Professional Documents
Culture Documents
ISSUE:
4. Issue/s (one sentence)
Whether or not the defendant, National Coconut Corporation, is obligated to pay rent to
the plaintiff, Sagrada Orden de Predicadores del Santisimo Rosario del Filipinas, for
commercial use of the lot.
HELD:
5. Disposition of the Case (one sentence)
Except for the part of the judgment that is being appealed, which sentences defendant-
appellant to pay rentals from August 1946 to February 28, 1949, the judgment is upheld
in its entirety.
6. Dictum (no more than five sentences addressing the issue relevant to the
topic under discussion)
The defendant is not responsible to pay the rentals since there was no privity of contract
or obligation between the Alien Property Custodian and the Taiwan Tekkosho. A party
allowed by the United States Alien Property Custodian to occupy and use the enemy
property is not liable to pay rentals therefor to the pre-war owner prior to the annulment
of the enemy's title to the property even when the enemy acquired it by duress, because
there was no privity (of contract or obligation) between the Alien Property Custodian and
the enemy owner, the former's title being based, by legal provision, on the right to seize
enemy property. The occupant's obligation to pay rentals, like any other obligation, must
arise from law, contract, quasi-contract, crime, or negligence (article 1089, Spanish Civil
Code). If occupant took possession of the property with the permission of the Alien
Property Custodian, without any express or implied agreement between them that
rentals would be paid for the use and occupation of the enemy property, none may be
recovered by the pre-war owner. As to the rentals collected by said occupant from its
lessee, the same should accrue to it as a possessor in good faith.
2) Mangonon vs. CA G.R. No. 125041 June 30, 2006
FACTS:
1. Petitioner’s / Plaintiff’s claim/s (no more than three sentences)
ISSUE:
4. Issue/s (one sentence)
Whether respondent Francisco C. Delgado should be held financially
responsible for his granddaughters.
HELD:
5. Disposition of the case (one sentence) Premises considered, the Decision
of the Court of Appeals on March 20, 1996, and Resolution on May 16, 1996,
affirming the Order dated September 12, 1995 of the Regional Trial Court,
Branch 149, Makati, establishing the amount of assistance pendente lite to
P5,000.00 for Rebecca Angela and Regina Isabel, is modified in that respondent
Francisco Delgado is found accountable for support pendente lite in the amount
to be decided by the trial court, where it shows this petition is partially granted.
6. Dictum (no more than five sentences addressing the issue relevant to the
topic under discussion)
FACTS:
On August 30, 1985, a 3rd-year commerce student, Carlitos Bautista died due to
a stabbing incident by the non-assailants who were not members of the school
community on the second-floor premises of the Philippine School of Business
Administration (PSBA). The deceased student's parents filed a suit in Regional Trial
Court Manila Branch 47 presided by Judge Regina Ordonez-Benitez for the damages
versus the petitioners, PSBA, and its authorities. Petitioners sought dismissal of the suit
because they were presumably sued under Article 2180 of the Civil Code, which states
that there are no grounds for action against them because jurisprudence on the subject
holds that academic institutions, such as the PSBA, are excluded from the rule in the
said article.
2. Respondent’s/ Defendant’s claims:
The defendants intended to hold the plaintiff’s responsibility for the victim's death
due to the alleged negligence, carelessness, and lack of security measures, means,
and procedures before, during, and after the victim's attack.
ISSUE:
4. Issue/s
Whether or not the Philippine School of Business Administration and its school
authorities can be held accountable for Carlos Bautista's death through the law of quasi-
delict.
HELD
Considering the conjectures of this claim, the suit is rejected, and RTC Manila, Br.
47 must continue proceedings in accordance with the court’s decision against the
petitioners.
6. Dictum:
No, the petitioners are not absolved from legal responsibility under quasi-delicts.
Necessarily, the school must ensure that adequate steps are taken to maintain
peace and order within the campus premises and to prevent the breakdown thereof.
Because the circumstances of the present case evince a contractual relation between
the Philippine School of Business Administration, and Carlitos Bautista, the rules on
quasi-delict do not really govern. A perusal of Article 2176 shows that obligations arising
from quasi-delicts or tort, also known as extra-contractual obligations, arise only
between parties not otherwise bound by contract, whether express or implied, however,
this impression has not prevented this Court from determining the existence of a tort
even when there obtains a contract. It can be concluded that should the act which
breaches a contract be done in bad faith and be violative of Article 21, then there is a
cause to view the act as constituting a quasi-delict, thus, in the circumstances obtaining
the present case, there is no finding that the contract between the school and Carlitos
Bautista had been breached through the former’s negligence in providing proper
security measures.
4) YHT Realty Corporation vs. Court of Appeals G.R. No. 126780, February 17,
2005
FACTS:
ISSUE:
5. Issue/s (one sentence) Whether or not the “Undertaking for The Use of
Safety Deposit Box” admittedly executed by private respondent is valid.
HELD:
6. Disposition of the case (one sentence)
Foregoing premises considered; the Decision of the Court of Appeals dated
19 October 1995 is affirmed.
7. Dictum (no more than five sentences addressing the issue relevant to the
topic under discussion)
No, the “Undertaking for The Use of Safety Deposit Box” admittedly executed
by private respondent is null and void. Under Article 2003, incorporated in the
New Civil Code as an expression of public policy precisely to apply to
situations such as that presented in the case, the hotelkeeper cannot free
himself from responsibility by posting notices to the effect that he is not liable
for the articles brought by the guest. The hotel business like the common
carrier's business is imbued with public interest. Catering to the public,
hotelkeepers are bound to provide the twin duty to provide lodging for hotel
guests and security to their persons and belongings. The law in turn does not
allow such duty to the public to be negated or diluted by any contrary
stipulation in so-called "undertakings" that ordinarily appear in prepared
forms imposed by hotel keepers on guests for their signature
5) Manliclic et.al. vs. Calaunan G.R. No. 150157 January 25, 2007
FACTS:
1. Petitioner's/Plaintiff's Claim/s
When petitioner Manliclic hit the rear left side of respondent Calaunan’s
owner-type jeep while driving a Philippine Rabbit Bus Lines Inc. (PRBLI) bus
headed to Manila from Concepcion, Tarlac, the respondent filed a claim for
damages against both Manliclic and PRBLI, with Manlilic criminally charged with
Reckless Imprudence Resulting in Property Damage with Physical Injury.
However, Manlilic’s party was adamant in claiming that the Calaunan was to
blame for the collision, while the respondent argued that Manliclic should be held
accountable. The petitioners requested a review of the Court of Appeals’ (CA)
ruling due to the following errors: (1) CA erred on a legal issue by upholding the
trial court’s dubious admission of the transcripts of stenographic notes and other
documents into evidence in the criminal case; (2) CA overstepped the mark on a
legal issue by upholding the trial court’s reliance on the respondent’s version of
how the accident allegedly occurred; (3) CA erred on a question of law in
affirming the trial court’s unfair disregard of PRBLI’s defense of exercising due
care in the selection and regulation of its employees; and (4) CA erred on a
question of law in affirming the trial court’s dubious award of damages and
attorney’s fees.
2. Respondent's/Defendant's Claim/s
ISSUE:
4. Issue/s
Whether or not petitioners Manlilic and PRBLI share solidarity
responsibility and several other liabilities for the aforementioned accident-related
damages.
HELD:
5. Disposition of the Case
The Court of Appeals' ruling in CA-G.R. CV No. 55909 is affirmed,
however with the revisions that (1) the moral damages award shall be decreased
to PhP50,000.00; and (2) the award of punitive damages shall also be
decreased to PhP50,000.00.
6. Dictum
Yes, petitioners Manlilic and PRBLI shall be held solidarily liable and
share responsibilities for the aforementioned damages in the collision incident.
FACTS:
1. Petitioner’s/Plaintiff’s claim/s (no more than 3 sentences)
Petitioner, Edgardo Mendoza testified in a joint trial that jeep-
owner-driver Salazar overtook the truck driven by Montoya, swerved
to the left going towards the poblacion of Marilao, and hit his car which
was bound for Manila. Mendoza further testified that before the
impact, Salazar had jumped from the jeep and that he was not aware
that Salazar's jeep was bumped from behind by the truck driven by
Montoya.
ISSUE
HELD