hernandez guilty of illegal recruitment
 Exh 1: Ph-Thai and/or Hernandez not licensed by POEA—offered and admitted w/o objection
o On admission
 Hernandez: hypothetical trial
 One of the parties move for continuance because of absence of W
 Opponent asks what facts to which W would testify. Stipulate that those are facts
 Lawyer: no, but will stipulate that if W were here, he would so testify
 First stipulation: stipulation of facts
 Second stipulation not; only same effect as if witness testified to facts
o Free to be contradicted
 But such distinction not applicable here
 Defense counsel already stipulated that from POEA record, Hernandez not licensed,
authorized AND POEA rep will confirm this fact
 = acquiescence to proposed stipulation = admission of non-possession of papers
o Stipulation of facts in crim case allowed
 Previously not so due to presumption of innocence until proven guilty and corollary duty of
prosec to prove guilt of accused beyond reasonable doubt
 New ROC: Rule 118, Sec 1: pre-trial; Sec 2: pre-trial to consider the ff: sof
 Also long been allowed || People v Mapa, People v Bocar: admissions were binding. Declarations
constitute judicial admissions, by virtue of which the prosec disnpensed with the introduction of
additional evidence and the defense waived the right to contest or dispute the veracity of
statements in exh
 No need to have it in writing and sgd ~ sof in pre-trial bc in open court, already written in
transcript
 Admission a waiver of rt to present evidence but such right can be waived
o JN of other ill recruitment case OK || Sec 3 (knowledge and no objection; even if erroneous, not fatal
o AFFIRMED. Penalties modified
Rustico Abay, Jr, Reynaldo Darilag v People (2008, Quisumbing)

- SLEX, Binan: Aban, Ricalde, Abay, Punzalan, Pascual, Darilag, Perello, p by direct participation; Reyes, Espeleta,
Camacho, p by indispensable coop
o On board Kapalaran Bus line, with bladed weapons, backup vehicle: owner
o Robbed four
o Shout Lumboy
o 7.30 pm—nighttime, band, motor vehicle; Espeta and Camacho prison guards; Aban a recidivist, Reyes a
recidivist, Darilag reitracion; Abay a recidivist, Punzalan a recidivist, Carpena a recidivist, Ricalde also
- RTC:
o Aban pleaded guilty; others, not guilty
o Andrade, witness: conductress; Tolentino: passenger. Somebody shouted ‘hold-up’, identified Abay,
Darilag, Reyes; Aban: prison guards took them and robbed other people (case: 4 th)
o Abay, Darilag, et al guilty of Highway Robbery
- CA: reversed, set aside: Espeleta, Camacho, Punzalan acquitted
- SC:
o Abay, Darilag: Aban not credible, testified on 22 Feb, not 17 Feb incident; no physical evidence; related
case where acquitted; alibi
o OSG: question of fact, Aban credible; positive testimonies by witnesses
o Abay, Darilag guilty
 EJ admission of conspirator confirmed in trial, it ceases to be hearsay; becomes judicial
admission, being testimony of eyewitness admissible in evidence against those it implicates
 Aban’s extrajudicial confession not instrumental in conviction
 BUT his court testimony reiterating declarations in extrajudicial admission
 Therefore, judicial admission
 Aban’s testimony not as credible as to Espeleta, et al
 Not similarly situated
 + conviction also based on Andrade and Tolentino’s positive ID
 Granted, Aban testified on 22 Feb incident, not 17 th, still OK. Same route and strategy. 22 a
replication of 17
 Failure to present physical evidence not fatal
 Physical evidence merely corroborative; there are credible witnesses
 Alibi cannot prevail over positive identification
 Elements of hway robbery clearly established
o AFFIRMED
People, piff-ee v Fernando Gutierrez (2009, Velasco)

- RTC:
o Prosecution: testimonies of police officers; chemistry report
 12 Sep, Ramos, Tarlac: shabu transaction tip. Fernando caught carrying bag, inspected in
presence of bgy capt: sacets of white crystalline substance (test: meth), laptop, phone, foil,
repacking plastic, weighing scale, check
o Defense: asked by neighbor to buy duck; neighbor had backpack of unknown contents; Fernando
admitted being Cortez’ companion when pointed to at some house
o Resumption of regularity in performance of duty
o Guilty of illegal possession of dangerous drugs
- CA: affirmed
- SC:
o Gutierrez guilty
 No reason to discredit polic officers
 No ill motive
 Evidence est fact that bona fide op undertaken || tip
 Testimonies OK
 Discrepancies: kubo, santol—extraneous matters
o More impt occurrence: scampering + Fernando holding bag with shabu, etc
 Two searches: SOP search immediately after arrest and one at police station
 Gutierrez failed to substantiate claims (framed, house, etc)
 + ownership of bag inconsequential
 Elements of illegal possession OK
 No lapses in safekeeping of seized items that affected integrity and evidentiary value
 Gutierrez veritably admits that crystalline substance were same substance sent for exam
 Gutierrez opted not to make an issue of whether the chain of custody of drugs broken
o Prosec and defense manifested that chain of custody of drug admitted
o Penalty OK
o DENIED. Affirmed
Theresita, Juan, Asuncion, Patrocinia, Ricardo, Gloria Dimaguila v Jose, Sonia Monteiro (2014, Mendoza)

- Monteiros: all co-owners of residential house and lot, 489 sq m

- RTC, Laguna: Monteiros and Noblezas v Dimaguilas: partition and damages || deed of sale executed by heirs of
Pedro Dimaguila (<Perfecto; Pedro share: 1/3 of northern half; was approached by F; geodetic engr survey)
o Dimaguilas: property long partitioned bet sons of Maria—Perfecto, Vitaliano. Heirs of Vitaliano
o Several motions. CA upheld orders of RTC
o Monteiros amended complaint: recovery of possession of portion of property; portion sold by heirs of P
 Adopted Dimgauilas’ admission that property already partitioned bet Perfecto, Vitaliano || deed
if ej partition; Vitaliano: north, Perfecto: south—partition observed by successors
o Dimaguilas denied admission that lot actually divided into N and S; Bilihan with Monteiros w/o metes, bds
o Monteiros entitled to possession of 1/3
 EJ partition: division share and share alike, but evidence aliunde apprecieated to show actual
division—observed and honored by heirs || cadastral map, list of claimants showing property
long been registered as lot northern and lot southern
 + manner of partition admitted in original answer
 No credence to claim that admission and error of former counsel; unaware of original answer
- CA: affirmed
- SC:
o Dimaguilas: no partition. Admission an error; Monteiros originally admitted no partition, being coo; even
if admission made, partition would then have been done by only some of coo, not all; Bilihan should not
have been admitted since no DST
o Questions of fact requiring looking into evidence, but OK. To put case to rest
o Property partitioned
 EJ not exact, but actually partitioned
 || cadastral: xpn to best evidence rule: certified true copies of original public records
 Admissions in original answer: Perfecto became sole and exclusive owner of S; Vitaliano N
o ROC, Sec 4, 129: admission made by party in course of proceedings in same case
does not require proof, may be contradicted only by showing it was made
through palpable mistake
o That lawyer made such mistake unacceptable—self-serving claim unsupported by
evidence; position made only 8 yrs after original answer
o || 1431, CC: through estoppel, admission is rendered conclusive upon person
making it, and cannot be denied or disporved as against the person relying
thereon
 Dimaguilas now estopped
o Sale valid
o DENIED. Affirmed
People, ee, v Victoriano dela Cruz, ant (2010, Nachura)

- RTC:
o Joel: Dela Cruz hitting wife outside house; dragged inside; shouting
o Dela Cruz: drunk. Wife hit window which stabbed her
o dela Cruz guilty of Parricide (wife)
- CA: affirmed
- SC:
o Dela Cruz: testimony of Joel merely circumstantial
o Dela Cruz guilty
 Elements of parricide: person killed; deceased killed by accused; relationship (key element)
 Key element of relationship admitted by Dela Cruz
 That married to wife, Anna
 Circumstantial evidence sufficient for conviction
 As long as more than one circumstance; facts from which inferences derived proven;
combination of all circumstances produces conviction beyond reasonable doubt
 Wound shows intent to kill
 Even if indeed accident, Victoriano not performing lawful act
 Physical maltreatment; therefore, not exempt || Art 12, EPC
o AFFIRMED