3. G.R. No.

112170 April 10, 1996

CESARIO URSUA, petitioner,
vs.
COURT OF APPEALS AND PEOPLE OF THE PHILIPPINES, respondents.
BELLOSILLO, J.:
FACTS: Petitioner Cesario Ursua was a Community Environment and Natural Resources Officer. Atty. Francis Palmones, counsel
for petitioner, asked his client, Ursua, to take his letter-request to the Office of the Ombudsman instead of his secretary, and
was advised that he could just sign as Oscar Perez (secretary) if ever he would be required to acknowledge receipt of the
complaint. However, it was soon learned that the one who introduced as Oscar Perez was actually the petitioner himself. This
matter was immediately reported to the Deputy Ombudsman who ordered that petitioner be accordingly charged in violation
of Sec.1 of Commonwealth Act No.142 as amended by R.A. No.6085 (An Act to Regulate the Use of Aliases).
ISSUE: Whether or not petitioner has violated Sec.1 of Commonwealth Act No.142 as amended by R.A.6085.
RULING: NO. The court ruled that there is no evidence showing that he had used or was intending to use that name in addition
to his real name. That name was used in an isolated transaction where he was not even legally required to expose his real
identity. The enactment of C.A. No. 142 as amended was made primarily to curb the common practice among the Chinese
adopting scores of different names and aliases which created tremendous confusion in the field of trade. C.A. No. 142 is a
penal statute and it should be construed strictly against the State in favor of the accused. The reason of this principle is the
tenderness of the law for the rights of individuals and the object is to establish a certain rule by conformity to which mankind,
would be safe, and the discretion of the court limited. Indeed, our mind cannot rest easy on the proposition that the petitioner
should be convicted on the law that does not clearly penalize the act done by him.

4. G.R. No. 79094 June 22, 1988

MANOLO P. FULE, petitioner,
vs.
THE HONORABLE COURT OF APPEALS, respondent.
MELENCIO-HERRERA, J.:
FACTS: Manolo Fule, petitioner, issued and made out a check. Moreover, the check was drawn in favor of the complaining
witness in remittance of collection. However, the check was presented for payment but the same was dishonored for the
reason that the said checking account was already closed. Thus, petitioner was convicted of Violation of Batas Pambansa Blg.
22 (The Bouncing Checks Law). On appeal, respondent Appellate Court upheld the Stipulation of Facts and affirmed the
judgment of conviction.
ISSUE: Whether or not the Court of Appeals erred in the decision of the Regional Trial Court convicting the petitioner of the
offense charged.
RULING: Yes, the basis of the conviction was based solely on the stipulation of facts made during the pre-trial on August 8,
1985, which was not signed by the petitioner, nor by his counsel, as stated in the 1985 Rules on Criminal Procedure – Section 4.
But, under the rule of statutory construction, penal statutes whether substantive and remedial or procedural are, by
consecrated rule, to be strictly applied against the government and liberally in favor of the accused. What the prosecution
should have done, upon discovering that the accused did not sign the Stipulation of Facts, as required by Rule 118, was to
submit evidence to establish the elements of the crime, instead of relying solely on the supposed admission of the accused in
the Stipulation of Facts. Under the circumstances obtaining in this case, the ends of justice require that evidence be presented
to determine the culpability of the accused. When a judgment has been entered by consent of an attorney without special
authority, it will sometimes be set aside or reopened. WHEREFORE, the judgment of respondent Appellate Court is REVERSED
and this case is hereby ordered RE-OPENED and REMANDED to the appropriate Branch of the Regional Trial Court.

1. A. M. No. MTJ-05-1610 September 26, 2005

DR. JOSE S. LUNA, Complainants,
vs.
JUDGE EDUARDO H. MIRAFUENTE, Municipal Trial Court, Buenavista, Marinduque, Respondent.
CARPIO MORALES, J.:
Facts: Dr. Luna filed a complaint for unlawful detainer against Sadiwa. Defendants filed an unverified answer seven days
beyond the reglementary period of 10 days from the service of the summons on them. Dr. Luna filed a Motion for judgment,
however respondent denied the judgment. Luna asserts that since defendants answer was unverified and belatedly filed,
respondent should, on motion of the plaintiffs, render judgment as warranted by the facts alleged in the complaint.
Respondent contends than his decision was premised on spirit of justice and fair play and that even if his judgement is
erroneous he may not be liable because it would render judicial office untenable because no one would try to interpret the law
in the process of administering law can be infallible in his judgment.
ISSUE: Whether or not Respondent is liable
Ruling: No, in the present case, respondent gave a liberal interpretation of the above-said Rule. Liberal interpretation or
construction of the law or rules, however, is not a free commodity that may be availed of in all instances under the cloak of
rendering justice. Liberality in the interpretation and application of Rules applies only in proper cases and under justifiable
causes and circumstances. While it is true that litigation is not a game of technicalities, it is equally true that every case must
be prosecuted in accordance with the prescribed procedure to insure an orderly and speedy administration of justice
However, respondent’s acts neither constitute grave misconduct nor gross ignorance of the law.
For it to process, the assailed order, decision or actuation of judge must not only be found erroneous but most importantly it
must be established that it was acted in bad faith, dishonesty and some other evil motive.
2. G.R. No. 113092 September 1, 1994
MARTIN CENTENO, petitioner,
vs.
HON. VICTORIA VILLALON-PORNILLOS, Presiding Judge of the Regional Trial Court of Malolos, Bulacan, Branch 10, and THE
PEOPLE OF THE PHILIPPINES, respondents.
Santiago V. Marcos, Jr. for petitioner.
REGALADO, J.:
Facts: Martin Centeno, Petitioner, is the head of Samahan ng Katandaan ng Nayon ng Tikay who solicited from judge Angeles
for the renovation of Tikay Chapel. It is supposed that solicitation were not permitted by the Department of Social Welfare and
Development. The petitioner was charged for the violation of PD 1564 otherwise known as Solicitation Permit Law, who then
filed a motion to quash and alleged that PD 1564 applies only to solicitations made for charitable or public welfare purposes
and not those made for a religious purpose. 
ISSUE: Whether or not solicitations for religious purposes are within the ambit of PD 1564
Ruling: NO, penal laws are to be construed strictly against the State and liberally in favor of the accused, they are not to be
extended or enlarged by implications. Thus, in the interpretation of a penal statute, the tendency is to subject it to careful
scrutiny and to construe it with such strictness as to safeguard the rights of the accused. If the statute is ambiguous and admits
of two reasonable but contradictory constructions, that which operates in favor of a party accused under its provisions is to be
preferred.
The principle is that acts in and of themselves innocent and lawful cannot be held to be criminal unless there is a clear and
unequivocal expression of the legislative intent to make them such. Whatever is not plainly within the provisions of a penal
statute should be regarded as without its intendment.

5. G.R. Nos. 136149-51               September 19, 2000

PEOPLE OF THE PHILIPPINES, appellee,
vs.
WALPAN LADJAALAM y MIHAJIL alias "WARPAN," appellant.
PANGANIBAN, J.:
FACTS: Ladjaalam was charged and convicted of the crime of Direct Assault with Multiple Attempted Homicide for firing on
unlicensed gun at several policemen who were about to enter his house to serve search warrant. Under the same
circumstance, he was likewise charged and convicted for the crime Illegal Possession of Firearm and Ammunition penalized
under PD 1866, as amended by RA 8294 based on the records showing that appellant had not filed any application for license
to possess firearm and ammunition, nor has he been given authority to carry firearms.
ISSUE: W/N accused-appellant can be convicted of illegal Possession of Firearm under RA 8294 when he used said firearm in
the commission of another crime.
HELD: No. Republic Act No. 8294 penalizes simple illegal possession of firearms, provided that the person arrested committed
"no other crime." Furthermore, if the person is held liable for murder or homicide, illegal possession of firearms is an
aggravating circumstance, but not a separate offense. Hence, where an accused was convicted of direct assault with multiple
attempted homicide for firing an unlicensed M-14 rifle, he cannot be held liable for the separate offense of illegal possession of
firearms. Moreover, penal laws are construed liberally in favor of the accused. In this case, the plain meaning of RA 8294’s
simple language is most favorable to herein appellant. Verily, no other interpretation is justified, for the language of the new
law demonstrates the legislative intent to favor the accused. Accordingly, appellant cannot be convicted of two separate
offenses of illegal possession of firearms and direct assault with attempted homicide. Moreover, since the crime committed
was direct assault and not homicide or murder, illegal possession of firearms cannot be deemed an aggravating circumstance.

6. G.R. No. 120082 September 11, 1996

MACTAN CEBU INTERNATIONAL AIRPORT AUTHORITY, petitioner,
vs.
HON. FERDINAND J. MARCOS, in his capacity as the Presiding Judge of the Regional Trial Court, Branch 20, Cebu City, THE
CITY OF CEBU, represented by its Mayor HON. TOMAS R. OSMEÑA, and EUSTAQUIO B. CESA, respondents.
DAVIDE, JR., J.: 
FACTS: Petitioner Mactan Cebu International Airport Authority (MCIAA) enjoyed the privilege of exemption from payment of
realty taxes in accordance with Section 14 of its Charter, R.A. No. 6958. However, the Office of the Treasurer demanded
payment for realty taxes on several parcels of land belonging to the petitioner. Petitioner objected to such demand for
payment as baseless and unjustified. Respondent City refused to cancel and set aside petitioner’s realty tax account, insisting
that the MCIAA is a government-controlled corporation whose tax exemption privilege has been withdrawn by virtue of
Sections 193 and 234 of the Local Government Code.
ISSUE: W/N petitioner is exempted from payment of realty taxes
HELD: No, tax statutes must be construed strictly against the government and liberally in favor of the taxpayer. But since taxes
are what we pay for civilized society, or are the lifeblood of the nation, the law frowns against exemptions from taxation and
statutes granting tax exemptions are thus construed against the taxpayers and liberally in favor of the taxing authority. A claim
of exemption from tax payment must be clearly shown and based on language in the law too plain to be mistaken. Elsewise
stated, taxation is the rule, exemption therefrom is the exception. There can be no question that under Section 14 of R.A. No.
6958 the petitioner is exempt from the payment of realty taxes imposed by the National Government or any of its political
subdivisions, agencies, and instrumentalities. Nevertheless, since taxation is the rule and exemption therefrom the exception,
the exemption may thus be withdrawn at the pleasure of the taxing authority.
7. G.R. No. 175188               July 15, 2015
COMMISSIONER OF INTERNAL REVENUE, Petitioner,
vs.
LA TONDENA DISTILLERS, INC. (LTDI [now GINEBRA SAN MIGUEL], Respondent.
DEL CASTILLO, J.: 
FACTS: Respondent La Tondena Distillers, Inc. entered into a Plan of Merger with Sugarland Beverage Corporation (SBC), SMC
Juice, Inc. (SMCJI), and Metro Bottled Water Corporation (MBWC). Consequently, the assets and liabilities of the absorbed
corporations were transferred to respondent, the surviving corporation and later changed its corporate name to Ginebra San
Miguel, Inc. (GSMI). The respondent requested with the BIR for a confirmation of the tax free nature of the said merger,
however the BIR states that pursuant to Section 40(C)(2) and (6)(b) of the 1997 National Internal Revenue Code (NIRC) M, no
gain  or loss shall be recognized by the absorbed corporations, however, transfer of assets shall be subject to Documentary
Stamp Tax (DST) under Sec. 196 of the NIRC, thus respondent paid the BIR DST. The respondent claiming that it is exempt from
paying DST and filed an administrative claim for refund or tax credit. The CTA rendered a decision finding respondent entitled
to its claim for tax refund or tax credit.
ISSUE: W/N the CTA erred in ruling that respondent is exempt from payment of DST.
RULING: NO. The petitioner's contention that respondent cannot claim Exemption under RA No. 9243 as this was enacted only
in 2004 or after respondent's tax liability accrued. Respondent did not file its claim for tax refund or tax credit based on the
Exemption found in RA No. 9243. Rather, it filed a claim of tax refund or tax credit on the ground that Section 196 of the NIRC
does not include the transfer of real property pursuant to merger. RA 9243 was mentioned only to emphasize that "the
enactment of the said law now removes any doubt and had made clear that the transfer of real properties as a consequence of
merger or consolidation is not subject to DST. The Court found no error on the part of CTA in granting respondent's claim for
tax refund or tax credit representing its erroneously paid DST. 
The Court stress that taxes must not be imposed beyond what the law expressly and clearly declares as tax laws must be
construed strictly against the State and liberally in favor of the taxpayer.

8. G.R. No. L-23623 June 30, 1977

ACTING COMMISSIONER OF CUSTOMS, petitioner,
vs.
MANILA ELECTRIC COMPANY and COURT OF TAX APPEALS, respondents.
FERNANDO, J.:
FACTS: The appealed decision set forth that petitioner MERALCO, now private respondent, in appealing from a determination
by the then Acting Commissioner of Custom, now petitioner,, "claims that it is exempt from the special import tax not only by
virtue of Sec. 6 of RA No. 1943, which exempts from said tax equipment and spare parts for use in industries, but also under
Par. 9, Part TWO of its franchise , which expressly exempts its insulator from all taxes of whatever kind and nature. " It then
made reference to the franchise of the private respondent Meralco. 
ISSUE: W/N the claim for exemption from tax statute be strictly construed against the respondent MERALCO.
RULING: No. In this case, the Court found the provision of Sec. 186-A, whenever a tax-free product is utilized, all encompassing
to comprehend tax-free raw materials, even if imported. Where the law provided no qualification for the granting of the
privilege, the court is not at liberty to supply any.
The law frowns on exemption from taxation, hence, an exempting provision should be construed strictly. However, it is equally
a recognized principle that where the provision of the law is clear and unambiguous, so that there is no occasion for the court's
seeking the legislative intent, the law must be taken as it is devoid of judicial addition or subtraction. 

9. G.R. No. 168856               August 29, 2012

EASTERN TELECOMMUNICATIONS PHILIPPINES, INC., Petitioner,
vs.
THE COMMISSIONER OF INTERNAL REVENUE, Respondents.
MENDOZA, J.:
FACTS: Petitioner, Eastern Telecommunications Philippines, Inc. (ETPI) is a duly authorized corporation engaged in
telecommunications services and various international service agreements with international non-resident
telecommunications companies. ETPI believes that it is entitled to a refund for the unutilized input VAT attributable to its zero-
rated sales, ETPI filed with the Bureau of Internal Revenue (BIR) an administrative claim for refund and/or tax credit
representing excess input VAT derived from its zero-rated sales. In a petition for review, the CTA (CTA-Division) found that ETPI
failed to imprint the word "zero-rated" on the face of its VAT invoices or receipts. CTA-En Banc affirmed the decision of the
CTA-Division.
ISSUE: W/N the CTA-En Banc erred when it sanctioned the denial of petitioner’s claim for refund.
RULING: NO. Imprinting of the word "zero-rated" on the invoices or receipts is required. The following invoicing requirements
enumerated in Section 4.108-1 of Revenue Regulations No. 7-95 must be observed by all VAT-registered taxpayers. A
consequence of failing to comply with the invoicing requirements is the denial of the claim for tax refund or tax credit, as
stated in Revenue Memorandum Circular No. 42-2003.
Also, Section 244 of the NIRC explicitly grants the Secretary of Finance the authority to promulgate the necessary rules and
regulations for the effective enforcement of the provisions of the tax code. Such rules and regulations "deserve to be given
weight and respect by the courts in view of the rule-making authority given to those who formulate them and their specific
expertise in their respective fields."
 
10. G.R. No. 175430               June 18, 2012
REPUBLIC OF THE PHILIPPINES, Petitioner,
vs.
KERRY LAO ONG, Respondent.
DEL CASTILLO, J.:
FACTS: Respondent Kerry Lao Ong, filed a Petition for Naturalization. He is registered as a resident alien and possesses an alien
certificate of registration and a native-born certificate of residence from the Bureau of Immigration. Ong alleged in his petition
that he has been a "businessman/business manager". The trial court granted Ong’s petition. The Republic, through the Solicitor
General, appealed to the CA. The appellate court dismissed the Republic’s appeal.
ISSUE: W/N Ong has proved that he has some known lucrative trade, profession or lawful occupation.
RULING: NO. The courts must always be mindful that naturalization proceedings are imbued with the highest public interest.
Naturalization laws should be rigidly enforced and strictly construed in favor of the government and against the applicant. The
burden of proof rests upon the applicant to show full and complete compliance with the requirements of law. In the case at
bar, the controversy revolves around respondent Ong’s compliance with the qualification found in Section 2, fourth paragraph
of the Revised Naturalization Law. Ong is a “businessman engaged in lawful trade and business since 1989” but did not cite the
evidence, which supports such finding. After poring over the records, the Court finds that the reason for the lack of citation is
the absence of evidence to support such a conclusion.

11. G.R. No. 127240             March 27, 2000

ONG CHIA, petitioner,
vs.
REPUBLIC OF THE PHILIPPINES and THE COURT OF APPEALS, respondents.
MENDOZA, J.:
Facts: Petitioner was born in Amoy, China. In 1932, as a nine-year old boy, he arrived at the port of Manila. Since then, he has
stayed in the Philippines where he found employment, started his own business, and married a Filipina, with whom he had
four children. He then filed a verified petition to be admitted as a Filipino citizen under C.A. No. 473, otherwise known as the
Revised Naturalization Law, as amended, at the age of 66. The trial court granted the petition, but the Republic, through the
Office of the Solicitor General, appealed from that decision and the Court of Appeals reversed the decision of the trial court.
Issue: Whether or not the documents annexed by the State to its appellant's brief without having been presented and formally
offered as evidence under Rule 132, Section 34 of the Revised Rules on Evidence justified the reversal of the Trial Court’s
decision.
Ruling: Yes, petitioner failed to note Rule #143 of the rules of court providing that These rules shall not apply to land
registration, cadastral and election cases, naturalization and insolvency proceedings, and other cases not herein provided for,
except by analogy or in a suppletory character and whenever practicable and convenient. That is not the case here, since
reliance upon the documents presented by the State for the first time on appeal, in fact, appears to be the more practical and
convenient course of action considering that decisions in naturalization proceedings are not covered by the rule on res
judicata. The effect of petitioner’s failure to include his address in his petition in accordance with Sec. 7 of C.A. 473 which is the
same address appearing on his immigrant’s certificate of residence which forms part as an annex of his petition for
naturalization, however, petitioner insisted that his full publication of his Immigrants certificate of residence already constitute
substantial compliance with the aforesaid provision. It is settled that naturalization laws shall be construed in favor of the State
and against the applicant, his failure to indicate such address already defeated his argument of substantial compliance with the
requirement of the law. Hence, petition was denied for lack of merit.
 
12. G.R. No. L-30058               March 28, 1969
LUIS G. DE CASTRO, petitioner,
vs.
JULIAN G. GINETE and UBALDO Y. ARCANGEL Judge of the Court of First Instance of Sorsogon, 10th Judicial District, Branch
I, respondents.
ZALDIVAR, J.: 
Facts: Petitioner de Castro and respondent Ginete were opposing candidates for the office of municipal mayor of Bulan,
Sorsogon to which the petitioner was declared winner and both parties filed their motion of protest against each other’s
candidacy. After the revision of all ballots, de castro filed a motion to dismiss the protest upon the ground of estoppel.  It is
alleged in his motion that Ginete filed his protest after acknowledging his victory over him. Ginete wrote to de Castro
containing such congratulatory words for his victory and upon inauguration.
Issue: W/N Ginete’s conduct of congratulating petitioner through a letter constitutes estoppel that would prevent him to
question De Castro’s election as Municipal Mayor of Bulan Sorsogon
Ruling: No, the Court stated that Ginete’s actions are just manifestation of him being a law-abiding citizen that respects the
proclamation of the board of canvassers. There are four (4) elements of estoppel by conduct namely; 1) that there must have
been a representation or concealment of material facts; 2) that the representation must have been made with knowledge of
the facts; 3) that the party to whom it was made must have been ignorant of the truth of the matter; and 4) that it must have
been made with intention that the other party would act upon it. As to the present case, these elements were not found by
the court as to the facts presented by petitioner. Hence, the act of a losing candidate of recognizing the one who is proclaimed
the winner should not bar the losing candidate from questioning the validity of the elect ion of the winner in the manner
provided by law. 
 

13. G.R. No. L-23139      December 17, 1966

MOBIL PHILIPPINES EXPLORATION, INC., plaintiff-appellant,
vs.
CUSTOMS ARRASTRE SERVICE and BUREAU of CUSTOMS, defendants-appellees.
Alejandro Basin, Jr. and Associates for plaintiff-appellant.
Felipe T. Cuison for defendants-appellees.
BENGZON, J.P., J.:
FACTS: Four cases of rotary drill parts were shipped from abroad on S.S “Leoville” consigned to Mobil Philippines Exploration,
Inc., Manila. It was discharged to the custody of the Customs Arrastre Service, the unit of the Bureau of Customs then handling
arrastre operations therein. The Customs Arrastre Service later delivered to the broker of the consignee three cases only.
Petitioner filed suit in the Court of First Instance of Manila against the Customs Arrastre Service and the Bureau of Customs to
recover the value of the undelivered case plus other damages. The respondents filed a motion to dismiss on the ground that
not being persons under the law, they cannot be sued.
ISSUE: Whether or not the defendants can invoke state immunity.
HELD: Yes, The Bureau of Customs is part of the Department of Finance with no personality of its own apart from that of the
national government. Its primary function is governmental, that of assessing and collecting lawful revenues from imported
articles and all other tariff and customs, duties, fees, charges, fines and penalties. To this function, arrastre service is a
necessary incident, thus, from the provision authorizing the Bureau of Customs to lease arrastre operations to private parties,
the Court sees no authority to sue the said Bureau in the instances where it undertakes to conduct said operation itself. The
Bureau of Customs, is immune from suit, there being no statute to the contrary. It must be remembered that statutory
provisions waiving State immunity from suit are strictly construed and that waiver of immunity, being in derogation of
sovereignty, will not be lightly inferred.

14. G.R. No. 133706            May 7, 2002

FRANCISCO ESTOLAS, petitioner,
vs.
ADOLFO MABALOT, respondent.
PANGANIBAN, J.:
FACTS: A Certificate of Land Transfer (CLT) was issued in favor of respondent over a 5,000 square meter lot. Needing money for
medical treatment, respondent passed on the subject land to the petitioner for the amount of P5,800.00 and P200.00 worth of
rice. According to respondent, there was only a verbal mortgage; while according to petitioner, a sale had taken place. Acting
on the transfer, the DAR officials authorized the survey and issuance of an Emancipation Patent, leading to the issuance of a
Transfer Certificate of Title No. 3736 in favor of the petitioner. Respondent filed a Complaint against the petitioner before the
Barangay Lupon in Pangasinan for the purpose of redeeming the subject land.
ISSUE: Whether or not the Court agrees about the non-transferability of Land under PD 27.
HELD: No. The Court does not agree. PD 27 specifically provides that title to land acquired pursuant to its mandate or to that of
the Land Reform Program of the government shall not be transferable except to the grantee’s heirs by hereditary succession,
or back to the government by other legal means. Upon the promulgation of PD 27, farmer-tenants were deemed owners of the
land they were cultivating. Their emancipation gave them the rights to possess, cultivate and enjoy the landholding for
themselves. These rights were granted by the government to them as the tillers and to no other. Thus, to insure their
continuous possession and enjoyment of the property, they could not, under the law, effect any transfer except back to the
government or, by hereditary succession, to their successors. The Court has always ruled that agrarian laws must be
interpreted liberally in favor of the grantees in order to give full force and effect to the clear intent of such laws: "to achieve a
dignified existence for the small farmers"; and to make them "more independent, self-reliant and responsible citizens, and a
source of genuine strength in our democratic society."

15. G.R. No. L-21905             March 31, 1966

EUFRONIO J. LLANTO, petitioner-appellant,
vs.
MOHAMAD ALI DIMAPORO, et al, respondents-appellees.
SANCHEZ, J.:
FACTS: Resolution No. 7, Series of 1960, adopted by the Provincial Board of Lanao del Norte on January 6, 1960, reverted the
1960-1961 salary appropriation for the position of Assistant Provincial Assessor to the general fund. In effect, that position
then held by petitioner was abolished. Appeals to the Commissioner of Civil Service, the Secretary of Finance, the Secretary of
Justice, the Auditor General and the President of the Philippines were of no avail. Petitioner came to court on mandamus.
ISSUE: Whether or not the petitioner can sought the annulment of the Resolution No. 7, Series of 1960.
RULING: No. Petitioner also advances the theory that the provincial board resolution abolishing his position is not effective,
because it did not bear the stamp of approval of the Secretary of Finance. The necessity for such approval, however, was done
away with by the passage of Republic Act No. 2264, otherwise known as the Local Autonomy Act. Section 3(a) of the Local
Autonomy Act gives the provincial board the power to appropriate money having in view the general welfare of the province
and its inhabitants. Concomitant to this express power is the implied power to withdraw unexpended money already
appropriated. Implied power of a province, a city or municipality shall be liberally construed in its favor. Any fair and
reasonable doubt as to the existence of the power should be interpreted in favor of the local government and it shall be
presumed to exist.

16. G.R. No. 46623 December 7, 1939

MARCIAL KASILAG, petitioner,
vs.
RAFAELA RODRIGUEZ, URBANO ROQUE, SEVERO MAPILISAN and IGNACIO DEL ROSARIO, respondents.
IMPERIAL, J.:
Facts: The parties entered into a contract of loan to which has an accompanying accessory contract of mortgage. The plaintiffs-
respondents are the owners of the disputed land, with its improvements, in common ownership with their brother Gavino
Rodriguez. The Petitioner accepted the contract of mortgage and took possession of the land believing that there are no
violations to the prohibitions in the alienation of lands. Thus, he has no knowledge that the enjoyment of the fruits of the land
is an element of the credit transaction of antichresis. The court of First Instance of Bataan held that the contract is entirely null
and void and without effect to which the Court of Appeals affirmed with modification.
Issue: Whether or not the Petitioner is deemed to be a possessor in good faith of the land.
Ruling: Yes. The accessory contract of mortgage of the improvements of on the land is valid. The verbal contract of antichresis
agreed upon is deemed null and void. Sec 433 of the Civil Code of the Philippines provides “Every person who is unaware of
any flaw in his title or in the manner of its acquisition by which it is invalidated shall be deemed a possessor of good faith.” And
in this case, the petitioner acted in good faith. Good faith maybe a basis of excusable ignorance of the law, the petitioner acted
in good faith in his enjoyment of the fruits of the land to which was done through his apparent acquisition thereof.

17. G.R. No. 100970 September 2, 1992

FINMAN GENERAL ASSURANCE CORPORATION, petitioner,
vs.
THE HONORABLE COURT OF APPEALS and JULIA SURPOSA, respondents.
NOCON, J.:
FACTS: The deceased, Carlie Surposa was insured with petitioner Finman General Assurance Corporation. The insured, Carlie
Surposa, died as a result of a stab wound inflicted by one of the three (3) unidentified men. Thereafter, private respondent and
the other beneficiaries of said insurance policy filed a written notice of claim with the petitioner insurance company which
denied said claim contending that murder and assault are not within the scope of the coverage of the insurance policy.
Subsequently, private respondent filed a complaint with the Insurance Commission wherein the judgment is ordering
respondent to pay complainant. Hence, petitioner filed this petition alleging grave abuse of discretion on the part of the
appellate court.
ISSUE:  W/N death resulting from assault or murder deemed included in the terms “accident” and “accidental”
RULING: Yes. The terms "accident" and "accidental" as used in insurance contracts have not acquired any technical meaning,
and are construed by the courts in their ordinary and common acceptation. Thus, the terms have been taken to mean that
which happen by chance or fortuitously, without intention and design, and which is unexpected, unusual, and unforeseen. An
accident is an event that takes place without one's foresight or expectation — an event that proceeds from an unknown cause,
or is an unusual effect of a known cause and, therefore, not expected. Moreover, it is well settled that contracts of insurance
are to be construed liberally in favor of the insured and strictly against the insurer. Thus ambiguity in the words of an insurance
contract should be interpreted in favor of its beneficiary.

18. G.R. No. 176832               May 21, 2009

GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner,
vs.
MARIAN T. VICENCIO Respondent.
PUNO, CJ.:
FACTS: Judge Vicencio, respondent’s husband, died. Per his Death Certificate, the immediate cause of his death was
Cardiopulmonary Arrest, and the antecedent cause was T/C Fatal Arrythmia. Thereafter, Mrs. Vicencio applied for the death
benefits of her late husband with petitioner Government Service Insurance System (GSIS) but her application was denied by
Mr. Marcelino S. Alejo, Manager of the GSIS Employees Compensation Department, on the ground that the illness which
caused Judge Vicencio’s death is not considered an occupational disease and there is no showing that his work as RTC Judge
has increased his risk of contracting said ailment. Respondent filed a petition before the Court of Appeals where GSIS is
ordered to grant the claim for the death benefits of Judge Honorato S. Vicencio under the Employees Compensation Act.
Hence, this petition.
ISSUE: W/N respondent Mrs. Vicencio’s claim for death benefits under Presidential Decree No. 626 (P.D. No. 626), as amended,
is compensable.
RULING: Yes. P.D. No. 626, as amended, defines compensable sickness as "any illness definitely accepted as an occupational
disease listed by the Commission, or any illness caused by employment subject to proof by the employee that the risk of
contracting the same is increased by the working conditions."
P.D. No. 626, as amended, is a social legislation whose primordial purpose is to provide meaningful protection to the working
class against the hazards of disability, illness and other contingencies resulting in the loss of income. Thus, the official agents
charged by law to implement social justice guaranteed by the Constitution should adopt a liberal attitude in favor of the
employee in deciding claims for compensability. Moreover, as the public agency charged by law in implementing P.D. No. 626,
petitioner GSIS should not lose sight of the fact that the constitutional guarantee of social justice towards labor demands a
liberal attitude in favor of the employee in deciding claims for compensability. 

19. G.R. No. L-44899 April 22, 1981

MARIA E. MANAHAN, petitioner,
vs.
EMPLOYEES' COMPENSATION COMMISSION and GSIS (LAS PIÑAS MUNICIPAL HIGH SCHOOL), respondents.
FERNANDEZ, J.:
Facts: Nazario Manahan, the deceased husband of the petitioner, died of "Enteric Fever" while employed as a classroom
teacher in Las Pinas Municipal High School. The Petitioner filed for a claim with Government Service Insurance (GSI) for death
benefit under PD 626. The GSI denied the claim upon discovering that the ailment of the deceased is not an occupational
disease on the ground that enteric fever is similar in effect to typhoid fever, in the sense that both are produced by Salmonella
organisms. The ECC affirmed the decision of the GSI.
Issue: W/N the Workmen's Compensation should be resolved in favor of the worker
Ruling: Yes. The provisions of the Workmen's Compensation Act in this case, the presumption of compensability subsists in
favor of the claimant. In the case at bar, the Supreme Court maintained that it should be resolved in favor of the worker, and
that social legislations - like the Workmen's Compensation Act and the Labor Code should be liberally construed to attain their
laudable objective, to give relief to the workman and/or his dependents in the event that the former should die or sustain an
injury

20. G.R. No. 78617 June 18, 1990

SALVADOR LAZO, petitioner,
vs.
EMPLOYEES' COMPENSATION COMMISSION & GOVERNMENT SERVICE INSURANCE SYSTEM (CENTRAL BANK OF THE
PHILIPPINES), respondents.
Oscar P. Paguinto for petitioner.
PADILLA, J.:
Facts: Petitioner Lazo, a security guard of the Central Bank of the Philippines assigned to its main office in Malate, Manila. His
regular tour of duty is from 2:00 in the afternoon to 10:00 in the evening. On June 18, 1986, he rendered an overtime duty
from 2:00 in the afternoon up to 5:00 in the morning. On his way home, the passenger jeepney he was riding involved in an
accident due to slippery road; he then sustained injuries. Petitioner filed a claim for disability benefits but the GSIS denied for
the reason that he was not at his workplace performing his duties when the incident occurred
Issue: W/N the injuries the petitioner sustained due to the vehicular accident should be construed as "arising out of or in the
course of employment" and thus, compensable
Ruling: Yes. In the case at bar, it can be seen that petitioner left his station at the Central Bank several hours after he was asked
to go on overtime. He went home and there is no evidence on record that petitioner deviated from his usual, regular
homeward route or that interruptions occurred in the journey. While the presumption of compensability and theory of
aggravation under the Workmen's Compensation Act may have been abandoned under the New Labor Code, it is significant
that the liberality of the law in general in favor of the working man still subsists. As agent charged by the law to implement
social justice guaranteed and secured by the Constitution, the Employees Compensation Commission should adopt a liberal
attitude in favor of the employee in deciding claims for compensability, especially where there is some basis in the facts for
inferring a work connection to the accident.

21. G.R. No. 96422 February 28, 1994

FRANCISCO S. TANTUICO, JR., petitioner,
vs.
HON. EUFEMIO DOMINGO, in his capacity as Chairman of the Commission on Audit, ESTELITO SALVADOR, MARGARITO
SILOT, VALENTINA EUSTAQUIO, ANICIA CHICO and GERMINIA PASCO, respondents.
QUIASON, J.:
FACTS: Petitioner Tantuico(ex-chairman of COA) applied for clearance from all money, property and other accountabilities in
preparation for his retirement. He obtained the clearance applied for. The clearance had all the required signatures and bore a
certification that petitioner was cleared from money, property and/or other accountabilities by this Commission. Petitioner
argues that notwithstanding the clearances previously issued (by COA), and respondent Chairman’s certification that petitioner
had been cleared of money and property accountability, respondent Chairman still refuses to release the remaining half of his
retirement benefits 
ISSUE: Whether or not the withholding of one-half of petitioner’s retirement benefits is valid.
HELD: NO. Petition was granted insofar as it seeks to compel respondent Chairman of the COA to pay petitioner’s retirement
benefits in full and his monthly pensions.
Under Section 4 of R.A. No. 1568 (An Act to Provide Life Pension to the Auditor General and the Chairman or Any Member of
the Commission of Elections), the benefits granted by said law to the Auditor General and the Chairman and Members of the
Commission on Elections shall not be subject to garnishment, levy or execution. Likewise, under Section 33 of P.D. No. 1146, as
amended, the benefits granted thereunder “shall not be subject, among others, to attachment, garnishment, levy or other
processes.”
Well settled is the rule that retirement laws are liberally interpreted in favor of the retiree because the intention is to
provide for the retiree’s sustenance and comfort, when he is no longer capable of earning his livelihood.
It has been seven years since petitioner’s retirement. Since then he was only paid half of his retirement benefits, with the other
half being withheld despite the issuance of two clearances and the approval of his retirement application.

22. G.R. No. 154243             December 22, 2007

DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO, ACTING CHIEF PHILIPPINE NATIONAL POLICE (PNP), DIRECTORATE FOR
PERSONNEL AND RECORDS MANAGEMENT (DPRM), INSPECTOR GENERAL, P/CHIEF SUPT. RAMSEY OCAMPO and P/SUPT.
ELMER REJANO, petitioners,
vs.
P/SENIOR INSPECTOR JOSE J. ASAYO, respondent.
AUSTRIA-MARTINEZ, J.:
FACTS: Before the Court is respondent’s Motion for Reconsideration of the Decision. In said Decision, the Court granted the
petition, holding that the Philippine National Police (PNP) Chief had jurisdiction to take cognizance of the civilian complaint
against respondent and that the latter was accorded due process during the summary hearing. Respondent insists that the
summary hearing officer did not conduct any hearing at all but only relied on the affidavits and pleadings submitted to him,
without propounding further questions to complainant's witnesses, or calling in other witnesses such as PO2 Villarama.
ISSUE: W/N the decision should be reconsidered for the reason that the evidence presented at the summary hearing does not
prove that respondent is guilty of the charges against him.
HELD: No. It should be borne in mind that the fact that there was no full-blown trial before the summary hearing officer does
not invalidate said proceedings. Moreover, to resolve the issue, respondent would have the Court re-calibrate the weight of
evidence presented before the summary hearing officer, arguing that said evidence is insufficient to prove respondent's guilt of
the charges against him. The general rule is that the filing of a petition for certiorari does not toll the running of the period to
appeal. However, Section 1, Rule 1 of the Rules of Court provides that the Rules shall be liberally construed in order to
promote their objective of securing a just, speedy and inexpensive disposition of every action and proceeding. In Ginete v.
Court of Appeals and Sanchez v. Court of Appeals, the Court saw it proper to suspend rules of procedure in order to promote
substantial justice where matters of life, liberty, honor or property, among other instances, are at stake. The present case
clearly involves the honor of a police officer who has rendered years of service to the country.

23. G.R. Nos. L-16693-4-5             January 30, 1962

GODOFREDO I. MOSUELA-(34), GREGORIO C. MON-(35) and HONORIO L. PADILLA-(36), petitioners-appellees,
vs.
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, respondent-appellant.
REYES, J.B.L., J.:
FACTS: Petitioner and respondent entered into agreements for the construction of a condominium project owned by
respondent with petitioner as contractor. In the course of the project’s construction, differences with respect to billings arose
between the parties. Petitioner thus filed a complaint for compulsory arbitration before the CIAC claiming payment for
approximately P97 Million as the outstanding balance due from respondent pursuant to the agreements. The CIAC rendered a
decision partially granting both petitioner and respondent’s claims in favor of petitioner. This award was affirmed by the Court
of Appeals. Thereafter, the Supreme Court promulgated its Decision affirming the judgment of the Court of Appeals and lifting
the TRO that was then still in effect. It became final and executory.
Respondent however filed a Petition with the Court of Appeals to restrain the scheduled execution sale and to nullify the
orders of the CIAC issued pursuant thereto which the CA granted. Petitioner’s remedy is to file a petition for review under Rule
45 of the Revised Rules of Civil Procedure which centers on attempts, regrettably entertained by respondent CA, to thwart the
execution of a final and executory decision of the SC. Respondent then asserts that prematurity, multiplicity of suits and lack of
respect for the hierarchy of courts afflict the petition, thereby necessitating its dismissal.
ISSUE: W/N the Court of Appeals gravely abused its discretion.
RULING: YES. Rule 1, Section 6 of the Rules of Court provides that the Rules shall be liberally construed in order to promote
their objective of securing a just, speedy and inexpensive disposition of every action and proceeding. We have at times relaxed
procedural rules in the interest of substantial justice.
But from the outset, it bears stressing that the subject of petitioner and respondent’s petitions is the execution of a final
judgment was affirmed by no less than this Court. This being so, the appellate court should have been doubly careful about
entertaining an obviously dilatory petition intended merely to delay the satisfaction of the judgment. Any lower court or
tribunal that trifles with the execution of a final and executory judgment of the Supreme Court flirts with insulting the highest
court of the land. While we do not diminish the availability of judicial remedies to the execution of final judgments of this
Court, as may be sanctioned under the Rules of Court, such actions could only prosper if they have basis in fact and in law. Any
court or tribunal that entertains such baseless actions designed to thwart the execution of final judgments acts with grave
abuse of discretion tantamount to lack of jurisdiction. It is the positive duty of every court of the land to give full recognition
and effect to final and executory decisions, much less those rendered by the Supreme Court.
The abuse of discretion amounting to lack or excess of jurisdiction in this case was made manifest by the fact that the appellate
court not only took cognizance of the case and issued the assailed restraining order. It eventually decided the case in
petitioner’s (respondent herein) favor as well notwithstanding the dearth of any basis for doing so.
24.
REVISED RULES ON EVIDENCE (Rules 128-134, Rules of Court)
AS AMENDED PER RESOLUTION ADOPTED ON MARCH 14, 1989 
PART IV RULES OF EVIDENCE
RULE 130
4. Interpretation Of Documents
Section 10. Interpretation of a writing according to its legal meaning. — The language of a writing is to be interpreted
according to the legal meaning it bears in the place of its execution, unless the parties intended otherwise. (8)
Section 11. Instrument construed so as to give effect to all provisions. — In the construction of an instrument, where there are
several provisions or particulars, such a construction is, if possible, to be adopted as will give effect to all. (9)
Section 12. Interpretation according to intention; general and particular provisions. — In the construction of an instrument, the
intention of the parties is to be pursued; and when a general and a particular provision are inconsistent, the latter is
paramount to the former. So a particular intent will control a general one that is inconsistent with it. (10)
Section 13. Interpretation according to circumstances. — For the proper construction of an instrument, the circumstances
under which it was made, including the situation of the subject thereof and of the parties to it, may be shown, so that the
judge may be placed in the position of those who language he is to interpret. (11)
Section 14. Peculiar signification of terms. — The terms of a writing are presumed to have been used in their primary and
general acceptation, but evidence is admissible to show that they have a local, technical, or otherwise peculiar signification,
and were so used and understood in the particular instance, in which case the agreement must be construed accordingly. (12)
Section 15. Written words control printed. — When an instrument consists partly of written words and partly of a printed form,
and the two are inconsistent, the former controls the latter. (13)
Section 16. Experts and interpreters to be used in explaining certain writings. — When the characters in which an instrument is
written are difficult to be deciphered, or the language is not understood by the court, the evidence of persons skilled in
deciphering the characters, or who understand the language, is admissible to declare the characters or the meaning of the
language. (14)
Section 17. Of Two constructions, which preferred. — When the terms of an agreement have been intended in a different
sense by the different parties to it, that sense is to prevail against either party in which he supposed the other understood it,
and when different constructions of a provision are otherwise equally proper, that is to be taken which is the most favorable to
the party in whose favor the provision was made. (15)
Section 18. Construction in favor of natural right. — When an instrument is equally susceptible of two interpretations, one in
favor of natural right and the other against it, the former is to be adopted. (16)
Section 19. Interpretation according to usage. — An instrument may be construed according to usage, in order to determine its
true character. (17)
 
25. G.R. No. 146739               January 16, 2004
LUZVIMINDA DE LA CRUZ, Petitioner,
vs.
DEPARTMENT OF EDUCATION, CULTURE AND SPORTS-CORDILLERA ADMINISTRATIVE REGION, MA. ELENA PRINCENA,
MYRNA BAYABOS, OFRINA BENABESE, REGINA POTOLIN, MELBA LINGAYO, ELIZABETH CASTILLO, ROSALINDA BILGERA and
ERNESTO CALLENA, Respondents.
QUISUMBING, J.:
FACTS: In a letter-complaint, the CSC Abra Field Office, disclosed to the Department of Education, Culture, and Sports-
Cordillera Administrative Region (DECS-CAR), alleged mismanagement and supposed violations of Civil Service Laws at the
Bangued East District of the DECS Division of Abra by Helen Hernandez, herein petitioner Luzviminda de la Cruz, Charito
Turqueza, and Eugene Belarmino. Hernandez was the District Supervisor, while de la Cruz was Principal I of Bacsil Elementary
School, Angad, Bangued, Abra. Further, CSC-CAR formally charged petitioner of conduct prejudicial to the best interest of the
service, grave misconduct, and dishonesty. Thereafter, petitioner appealed to the Court of Appeals and contends that (1) the
CSC gravely abused its discretion in finding her guilty of grave misconduct and dishonesty; (2) she was denied administrative
due process; (3) the fact-finding committee of the DECS was illegally composed; (4) the complaints should have been dismissed
for being fatally defective; (5) the resolution of the DECS fact-finding committee was not supported by substantial evidence; (6)
assuming arguendo that petitioner was liable, the penalty should not have been dismissal considering the length of service
petitioner has rendered and that this is the first time she has been charged in her 25 years of service. However, her petition
was dismissed.
ISSUE: W/N the Honorable Court of Appeals erred in finding herein petitioner guilty of grave misconduct and dishonesty
considering that the decision is not in accord with law and with the applicable decisions of the Supreme Court
RULING: No. The charges against her for dishonesty and grave misconduct, after satisfying the requirements of administrative
due process, has been sufficiently established. Petitioner has shown no legal right that has been violated. Hence, there is
utterly no basis for the issuance of a writ of preliminary mandatory injunction. In fact, her dismissal from the service is in full
accord with applicable law.
The technical rules of procedure are liberally applied to administrative agencies exercising quasi-judicial functions. The
intention is to resolve disputes brought before such bodies in the most expeditious and inexpensive manner possible.

1-2-21 Diego
3-4 Eman
5-6-22 Ma. Rizalyn Garchitorena
7-8 Reynan
9-10-23 Jog
11-12 Jun Ivan
13-14-24 Dorothy
15-16 Mikel
17-18-25 Love
19-20 Kelly

1. A. M. No. MTJ-05-1610 September 26, 2005

DR. JOSE S. LUNA, Complainants,
vs.
JUDGE EDUARDO H. MIRAFUENTE, Municipal Trial Court, Buenavista, Marinduque, Respondent.
DECISION
CARPIO MORALES, J.:
Facts: Dr. Luna filed a complaint for unlawful detainer against Sadiwa. Defendants filed an unverified answer seven days
beyond the reglementary period of 10 days from the service of the summons on them. Dr. Luna filed a Motion for judgment,
however respondent denied the judgment. Luna asserts that since defendants answer was unverified and belatedly filed,
respondent should, on motion of the plaintiffs, render judgment as warranted by the facts alleged in the complaint.
Respondent contends than his decision was premised on spirit of justice and fair play and that even if his judgement is
erroneous he may not be liable because it would render judicial office untenable because no one would try to interpret the law
in the process of administering law can be infallible in his judgment.
ISSUE: Whether or not Respondent is liable
Ruling: No, Section 5 and 6 of Rules on Summary Procedure states that
Sec. 5. Answer. – Within ten (10) days from service of summons, the defendant shall file his answer to the complaint and serve
a copy thereof on the plaintiff
Sec. 6. Effect of failure to answer. – Should the defendant fail to answer the complaint within the period above provided, the
court, motu proprio, or on motion of the plaintiff, shall render judgment as may be warranted by the facts alleged in the
complaint and limited to what is prayed for therein
n the present case, respondent gave a liberal interpretation of the above-said Rule. Liberal interpretation or construction of
the law or rules, however, is not a free commodity that may be availed of in all instances under the cloak of rendering justice.
Liberality in the interpretation and application of Rules applies only in proper cases and under justifiable causes and
circumstances. While it is true that litigation is not a game of technicalities, it is equally true that every case must be
prosecuted in accordance with the prescribed procedure to insure an orderly and speedy administration of justice
However, respondent’s acts neither constitute grave misconduct nor gross ignorance of the law.
For it to process, the assailed order, decision or actuation of judge must not only be found erroneous but most importantly it
must be established that it was acted in bad faith, dishonesty and some other evil motive.
 
RESPONDENT IS REPRIMANDED, WITH A WARNING THAT A REPITITION OF THE SAME SHALL BE DEALT MORE STRICTLY.

2. G.R. No. 113092 September 1, 1994

MARTIN CENTENO, petitioner,
vs.
HON. VICTORIA VILLALON-PORNILLOS, Presiding Judge of the Regional Trial Court of Malolos, Bulacan, Branch 10, and THE
PEOPLE OF THE PHILIPPINES, respondents.
Santiago V. Marcos, Jr. for petitioner.

REGALADO, J.:
Facts: Petitioner Centeno, the head of Samahan ng Katandaan ng Nayon ng Tikay solicited from judge Angeles the amount of
1,500 for the renovation of Tikay Chapel. It is alleged that such solicitation were not permitted by the Department of Social
Welfare and Development. Based on the complaint of Respondent Angeles, petitioner was charged for the violation of PD 1564
otherwise known as Solicitation Permit Law. Petitioner filed a motion to quash and alleged that PD 1564 applies only to
solicitations made for charitable or public welfare purposes and not those made for a religious purpose. Municipal trial court
found them guilty beyond reasonable doubt. Petitioners appealed to the RTC which affirmed the decision of lower court. 
ISSUE: Whether or not solicitations for religious purposes are within the ambit of PD 1564
Ruling: NO, Section 2 of the PD 1564 are as follows;
Sec. 2. Any person, corporation, organization, or association desiring to solicit or receive contributions for charitable or public
welfare purposes shall first secure a permit from the Regional Offices of the Department of Social Services and Development as
provided in the Integrated Reorganization Plan.
it is an elementary rule of statutory construction that the express mention of one person, thing, act, or consequence excludes
all others.
it is also a well-entrenched rule that penal laws are to be construed strictly against the State and liberally in favor of the
accused. They are not to be extended or enlarged by implications. They are not to be strained by construction to spell out a
new offense, enlarge the field of crime or multiply felonies. Hence, in the interpretation of a penal statute, the tendency is to
subject it to careful scrutiny and to construe it with such strictness as to safeguard the rights of the accused. If the statute is
ambiguous and admits of two reasonable but contradictory constructions, that which operates in favor of a party accused
under its provisions is to be preferred.
The principle is that acts in and of themselves innocent and lawful cannot be held to be criminal unless there is a clear and
unequivocal expression of the legislative intent to make them such. Whatever is not plainly within the provisions of a penal
statute should be regarded as without its intendment.

3. G.R. No. 112170 April 10, 1996

CESARIO URSUA, petitioner,
vs.
COURT OF APPEALS AND PEOPLE OF THE PHILIPPINES, respondents.
BELLOSILLO, J.:
FACTS: Petitioner Cesario Ursua was a Community Environment and Natural Resources Officer. Atty. Francis Palmones, counsel
for petitioner, asked his client, Ursua, to take his letter-request to the Office of the Ombudsman instead of his secretary, and
was advised that he could just sign as Oscar Perez (secretary) if ever he would be required to acknowledge receipt of the
complaint. However, it was soon learned that the one who introduced as Oscar Perez was actually the petitioner himself. This
matter was immediately reported to the Deputy Ombudsman who ordered that petitioner be accordingly charged in violation
of Sec.1 of Commonwealth Act No.142 as amended by R.A. No.6085 (An Act to Regulate the Use of Aliases).
ISSUE: Whether or not petitioner has violated Sec.1 of Commonwealth Act No.142 as amended by R.A.6085.
RULING: NO. The court ruled that there is no evidence showing that he had used or was intending to use that name in addition
to his real name. That name was used in an isolated transaction where he was not even legally required to expose his real
identity. The enactment of C.A. No. 142 as amended was made primarily to curb the common practice among the Chinese
adopting scores of different names and aliases which created tremendous confusion in the field of trade. C.A. No. 142 is a
penal statute and it should be construed strictly against the State in favor of the accused. The reason of this principle is the
tenderness of the law for the rights of individuals and the object is to establish a certain rule by conformity to which mankind,
would be safe, and the discretion of the court limited. Indeed, our mind cannot rest easy on the proposition that the petitioner
should be convicted on the law that does not clearly penalize the act done by him.
 
4. G.R. No. 79094 June 22, 1988
MANOLO P. FULE, petitioner,
vs.
THE HONORABLE COURT OF APPEALS, respondent.
MELENCIO-HERRERA, J.:
FACTS: Manolo Fule, petitioner, issued and made out a check. Moreover, the check was drawn in favor of the complaining
witness in remittance of collection. However, the check was presented for payment but the same was dishonored for the
reason that the said checking account was already closed. Thus, petitioner was convicted of Violation of Batas Pambansa Blg.
22 (The Bouncing Checks Law). On appeal, respondent Appellate Court upheld the Stipulation of Facts and affirmed the
judgment of conviction.
ISSUE: Whether or not the Court of Appeals erred in the decision of the Regional Trial Court convicting the petitioner of the
offense charged.
RULING: Yes, the basis of the conviction was based solely on the stipulation of facts made during the pre-trial on August 8,
1985, which was not signed by the petitioner, nor by his counsel, as stated in the 1985 Rules on Criminal Procedure – Section 4.
But, under the rule of statutory construction, penal statutes whether substantive and remedial or procedural are, by
consecrated rule, to be strictly applied against the government and liberally in favor of the accused. What the prosecution
should have done, upon discovering that the accused did not sign the Stipulation of Facts, as required by Rule 118, was to
submit evidence to establish the elements of the crime, instead of relying solely on the supposed admission of the accused in
the Stipulation of Facts. Under the circumstances obtaining in this case, the ends of justice require that evidence be presented
to determine the culpability of the accused. When a judgment has been entered by consent of an attorney without special
authority, it will sometimes be set aside or reopened. WHEREFORE, the judgment of respondent Appellate Court is REVERSED
and this case is hereby ordered RE-OPENED and REMANDED to the appropriate Branch of the Regional Trial Court.

5. G.R. Nos. 136149-51               September 19, 2000

PEOPLE OF THE PHILIPPINES, appellee,
vs.
WALPAN LADJAALAM y MIHAJIL alias "WARPAN," appellant.
DECISION
PANGANIBAN, J.:
FACTS:
Ladjaalam was charged and convicted of the crime of Direct Assault with Multiple Attempted Homicide for firing on
unlicensed gun at several policemen who were about to enter his house to serve search warrant. Under the same
circumstance, he was likewise charged and convicted for the crime Illegal Possession of Firearm and Ammunition penalized
under PD 1866, as amended by RA 8294 based on the records showing that appellant had not filed any application for license
to possess firearm and ammunition, nor has he been given authority to carry firearms.
ISSUE:
W/N accused-appellant can be convicted of illegal Possession of Firearm under RA 8294 when he used said firearm in
the commission of another crime.
HELD:
No. Republic Act No. 8294 penalizes simple illegal possession of firearms, provided that the person arrested committed
"no other crime." Furthermore, if the person is held liable for murder or homicide, illegal possession of firearms is an
aggravating circumstance, but not a separate offense. Hence, where an accused was convicted of direct assault with multiple
attempted homicide for firing an unlicensed M-14 rifle, he cannot be held liable for the separate offense of illegal possession of
firearms.
Moreover, penal laws are construed liberally in favor of the accused. In this case, the plain meaning of RA 8294’s
simple language is most favorable to herein appellant. Verily, no other interpretation is justified, for the language of the new
law demonstrates the legislative intent to favor the accused. Accordingly, appellant cannot be convicted of two separate
offenses of illegal possession of firearms and direct assault with attempted homicide. Moreover, since the crime committed
was direct assault and not homicide or murder, illegal possession of firearms cannot be deemed an aggravating circumstance.

 
 
 
6. G.R. No. 120082 September 11, 1996
MACTAN CEBU INTERNATIONAL AIRPORT AUTHORITY, petitioner,
vs.
HON. FERDINAND J. MARCOS, in his capacity as the Presiding Judge of the Regional Trial Court, Branch 20, Cebu City, THE
CITY OF CEBU, represented by its Mayor HON. TOMAS R. OSMEÑA, and EUSTAQUIO B. CESA, respondents.
DAVIDE, JR., J.: 
FACTS:
         Petitioner Mactan Cebu International Airport Authority (MCIAA) was created by virtue of RA 6958, mandated to
“principally undertake the economical, efficient and effective control, management and supervision of the Mactan
International Airport in the Province of Cebu and the Lahug Airport in Cebu City, and such other airports as may be established
in the Province of Cebu. Since the time of its creation, petitioner MCIAA enjoyed the privilege of exemption from payment of
realty taxes in accordance with Section 14 of its Charter. However, the Office of the Treasurer demanded payment for realty
taxes on several parcels of land belonging to the petitioner. Petitioner objected to such demand for payment as baseless and
unjustified, claiming in its favor the aforecited Section 14 of RA 6958 which exempts it from payment of realty taxes.
         Respondent City refused to cancel and set aside petitioner’s realty tax account, insisting that the MCIAA is a
government-controlled corporation whose tax exemption privilege has been withdrawn by virtue of Sections 193 and 234 of
the Local Government Code.
ISSUE:
         W/N petitioner is exempted from payment of realty taxes
HELD:
         No. Verily, taxation is a destructive power which interferes with the personal and property for the support of the
government. Accordingly, tax statutes must be construed strictly against the government and liberally in favor of the taxpayer.
But since taxes are what we pay for civilized society, or are the lifeblood of the nation, the law frowns against exemptions from
taxation and statutes granting tax exemptions are thus construed strictissimi juris against the taxpayers and liberally in favor of
the taxing authority. A claim of exemption from tax payment must be clearly shown and based on language in the law too plain
to be mistaken. Elsewise stated, taxation is the rule, exemption therefrom is the exception.
         There can be no question that under Section 14 of R.A. No. 6958 the petitioner is exempt from the payment of realty
taxes imposed by the National Government or any of its political subdivisions, agencies, and instrumentalities. Nevertheless,
since taxation is the rule and exemption therefrom the exception, the exemption may thus be withdrawn at the pleasure of the
taxing authority.
 
7. G.R. No. 175188               July 15, 2015
COMMISSIONER OF INTERNAL REVENUE, Petitioner,
vs.
LA TONDENA DISTILLERS, INC. (LTDI [now GINEBRA SAN MIGUEL], Respondent.
DECISION
DEL CASTILLO, J.: 
FACTS:
Respondent La Tondena Distillers, Inc. entered into a Plan of Merger with Sugarland Beverage Corporation (SBC), SMC Juice,
Inc. (SMCJI), and Metro Bottled Water Corporation (MBWC). Consequently, the assets and liabilities of the absorbed
corporations were transferred to respondent, the surviving corporation.
The respondent requested with the BIR for a confirmation of the tax free nature of the said merger, however the BIR states
that pursuant to Section 40(C)(2) and (6)(b) of the 1997 National Internal Revenue Code (NIRC) M, no gain  or loss shall be
recognized by the absorbed corporations, however, transfer of assets shall be subject to Documentary Stamp Tax (DST) undrr
Sec. 196 of the NIRC, thus respondent paid the BIR DST in the amount of 14, 140.980.00
Thus, the respondent claiming that it is exempt from paying DST filed an administrative claim for refund or tax credit. The CTA
rendered a decision finding respondent entitled to its claim for tax refund or tax credit.
Unfazed petitioner filed the present petition.
ISSUE :
W/N the CTA erred in ruling that respondent  is exempt from payment of DST.
RULING:
NO. The petitioner's contention that respondent cannot claim Exemption under RA No. 9243 as this was enacted only in 2004
or after respondent's tax liability accrued. Respondent did not file its claim for tax refund or tax credit based on the Exemption
found in RA No. 9243. Rather, it filed a claim of tax refund or tax credit on the ground that Section 196 of the NIRC does not
include the transfer of real property pursuant to merger. RA 9243 was mentioned only to emphasize that "the enactment of
the said law now removes any doubt and had made clear that the transfer of real properties as a consequence of merger or
consolidation is not subject to DST.
The Court find no error on the part of CTA in granting respondent's claim for tax refund or tax credit in the amount of 14, 140,
980.00, representing its erroneously paid DST. 
The Court stress that taxes must not be imposed beyond what the law expressly and clearly declares as tax laws must be
construed strictly against the State and liberally in favor of the taxpayer.
WHEREFORE, the petition was denied.

8. G.R. No. L-23623 June 30, 1977

ACTING COMMISSIONER OF CUSTOMS, petitioner,
vs.
MANILA ELECTRIC COMPANY and COURT OF TAX APPEALS, respondents.
FERNANDO, J.:
FACTS:
The appealed decision set forth that petitioner MERALCO, now private respondent, in appealing from a determination by the
then Acting Commissioner of Custom, now petitioner,, "claims that it is exempt from the special import tax not only by virtue
of Sec. 6 of RA No. 1943, which exempts from said tax equipment and spare parts for use in industries, but also under Par. 9,
Part TWO of its franchise , which expressly exempts its insulator from all taxes of whatever kind and nature. " It then made
reference to the franchise of the private respondent Meralco. 
ISSUE:
W/N the claim for exemption from tax statute be strictly construed against the respondent MERALCO.
RULING:
No. The law frowns on exemption from taxation, hence, an exempting provision should be construed strictissimi juris.
However, it is equally a recognized principle that where the provision of the law is clear and unambiguous, so that there is no
occasion for the court's seeking the legislative intent, the law must be taken as it is devoid of judicial addition or subtraction. 
In this case, the Court found the provision of Sec. 186-A, whenever a tax-free product is utilized, all encompassing to
comprehend tax-free raw materials, even if imported. Where the law provided no qualification for the granting of the privilege,
the court is not at liberty to supply any. 
WHEREFORE, the petition for review was denied
 
9. G.R. No. 168856               August 29, 2012
EASTERN TELECOMMUNICATIONS PHILIPPINES, INC., Petitioner,
vs.
THE COMMISSIONER OF INTERNAL REVENUE, Respondents.
DECISION
MENDOZA, J.:
FACTS:
Petitioner Eastern Telecommunications Philippines, Inc. (ETPI) is a duly authorized corporation engaged in telecommunications
services and various international service agreements with international non-resident telecommunications companies.
ETPI believes that it is entitled to a refund for the unutilized input VAT attributable to its zero-rated sales, ETPI filed with the
Bureau of Internal Revenue (BIR) an administrative claim for refund and/or tax credit representing excess input VAT derived
from its zero-rated sales.
In a petition for review, the CTA (CTA-Division) denied the petition for lack of merit, finding that ETPI failed to imprint the word
"zero-rated" on the face of its VAT invoices or receipts, in violation of Revenue Regulations No. 7-95. CTA-En Banc affirmed the
decision of the CTA-Division. The CTA-En Banc ruled that in order for a zero-rated taxpayer to claim a tax credit or refund, the
taxpayer must first comply with the mandatory invoicing requirements under the regulations. One such requirement is that the
word "zero-rated" be imprinted on the invoice or receipt.
ISSUE:
W/N the CTA-En Banc erred when it sanctioned the denial of petitioner’s claim for refund on the ground that petitioner’s
invoices do not bear the imprint "zero-rated".
RULING:
NO. Imprinting of the word "zero-rated" on the invoices or receipts is required. The following invoicing requirements
enumerated in Section 4.108-1 of Revenue Regulations No. 7-95 must be observed by all VAT-registered taxpayers:
Sec. 4.108-1. Invoicing Requirements. – All VAT-registered persons shall, for every sale or lease of goods or properties or
services, issue duly registered receipts or sales or commercial invoices which must show:
1. the name, TIN and address of seller;
2. date of transaction;
3. quantity, unit cost and description of merchandise or nature of service;
4. the name, TIN, business style, if any, and address of the VAT-registered purchaser, customer or client;
5. the word "zero-rated" imprinted on the invoice covering zero-rated sales; and
6. the invoice value or consideration.
The need for taxpayers to indicate in their invoices and receipts the fact that they are zero-rated or that its transactions are
zero-rated became more apparent upon the integration of the above quoted provisions of Revenue Regulations No. 7-95 in
Section 113 of the NIRC enumerating the invoicing requirements of VAT-registered persons when the tax code was amended
by Republic Act (R.A.) No. 9337.
A consequence of failing to comply with the invoicing requirements is the denial of the claim for tax refund or tax credit, as
stated in Revenue Memorandum Circular No. 42-2003, to wit:
A-13: Failure by the supplier to comply with the invoicing requirements on the documents supporting the sale of goods and
services will result to the disallowance of the claim for input tax by the purchaser-claimant.
Lastly, Section 244 of the NIRC explicitly grants the Secretary of Finance the authority to promulgate the necessary rules and
regulations for the effective enforcement of the provisions of the tax code. Such rules and regulations "deserve to be given
weight and respect by the courts in view of the rule-making authority given to those who formulate them and their specific
expertise in their respective fields."
 
10. G.R. No. 175430               June 18, 2012
REPUBLIC OF THE PHILIPPINES, Petitioner,
vs.
KERRY LAO ONG, Respondent.
DECISION
DEL CASTILLO, J.:
FACTS:
Respondent Kerry Lao Ong, filed a Petition for Naturalization. He is registered as a resident alien and possesses an alien
certificate of registration and a native-born certificate of residence from the Bureau of Immigration. Ong can speak and write
Tagalog, took his education here in the Philippines, he is also very helpful in the community and adopts the Filipino culture and
possesses the qualifications of a good citizen of the Philippines, as attested by his character witnesses. Ong alleged in his
petition that he has been a "businessman/business manager". The trial court granted Ong’s petition.
The Republic, through the Solicitor General, appealed to the CA. The Republic faulted the trial court for granting Ong’s petition
despite his failure to prove that he possesses a known lucrative trade, profession or lawful occupation as required under
Section 2, fourth paragraph of the Revised Naturalization Law. The appellate court dismissed the Republic’s appeal.
ISSUE:
W/N Ong has proved that he has some known lucrative trade, profession or lawful occupation in accordance with Section 2,
fourth paragraph of the Revised Naturalization Law.
RULING:
NO. The courts must always be mindful that naturalization proceedings are imbued with the highest public interest.
Naturalization laws should be rigidly enforced and strictly construed in favor of the government and against the applicant. The
burden of proof rests upon the applicant to show full and complete compliance with the requirements of law.
In the case at bar, the controversy revolves around respondent Ong’s compliance with the qualification found in Section 2,
fourth paragraph of the Revised Naturalization Law.
That the qualification of "some known lucrative trade, profession, or lawful occupation" means "not only that the person
having the employment gets enough for his ordinary necessities in life. It must be shown that the employment gives one an
income such that there is an appreciable margin of his income over his expenses as to be able to provide for an adequate
support in the event of unemployment, sickness, or disability to work and thus avoid one’s becoming the object of charity or a
public charge." His income should permit "him and the members of his family to live with reasonable comfort, in accordance
with the prevailing standard of living, and consistently with the demands of human dignity, at this stage of our civilization."
Ong is a “businessman engaged in lawful trade and business since 1989” but did not cite the evidence, which supports such
finding. After poring over the records, the Court finds that the reason for the lack of citation is the absence of evidence to
support such a conclusion.
 
11. G.R. No. 127240             March 27, 2000
ONG CHIA, petitioner,
vs.
REPUBLIC OF THE PHILIPPINES and THE COURT OF APPEALS, respondents.
MENDOZA, J.:
Facts: Petitioner was born on January 1, 1923 in Amoy, China. In 1932, as a nine-year old boy, he arrived at the port of Manila
on board the vessel "Angking." Since then, he has stayed in the Philippines where he found employment and eventually started
his own business, married a Filipina, with whom he had four children. On July 4, 1989, at the age of 66, he filed a verified
petition to be admitted as a Filipino citizen under C.A. No. 473, otherwise known as the Revised Naturalization Law, as
amended. The trial court granted the petition and admitted Ong Chia to the Philippine Citizenship. The State, through the
Office of the Solicitor General, appealed from that decision on the ground that Ong Chia failed to state all his former places of
residence, failed to conduct himself in a proper and irreproachable manner during his stay in the Philippines, has no known
lucrative occupation and failed to support his petition with the appropriate documentary evidence in violation of C.A. No. 473.
The Court of Appeals reversed the decision of the trial court, holding that the grounds relied on in the appeal were correct as
Ong Chia failed to state his other names in which he was known and failed to indicate in his petition that he lived in J.M. Basa,
Iloilo, which are both mandatory requirement under the Naturalization Law. The C.A. reversed the decision of the trial court.
Hence this petition.
Issue: Whether or not the documents annexed by the State to its appellant's brief without having been presented and formally
offered as evidence under Rule 132, Section 34 of the Revised Rules on Evidence justified the reversal of of the Trial Court’s
decision.
Ruling: Petition was denied, petitioner failed to note Rule #143 of the rules of court providing that These rules shall not apply
to land registration, cadastral and election cases, naturalization and insolvency proceedings, and other cases not herein
provided for, except by analogy or in a suppletory character and whenever practicable and convenient. That is not the case
here, since reliance upon the documents presented by the State for the first time on appeal, in fact, appears to be the more
practical and convenient course of action considering that decisions in naturalization proceedings are not covered by the rule
on res judicata. The effect of petitioner’s failure to include his address in his petition in accordance with Sec. 7 of C.A. 473
which is the same address appearing on his immigrant’s certificate of residence which forms part as an annex of his petition for
naturalization, however, petitioner insisted that his full publication of his Immigrants certificate of residence already constitute
substantial compliance with the aforesaid provision. It is settled that naturalization laws shall be construed in favor of the State
and against the applicant, his failure to indicate such address already defeated his argument of substantial compliance with the
requirement of the law. Hence, petition was denied for lack of merit.
 
12. G.R. No. L-30058               March 28, 1969
LUIS G. DE CASTRO, petitioner,
vs.
JULIAN G. GINETE and UBALDO Y. ARCANGEL Judge of the Court of First Instance of Sorsogon, 10th Judicial District, Branch
I, respondents.
ZALDIVAR, J.: 
Facts: Petitioner de castro and respondent ginete were opposing candidates for the office of municipal mayor of the
municipality of Bulan, province of Sorsogon, in the general elections held on November 14, 1967. To which petitioner was
declared the winner by a margin of 12 votes. Both parties filed their motion of protest again each other’s candidacy. After the
revision of all ballots in 20 precinct, de castro a motion to dismiss the protest upon the ground of estoppel.  It is alleged in his
motion that Ginete filed his protest after acknowledging his victory over him. The Judge of C.F.I. Sorsogon denied de castro’s
motion, he filed a motion for recon which was later on denied as well. Evidence shows that Ginete wrote to de castro
containing such congratulatory words for his victory and upon inauguration, Ginete then encouraged its constituents to
cooperate with de castro’s administration. Petitioner filed a review on certiorari praying for the annulment of the order issued
by the trial court, dismissal of Ginete’s protest  and writ of preliminary injunction be issued against respondent Judge to
prevent him from proceeding further with the election protest of Ginete, pending the resolution of his petition.
Issue: W/N Ginete’s conduct of congratulating petitioner through a letter constitutes estoppel that would prevent him to
question De Castro’s election as Municipal Mayor of Bulan Sorsogon
Ruling: No, the Court stated that Ginete’s actions are just manifestation of him being a law-abiding citizen that respects the
proclamation of the board of canvassers. There are four (4) elements of estoppel by conduct namely; 1) that there must have
been a representation or concealment of material facts; 2) that the representation must have been made with knowledge of
the facts; 3) that the party to whom it was made must have been ignorant of the truth of the matter; and 4) that it must have
been made with intention that the other party would act upon it. As to the present case, these elements were not found by
the court as to the facts presented by petitioner. Hence, the act of a losing candidate of recognizing the one who is proclaimed
the winner should not bar the losing candidate from questioning the validity of the elect ion of the winner in the manner
provided by law. 
 

13.
G.R. No. L-23139    December 17, 1966
MOBIL PHILIPPINES EXPLORATION, INC., plaintiff-appellant,
vs.
CUSTOMS ARRASTRE SERVICE and BUREAU of CUSTOMS, defendants-appellees.
Alejandro Basin, Jr. and Associates for plaintiff-appellant.
Felipe T. Cuison for defendants-appellees.
FACTS:
Four cases of rotary drill parts were shipped from abroad on S.S “Leoville” consigned to Mobil Philippines Exploration, Inc.,
Manila. It was discharged to the custody of the Customs Arrastre Service, the unit of the Bureau of Customs then handling
arrastre operations therein. The Customs Arrastre Service later delivered to the broker of the consignee three cases only.
Petitioner filed suit in the Court of First Instance of Manila against the Customs Arrastre Service and the Bureau of Customs to
recover the value of the undelivered case plus other damages. The respondents filed a motion to dismiss on the ground that
not being persons under the law, they cannot be sued.
ISSUE:
Whether or not the defendants can invoke state immunity.

HELD:
Yes. Now, the fact that a non-corporate government entity performs a function proprietary in nature does not necessarily
result in its being suable. If said non-governmental function is undertaken as an incident to its governmental function, there is
no waiver thereby of the sovereign immunity from suit extended to such government entity. The Bureau of Customs, to repeat,
is part of the December of Finance with no personality of its own apart from that of the national government. Its primary
function is governmental, that of assessing and collecting lawful revenues from imported articles and all other tariff and
customs, duties, fees, charges, fines and penalties. To this function, arrastre service is a necessary incident.
It must be remembered that statutory provisions waiving State immunity from suit are strictly construed and that waiver of
immunity, being in derogation of sovereignty, will not be lightly inferred. (49 Am. Jur., States, Territories and Dependencies,
Sec. 96, p. 314; Petty vs. Tennessee-Missouri Bridge Com., 359 U.S. 275, 3 L. Ed. 804, 79 S. Ct. 785). From the provision
authorizing the Bureau of Customs to lease arrastre operations to private parties, the Court sees no authority to sue the said
Bureau in the instances where it undertakes to conduct said operation itself. The Bureau of Customs, acting as part of the
machinery of the national government in the operation of the arrastre service, pursuant to express legislative mandate and as
a necessary incident of its prime governmental function, is immune from suit, there being no statute to the contrary.
Wherefore, the order of dismissal appealed from is hereby affirmed, with costs against appellant.

14. 
G.R. No. 133706            May 7, 2002
FRANCISCO ESTOLAS, petitioner,
vs.
ADOLFO MABALOT, respondent.
FACTS:
A certificate of Land Transfer (hereinafter referred to as CLT) was issued in favor of respondent over a 5,000 square meter lot
(hereinafter referred to as subject land) located in Barangay Samon, Sta. Maria, Pangasinan. Sometime in May, 1978, needing
money for medical treatment, respondent passed on the subject land to the petitioner for the amount of P5,800.00 and
P200.00 worth of rice. According to respondent, there was only a verbal mortgage; while according to petitioner, a sale had
taken place. Acting on the transfer, the DAR officials in Sta. Maria, Pangasinan authorized the survey and issuance of an
Emancipation Patent, leading to the issuance of a Transfer Certificate of Title No. 3736 on December 4, 1987, in favor of the
petitioner. Respondent filed a Complaint against the petitioner before the Barangay Lupon in Pangasinan for the purpose of
redeeming the subject land.
ISSUE:
Whether or not the Court agrees about the non-transferability of Land under PD 27.
HELD:
No. The Court does not agree. PD 27 specifically provides that title to land acquired pursuant to its mandate or to that of the
Land Reform Program of the government shall not be transferable except to the grantee’s heirs by hereditary succession, or
back to the government by other legal means. The law is clear and leaves no room for interpretation.
Upon the promulgation of PD 27, farmer-tenants were deemed owners of the land they were tilling. Their emancipation gave
them the rights to possess, cultivate and enjoy the landholding for themselves. These rights were granted by the government
to them as the tillers and to no other. Thus, to insure their continuous possession and enjoyment of the property, they could
not, under the law, effect any transfer except back to the government or, by hereditary succession, to their successors
Furthermore, the Court has always ruled that agrarian laws must be interpreted liberally in favor of the grantees in order to
give full force and effect to the clear intent of such laws: "to achieve a dignified existence for the small farmers"; and to make
them "more independent, self-reliant and responsible citizens, and a source of genuine strength in our democratic society."
Wherefore, the petition is hereby denied and the assailed decision affirmed. Costs against petitioner.

15.
G.R. No. L-21905             March 31, 1966
EUFRONIO J. LLANTO, petitioner-appellant,
vs.
MOHAMAD ALI DIMAPORO, Provincial Governor of Lanao del Norte;
PROVINCIAL BOARD OF LANAO DEL NORTE; VALERIO V. ROVIRA, Vice-Governor;
BIENVENIDO L. PADILLA, Member; FELIXBERTO ABELLANOSA, Member; PROVINCE OF LANAO DEL NORTE; PROVINCIAL
AUDITOR OF LANAO DEL NORTE; PROVINCIAL TREASURER OF LANAO DEL NORTE, and PROVINCIAL ASSESSOR OF LANAO DEL
NORTE, respondents-appellees.
SANCHEZ, J.:
Facts:
Resolution No. 7, Series of 1960, adopted by the Provincial Board of Lanao del Norte on January 6, 1960, reverted the 1960-
1961 salary appropriation for the position of Assistant Provincial Assessor to the general fund. In effect, that position then held
by petitioner was abolished. Appeals to the Commissioner of Civil Service, the Secretary of Finance, the Secretary of Justice,
the Auditor General and the President of the Philippines were of no avail. Petitioner came to court on mandamus.
Issue:
Whether or not  the petitioner can sought the annulment of the resolution aforesaid?
Ruling:
No. Petitioner also advances the theory that the provincial board resolution abolishing his position is not effective,
because it did not bear the stamp of approval of the Secretary of Finance, citing Republic Act No. 1062. The necessity for such
approval, however, was done away with by the passage of Republic Act No. 2264, otherwise known as the Local Autonomy Act.
Section 3(a) of the Local Autonomy Act gives the provincial board the power to appropriate money having in view the general
welfare of the province and its inhabitants. Concomitant to this express power is the implied power to withdraw unexpended
money already appropriated.
We observe that the sole authority given by the Autonomy Act to the Secretary of Finance is to review provincial and city
budgets and city and municipal tax ordinances.  Nothing therein contained requires his approval for the abolition of positions
in the provincial or city or municipal governments. We do not even discern in the law a purpose to require such approval. For
the language is restrictive. We are not prepared to take imperishable liberties with and recast said law. Such is not within the
scope of the powers entrusted to courts of justice.
On top of all of these is the fact that section 12 of the Local Autonomy Act leaves us with but one guidepost in the
interpretation of powers allocated to local governments, thus:
Sec. 12. Rules for the interpretation of the Local Autonomy Act. —
1. Implied power of a province, a city or municipality shall be liberally construed in its favor. Any fair and reasonable doubt as
to the existence of the power should be interpreted in favor of the local government and it shall be presumed to exist.
Autonomy is the underlying rationale of the Local Autonomy Act. By the statute itself no interpretation thereof should be
indulged in which would cripple the board's powers. This legal yardstick stops us, too, from writing into the statute the Finance
Secretary's approval as a condition precedent to effectivity of the resolution herein questioned.

16.
G.R. No. 46623 December 7, 1939
MARCIAL KASILAG, petitioner,
vs.
RAFAELA RODRIGUEZ, URBANO ROQUE, SEVERO MAPILISAN and IGNACIO DEL ROSARIO, respondents.
IMPERIAL, J.:
Facts:
This is an appeal taken by the defendant-petitioner from the decision of the Court of Appeals which modified that
rendered by the court of First Instance of Bataan. The said court held: that the contract is entirely null and void and without
effect; that the plaintiffs-respondents, then appellants, are the owners of the disputed land, with its improvements, in
common ownership with their brother Gavino Rodriguez, hence, they are entitled to the possession thereof; that the
defendant-petitioner should yield possession of the land in their favor, with all the improvements thereon and free from any
lien
The parties entered into a contract of loan to which has an accompanying accessory contract of mortgage. The
executed accessory contract involved the improvements on a piece land, the land having been acquired by means of
homestead. P for his part accepted the contract of mortgage.
Believing that there are no violations to the prohibitions in the alienation of lands P, acting in good faith took
possession of the land. To wit, the P has no knowledge that the enjoyment of the fruits of the land is an element of the credit
transaction of Antichresis
Issue:
Whether or not P is deemed to be a possessor in good faith of the land, based upon Article 3 of the New Civil Code as
states “Ignorance of the law excuses no one from compliance therewith,” the P’s lack of knowledge of the contract of
antichresis.

Ruling:
Yes. The accessory contract of mortgage of the improvements of on the land is valid. The verbal contract of antichresis
agreed upon is deemed null and void.Sec 433 of the Civil Code of the Philippines provides “Every person who is unaware of any
flaw in his title or in the manner of its acquisition by which it is invalidated shall be deemed a possessor of good faith.” And in
this case, the petitioner acted in good faith. Good faith maybe a basis of excusable ignorance of the law, the petitioner acted in
good faith in his enjoyment of the fruits of the land to which was done through his apparent acquisition thereof.The cardinal
rule in the interpretation of contracts is to the effect that the intention of the contracting parties should always prevail because
their will has the force of law between them. Article 1281 of the Civil Code consecrates this rule and provides, that if the terms
of a contract are clear and leave no doubt as to the intention of the contracting parties, the literal sense of its stipulations shall
be followed; and if the words appear to be contrary to the evident intention of the contracting parties, the intention shall
prevail. 
Another fundamental rule in the interpretation of contracts, not less important than those indicated, is to the effect
that the terms, clauses and conditions contrary to law, morals and public order should be separated from the valid and legal
contract and when such separation can be made because they are independent of the valid contract which expresses the will
of the contracting parties.

17.

G.R. No. 100970 September 2, 1992

FINMAN GENERAL ASSURANCE CORPORATION, petitioner,
vs.
THE HONORABLE COURT OF APPEALS and JULIA SURPOSA, respondents.

NOCON, J.:

FACTS: The deceased, Carlie Surposa was insured with petitioner Finman General Assurance Corporation under Finman
General Teachers Protection Plan Master Policy No. 2005 and Individual Policy No. 08924 with his parents, spouses Julia and
Carlos Surposa, and brothers Christopher, Charles, Chester and Clifton, all surnamed, Surposa, as beneficiaries.
Moreover, the insured, Carlie Surposa, died as a result of a stab wound inflicted by one of the three (3) unidentified men.
Thereafter, private respondent and the other beneficiaries of said insurance policy filed a written notice of claim with the
petitioner insurance company which denied said claim contending that murder and assault are not within the scope of the
coverage of the insurance policy.
Subsequently, private respondent filed a complaint with the Insurance Commission wherein the judgment is ordering
respondent to pay complainant. Hence, petitioner filed this petition alleging grave abuse of discretion on the part of the
appellate court in applying the principle of "expresso unius exclusio alterius" in a personal accident insurance policy since
death resulting from murder and/or assault are impliedly excluded in said insurance policy considering that the cause of death
of the insured was not accidental but rather a deliberate and intentional act of the assailant in killing the former as indicated
by the location of the lone stab wound on the insured. 

ISSUE:  W/N death resulting from assault or murder deemed included in the terms “accident” and “accidental”

RULING: Yes. The terms "accident" and "accidental" as used in insurance contracts have not acquired any technical meaning,
and are construed by the courts in their ordinary and common acceptation. Thus, the terms have been taken to mean that
which happen by chance or fortuitously, without intention and design, and which is unexpected, unusual, and unforeseen. An
accident is an event that takes place without one's foresight or expectation — an event that proceeds from an unknown cause,
or is an unusual effect of a known cause and, therefore, not expected.
Moreover, it is well settled that contracts of insurance are to be construed liberally in favor of the insured and strictly against
the insurer. Thus ambiguity in the words of an insurance contract should be interpreted in favor of its beneficiary.

18.

G.R. No. 176832               May 21, 2009

GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner,
vs.
MARIAN T. VICENCIO Respondent.
PUNO, CJ.:
FACTS: Judge Vicencio, respondent’s husband, died. Per his Death Certificate, the immediate cause of his death was
Cardiopulmonary Arrest, and the antecedent cause was T/C Fatal Arrythmia. Thereafter, Mrs. Vicencio applied for the death
benefits of her late husband with petitioner Government Service Insurance System (GSIS) but her application was denied by
Mr. Marcelino S. Alejo, Manager of the GSIS Employees Compensation Department, on the ground that the illness which
caused Judge Vicencio’s death is not considered an occupational disease and there is no showing that his work as RTC Judge
has increased his risk of contracting said ailment. Respondent filed a petition before the Court of Appeals where GSIS is
ordered to grant the claim for the death benefits of Judge Honorato S. Vicencio under the Employees Compensation Act.
Hence, this petition.
ISSUE: W/N respondent Mrs. Vicencio’s claim for death benefits under Presidential Decree No. 626 (P.D. No. 626), as amended,
is compensable.
RULING: Yes. P.D. No. 626, as amended, defines compensable sickness as "any illness definitely accepted as an occupational
disease listed by the Commission, or any illness caused by employment subject to proof by the employee that the risk of
contracting the same is increased by the working conditions."
It must be remembered that P.D. No. 626, as amended, is a social legislation whose primordial purpose is to provide
meaningful protection to the working class against the hazards of disability, illness and other contingencies resulting in the loss
of income. Thus, the official agents charged by law to implement social justice guaranteed by the Constitution should adopt a
liberal attitude in favor of the employee in deciding claims for compensability especially where there is some basis in the facts
for inferring a work-connection with the illness or injury, as the case may be. It is only this kind of interpretation that can give
meaning and substance to the compassionate spirit of the law as embodied in Article 4 of the New Labor Code which states
that all doubts in the implementation and interpretation of the provisions of the Labor Code including their implementing rules
and regulations should be resolved in favor of labor.
Moreover, as the public agency charged by law in implementing P.D. No. 626, petitioner GSIS should not lose sight of the fact
that the constitutional guarantee of social justice towards labor demands a liberal attitude in favor of the employee in deciding
claims for compensability. 

19.
Manahan vs Employees' Compensation Commission
GR No. L-44899 April 22,1981
Fernandez, J.

Facts: Nazario Manahan, the deceased husband of the petitioner, died of "Enteric Fever" while employed as a classroom
teacher in Las Pinas Municipal High School. The Petitioner filed for a claim with Government Service Insurance (GSI) for death
benefit under PD 626. The GSI denied the claim upon discovering that the ailment of the deceased is not an occupational
disease on the ground that enteric fever is similar in effect to typhoid fever, in the sense that both are produced by Salmonella
organisms. The ECC affirmed the decision of the GSI.

Issue: W/N the Workmen's Compensation should be resolved in favor of the worker

Ruling:Yes. The provisions of the Workmen's Compensation Act in this case, the presumption of compensability subsists in
favor of the claimant. In the case at bar, the Supreme Court maintained that it should be resolved in favor of the worker, and
that social legislations - like the Workmen's Compensation Act and the Labor Code should be liberally construed to attain their
laudable objective, to give relief to the workman and/or his dependents in the event that the former should die or sustain an
injury

20.
Lazo vs Employees' Compensation Commission
Gr No. 78617 June 18, 1990
Padilla, J.

Facts: Petitioner Lazo, a security guard of the Central Bank of the Philippines assigned to its main office in Malate, Manila. His
regular tour of duty is from 2:00 in the afternoon to 10:00 in the evening. On June 18, 1986, he rendered an overtime duty
from 2:00 in the afternoon up to 5:00 in the morning of June 19, 1986. On his way home, the passenger jeepney he was riding
on turned turtle due to slippery road; he then sustained injuries. Petitioner filed a claim for disability benefits but the GSIS
denied for the reason that he was not at his workplace performing his duties when the incident occurred

Issue: W/N the injuries the petitioner sustained due to the vehicular accident should be construed as "arising out of or in the
course of employment" and thus, compensable

Ruling:Yes. In the case at bar, it can be seen that petitioner left his station at the Central Bank several hours after his regular
time off, because the reliever did not arrive, and petitioner was asked to go on overtime. After permission to leave was given,
he went home. There is no evidence on record that petitioner deviated from his usual, regular homeward route or that
interruptions occurred in the journey. 
While the presumption of compensability and theory of aggravation under the Workmen's Compensation Act (under
which the Baldebrin case was decided) may have been abandoned under the New Labor Code, it is significant that the liberality
of the law in general in favor of the working man still subsists. As agent charged by the law to implement social justice
guaranteed and secured by the Constitution, the Employees Compensation Commission should adopt a liberal attitude in favor
of the employee in deciding claims for compensability, especially where there is some basis in the facts for inferring a work
connection to the accident.

21.Tantuico jr. Vs. Domingo

FACTS:
Petitioner Tantuico(ex-chairman of COA) applied for clearance from all money, property and other accountabilities in
preparation for his retirement. He obtained the clearance applied for. The clearance had all the required signatures and bore a
certification that petitioner was cleared from money, property and/or other accountabilities by this Commission. Petitioner
argues that notwithstanding the clearances previously issued (by COA), and respondent Chairman’s certification that petitioner
had been cleared of money and property accountability, respondent Chairman still refuses to release the remaining half of his
retirement benefits 
ISSUE:
Whether or not the withholding of one-half of petitioner’s retirement benefits is valid.
HELD:
NO. Petition was granted insofar as it seeks to compel respondent Chairman of the COA to pay petitioner’s retirement benefits
in full and his monthly pensions.
Under Section 4 of R.A. No. 1568 (An Act to Provide Life Pension to the Auditor General and the Chairman or Any Member of
the Commission of Elections), the benefits granted by said law to the Auditor General and the Chairman and Members of the
Commission on Elections shall not be subject to garnishment, levy or execution. Likewise, under Section 33 of P.D. No. 1146, as
amended, the benefits granted thereunder “shall not be subject, among others, to attachment, garnishment, levy or other
processes.”

Well settled is the rule that retirement laws are liberally interpreted in favor of the retiree because the intention is to
provide for the retiree’s sustenance and comfort, when he is no longer capable of earning his livelihood.

It has been seven years since petitioner’s retirement. Since then he was only paid half of his retirement benefits, with the other
half being withheld despite the issuance of two clearances and the approval of his retirement application. As of the filing of this
petition on December 21, 1990, no criminal or administrative charge had been filed against petitioner in connection with his
position as former Acting Chairman and Chairman of the COA.
 the petition is GRANTED insofar as it seeks to compel respondent Chairman of the COA to pay petitioner’s retirement benefits
in full.

22.
G.R. No. 154243             December 22, 2007
DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO
vs.
P/SENIOR INSPECTOR JOSE J. ASAYO

FACTS:
Before the Court is respondent’s Motion for Reconsideration of the Decision. In said Decision, the Court granted the
petition, holding that the Philippine National Police (PNP) Chief had jurisdiction to take cognizance of the civilian complaint
against respondent and that the latter was accorded due process during the summary hearing.
Respondent insists that the summary hearing officer did not conduct any hearing at all but only relied on the affidavits
and pleadings submitted to him, without propounding further questions to complainant's witnesses, or calling in other
witnesses such as PO2 Villarama.
ISSUE:
W/N the decision should be reconsidered for the reason that the evidence presented at the summary hearing does not
prove that respondent is guilty of the charges against him.
HELD:
No. It should be borne in mind that the fact that there was no full-blown trial before the summary hearing officer does
not invalidate said proceedings. 
Moreover, to resolve the issue, respondent would have the Court re-calibrate the weight of evidence presented before
the summary hearing officer, arguing that said evidence is insufficient to prove respondent's guilt of the charges against him. 
The general rule is that the filing of a petition for certiorari does not toll the running of the period to appeal. However,
Section 1, Rule 1 of the Rules of Court provides that the Rules shall be liberally construed in order to promote their objective of
securing a just, speedy and inexpensive disposition of every action and proceeding. In Ginete v. Court of Appeals and Sanchez
v. Court of Appeals, the Court saw it proper to suspend rules of procedure in order to promote substantial justice where
matters of life, liberty, honor or property, among other instances, are at stake.
The present case clearly involves the honor of a police officer who has rendered years of service to the country.
 
23. DSM CONSTRUCTION AND DEVELOPMENT CORPORATION, Petitioner, vs. COURT OF APPEALS and MEGAWORLD
GLOBUS, Respondents.
G.R. No. 16693, December 19, 2005
FACTS:
Petitioner and respondent entered into agreements for the construction of a condominium project owned by respondent with
petitioner as contractor. In the course of the project’s construction, differences with respect to billings arose between the
parties. Petitioner thus filed a complaint for compulsory arbitration before the CIAC claiming payment for approximately P97
Million as the outstanding balance due from respondent pursuant to the agreements. The CIAC rendered a decision partially
granting both petitioner and respondent’s claims in favor of petitioner. This award was affirmed by the Court of Appeals.
Thereafter, the Supreme Court promulgated its Decision affirming the judgment of the Court of Appeals and lifting the TRO
that was then still in effect. It became final and executory.
Respondent however filed a Petition with the Court of Appeals to restrain the scheduled execution sale and to nullify the
orders of the CIAC issued pursuant thereto which the CA granted. Petitioner’s remedy is to file a petition for review under Rule
45 of the Revised Rules of Civil Procedure which centers on attempts, regrettably entertained by respondent CA, to thwart the
execution of a final and executory decision of the SC. Respondent then asserts that prematurity, multiplicity of suits and lack of
respect for the hierarchy of courts afflict the petition, thereby necessitating its dismissal.
ISSUE:
W/N the Court of Appeals gravely abused its discretion.
RULING:
YES. Rule 1, Section 6 of the Rules of Court provides that the Rules shall be liberally construed in order to promote their
objective of securing a just, speedy and inexpensive disposition of every action and proceeding. We have at times relaxed
procedural rules in the interest of substantial justice.
But from the outset, it bears stressing that the subject of petitioner and respondent’s petitions is the execution of a final
judgment was affirmed by no less than this Court. This being so, the appellate court should have been doubly careful about
entertaining an obviously dilatory petition intended merely to delay the satisfaction of the judgment. Any lower court or
tribunal that trifles with the execution of a final and executory judgment of the Supreme Court flirts with insulting the highest
court of the land. While we do not diminish the availability of judicial remedies to the execution of final judgments of this
Court, as may be sanctioned under the Rules of Court, such actions could only prosper if they have basis in fact and in law. Any
court or tribunal that entertains such baseless actions designed to thwart the execution of final judgments acts with grave
abuse of discretion tantamount to lack of jurisdiction. It is the positive duty of every court of the land to give full recognition
and effect to final and executory decisions, much less those rendered by the Supreme Court.
The abuse of discretion amounting to lack or excess of jurisdiction in this case was made manifest by the fact that the appellate
court not only took cognizance of the case and issued the assailed restraining order. It eventually decided the case in
petitioner’s (respondent herein) favor as well notwithstanding the dearth of any basis for doing so.

24.

REVISED RULES ON EVIDENCE

(Rules 128-134, Rules of Court)

AS AMENDED PER RESOLUTION

ADOPTED ON MARCH 14, 1989
 
PART IV
RULES OF EVIDENCE

RULE 130
4. Interpretation Of Documents

Section 10. Interpretation of a writing according to its legal meaning. — The language of a writing is to be interpreted
according to the legal meaning it bears in the place of its execution, unless the parties intended otherwise. (8)
Section 11. Instrument construed so as to give effect to all provisions. — In the construction of an instrument, where there are
several provisions or particulars, such a construction is, if possible, to be adopted as will give effect to all. (9)
Section 12. Interpretation according to intention; general and particular provisions. — In the construction of an instrument, the
intention of the parties is to be pursued; and when a general and a particular provision are inconsistent, the latter is
paramount to the former. So a particular intent will control a general one that is inconsistent with it. (10)
Section 13. Interpretation according to circumstances. — For the proper construction of an instrument, the circumstances
under which it was made, including the situation of the subject thereof and of the parties to it, may be shown, so that the
judge may be placed in the position of those who language he is to interpret. (11)
Section 14. Peculiar signification of terms. — The terms of a writing are presumed to have been used in their primary and
general acceptation, but evidence is admissible to show that they have a local, technical, or otherwise peculiar signification,
and were so used and understood in the particular instance, in which case the agreement must be construed accordingly. (12)
Section 15. Written words control printed. — When an instrument consists partly of written words and partly of a printed form,
and the two are inconsistent, the former controls the latter. (13)
Section 16. Experts and interpreters to be used in explaining certain writings. — When the characters in which an instrument is
written are difficult to be deciphered, or the language is not understood by the court, the evidence of persons skilled in
deciphering the characters, or who understand the language, is admissible to declare the characters or the meaning of the
language. (14)
Section 17. Of Two constructions, which preferred. — When the terms of an agreement have been intended in a different
sense by the different parties to it, that sense is to prevail against either party in which he supposed the other understood it,
and when different constructions of a provision are otherwise equally proper, that is to be taken which is the most favorable to
the party in whose favor the provision was made. (15)
Section 18. Construction in favor of natural right. — When an instrument is equally susceptible of two interpretations, one in
favor of natural right and the other against it, the former is to be adopted. (16)
Section 19. Interpretation according to usage. — An instrument may be construed according to usage, in order to determine its
true character. (17)
 
25. 

G.R. No. 146739               January 16, 2004

LUZVIMINDA DE LA CRUZ, Petitioner,
vs.
DEPARTMENT OF EDUCATION, CULTURE AND SPORTS-CORDILLERA ADMINISTRATIVE REGION, et. al., Respondents.
QUISUMBING, J.:
FACTS: In a letter-complaint, the CSC Abra Field Office, disclosed to the Department of Education, Culture, and Sports-
Cordillera Administrative Region (DECS-CAR), alleged mismanagement and supposed violations of Civil Service Laws at the
Bangued East District of the DECS Division of Abra by Helen Hernandez, herein petitioner Luzviminda de la Cruz, Charito
Turqueza, and Eugene Belarmino. Hernandez was the District Supervisor, while de la Cruz was Principal I of Bacsil Elementary
School, Angad, Bangued, Abra. Further, CSC-CAR formally charged petitioner of conduct prejudicial to the best interest of the
service, grave misconduct, and dishonesty. Thereafter, petitioner appealed to the Court of Appeals and contends that (1) the
CSC gravely abused its discretion in finding her guilty of grave misconduct and dishonesty; (2) she was denied administrative
due process; (3) the fact-finding committee of the DECS was illegally composed; (4) the complaints should have been dismissed
for being fatally defective; (5) the resolution of the DECS fact-finding committee was not supported by substantial evidence; (6)
assuming arguendo that petitioner was liable, the penalty should not have been dismissal considering the length of service
petitioner has rendered and that this is the first time she has been charged in her 25 years of service. However, her petition
was dismissed.
ISSUE: W/N the Honorable Court of Appeals erred in finding herein petitioner guilty of grave misconduct and dishonesty
considering that the decision is not in accord with law and with the applicable decisions of the Supreme Court
RULING: No. The charges against her for dishonesty and grave misconduct, after satisfying the requirements of administrative
due process, has been sufficiently established. Petitioner has shown no legal right that has been violated. Hence, there is
utterly no basis for the issuance of a writ of preliminary mandatory injunction. In fact, her dismissal from the service is in full
accord with applicable law.
The technical rules of procedure are liberally applied to administrative agencies exercising quasi-judicial functions. The
intention is to resolve disputes brought before such bodies in the most expeditious and inexpensive manner possible.