CASE DIGEST: US v.

Luis Toribio (15 Phil 85, 97)

ISSUE:

Whether the act of taking a property for public use in the exercise of the power of eminent domain, without

due compensation to its owner is an undue and unauthorized use of police power by the state.

RULE OF LAW

I. Act. No. 1147: an Act regulating the registration, branding, and slaughter of Large Cattle

II. States’ eminent domain and police powers

III. Section 5 of the Philippine Bill: No law shall be enacted which shall deprive any person of life, liberty, or

property without due process of law

APPLICATION

Luis Toribio was found guilty in violating Sections 30 and 33 of Act No. 1147 which regulates the

registration, branding and slaughter of large cattle, after he slaughtered his cattle for human consumption without

permit required by the said law. However, he contends that the regulations under the law stated, and any act that

constitutes taking a property under the power of eminent domain, without compensation to the owner, is an

unjustified and unlawful exercise of police power by the state.

On the other hand, according to the court of law, the rights to property, like any other rights, is subject to

limitations, especially if it can hamper the equal rights of the people and community. Accordingly, the regulations

under Act 1147 are necessary limitations to prevent the use of any property from injuring the public interest.

Further, it was explained that these carabaos are of public interest as it is an essential tool in the production of crops,

hence it satisfies the requisites for the legitimate use of police powers. Moreover, the court clarifies that the

regulations set under the Act 1147 is not, in any case, an exercise of eminent domain, as it does not take the carabaos

for public use, but rather, it just simply regulates its consumption to protect the general welfare of the people and the

public interest. Lastly, the court cited paragraphs from the highest judicial textbook of authority which strengthen its

opinion that the provisions under the Act in question is a legitimate use of police power, and does not, in any way,

violate Section 5 of Philippine Bill.

CONCLUSION

The Supreme Court affirmed the conviction and sentence set by the trial court against Toribio, the

appellant.
 CASE DIGEST: National Labor Union v. CIR (68 Phil. 732)

ISSUE

Whether the CIR violated the law and the rights of the petitioners in its decision favoring the respondent

company Manila Gas Corporation.

RULE OF LAW

A.) Property Rights of the Company, B.) Right to strike for a just cause of the workers, C.) Section 19 of

Commonwealth Act No. 103, as amended by section 1 of Commonwealth Act No. 355

APPLICATION

The National Labor Union filed a petition to reverse the decision of the Court of Industrial Relations which

favors the respondent company Manila Gas Corporation against its workers who engaged in strike. Accordingly, the

CIR erred in not ordering the strikers to return to their work and the respondent company to permit them to continue

in their employment. Moreover, it was claimed that the company was in contempt of the prohibitions under Section

19 of Commonwealth Act No. 103, as amended by section 1 of Commonwealth Act No. 355.

However, the court found that the strikers violated both an implied condition in their signed contract, in

which they are required to take care of the material provided for the fulfillment of the said contract, and the property

rights of the respondent company. Accordingly, the strikers sabotaged the operation of the company and have

damaged the property necessary for the continuation of the business. The laborers may have the right to go on a

strike for a just causes, however, they cannot avail of this right through acts of sabotage to the injury of the property

rights of the employer; Moreover, it was stated that, the respondent company is required to contract other workers

for the view of public interest, otherwise they would be liable through their certificate of public convenience. It was

also clarified that the company, as a public utility, is exempted from the prohibitions under Section 19 of

Commonwealth Act No. 103, as amended by section 1 of Commonwealth Act No. 355. Lastly, the strikers were said

to be uncompromising which made dispute settlement impossible through concessions based on equity and justice

for the general good and harmony between employers and employees.

CONCLUSION

The Supreme Court found no error in the decision of the CIR; hence, the same decision is affirmed against

the petitioners.
 CASE DIGEST: Philippine Blooming Mills Employees Organization v. Philippine Blooming Mills Co. Inc.

(50 SCRA 189, 1973)

ISSUE

Whether the respondents’ decision to expel the petitioners from the company is a violation of their liberty.

RULE OF LAW

A.) Section 4(a)-6 in relation to Sections 13 and 14, as well as Section 15, all of Republic Act No. 875, B.)

CBA providing for ‘No Strike and No Lockout, C.) The precedence of the rights of liberty over the rights of

property, D.) Section 3 of Republic Act No. 875 or Industrial Peace Act and Section 3 of Republic Act No. 8

APPLICATION

The respondent company expelled the petitioners from their job after the said employees attended the mass

demonstration against the alleged abuses of some police officers. The respondents charged the petitioners claiming

that they violated the Section 4(a)-6 in relation to Sections 13 and 14, as well as Section 15, all of Republic Act No.

875and the CBA providing for “No Strike and No Lockout”. The CIR in an order dated September 15, 1969, found

the petitioners guilty of bargaining in bad faith in the perpetuation of the alleged unfair labor practice.

However, the Supreme Court stipulated otherwise to the decision of CIR. Accordingly, the respondents’

claim that the absence of the employees caused a loss or damage to the company is a mere selfish act of preservation

of their property, and that, even if the rights to property is also protected by the constitution, the primacy of rights to

liberty of the petitioners over the respondents; right to property is well recognized. The court further stated that these

liberty rights are delicate and vulnerable and that any threat of sanction in its exercise may deter its application.

Moreover, the petitioner’s participation in the demonstration is an act of fighting for their existence using only the

weapon given by the constitution. Lastly, the court stated that the respondent company violated Section 3 of

Republic Act No. 875 or Industrial Peace Act and Section 3 of Republic Act No. 8 which guarantees the employees

the right to engage in concert activities for mutual aid or protection. And that the respondent company in its

insistence to inhibit its employees to participate in the said demonstration is a potent means of inhibiting their right

to liberty, specifically the rights to speech and demonstration.

CONCLUSION

The Supreme Court declared the decision of the CIR null and void and ordered the reinstatement of the

petitioners with due compensation from the respondent company.

 CASE DIGEST: People v. Vera (65 Phil 56, 1973)

ISSUE

Whether Section 11 of Act NO. 4221or the Probation Act violates the Equal Protection Clause of the

Constitution.

RULE OF LAW

A.) Section 11 of Act NO. 4221or the Probation Act, B.) Equal protection Clause of the Constitution, C.)

Unfair delegation of legislative power.

APPLLICATION

The respondent Judge Vera granted the petition for probation for criminally convicted Cu-Unjieng.

Meanwhile, the petitioners filed a case stipulating that the respondent has no power to put the said convict in

probation as it violates Section 11 of Act NO. 4221which grants the provincial boards the power to provide a system

of probation to convicted person as there is no clear provision which provides that the said section includes

chartered cities like that of Manila wherein the probation was granted. Furthermore, the petitioners claimed that,

even if the said act includes chartered cities, it is in violation of the constitution under Article III of the Constitution

guaranteeing equal protection of the laws.

With these considerations, the Supreme Court decided that the said act is indeed violating the equal

protection clause of the constitution as the class legislations that discriminate some and favors others is proscribed.

Accordingly, classification is permitted for a reasonable basis in which it must be based on substantial distinction,

germane to the purpose of the law, must not be limited to existing conditions and must apply equally to each

member of the class. However, the said act failed to meet these requisites, hence it is unconstitutional. It was further

stated that the unequal protection emanates from the unwarranted delegation of legislative power to each provincial

board, since it is in their own discretion to set probation system and that there is no guarantee that all provincial

boards will adopt the same and create the same probation system. Lastly, it was clear that section 11 of the Probation

Act creates a situation in which discrimination and inequality are permitted or allowed, hence, the act is of no good.

CONCLUSION

The Supreme Court declared Act No. 4221 unconstitutional as it violated the Equal Protection Clause of the

Constitution, the court further granted the writ of prohibition.

 CASE DIGEST: People v. Cayat (68 Phil 12, 1939)

ISSUE

Whether Act No. 1639 is unconstitutional under the grounds of violating the equal protection clause, the

due process and is an undue exercise of police power.

RULE OF LAW

A.) Equal protection of the law under reasonable classifications: (1) must rest on substantial distinctions;

(2) must be germane to the purposes of the law; (3) must not be limited to existing conditions only; (4) must apply

equally to all members of the same class, B.) Act No. 1639 Sections 2 and 3.

APPLICATION

Cayat, the respondent, is a native member of a non-Christian tribe in Baguio. He was found guilty of

violating sections 2 of Act No. 1639 which prohibits any one from non-Christian Philippine native tribes to buy,

receive and possess any intoxicating liquor other than native wines. He was fined for 5 pesos under section 3 of the

same law. With this, the respondent questioned the constitutionality of the Act stated by arguing that it is

discriminatory and denies the equal protection of the law under the constitution. He further claimed that it violates

due process and that it is an improper exercise of the states’ police power.

However, it was found by the court that the Act does not violate the equal protection clause of the

constitution as this legislative classification meets the requisites of reasonable grounds. First, the law rests on the

real and substantial distinction of the non-Christian tribes, whom are classified not based on religion, but on the

lower grades of civilization. Secondly, the act ensures peace and order in accordance with the purpose of the law as

the past records from the lower courts have shown that highly intoxicating liquors consumed by the non-Christian

tribes often lead to lawlessness which renders inhibition to the government in its efforts to develop a higher quality

of life and civilization. Then, the act can also be applied at all times, so long as the distinguished conditions remain

prevalent, thus the lawmakers considered the gradual process of civilized development to be matched with measures

of security and protection. Lastly, the Act is equally applicable to all members of the specified classification.

CONCLUSION

The Supreme Court stipulated that the Act in question does not violate the Equal protection clause as it has

reasonable grounds for classifications, thus the decision of the lower court was affirmed against the respondent.
 CASE DIGEST: Posadas v. Court of Appeals (G.R. No.89139)

ISSUE

Whether the act of warrantless search and seizure is lawful under the circumstances of the case.

RULE OF LAW

A.) Section 12, Rule 136 of the Rules of Court: warrantless search is due after a lawful arrest, B.) Section

5, Rule 113 of the 1985 Rules on Criminal Procedure: justifying warrantless arrest under the following

circumstances (a) if the person is actually committing, or is attempting to commit an offense (b) an offense has in

fact just been committed (c) when the person to be arrested is a fugitive, C.) Terry vs. Ohio, 392 U.S. 1 (1968) “stop

and frisk” D.) Constitutional guarantee against warrantless arrest and search.

APPLICATION

The petitioner was found guilty of the possession of illegal firearms by the lower court and the Court of

Appeals; thus, the case was brought before the supreme court with the contention that the warrantless arrest and

search is unlawful, hence the evidences gathered from the said search should be inadmissible. On the other hand, the

Solicitor General justified the warrantless search to be lawful within Section 12, Rule 136 of the Rules of Court, and

the arrest was lawful under Section 5, Rule 113 of the 1985 Rules on Criminal Procedure.

The Supreme Court disagrees that the arrest is lawful since the circumstances of the case did not meet the

prerequisites of a lawful warrantless arrest, hence the claim of lawful search was, in effect, undue if the basis is the

aforementioned Section 12, Rule 136 of the Rules of Court. However, the Supreme Court upheld the decision since

accordingly, warrantless search and seizure is still lawful under the principle of “stop and frisk” as the case of Terry

vs. Ohio. Accordingly, the arresting officers saw a probable cause when the assailant attempted to escape after he

was apprehended by the said officers. Moreover, the officers acted in the object of determining the identity of the

suspicious individual and have maintained the status quo, momentarily, while they seek to obtain more information.

CONCLUSION

The Supreme court upheld the decision of the CA against the petitioner stipulating that the warrantless

arrest under the principle of “stop and frisk” did not, in any way, violated the constitutional right against warrantless

arrest and warrantless search and seizure.

 CASE DIGEST: People v. De Gracia (G.R.No.102009-10)

ISSUE

Whether the warrantless arrest and warrantless search and seizure is valid given the circumstances of this

case.

RULE OF LAW

A.) Exemption from the Prohibitions of a warrantless arrest (a) if the person is actually committing, or is

attempting to commit an offense (b) an offense has in fact just been committed (c) when the person to be arrested is

a fugitive

APPLICATION

The respondent was found guilty of illegal possession of fire arms in furtherance of rebellion by the lower

court. The case was brought to the Supreme Court, though the issue was not posed by the assailant, the Supreme

Court still justified the warrantless arrest and search due to necessity given the weight of the case being heard.

Accordingly, during the period of coup de’ tat, against the newly established Aquino government in 1989, the rebel

forces occupied some establishments including the Eurocar Sales Office, in which the assailant was arrested. Due to

the information from intelligence forces, the arresting police officers conducted a surveillance on the said

establishment, following that, members of the rebelling group open fired to the surveillance car injuring one officer.

Following this, the police forces conducted a raid on the said establishments wherein they caught the respondent, De

Gracia in a room with varied weapon contrabands.

Given the circumstances, though the raiding and arresting forces do not have a warrant, the arrest is still

legal as it falls under the exemption of the prohibition of warrantless arrest, where in the arresting officer has a

reasonable cause to believe that a crime is being committed. Moreover, there are probable cause that warrants the

search and seizure of the contrabands from the same establishment. Lastly, due to extreme disorder brought by the

rebellion, the courts of law were closed, hence there are no means to secure the needed warrant and waiting for the

issuance of the warrant is unnecessary given the present circumstances of the case.

CONCLUSION

The Supreme Court affirmed the decision of the lower courts; hence the warrantless search and arrest is

valid under the circumstances of the case which are included in the exemptions of the prohibition of warrantless

arrest and search.

 CASE DIGEST: US v. Arceo (3 Phil 381, 1984)

ISSUE

Whether the lack of expressed prohibition to enter validates the entry to other peoples’ residence.

RULE OF LAW

A.) The inviolability of the dwelling: The right to be free from unauthorized entrance into one’s dwelling

B.) Subsection 2 of Article 491 of the Penal Code: forbids the forcible entry into the dwelling of another, C.)

Express prohibition: the act of expressly prohibiting one’s act.

APPLICATION

The defendants were found guilty by the lower court with the crime of entering the house of another, with

violence and intimidation. Such crime is punishable under subsection 2 of article 491 of the Penal Code with

aggravating circumstances under article 11 of the Penal Code. Such crime violates the principle on the inviolability

of another’s’ dwelling, which is considered as one of he most essential right of a person that is recognized by

political codes of any civilized nations. This means that, no one, can enter into the house of another without consent

of the owner.

The simplified definition might be contended by arguing that a person who enters the dwelling of another is

not liable, unless he is forbidden. In simpler terms, the act of express prohibition of entry is essential for liability. In

this case, since the defendants entered the house without the knowledge of the owner, hence, they were not expressly

prohibited, thus making the case invalid. However, the Supreme Court clarified this contention. Accordingly, the

statute does not simply refer to the method by which one may enter the residence, rather it also relates to the

conduct, immediately after the entrance without consent. Moreover, given that the assailants were armed with

deadly weapons and commits acts of violence or intimidation, then, they are guilty of the crime as stated above. It

was further stipulated by the court that the contention on the absence of expressed prohibition is unreasonable,

because the entrance itself, is generally forbidden, unless permission from the owner was given. Furthermore,

allowing such construct of stipulation would destroy the spirit of the law. Lastly, it was emphasized that the privacy

of the home has always been regarded by civilized nations as one of the most sacred rights that a person is entitled

of.

CONCLUSION

The Supreme Court affirmed the guilt of the defendants and have slightly modified the sentence given.
 CASE DIGEST: People v. Escaño (G.R No. 129756-58, Jan 28,2000)

ISSUE

Whether the evidence gathered through a warrantless search and seizure is admissible in the court of law.

RULE OF LAW

A.) Six generally accepted circumstances for a warrantless search and seizure: (1) incidental to an arrest,

(2.) moving vehicles, (3.) evidence in plain sight, (4.) customs searches, (5.) consented warrantless search and (6.)

stop and frisk situations. B.) Section 4, Article II of Republic Act No. 6425

APPLICATION

Julian Deen Escaño, Virgilio Tome Usana and Jerry Casabaan Lopez, the respondents, were found guilty

by the Trial Court in violation of Section 4, Article II of Republic Act No. 6425, after they were caught in

possession of an illegal drugs. In an appeal to the supreme court, the Usana and Lopez claimed that they should be

acquitted from the case for the search conducted, that found the illegal drugs is warrantless, even if the police

officers had the chance to request for a search warrant after the bag was found in the car of Escaño. Accordingly,

this renders the evidence inadmissible to the court. Moreover, even if the search is found to be valid, there is no

sufficient evidence to prove that all three of them owned the illegal drugs, as the car was solely owned by Escaño.

With this appeal, the Supreme Court reversed the conviction of Ursana and Lopez due to reasonable doubt,

however, the court also clarified that the search without warrant is legal as there is sufficient evidence that Escaño

consented with the search. Even if Escaño in his affidavit denied any consent to the search, the testimonies given by

the searching officer and the plaintiffs Ursana and Lopez proved otherwise. In this case, the evidences gathered from

the warrantless search is considered valid and admissible to the court of law, contrary to the claims of the plaintiffs.

However, it was found that there is no sufficient evidence that Ursana and Lopez actually nor constructively owned

the illegal drugs, hence, they were acquitted from the case of the illegal drugs, leaving Escaño the only one

convicted for the case.

CONCLUSION

The Supreme Court Acquitted Ursana and Lopez due to reasonable doubt, but also stipulated that the

warrantless search is lawful.

 CASE DIGEST: People v. Bolasa (G.R. No. 125754, Dec. 22, 1999)

ISSUE

Whether the warrantless arrest and search and seizure done by the police officers have reasonable grounds.

RULE OF LAW

A.) Section 2, Art. III, of the 1987 Constitution, B.) Sec. 8, Art. II, of RA 6425 or The Dangerous Drugs

Act of 1972, C.) Exemptions to the prohibitions of warrantless arrest and warrantless search.

APPLICATION

The respondents were convicted for the violation of Sec. 8, Art. II, of RA 6425 or The  Dangerous Drugs

Act of 1972 after they were arrest in their house by police officers, whom without warrant to arrest nor search,

raided the place due to the information provided by their informant. However, the respondents appealed to the court

questioning the constitutionality of the arrest and search and seizure of evidences without warrant. Accordingly, the

action of the officers is a violation of the inviolable right of the people to be secure in their persons, houses, papers,

and effects against unreasonable searches and seizures of whatever nature and for any purpose, stipulated under

Section 2, Art. III, of the 1987 Constitution.

The court found that the warrantless arrest is illegal as the probable cause was not established, nor the

circumstances qualified under the exemptions to the prohibitions of warrantless arrest. Since the arrest was found to

be undue, the search and seizure that it entailed is also illegal, as it do not also qualify under reasonable grounds for

warrantless search and seizures, rendering the evidences gathered therein inadmissible to the court of law. Due to

this, there are no valid evidences to support the conviction of the assailants, hence the court has no choice but to

acquit the respondents due to reasonable doubt brought by the lack of valid evidences.

In this case, the constitutional rights of the assailants served as an impenetrable armor against undue arrests

and searches together with the inviolable right of privacy within ones’ home.

CONCLUSION

Since there is no reasonable grounds to support the warrantless arrest and search, the evidences gathered

will be rendered inadmissible, and with the lack of evidences, the respondents were acquitted in faithful obeisance to

the fundamental law.

 CASE DIGEST: Sony Music v. Judge Español (G.R. No. 156804, March 14,2005)

ISSUE

Whether the issuance of search warrant No. 219-00 is valid with reasonable grounds and probable cause.

RULE OF LAW

A.) Article III, Section 2 of the 1987 Constitution, B.) Section 4, Rule 126 of the Rules of Court, C.)

Probable Cause, D.) Columbia Pictures, Inc. vs. Court of Appeals

APPLICATION

The respondent judge issued the Search Warrant No. 219-00 for an alleged violation of Section 208 of R.A.

No. 8293. The following day, the police conducted the search, however, the DOJ in its resolution found that the

alleged assailants did not violate the mentioned Republic Act, hence, the respondent judge quashed the issued search

warrant. However, the petitioners of this case filed a case against the respondent judge questioning the quashal of

the mentioned search warrant, which in turn, leads to the question of the propriety of the issuance of the warrant

itself.

Following the provisions under Article III, Section 2 of the 1987 Constitution, it was stated that no warrant

shall be issued without probable cause and the probable cause defined under Section 4, Rule 126 of the Rules of

Court must be determined personally by the judge after examination under oath or affirmation of the complainant

and the witnesses. In the same rule, in its section 5, it was provided that the probable cause must be facts personally

known to the complainants. Moreover, there are instances like the case of Columbia Pictures, Inc. vs. Court of

Appeals where in the person requesting for the warrant has no personal knowledge about the facts, but can present

valid witnesses who knows the facts personally. However, in the case at hand, the requesting personnel for the

warrant has no personal knowledge about the facts of a crime being committed, nor was able to present witnesses

who personally knows the required facts. The case also does not align with the mentioned Columbia Pictures Inc.

case. Accordingly, unlike the previous case, there are misinterpretations in the present case at hand.

With these, the issuance of the search warrant in question did not meet the requirements of probable cause

moreover, the respondent judge did not accordingly err in quashing the same warrant.

CONCLUSION
 The Supreme Court was not able to find a probable cause for the issuance of the search warrant in question,

hence, it was rendered to be invalid.

CASE DIGEST: Stonehill v. Diokno (L-19550, June 19,1967)

ISSUE

Whether the contested search warrants are valid and issued in accordance to the law

RULE OF LAW

A.) Constitutional Provision against warrantless search and seizures without due and definite probable

cause. B.) Section 3 of Rule 122 of the former Rules of Court and Revised Rules of Court

APPLICATION

The respondents of this case issued and 42 search warrants against the petitioners of this case. However, the

petitioners appealed to the supreme court that the search warrants issued are invalid for the following reasons: (1)

they do not describe with particularity the documents, books and things to be seized; (2) cash money, not mentioned

in the warrants, were actually seized; (3) the warrants were issued to fish evidence against the aforementioned

petitioners in deportation cases filed against them; (4) the searches and seizures were made in an illegal manner; and

(5) the documents, papers and cash money seized were not delivered to the courts. With these, the issuance of the

said warrants and its use violated the provisions of the constitution and the Rules of Courts.

Under the constitution, no warrant shall be issued without probable cause, to be determined by the judge in

the manner set forth in said provision; and (2) that the warrant shall particularly describe the things to be seized.

None of the warrants met these requirements. Moreover, the warrant was issued from mere allegation that

petitioners committed a “violation of Central Bank Laws, Tariff and Customs Laws, Internal Revenue (Code) and

Revised Penal Code and that no specific offense had been alleged in said applications. The averments thereof with

respect to the offense committed were abstract. As a consequence, it was impossible for the judges who issued the

warrants to have found the existence of probable cause, for the same presupposes the introduction of competent

proof that the party against whom it is sought has performed particular acts, or committed specific omissions,

violating a given provision of our criminal laws.

CONCLUSION
 The Supreme Court found that the search warrants were issued without probable cause and its usage have

gravely violated the provisions of the constitution, hence, the court rendered the warrants to be invalid.

CASE DIGEST: Collector of Customs v. Villaluz (71 SCRA 673)