CASE DIGEST IN PHILOSOPHY OF LAW

By: Marc Kevin P. Leoncito – Juris Doctor - I

PHILOSOPHERS ON LAW AND ACADEMIC FREEDOM

FELIXBERTO STA. MARIA vs SALVADOR P. LOPEZ, ET AL.
G.R. NO. L-30773, February 18, 1970)

Facts:

Felixberto C. Sta. is the petitioner. Maria was the Dean of the College of Education of the
University of the Philippines (UP), and the respondent was the University President, Salvador P.
Lopez. Sta. Maria, an English and Comparative Literature professor, was appointed Dean of the
College of Education by the Board of Regents on May 5, 1967, on the nomination of the UP
President. His appointment as Dean was for a five-year term, effective May 16, 1967 until May
17, 1972, unless sooner terminated, with all of the rights and privileges as well as the duties and
obligations attached to the position in accordance with the rules and regulations of the University
and the Constitution and laws of the Republic of the Philippines.

The graduate and undergraduate students of the UP College of Education presented President
Salvador P. Lopez with a number of requests concerning the main academic program as well as
the physical plant and services, as well as a cluster of unique concerns, in February 1969. As a
result, President Lopez formed a commission that met with Sta. Maria on a regular basis.

As a consequence of the discussions and proposals made by Sta. The students were not satisfied,
according to Maria to the president. The students then boycotted their courses, infecting the other
colleges, and the newly elected members of the UP-Student Council voted in support of the
education students' strike. Until the day when all academic work at the university came to a
halt and the UP President summoned the faculty of the College of Education to a conference.
Those in attendance granted him a vote of confidence (40 in favor, 7 abstained) to handle the
situation as he deems proper.

Armed with the vote of confidence of the education faculty, President Lopez issued the transfer
order herein challenged, Administrative Order 77. The order, addressed to Dean Sta. Maria and
simultaneously appointed ad interim Professor Nemesio R. Ceralde as "acting Dean of the
College of Education, without additional compensation.

Issue:

Whether or not the removal of Sta. Maria constitutes removal.

Ruling:

Yes, A transfer is a movement from one position to another which is of equivalent rank, level or
salary, without break in service. Promotion is the advancement from one position to another with
an increase in duties and responsibilities as authorized by law, and usually accompanied by an
increase in salary.
A transfer that results in promotion or demotion, advancement or reduction or a transfer that
aims to lure the employee away from his permanent position cannot be done without the
employee’s consent. For that would constitute removal from office. Indeed, no permanent unless
the officer or employee is transfer can take place unless the officer of the employee is first
removed from the position held, and then appointed to another position. The transfer was a
demotion. A demotion, because: First, Deanship in a university, being an academic position,
which requires learning, ability and scholarship, is more exalted than that of a special assistant
who merely assists the President, as the title indicates. The special assistant does not make
authoritative decisions. Second. The position of dean is a line position where the holder makes
authoritative decisions in his own name and responsibility. A special assistant does not rise
above the level of staff position. Third. The position of dean is created by law, the university
charter, and cannot be abolished even by the Board of Regents. That of special assistant, upon
the other hand, is not so provided by law; it was a creation of the university president. It will not
avail respondents any to say that Sta. Maria retained the rank of Dean. In actual administrative
practice, the terms with rank of dean is meaningless. He is no dean at all. He of course, basks, in
the trappings of the dean. A palliative it could have been intended to be. But actually, he is a
dean without a college.

PHILISOPHERS ON LAW AND JUSTICE

JORGE B. VARGAS v. EMILIO RILLORAZA, ET AL.
(G.R. No. L-1612, February 26, 1948)

Facts:

A motion dated on August 28, 1947, assails the constitutionality of section 14 of the people’s
Court Act (Commonwealth Act No. 682) for the following reasons, among others: (a) it provides
for qualification of members of the Supreme Court, other than those provided in Section 6,
Article VIII of the Philippine Constitution; (b) it authorizes the appointment of members of the
Supreme Court who do not possess the qualifications set forth in section 6, Article VIII of the
Philippine Constitution; (c) it removes from the office the members of the Supreme Court by
means of a procedure other than impeachment; (d) It creates two Supreme Court.
The Solicitor General, in behalf of the prosecution, opposes the motion and inn support of his
opposition submits that Power of Congress to enact section 14 of the Commonwealth Act No. 68
and CA 68 does not amend nor add to the Constitutional provisions. The law provides,
Section 14. Any Justice of the Supreme Court who held any office or position under the
Philippine Executive Commission or under the government called Philippine Republic may not
sit and vote in any case brought to that Court under section thirteen hereof in which the accused
is a person who held any office or position under either or both of the Philippine Executive
Commission or the Philippine Republic or any branch, instrumentality and/or agency thereof.
If, on account of such disqualification, or because of any of the grounds or disqualification of
judges, in Rule 126, section 1 of the Rules of Court, or on account of illness, absence of
temporary disability the requisite number of Justice necessary to constitute a quorum or to render
judgement in any case is not present, the President may designate such number of Judges of First
Instance, Judges-at-large of First Instance, or Cadastral Judges, having none of the
disqualifications set forth in said section one hereof, as may be necessary to sit temporarily as
Justice of said Court, in order to form a quorum or until a judgment in said case is reached.

Issues:

Whether or not Section 14 of CA 682 is constitutional.

Ruling:

No. Section 14 of CA 682 is unconstitutional.

(a) To discover whether the above quoted section 14 of the People’s Court Act is repugnant to
the constitution, one of the best tests would be to compare the operation with the same section if
the latter were to be allowed to produce its effects. It is self-evident that before the enactment of
the oft-quoted section of the People’s Court Act, it was not only the power but the bounden duty
of all members of the Supreme Court to sit in judgement in all treason cases duly brought or
appealed to the Court. That power and that duty arise from the above cited sections of Article
VIII of the Constitution, namely, section 4, providing how the court shall be composed and how
it may sit, section 9, ordaining that they shall hold office during good behavior until they reach
the age of seventy years or become,, incapacitated to discharge the duties of their office, and the
pertinent constitutional and statutory provisions bearing on the jurisdiction, powers, and
responsibilities of the Supreme Court. Competently referring to the instant case, if section
14 of the People’s Court Act had not been inserted therein, there can be no question that each
and every member of this Court would have to sit in judgement in said case.
But if said section 14 were to be effective, such members of the Court “who held any office or
position under the Philippine Executive Commission or Philippine Republic” would be
disqualified from sitting and voting in the instant case, because the accused herein is a person
who likewise held an office or position at least under the Philippine Executive Commission. In
other words, what the constitution in this respect ordained as a power and duty to be exercised
and fulfilled by said members of the People’s Court Act would prohibit them from exercising
and fulfilling what the constitution directs the section prohibits. A clearer case of repugnancy of
fundamental of law can hardly be imagined. For repugnancy to result it is not necessary that
there should be an actual removal of the disqualified Justice from his office for, as above
demonstrated, were it not for the challenged section 14 there would have been an uninterrupted
continuity in the tenure of the displaced Justice and in his exercise of the powers and fulfillment
of the duties appertaining to his office., saving only proper cases or disqualification under Rule
126.
(b) In the face of constitutional requirement (section 5, Art VIII, Philippine Constitution) that the
members of the Supreme Court should be appointed by the President with the consent of the
Commission on Appointments, we are of the opinion that no person not so appointed may act as
Justice of the Supreme Court and that the “designation” authorized in section 14 of the People’s
Court Act to be made by the President of any Judge of First
Instance, Judge-at-large of First Instance or cadastral judge cannot possibly be a compliance with
the provision requiring that appointment. An additional disqualifying circumstances of the
“designee” is the lack of confirmation by or consent of the Commission on Appointments.
Without intending the least reflection on the ability, learning and integrity of any such
“designee”, we are merely construing and applying the fundamental law of the land. A Judge of
First Instance, Judge-at-large of First Instance or Cadastral Judge, under section 149 of the
Revised Administrative Code, need not be at forty years of age, nor have more than ten years or
more been a judge of court of record or engaged in the practice of law in the Philippines (as
required in section 6 of Article
VIII of the Philippine Constitution), because under said section he need only have practiced law
for a period of not less than five years or have held during like a period within the Philippines an
office requiring a lawyer’s diploma. So that it may happen that the “designee” under section 14
of the People’s Court Act, sitting as a substitute Justice of the Supreme Court in particular
collaboration cases, and participating therein in the deliberations and functions of the Supreme
Court, like any regular Justice thereof, does not possess the required constitutional qualifications
of a regular member of said Court. Here again is another point of repugnancy between the
challenged section and the constitution.

HEGEL AND THE SPIRIT OF STATUTES

WILLIAM F. PERALTA v. THE DIRECTOR OF PRISONS
(G.R. No. L-49, November 12, 1945)

Facts:
William Peralta was accused of robbery and sentenced to life imprisonment in accordance with
Act No. 65 of the National Assembly of the Republic of the Philippines.
The petition for habeas corpus is based on the claim that the Court of Special and Exclusive
Criminal Jurisdiction established by Ordinance No. 7 was a political instrument of Japan’s
military forces and is incompatible with the goals of the Commonwealth of the Philippines
because it does not provide a fair trial and violates the accused's constitutional rights.

Issues:
1.) Whether or not the creation of court by Ordinance No. 7 is valid?
2.) Whether or not the sentence of life imprisonment is valid?

3.) Whether or not the punitive sentence ceased to be valid from the time of the restoration of
Commonwealth, by virtue of the principle of posliminium.

Ruling:
1.) Yes. There is no room for doubt to the validity of Ordinance No. 7 since the criminal
jurisdiction established by the invader is drawn entirely from the law martial as defined in the
usages of nations. It is merely a governmental agency.
2.) Yes. The sentence rendered, likewise, is good and valid since it was within the power and
competence of the belligerent occupant to promulgate Act No. 65.
3.) Yes. All judgements of political complexion of the courts during Japanese regime ceased to
be valid upon reoccupation of the Islands, as such, the sentence which convicted the petitioner of
a crime of a political complexion must be considered as having ceased to be valid.

H.L.A. HART ON LAW AND MORALITY

ALEJANDRO ESTRADA v. SOLEDAD ESCRITOR
(A.M. No. P-02-1651, August 4, 2003)

Facts:

Complainant Alejandro Estrada requested an inquiry into reports that respondent Soledad
Escritor, court interpreter, is living with someone other than her spouse. They apparently have a
child aged eighteen to twenty. Estrada has no personal ties to Escritor or her partner.
Nonetheless, he brought the accusation against Escritor because he feels she is conducting an
immoral act that tarnishes the image of the court and should not be allowed to continue working
there since it may look that the court condones her behavior. Respondent Escritor stated that she
was already a widow when she entered the judiciary in 1999, her spouse having died in 1998.
She confirmed that she has been living with Luciano Quilapio, Jr. for twenty years without the
benefit of marriage and that they had a son. However, being members of the Jehovah’s
Witnesses and the Watch Towerand Bible Tract Society, their marital arrangement is consistent
with their religious convictions. In fact, after 10 years of living together, she completed a
Declaration of Pledging Faithfulness on July 28, 1991, inasmuch as the congregation is
concerned, there is nothing immoral about Escritor and Quilapio's marital arrangement,
and they remain members in good standing in the community.

Issue:

Whether or not respondent should be found guilty of the administrative charge of “gross and
immoral conduct.

Ruling:

The two streams of jurisprudence - separationist or accommodationist – are anchored on a

different reading of the wall of separation; Separationist - This approach erects an absolute
barrier to formal interdependence of religion and state. Religious institutions could not receive
aid, whether direct or indirect, from the state. Nor could the state adjust its secular programs to
alleviate burdens the programs placed on believers. The strict neutrality or separationist view is
largely used by the Court, showing the Court’s tendency to press relentlessly towards a more
secular society Accommodationist -Benevolent neutrality thus recognizes that religion plays an
important role in the public life of the United States as shown by many traditional government
practices which an
accommodationist holds that it is good public policy, and sometimes constitutionally required,
for the state to make conscious and deliberate efforts to avoid interference with religious
freedom. On the other hand, the strict neutrality adherent believes that it is good public policy,
and also constitutionally required, for the government to avoid religion-specific policy even at
the cost of inhibiting religious exercise. First, the accommodationist interpretation is most
consistent with the language of the First Amendment. Second, the accommodationist position
best achieves the purposes of the First Amendment. Third, the accommodationist interpretation is
particularly necessary to protect adherents of minority religions from the inevitable effects of
majoritarianism, which include ignorance and indifference and overt hostility to the minority
Fourth, the accommodationist position is practical as it is a commonsensical way to deal with the
various needs and beliefs of different faiths in a pluralistic nation. The compelling state interest
test is proper where conduct is involved for the whole gamut of human conduct has different
effects on the state’s interests: some effects may be immediate and short-term while others
delayed and far-reaching. A test that would protect the interests of the state in preventing a
substantive evil, whether immediate or delayed, is therefore necessary in applying the test, the
first inquiry is whether respondent’s right to religious freedom has been burdened. There is no
doubt that choosing between keeping her employment and abandoning her religious belief and
practice and family on the one hand, and giving up her employment and keeping her religious
practice and family on the other hand, puts a burden on her free exercise of religion The second
step is to ascertain respondent’s sincerity in her religious belief. Respondent appears to be
sincere in her religious belief and practice and is not merely using the Declaration of Pledging
Faithfulness to avoid punishment for immorality. She did not secure the Declaration only after
entering the judiciary where the moral standards are strict and defined, much less only after an
administrative case for immorality was filed against her Indeed, it is inappropriate for the
complainant, a private person, to present evidence on the compelling interest of the state. The
burden of evidence should be discharged by the proper agency of the government which is the
Office of the Solicitor General. To properly settle the issue in the case at bar, the government
should be given the opportunity to demonstrate the compelling state interest it seeks to uphold in
opposing the respondent’s stance that her conjugal arrangement is not immoral and punishable as
it comes within the scope of free exercise protection.

HOLMES ON LAW AND EXPERIENCE

JOEL G. MIRANDA v. ANTONIO M. ABAYA and the COMMISSION ON ELECTIONS
(G.R. No. 136351, July 28, 1999)

Facts:

Jose “Pempe” Miranda, then incumbent Mayor of Santiago City, Isabela, filed his certificate of
candidacy for the same mayoralty post for the synchronized May 11, 1998 elections. Private
respondent Antonio M. Abaya filed a Petition to Deny Due Course to and/or Cancel Certificate
of Candidacy. The Petition was GRANTED by the Comelec and they further ruled to
DISQUALIFY Jose “Pempe” Miranda. On May 6, 1998, way beyond the deadline for filing a
certificate of candidacy, petitioner Joel G. Miranda filed his certificate of candidacy for the
mayoralty post supposedly as a substitute for his father , Jose “Pempe” Miranda.

HOLMES ON PLAIN CONSTRUCTION

CO KIM CHAM VS EUSEBIO VALDEZ TAN KEH
G.R. No. L-5
September 17, 1945

FACTS:

The so-called Republic of the Philippines, which was established during the Japanese military
occupation of the islands, was the regime that brought about the civil case no. 3012, for which
the petitioner filed a motion for mandamus, asking that the respondent judge be ordered to order
the proceedings to continue.
The proclamation issued on October 23, 1944 by General Mac Arthur had the effect of
invalidating and nullifying all judicial proceedings and judgments of the courts of the Philippines
under the Philippine Executive Commission and the Republic established during the Japanese
occupation; (1) the respondent judge refused to take cognizance of and continue the proceedings;
and (2) In the absence of an enabling law granting such authority, the lower courts lack the
authority to take cognizance of and continue judicial proceedings pending in the courts of the
defunct Republic; and 3) the government established in the Philippines during the Japanese
occupation was not a de facto government.

ISSUE
1. Whether or not a de facto government was established under the Japanese occupation.
2. Whether or if the legal proceedings and hearings conducted by the Philippine courts as
specified by the Phil. The Executive Commission and the Republic of the Philippines
were still trustworthy and legitimate even after the Philippines were liberated or
reoccupied by US and Filipino forces.

RULING
A civil government and a de facto government of the second kind—that which is established and
maintained by military forces who invade and occupy an enemy territory in the course of war—
was established under the names Philippine Executive Commission and Republic of the
Philippines during the Japanese occupation.

Being a de facto government, it follows that the judicial acts and proceedings of those
governments' courts of justice, which lack political overtones, were good and valid and, in
accordance with the widely accepted postliminary principle of international law, continued to be
good and valid after the liberation or reoccupation of the Philippines by the American and
Filipino forces.

HOLMES ON LAWYER’S OATH TO CLIENTS

TEODORO REGALA, ET AL. VS. THE HONORABLE SANDIGANBAYAN
G.R. No. 105938
September 20, 1996

FACTS:

In PCGG Case No. 33 (Civil Case No. 0033), titled "Republic of the Philippines versus Eduardo
Cojuangco, et al.," the Presidential Commission on Good Government (PCGG) filed a complaint
with the Sandiganbayan (SB) against Eduardo M. Cojuangco, Jr. and Teodoro Regala and his
partners in the ACCRA law firm for the recovery of alleged ill-gotten wealth, including shares of
stock in the named corporations.

Raul S. Roco, a private respondent, was left out of the lawsuit when PCGG submitted a "Motion
to Admit Third Amended Complaint," in exchange for his promise to disclose the identity of the
principal(s) for whom he served as nominee/stockholder.

Lawyers for ACCRA requested that PCGG treat them similarly to Roco in their response to the
Expanded Amended Complaint. The PCGG has made the identical conditions available to Roco's
lawyers to the ACCRA lawyers, but the ACCRA lawyers have declined to reveal the names of
their clients. Attorneys for ACCRA submitted the petition for certiorari, alleging severe abuse of
discretion on the part of the Honorable Sandiganbayan.

ISSUE
Whether or not the attorney-client privilege prevents the lawyers for the petitioners ACCRA
from disclosing the names of their clients and the other information the PCGG has asked for.

RULING
Roco and ACCRA lawyers are in comparable situations and should be treated equally as a result.

In order to avoid violating the equal protection clause of the Constitution, PCGG must
demonstrate that ROCO and ACCRA LAWYERS were not treated differently in the case at hand
despite being "similarly situated" in that both of their actions were taken in support of "legal
lawyering."

The PCGG must indubitably demonstrate that Mr. Roco was treated as a species distinct from the
other ACCRA attorneys on the basis of a classification that made meaningful distinctions based
on genuine differences in order to justify the withdrawal of ROCO from the case or the filing of
the lawsuit in the Sandiganbayan without him. There are no such significant differences in the
case's records, which is against the equal protection provision.

We determine that the petitioners' exclusion from being parties-defendants in PCGG Case No. 33
was contingent upon meeting the condition precedent demanded by the respondent PCGG, which
violates the attorney-client privilege. The condition also entails a violation of the Constitution's
equal protection guarantee by respondents Sandiganbayan and PCGG.

Exempting one litigant in a similar situation from prosecution while denying the others the same
relief is blatantly unfair. Furthermore, the PCGG's request touches on both the issue of their
clients' identities as well as documents relating to the alleged transactions, which violates both
the attorney-client privilege and the right against self-incrimination guaranteed by the
Constitution. Any way you look at it, this is a free ride at the expense of those rights and a
fishing expedition.

HOLMES ON PUBLIC OVER PRIVATE INTEREST

PRIMICIAS VS. FUGOSO
G.R. No. L-1800
January 27, 1948

FACTS:
The petitioner filed a lawsuit after the respondent refused to grant them permission to attend a
public gathering in Plaza Miranda to air their issues with the government. The respondent claims
in his defense that he has a "reasonable basis to believe, based on previous utterances and upon
the fact that passions, particularly on the part of the losing groups, remain bitter and high, that
similar speeches will be delivered tending to undermine the faith and confidence of the people in
their government, and in the duly constituted authorities, which might threaten breaches of the
peace and a dispersal of the population."

Putting focus on the local government's entrusted police authority. Included herein is Sec. 1119,
Free Use of Public Place, which states that "any act, in any public place, meeting, or procession,
tending to disturb the peace or excite a riot; or collect with other persons in a body or crowd for
any unlawful purpose; or disturb or disquiet any congregation engaged in any lawful assembly"
is prohibited as an offense against public peace and is punishable as a misdemeanor.

ISSUES:

Whether or not the freedom of speech was violated.

RULING:
Yes. Regarding the ordinance, specifically Section 1119, it states that: (1) The Mayor of the City
of Manila is granted unrestricted discretion to grant or refuse a permit for the holding of a lawful
assembly or meeting, parade, or procession in the streets and other public places of the City of
Manila; and (2) The Mayor of the City of Manila is vested with unrestricted discretion to refuse
to grant a permit for the holding of a procession or parade. (2) With the aim of preventing
confusion by overlap, ensuring others may use the streets and public spaces conveniently, and
ensuring appropriate and proper policing to reduce the risk of disruption, the Mayor has the
power to select or specify the streets or public places to be used. The second build was favored
by the court. First building is equivalent to giving the Mayor permission to forbid using the
streets. No officer of the government may legitimately be granted such unrestricted power under
our democratic system of governance, with the possible exception of times of national
emergency.
HOLMES ON VAGUENESS OF LAW
ESTRADA VS. SANDIGANBAYAN
G.R. No. 148560
November 19, 2001

FACTS:
Part 2 of R.A. No. 7080, as amended by R.A. 7659, An Act Defining and Punishing the Crime of
Plunder. According to No. 7659, any public official who amasses, collects, or acquires illicit
money by a combination or sequence of overt or criminal conduct totaling at least fifty million
pesos (P50,000,000.00) is guilty of plunder. As a result of his prosecution under the
aforementioned Act, petitioner Joseph Ejercito Estrada challenged the constitutionality of the
law, claiming, among other things, that the elimination of the mens rea requirement for crimes
already punishable by the Revised Penal Code violates the accused's fundamental rights to due
process and the right to know the specifics of the charges against him.
ISSUES:

Whether or not the crime of plunder as defined in R.A. No. 7080 is a malum prohibitum.

RULING:

No. The Supreme Court ruled that theft constituted a crime in and of itself, requiring evidence of
criminal intent. R.A.'s legislative declaration further mentions that the U.S. Plunder is implied to
be a mala in se by No. 7659, which classifies it as a terrible offense. When plunder is involved,
the predicate crimes are activities that are morally or legally wrong from the start and are done so
"willfully, unlawfully, and criminally" by the offender with knowledge of his guilt. Therefore,
theft is a crime in and of itself.

However, the petitioner laments that the legislation does not define the terms "combination" and
"series" in the crucial phrase "a combination or series of overt or criminal activities" by statute.
The petitioner claims that these omissions make the Plunder Law unconstitutional because they
are too vague and overbroad and deprive him of his right to know the specifics of the charges
against him, infringing on his fundamental right to due process.

Simply because general terms are employed here or because terms are used without definition
does not make a statute ambiguous or null.
DWORKIN ON LEGAL PRINCIPLES
PADUA VS. ROBLES
G.R. No. 148560
November 19, 2001

FACTS:

Normandy Padua, 10, was struck by a taxicab early on New Year's Day in 1969 while it was
being driven by Romeo N. Punzalan and was run by the Bay Taxi Cab owned by Gregorio N.
Robles. The taxicab had a 1968 license plate number TX-9395. Normandy was hit by the crash
and was propelled roughly 40 meters away from the spot where the taxicab struck him, killing
him.

The parents of Normandy filed a claim for damages against Punzalan and the Bay Taxi Cab
(civil case 427-O). The city fiscal reported a homicide by reckless imprudence before the same
court (criminal case 1158-O). Punzalan was ordered by the TC in the civil case to pay the
plaintiffs' actual, moral, and exemplary damages as well as legal costs.

Punzalan was found guilty of the crime of homicide by reckless imprudence by the trial court in
the criminal case. The Paduas asked for the decision to be executed, and the court denied their
request, saying that "the civil liability of the accused has already been determined and assessed
in the civil case." This was fruitless. In order to enforce Robles' subsidiary obligation under
Article 103 of the RPC, they filed a lawsuit against him. Robles submitted a dismissal motion.
The court granted the request.

ISSUES:

Whether or if Punzalan's civil accountability resulting from his criminal act, upon which Robles'
subsidiary civil responsibility may be predicated, is determined and adjudicated in the criminal
case decision.

RULING:

YES. According to the ruling in the criminal case, Robles is still liable for the concomitant
subsidiary responsibility stated in Paduas' complaint in the civil case. According to the
aforementioned verdict, Punzalan has no civil liability for the alleged offense. The court, on the
other hand, recognized the enforceable right of the Paduas to the civil liability stemming from
the offense committed by Punzalan and granted the equivalent indemnity after carefully
examining the case, the scenario to which it applies, and the surrounding circumstances.
JOHN FINNIS AND CONTEMPORARY NATURAL LAW PHILOSOPHY
REPUBLIC VS. SANDIGANBAYAN
G.R. No. 104768
July 21, 2003

FACTS:
With the assistance of the AFP Anti-Graft Board, the Presidential Commission on Good
Government (PCGG) looked into reports of Major General Josephus Q. Ramas' alleged
unexplained wealth. Ramas had ill-gotten money, according to the Board, and the PCGG
petitioned for forfeiture under Republic Act No. 1379. Ramas was accused of obtaining income
unlawfully using his position of public trust and his personal friendship with the late President
Marcos, according to the lawsuit. Ramas denied ownership of the other things in question and
asserted that his wealth was commensurate to his income and compensation. In the meantime,
Ramas' former employee Dimaano asserted ownership of the cash, electronics, jewelry, and land
titles that had been removed from her home.
Due to an unauthorized search and seizure, the Sandiganbayan dismissed the case and mandated
that Dimaano receive the returned things. A motion for reconsideration submitted by the PCGG
was turned down. The PCGG contends that private respondents did not have any constitutional
protections at the time of the search since the exclusionary right against illegal search only
became effective after the 1987 Constitution was ratified.

ISSUE:
Whether the revolutionary government was subject to the 1973 Constitution's Bill of Rights
during the interim period, that is, after the revolutionary government actually and effectively
assumed control after loyalist forces' resistance had ceased up until March 24, 1986, just before
the Provisional Constitution was adopted.

Whether or whether people were still protected during the interim under the International
Covenant on Civil and Political Rights and the Universal Declaration of Human Rights.

RULING:
The revolutionary government was not bound by the 1973 Constitution's Bill of Rights during
the interregnum, which is the time following the actual and effective assumption of power by the
revolutionary government after the cessation of resistance by loyalist troops up until 24 March
1986.
There was no municipal legislation superior to the commands and orders of the successful
revolution because the 1973 Constitution had been repealed by that point. The due process and
search and seizure clauses of the Bill of Rights would have been violated by the sequestration
orders, which directed the freezing and taking over of private property by executive issuance
without judicial action, but they were not questioned as violations of the Bill of Rights during the
interregnum because there was no Bill of Rights at the time.
The sequestered companies, however, contested the sequestration orders after the Provisional
Constitution was adopted on the grounds that they were against the Provisional Constitution's
Bill of Rights. The Provisional Constitution acknowledges the President's authority and
responsibility to seize illegally obtained property and defend the interests of the populace
through freezing or sequestration measures.
SOCRATES AND PLATO ON ACADEMIC FREEDOM
ATENEO DE MANILA VS. CAPULONG
G.R. No. 99327
May 27, 1993

FACTS:
First-year law student Leonardo H. Villa of Petitioner University passed away as a result of
severe physical wounds received during the Aquila Legis initiation procedures. After the
incident, Bienvenido Marquez, another student, was also taken to the hospital. In response,
petitioner Dean Cynthia del Castillo established a Joint Administration-Faculty-Student
Investigating Committee, whose job it was to look into the facts surrounding Villa's passing and
deliver a report within 72 hours. The response pupils were also supposed to submit written
statements within 24 hours of receiving the notice, but they didn't.
The respondent students were consequently put on prophylactic suspension. The Investigating
Committee determined that the students had a strong case to prove that they had broken Rule 3
of the Law School Catalogue, which forbade hazing practices. A Disciplinary Board was
established to hear the formal charges against the respondents, and they were compelled to
submit written responses to them. Although the Board members could not agree on the
punishment of dismissal, they judged the students guilty of breaking the discipline rules and left
it up to the University Administration to decide how to punish them. Fr. All respondent students
were sentenced to be dismissed by Bernas, but the students appealed this judgment and requested
a Temporary Restraining Order from RTC Makati.

ISSUES:

Whether or not the respondent pupils were denied a fair trial.

RULING:
The Dean of the Ateneo Law School accused the students in issue of taking part in a hazing
activity and informed them of the accusations. By providing written notice of the charges against
the students, allowing them to respond to the charges with the aid of counsel, informing them of
the evidence against them, granting them the right to present evidence in their own defense, and
taking into account the evidence offered by all parties, the school complied with the minimum
requirements of due process. The students had plenty of time to submit their case and received
legal assistance from the outset of the investigation. The disciplinary proceedings need not have
the same characteristics as a legal action, and the students were nevertheless granted a hearing
where they could respond to clarifying questions even if they were not given the chance to
examine the written statements that served as the basis of the judgment. The choice was made
after taking into account witness testimony and written remarks.

ANCIENT PHILISOPHERS ON THE LAW OF NATIONS

YAMASHITA VS. STYER
G.R. No. L-129
December 19, 1945

FACTS:

Initially held as an American prisoner of war, Lieutenant General Styer of the United States
Army Forces Western Pacific's American Military Commission later stripped Tomoyuki
Yamashita of his status and had him detained as a war criminal. Yamashita served as the
commanding general of the Japanese Imperial Army's 14th army group in the Philippines.
Yamashita asks to be returned to his previous status as a prisoner of war and to have the Military
Commission barred from trying him further in his habeas corpus and prohibition filing.
Additionally, he challenges the Military Commission's authority.

ISSUES:
Should the habeas corpus and prohibition petitions be allowed in this instance?

RULING:
When the objective is to simply reinstate the petitioner's prior status as a prisoner of war and
have them detained rather than confined, a petition for habeas corpus is not proper. The
discrepancy in the level of imprisonment is a military issue, hence the civil courts have no
authority over it. Lieutenant General Wilhelm D. Styer was not designated a party respondent,
and the Military Commission, which might be acting without authority, is not a respondent in the
matter, therefore the petition for prohibition against him cannot be successful.
Even if the commission were added as a respondent, the court would not have the authority to
hear the case. Raquiza v. Bradford precedents hold that any attempt by civil courts to exercise
jurisdiction over the United States Army prior to the end of a state of war would be viewed as a
betrayal of the nation's faith, which the court should not assist in betraying.

ARISTOTLE ON THE SEPARTION OF GOVERNMENT POWERS

CARAOS VS. DAZA
G.R. No. L-129
December 19, 1945

FACTS:
In a court case in Batangas, Jose Caraos and his two brothers, Ramon and Emilio, were accused
with the crime of homicide. In May 1944, Jose was found guilty and given a sentence of six to
twelve years in prison. He started spending his time in the provincial jail. However, a pardon
granted during the Japanese military occupation resulted in his release from prison on November
9, 1944. Following liberation, the deceased's wife filed a complaint, and the provincial fiscal of
Batangas launched an investigation. Jose's arrest warrant was requested in an ex parte motion
that was submitted in March 1946 and approved by the court. Jose submitted a request for
reconsideration, but it was denied.

The directors of prisons and the provincial fiscal of Batangas are among the respondents who
submitted responses to the petition. The Solicitor General contended that Jose was serving his
sentence and that the Solicitor General had no authority over it, while the Provincial Fiscal
agreed the petition's claims—with the exception of the claim of the pardon.

ISSUE:
Whether Jose Caraos' release from the Batangas provincial prison was legitimately accomplished
through a pardon given by appropriate authorities.
RULING:
Because the petitioner in this case did not turn himself in to the relevant authorities after being
freed, his situation is comparable to that of a prisoner who has escaped from a penal institution.
In these circumstances, it was not only the right but also the imperative duty of the courts, acting
concurrently with the Chief Executive (Rev. Adm. Code, section 64 I to order his arrest in order
that he might serve the remaining time on his sentence. The agents of the authorities also
required the corresponding warrant of arrest for their own safety.

Given the foregoing, it is clear that petitioner Jose Caraos has completely failed to prove that he
was pardoned by the appropriate authorities and released from the provincial jail of Batangas, in
accordance therewith, on or about November 9, 1944. As a result, he must remain incarcerated to
serve the remaining portion of the sentence imposed upon him, and his petition for certiorari and
habeas corpus is denied.

ARISTOTLE ON CITIZENSHIP
TECSON VS COMELEC, POE ET AL
G.R. No. 161434
March 3, 2004

FACTS:
Respondent Ronald Allan Kelly Poe, popularly known as Fernando Poe Jr. (FPJ), submitted his
declaration of candidacy for the presidency of the Philippines in the upcoming general elections
in December 2003. He identified himself as a natural-born Filipino citizen on his certificate,
giving his name as "Fernando Jr." or "Ronald Allan" Poe, his birthdate as August 20, 1939, and
his place of birth as Manila.
But petitioner Fornier asserted that FPJ was not a natural-born Filipino citizen because his
parents were foreigners in a petition to the Commission on Elections (COMELEC) to disqualify
FPJ and revoke his certificate of candidacy. His father, Allan Poe, was a Spanish national
because he was the son of Lorenzo Pou, a Spanish subject, while his mother, Bessie Kelley Poe,
was an American. The petition was rejected by the COMELEC due to its lack of merit.

ISSUE:

Whether or not FPJ is a natural-born citizen of the Philippines.

RULING:
A person in the Philippines can only be elected as president if they were born there, are a natural-
born citizen, are registered to vote, can read and write, are at least 40 years old on election day,
and have lived in the country for at least ten years before the election. Citizens who are natural
born are persons who have been granted citizenship from birth, without having to take any
further steps to obtain or improve their citizenship.
The evidence in the case of private respondent Fernando Poe Jr., who was running for president
and was being asked about his citizenship, was taken into consideration by the Supreme Court.
The court discovered that Lorenzo Poe, Fernando's grandfather, was listed as having died in San
Carlos, Pangasinan, in 1954, and that San Carlos, Pangasinan was also listed as his place of
abode. This led to speculation that Lorenzo Poe had lived in San Carlos before his death and
would have benefited from the "en masse Filipinization" in 1902. Due to the fact that Fernando
was born in 1939 and the 1935 Constitution recognized children of Filipino fathers as citizens,
Allan Poe, Fernando's father, was a Filipino citizen.

BLACKSTONE ON THE PLEA OF INSANITY

THE UNITED STATES VS. GUENDIA
G.R. No. L-12462
December 20, 1917

FACTS:

The case of a defendant charged with frustrated murder was brought to the court of first instance
in the Province of Iloilo. The defendant was found guilty, but the court of appeal found that he
was insane at the time of the crime and exempt from criminal liability. The court also noted that
the trial judge recognized the defendant's insanity but still passed sentence. The court reversed
the judgment of the lower court and acquitted the defendant.

The court discussed the well-established rule that no person with imbecility or insanity should be
put on trial or suffer the judgment of the law. However, the trial court has discretion to determine
whether a preliminary investigation into the prisoner's sanity should be made. In this case, the
court had the discretion to proceed with the trial and reverse the judgment, acquitting the
defendant.

ISSUE:

Whether or not the petitioner’s claim of imbecilty can be taken cognizance by the court and
acquit him.

RESOLUTION:
The conclusion reached is that it is within the discretion of a judge to investigate the present
condition of insanity or imbecility of an accused person, if it is discovered or reported to the
judge. If the investigation shows that the accused is unable to defend themselves properly with
the aid of their counsel, it is the duty of the court to suspend the proceedings and commit the
accused to a proper place of detention until their faculties have recovered. If the investigation is
deemed unnecessary and the trial proceeds, the court will acquit the accused if they are found
exempt from criminal responsibility due to their condition. In such a case, an order for
commitment to an asylum should be made.

When deciding on the propriety of suspending the proceedings against an accused person due to
present insanity, the judges should keep in mind that not every mental aberration or deficiency is
sufficient to justify such suspension. The test is to determine if the accused would have a fair
trial with the assistance provided by the law. The system of procedure in place, with legal
counsel for every accused person, ensures a fair trial. The judgment has been reversed and the
defendant has been acquitted, with costs. However, the defendant will remain in confinement in
the San Lazaro Hospital or other designated insane asylum, and cannot leave without the prior
approval of the Court of First Instance of the Province of Iloilo.

BLACKSTONE ON ARREST WITHOUT WARRANT

THE UNITED STATES VS. SANTOS
G.R. No. L-12779
September 10, 1917

FACTS:

Dionisio Santos is a policeman of Pateros in the Province of Rizal. Santos was patrolling a
district to stop pilfering and at midnight, saw two persons entering an uninhabited camarin and
arrested them without warrant.

The two persons were taken to the municipal presidencia and detained in jail for six or seven
hours before they were released.

ISSUE:

Whether or not Santos is guilty of coercion?

RESOLUTION:

The powers of peace officers in the Philippines are similar to those of constables under Anglo-
American Common Law. Peace officers can make arrests without warrant if there is reasonable
ground of suspicion supported by circumstances that show the person has committed or is about
to commit a crime or breach of peace.An officer must act in good faith and even if the suspect is
later found to be innocent, the officer is not liable if they acted with reasonable suspicion and
good faith.

A policeman is not expected to exercise the subtle reasoning of a judicial officer and may make
mistakes in haste while trying to prevent the escape of the criminal. If a peace officer makes a
mistake in good faith, they should be exculpated. The Common Law rule allows peace officers to
arrest and detain night-walkers if there is reasonable ground to suspect a felony has been
committed. The Spanish law is not essentially different from the American and English Common
Law in regards to the powers of peace officers. Santos is acquitted of the charges against him and
the judgment is reversed, with the costs de officio.

BLACKSTONE AND BETHAM ON THE POLICE POWER

PEOPLE VS. JULIO POMAR
G.R. No. L-22008
November 3, 1924

FACTS:

On October 26, 1923, Pomar was charged at the CFI Manila for violating Section 13 in
connection with Section 15 of Act No. 3071. On August 27, 1923, Pomar, who was the manager
and in charge of La Flor de la Isabela (a tobacco factory), deliberately failed to pay Macaria
Fajardo P80 for her regular wages for the 30 days before and after her delivery and confinement
which occurred on August 12, 1923. During the trial, Pomar admitted to the allegations in the
complaint, but argued that the provisions of Act No. 3071 were illegal, unconstitutional and void.

ISSUES:

Whether or not the provisions of sections 13 and 15 of Act No. 3071 are a reasonable and lawful
exercise of the police power of the state.

RESOLUTION:

The Section 13 of Act No. 3071 was enacted in the exercise of the police power with the aim of
safeguarding the health of pregnant women laborers. However, the law created a term in every
employment contract with such women, without their consent and thereby deprived them of their
constitutional right to contract. The liberty of individuals to enter into contracts is protected by
the "due process of law" clause in the constitution and it includes the right to terminate contracts
as well.
The Civil Code also establishes that contracting parties can establish any terms and conditions
they wish, as long as they are not contrary to law, morals, or public policy. The Supreme Court
of the United States has also established that the right to contract is part of the individual's liberty
and protected by the due process of law clause. In light of these considerations, the lower court's
sentence was revoked and the defendant was discharged from custody, with costs.

BLACKSTONE ON LIBERTY OF THE PRESS

RE: IN THE MATTER OF THE ALLEGATIONS CONTAINED IN THE COLUMNS OF
MR. AMADO A.P. MACASAET PUBLISHED IN MALAYA DATED SEPTEMBER 18,
19, 20, AND 21, 2007
A.M. No. 07-09-13-SC
August 8, 2008

FACTS:

A daily column called "Business Circuit" in a newspaper called Malaya ran a story based on
confidential sources about an alleged bribery incident in the Philippine Court. The story claimed
that a staff member of a judge received 5 boxes of cash worth 10 million pesos, which the judge
discovered and led to the termination of the staff member's employment. The story also named
the judge involved in the incident as Justice Consuelo Ynares-Santiago. Online magazine
Newsbreak also posted a similar story on its website. Justice Santiago issued a statement denying
the accusations and asked the Court to investigate the matter.

The Court then ordered the column writer, Macasaet, to explain why he shouldn't be held in
indirect contempt of court and created a committee to investigate the matter. During the hearings,
Macasaet, the Newsbreak writer, and a staff member all testified, with the staff member denying
receiving any cash. It was determined that the case referred to was a petition seeking the
nullification of a ruling against a businessman for violation of anti-graft laws, which was
reversed by a special Third Division of the Court with a divided vote.

ISSUE:

Whether or not Macasaet is guilty of indirect contempt.

RESOLUTION:

The Supreme Court Justices and the Supreme Court as an institution are not immune from
criticism and are entitled to the same level of criticism as other public officials and institutions.
The contempt power should protect immediate litigants and the public from a mischievous
tribunal and not protect the court or its judges from criticism in a democratic society. The
Supreme Court must balance its need to defend itself with the freedom of the press, which is
essential in a democratic society. Courts must only act in the face of an extremely serious threat
that impedes, obstructs or degrades the administration of justice. Corruption in government is a
matter of highest concern and the free press serves as a deterrent against government misdeeds.
The freedom of speech, expression, and press should not be abridged, even if some newsmen
abuse it, and the press is not meant to be the cheerleader of government but rather the agent of
the people gathering news for informed public opinion. Macasaet is not guilty of contempt.

BLACKSTONE ON DOUBLE JEOPARDY

PEOPLE VS. VELASCO ET AL.
G.R. No. 127444
September 13, 2000

FACTS:

The case challenges the doctrine of double jeopardy and the constitutional safeguard against
exposing the accused to the risk of answering twice for the same offense. The accused was
acquitted of murder and frustrated murder, but the state wants the acquittal reversed. The case is
based on the shooting in San Ildefonso, Bulacan, that claimed the life of Alex Vinculado and
seriously injured his twin brother and uncle. Three criminal informations were filed against the
accused, Honorato Galvez, the mayor of San Ildefonso, and Godofredo Diego, a municipal
employee. The charges were later upgraded to murder and frustrated murder. Galvez was also
charged with unauthorized carrying of a firearm.

The trial court found Diego guilty of murder and double frustrated murder, but acquitted Galvez
due to insufficient evidence. The government is challenging the acquittal of Galvez and is
proposing a re-examination of the evidence by the court to rectify the gross judicial indiscretion
and arbitrariness, without violating the constitutional guarantee against double jeopardy.

ISSUE:

Whether or not a review of the case will not transgress the constitutional guarantee against
double jeopardy?

RESOLUTION:

The court has dismissed the petition for certiorari which sought to nullify the decision of the
respondent judge acquitting the accused Honorato Galvez. The petition was dismissed as the
court found that the judge had considered the evidence presented by both parties during the trial,
which showed that the evidence was passed upon, even if there may have been lapses in the
evidence evaluation. The court held that the decision of the judge was not reviewable by
certiorari as it is an error of judgment, not an error in the exercise of jurisdiction.
Philippine jurisprudence has been consistent in its application of the Double Jeopardy Clause
such that it has viewed with suspicion, and not without good reason, applications for the
extraordinary writ questioning decisions acquitting an accused on ground of grave abuse of
discretion.

BLACKSTONE ON STATE ALLEGIANCE

LAUREL VS. MISA
G.R. No. L-409
January 30, 1947

FACTS:

Anastacio Laurel vs. Eriberto Misa, the Court considered a petition for habeas corpus filed by
Anastacio Laurel, who was being prosecuted for the crime of treason during the Japanese
occupation. The Court held that the absolute and permanent allegiance of a citizen to their
government cannot be suspended, even during an enemy occupation. The sovereignty of the
legitimate government cannot be suspended as it cannot be put out of existence or divested. The
exercise of the rights of sovereignty may be suspended, but not the sovereignty itself. The Court
concluded that the allegiance of citizens to their legitimate government subsists during enemy
occupation and that there is no such thing as suspended allegiance. The Court also stated that the
theory that sovereignty is suspended during enemy occupation is obsolete after the adoption of
the Hague Regulations in 1907 and cannot be applied to the present case.

ISSUE:

Whether or not Anastasio Laurel can be prosecuted for the crime of treason.

RESOLUTION:

The Philippine Commonwealth was a sovereign government subject to certain limitations under
the Independence Act and incorporated as an ordinance in the Philippine Constitution. This
sovereignty was recognized by the US legislative and executive departments, including President
Roosevelt who stated the Philippines had the status of a respected independent nation. The
Supreme Court of the United States has ruled that questions of sovereignty are political questions
determined by the legislative and executive departments.

The limitation of Philippine citizens owing allegiance to the US was one of the few limitations
on Philippine sovereignty retained by the US. The change from a Commonwealth to a Republic
did not affect the prosecution of treason committed during the Commonwealth as it is an offense
against the same government and sovereign people. The court denies the petitioner's petition and
may write a more extensive opinion in the future, with some justices dissenting or concurring
separately.

BLACKSTONE ON HUMAN AND DIVINE LAW

LAUREL VS. MISA
G.R. No. L-200
March 28, 1946

FACTS:

Anastacio Laurel is a political prisoner who has been detained in Bilibid Prison and is
demanding his release. He argues that Commonwealth Act No. 682, which established the
People's Court and the provision under which he is being held, is unconstitutional and void. The
Solicitor General, however, supports the validity of the law.

Laurel claims that his arrest and detention by the US military are now beyond question and that
his current incarceration has lasted more than six months. He also argues that the provision
violates the Constitution as it is discriminatory, involves an unlawful delegation of legislative
powers, and is retroactively applied.

ISSUE:

Whether or not Laurel be granted with the petition for Habeas Corpus.

RESOLUTION:

The order was issued by the President due to the urgent and momentous situation of having
6,000 detained individuals who were suspected of aiding the Japanese and needed to be held in
restraint until their cases could be investigated and prosecuted. The order suspended Article 125
for not more than thirty days, but was later extended to six months by Congress through the
approval of Commonwealth Act No. 682. The court found that the extension was reasonable
considering the circumstances and was within the power of the Legislature to decide. The court
also rejected arguments that the section constituted an invalid delegation of legislative powers
and that it was retroactive in its operation.
The petitioner, Anastacio Laurel, was arrested in May 1945 and has been detained since then,
claiming that the law that governs his detention, Commonwealth Act No. 682, is
unconstitutional. He argues that the law is discriminatory, an unlawful delegation of legislative
powers, and retroactive in operation. However, the court dismissed these arguments and stated
that the law is valid and not in conflict with the Constitution. The court also stated that the other
challenges to the People's Court Act do not require specific explanation at this time. The petition
for the writ of habeas corpus was denied with costs.

GROTIUS ON ACTUAL DAMAGES

MANZANARES VS. MORETA
G.R. No. L-12306
October 22, 1918

FACTS:

A young boy, aged 8 or 9, died as a result of the defendant's negligent driving in his Moreta
automobile. The deceased's mother, who is a widowed and poor washerwoman, filed a lawsuit
against the defendant to claim damages for her loss, with an amount of P5,000 requested. Despite
the lack of evidence to support the amount claimed, the trial court found the defendant guilty and
ordered him to pay P1,000 to the plaintiff. The decision made by Justice Torres in this case
upholds the judgment of the Court of First Instance.

ISSUE:

Whether or not Moreta is liable for damages.

RESOLUTION:

The court ruled that Moreta must pay damages of P1,000, according to the decision of the trial
court. It was noted that if Moreta had been coming from the south on Solana Street and had to
stop before crossing Real Street due to other vehicles, he should have reduced his speed until he
had safely crossed Real Street and reached a clear path on Solana Street. However, the child was
struck by Moreta's car at the entrance of Solana Street, indicating that the car was not moving at
a slow speed.

The defendant could have seen the child crossing the street from the sidewalk and should have
taken precautions, such as slowing down and honking the horn, which could have prevented the
boy's death.
THE JUSTINIAN CODE ON MUTUAL BAD FAITH MARCIAL
KASILAG VS. RODRIGUEZ ET. AL
G.R. No. 46623
December 7, 1939

FACTS:

Marcial Kasilag and Emiliana Ambrosio entered into a mortgage agreement for the
improvements made on a homestead land, as collateral for a debt of P1,000 with interest. The
agreement stipulated that Emiliana would pay off the debt with interest within 4 and a half years,
and if she did, the mortgage would have no effect. If the debt was not paid, Emiliana was to
execute a deed of sale and pay the land tax. However, after a year, Emiliana was unable to pay
the tax. As a result, they made a verbal agreement where she gave the possession of the land to
Marcial, on the condition that they would not collect the interest on the loan, pay the land tax,
enjoy the fruits of the land, and make improvements to the property.

These separate agreements had the intent of altering the original mortgage contract and turning it
into a contract of antichresis. However, this type of real encumbrance on the land is illegal and
void, as it goes against the laws and regulations.

ISSUE:

Whether or not the petitioner should be deemed the possessor of the land in good faith because
he was unaware of any flaw in his title or in the manner of its acquisition by which it is
invalidated.

RESOLUTION:

The Court of Appeals found that the petitioner did not know of any flaws in his title or how it
was acquired, aside from the legal prohibition. Good faith can be based on ignorance of the law,
but only if the ignorance is excusable, not gross and inexcusable.

Since the petitioner is not a lawyer and acted based on his belief that he was not violating any
law, his ignorance of the prohibition in section 116 can be considered excusable and a basis for
his good faith.
THE ROMAN LAW ON THEFT
JAIN VS. IAC
G.R. No. L-63129
September 28, 1984

FACTS:

Wayne Jain and Andres Resfuentes were accused of conspiring and taking 19 canecars loaded
with sugarcane valued at 8,351.55 pesos, which belonged to Tomasa Bermejo without her
consent. Andres was convicted as an accessory in the crime of simple theft, but Jain questioned
his conviction of theft and argued that if he committed a crime, it was estafa and not theft, as he
did not physically take or steal the sugarcane.

Jain further claimed that he did not actually take the sugarcane but in conspiracy with Bermejo's
sugarcane guard, withdrew the trainman's receipt from the box and replaced it with another one
in his name, making it appear that the sugarcane belonged to him. This created a confusion
regarding the ownership of the sugarcane and led to the charges against Jain.

ISSUE:

Whether or not Wayne Jain should be accused of theft and Supreme Court erred in accusing Jain
of theft.

RESOLUTION:

Wayne Jain and Andres Resfuentes were accused of stealing 19 cane cars loaded with sugarcane
valued at 8351.55 Philippine currency. The cane cars were owned by Tomasa Bermejo and were
taken without her consent. Andres was convicted as an accessory to the crime of simple theft and
did not appeal, while Jain questioned whether he could be convicted of theft. Jain insisted that he
did not commit theft and that, if anything, the crime he committed was estafa. He argued that he
did not physically take, steal, or carry away the cane cars. Instead, he substituted the train
receipts to claim the proceeds of the cane cars, not the cane cars themselves.

Jain's argument is based on the definition of theft, which requires the taking of a thing into the
physical power of the thief. In Jain's case, he never laid his hands on the sugarcane and therefore,
did not commit theft. The evidence suggests that for theft to occur, there must be a physical
handling of personal property, which was not present in Jain's case. Jain is correct in stating that
he did not commit theft, but he may have committed estafa.

ON THE RIGHT TO LIFE

ECHEGARAY VS.SECRETARY OF JUSTICE
G.R. No. 132601
January 19, 1999

FACTS:

In October 1998, the Supreme Court of the Philippines affirmed the conviction of Leo Echegaray
for the crime of raping a minor, who was the daughter of his common-law wife, and imposed the
death penalty. However, before the execution could take place, Congress passed R. A. 8177,
changing the mode of execution from electrocution to lethal injection. In response to this, Leo
Echegaray filed a petition for Prohibition, Injunction, and a Temporary Restraining Order,
claiming that lethal injection was unconstitutional and violated his rights. The court granted the
Temporary Restraining Order and directed the respondents to give their comments.

In response to the Temporary Restraining Order, the respondents filed an Urgent Motion for
Reconsideration and a Supplemental Motion to Urgent Motion for Reconsideration. They argued
that the court had lost jurisdiction over the case since the decision had become final and
executory, and that the Temporary Restraining Order encroached on the exclusive authority of
the Executive Authority. The court was tasked with resolving these issues raised by the
respondents in their motion for reconsideration.

ISSUE:

Whether or not the Court has lost Jurisdiction over the case upon the Decision becoming final
and executory.

RESOLUTION:

The case at bar deals with the execution of a death sentence, and it is accepted that the execution
can be postponed upon request. The common law provides three ways in which the execution
date can be postponed, including by command of the King, by discretion of the court, or by
mandate of the law. It is therefore possible for a court to reopen the case even after the execution
date has been fixed, if circumstances arise that require investigation and a postponement of the
execution.

The power to control the execution of a decision is an integral part of jurisdiction, and the
Constitution vests all judicial power in the Supreme Court and lower courts established by law.
The process of execution is an important aspect of litigation, where supervening events may
require courts to intervene and adjust the rights of the litigants. As a result, courts have the
inherent and necessary power to control the execution of their decisions to ensure conformity
with the law and justice. The Supreme Court temporarily restrained the execution of its own
decision in this case to allow for a reasonable time to check the fairness of the decision in light of
supervening events in Congress, as alleged by the petitioner.
ON PSYCHOLOGICAL INCAPACITY
SANTOS VS.  CA
G.R. No. 112019
January 4, 1995

FACTS:

Leouel Santos and Julia Rosario Bedia-Santos were married in 1986 and lived with Julia's
parents. However, they went on to have a number of conflicts and Julia left for the United States
to work as a nurse in 1988, breaking her promise to return. Leouel tried to find her while he was
in the United States for training, but was unsuccessful. He filed a complaint to have the marriage
voided due to Julia's psychological incapacity to enter into married life, citing her failure to
return and lack of communication for over 5 years. However, the complaint was dismissed by the
trial court and the decision was affirmed by the Court of Appeals. Leouel's appeal was denied
due to lack of merit and non-compliance with Circular 28-91.

Leouel argued that Julia's actions constituted psychological incapacity to enter into married life.
However, the courts found otherwise and the appeal was unsuccessful. The court emphasized
that the requirements of Circular 28-91, including a certification of non-forum shopping, must be
met in addition to the case having merit in order for an appeal to be successful.

ISSUES:

Whether or not psychological incapacity is attendant to the case at bar.

RESOLUTION:

The court found that Julia's actions of not returning home and not communicating with her
husband did not meet the definition of psychological incapacity under the Family Code.
Psychological incapacity must be a serious mental condition that prevents a party from
understanding and fulfilling their basic marital obligations such as love, respect, and support.
The condition must also exist at the time of the marriage. In this case, the court found that the
evidence presented was not enough to prove that Julia had a psychological incapacity. Therefore,
the petition was dismissed.

Article 36 of the Family Code cannot be taken and construed independently of but must stand in
conjunction with, existing precepts in our law on marriage. Psychological incapacity should refer
to no less than a mental (not physical) incapacity that causes a party to be truly incognitive of the
basic marital covenants that concomitantly must be assumed and discharged by the parties to the
marriage which (Art. 68), include their mutual obligations to live together, observe love, respect
and fidelity and render help and support. The intendment of the law has been to confine the
meaning of psychological incapacity to the most serious cases of personality disorders clearly
demonstrative of an utter insensitivity or inability to give meaning and significance to the
marriage. This psychological condition must exist at the time the marriage is celebrated.
ST. THOMAS AQUINAS ON ROBBERY
PEOPLE VS. DE LA CRUZ
G.R. No. L-52
February 21, 1946

FACTS:

On June 25, 1945, four men armed with revolvers robbed a drug store in Manila.The appellant,
Teodoro de la Cruz, was charged with the crime of robbery in band.Two witnesses for the
prosecution identified the appellant as one of the robbers. Dr. Gregorio B. Sison testified that he
recognized the appellant when he pointed a revolver at his ribs.

Luz Mendoza de Sison testified that she heard one of the robbers being called "Doro" and saw
the appellant's face twice. Detective Alejandro Eugenio testified that the appellant was brought to
the drug store for identification by the witnesses and was recognized by Luz Mendoza de Sison.
The appellant denied participating in the crime and stated that he lives by selling goods and
gambling.

ISSUES:

Whether or not Teodoro was one of the robbers.

RESOLUTION:

The Supreme Court found that the appellant was conclusively identified as one of the robbers
who kept watch of the people inside the drug store and was manipulating a revolver. The fact
that the prosecution witnesses singled him out as the only one among the four robbers they could
identify, with no unreasonable motive to point him out, strengthens the credibility of their
identification.

The Supreme Court affirmed the sentence of the Court of First Instance of Manila, which was an
indeterminate sentence of not less than six months nor more than six years, ten months and one
day of imprisonment, to indemnify the offended party in the amount of P8,000, with subsidiary
imprisonment in case of insolvency, and to pay the costs.

MANSFIELD ON UNCONSCIONABLE SALES

US VS. TAN QUINGCO CHUA
G.R. No. L-13708
January 29, 1919
FACTS:

An appeal was made against a judgment by the Court of First Instance of Nueva Ecija, which
found Francisco Constantino Tan Quingco Chua guilty of usury and sentenced him to pay a fine
of P225 or face subsidiary imprisonment if he was unable to pay and to pay the costs.

The usury charges were based on a document signed by Pedro Andres and Tan Quingco Chua on
October 25, 1916, in which Andres sold a parcel of land and a female carabao to Tan Quingco
Chua for the amount of P684.20, with a five-month redemption period. During this time, Andres
was to hold the land as a lessee and pay a rent of 90 cavanes of palay. Execution of the judgment
resulted in Andres paying Tan Quingco Chua P474 and turning over 98 cavanes of palay. The
transaction led to the provincial fiscal of Nueva Ecija filing an information charging Tan
Quingco Chua with the crime of usury.

ISSUES:

Whether or not the accused if guilty of usury.

RESOLUTION:

The law regarding usury is usually applied prospectively, rather than retrospectively. However,
in certain cases, the courts may examine past events to determine if there was a violation of the
law and to understand the criminal intent. The key component of usurious transactions is a
corrupt intention. To be considered usury, there must be a deliberate agreement to take or
contract for an excessive interest rate.

If neither party has this intention and act in good faith, the law will not consider it usury.
However, if the contract explicitly states a higher than legal interest rate, the intent is clear and
the agreement is considered usury. On the other hand, if the contract only mentions a legal
interest rate, it must be proven that there was some secret agreement or scheme to cover up the
usury and that both parties were aware of it.

PNB VS. THE NATIONAL CITY BANK OF NEW YORK

G.R. No. L-43596
October 31, 1936

FACTS: On April 7th and 9th, 1933, unknown individuals bought tires and paid with checks
purporting to have been issued by Pangasinan Transportation Co., Inc. (Pantranco), signed by J.
L. Klar as Manager and Treasurer, against Philippine National Bank (PNB) and in favor of
International Auto Repair Shop. The Motor Service Company, Inc. (MSCI) endorsed the checks
for deposit at the National City Bank of New York, which resulted in MSCI being credited with
the amounts of P144.50 and P215.75. The checks were cleared on April 8th and 10th, 1933 and
PNB credited the National City Bank. PNB later discovered that the signatures of J. L. Klar were
forged and demanded repayment from MSCI and National City Bank of New York. PNB then
filed a case in the municipal court of Manila against National City Bank and MSCI. Pantranco
also objected to having the proceeds of the checks deducted from their deposit. The Regional
Trial Court ruled in favor of PNB, and MSCI appealed the decision.

ISSUES:
Whether or not the National City Bank failed to exercise due diligence.

RULING:
A check is a type of bill of exchange that is payable on demand and thus, only the rules that
apply to bills of exchange payable on demand apply to checks. The concept of acceptance, which
is necessary in the case of negotiable instruments, is not applicable to checks as it involves
subsequent negotiation of the instrument. When a check is paid, it is withdrawn from circulation
and cannot be negotiated again. In determining the rights of parties involved in a case where a
drawee has mistakenly paid a check with a forged signature, it is important to consider the
diligence and negligence of both parties. The drawee bank, who pays a forged check, is only
fully responsible for the authenticity of the signature if the holder of the check did not contribute
to the fraud or mislead the drawee through their own fault or negligence. The undisputed facts in
this case indicate that National City Bank acted negligently in purchasing the checks from
unknown individuals without verifying their identity or authority to negotiate and endorse the
checks. This contributed to PNB's loss and allowing National City Bank to recover in this case
will not change the injury or prejudice suffered by the appellant (MSCI).

COMPAGNIE FRANCO-INDOCHINOISE VS. DEUTSCH-AUSTRALISCHE

DAMPSCHIFFS GESELLSCHAFT
G.R. No. L-43596 January 17, 1919

FACTS:

The case is about the liability of the defendant company, owner of the steamship Esslingen, for
damages due to the illegal detention of cargo belonging to the plaintiff. The previous decision of
the court was to return the case to the court of origin with instructions to grant a new trial to
determine the amount the cargo would have sold for if it had been offered for sale in an
undamaged condition. The trial was reheard and the court found that the rice meal portion of the
cargo would have sold for 30 centavos more per cavan if undamaged. Judgment was rendered in
favor of the plaintiff for the amount of the loss, P35,949.30, with interest from November 6,
1914. Both parties have appealed the judgment, with the plaintiff insisting that the trial court
awarded too little and the defendant that it awarded too much. The only issue is the point of
damages. The rice meal portion of the cargo is in dispute, as the cargo meal portion was sold for
its full value. The court suggests that the proper date to determine the value of the cargo was
November 6, 1914 and not September 14th, when the defendant wrongfully refused to deliver the
cargo.

ISSUE:
Is the amount collected correct assuming the calculations on the damages were made?

RULING:
The court affirms the judgment, modifying the amount of damages awarded to the plaintiff from
P35,949.30 to P87,777.56 with interest from November 5, 1914. The part of the judgment
awarding the plaintiff P57,823.35, less the commission of the clerk, from the proceeds of the
receiver's sale, is vacated as it has already been satisfied. The law of the Philippine Islands, local
law of the country where it was executed, and the general maritime law all apply to this charter
party. The maritime law is not the law of a particular country, but the general law of nations and
is the same among all nations and at all times. The commercial documents of similar form should
as far as possible be understood the same way everywhere, and the court follows the English
decision.

APIAG VS. CANTERO

G.R. No. L-43352
January 17, 1919

FACTS:
On November 10, 1993, Maria Apiag Cantero, accompanied by her daughter Teresita A. Cantero
Sacurom and son Glicerio A. Cantero, filed a complaint letter against the respondent, Judge
Esmeraldo G. Cantero of the Municipal Circuit Trial Court of Pinamungajan-Aloquinsan, Cebu,
accusing him of gross misconduct, bigamy, and falsification of public documents. After
receiving the respondent's comment, the court referred the case to Executive Judge Gualberto P.
Delgado of the Regional Trial Court of Toledo City, Cebu, for investigation, report, and
recommendation. He submitted his report on July 26, 1996. The case was then referred to the
Office of the Court Administrator for evaluation, report, and recommendation.

ISSUE: Whether or not the respondent is guilty of misconduct.

RULING:
The Court thoroughly reviewed the respondent's record and found no evidence of misconduct in
his judicial duties prior to the filing of the administrative case. Taking into consideration his 32
years of unwavering service in the government, the Court is inclined to extend leniency. The
Court acknowledges that the respondent may have made a mistake in the past, but his sincere
effort to repent, make restitution, and reform his life should not forever overshadow his
accomplishments. However, the Court cannot ignore the fact that the respondent was negligent in
fulfilling his responsibilities towards his children from his first marriage. Despite neglecting and
not supporting them, he did not deny their affiliation with him. The Court would have imposed a
penalty for this conduct, but due to the respondent's death before the decision was made, the case
must be dismissed.

ARIANZA VS. WORK COMPENSATION COMMISSION

G.R. No. L-43352
February 28, 1978

FACTS:
The Workmen’s Compensation Commission dismissed the petitioner's claim for compensation
under the Workmen’s Compensation Act against his employer, Central Azucarera de la Carlota,
Inc. The decision was made in a sitting en banc on December 27, 1975, reversing the earlier
decision of the Workmen’s Compensation Unit of the Department of Labor, Sub-Regional Office
No. VII in Bacolod City. According to the records, the petitioner was employed by the private
respondent company in 1960. Before he started his job, he underwent a medical examination and
was found to be fit to work. He was assigned to pack bagasse, working eight hours per day,
alternating between day and night shifts, at a rate of P8.00 per day for four years. He was then
assigned as a piler of bagasse and, finally, as a water tender in the mill department fire-room for
three years. The petitioner's first and second assignments involved strenuous physical exertion,
while his last assignment required his body to be immersed in hot water up to his waist, with the
upper part exposed to cold. Sometime in 1965, the petitioner noticed a general weakening of his
body. He didn't initially pay much attention to it, but in April 1972, he learned that his illness had
become serious. He stopped working and was hospitalized at the expense of the respondent
company. A physician’s report signed by Dr. Orville Varona advised the petitioner to take
complete rest and diagnosed his illness as liver cirrhosis.

ISSUE: Whether or not the petitioner should be compensated under the Workmen’s
Compensation Act.

RULING:
According to the Workmen's Compensation Act, if an employee dies while on the job, the
employer bears the burden of proof to demonstrate that the death was not work-related. In the
case of Eduardo Labiyo's death, it is acknowledged that he passed away while he was on active
duty as an engineer for the petitioner. The need to prove that the cause of death was connected to
the work becomes less important as it is assumed that the death occurred as a result of the nature
of the employment. The law presumes that if an employee dies during their job, the death is
either caused by or worsened by the work. It is not enough for the employer's physician to
simply state that the death was not connected to the work, as the opinion of the company doctor
is not enough to overcome the legal presumption in favor of the compensability of the death.

TOLENTINO AND MOJICA VS. COMELEC

G.R. No. 148334
January 21, 2004

FACTS:
In 2001, Arturo Tolentino and Arturo Mojica, as voters and taxpayers, filed a petition for
prohibition against the Commission on Elections (Comelec) to enjoin it from proclaiming the
candidate for Senator receiving the 13th highest number of votes as the winner in the special
election for a single 3-year term seat. The petitioners argued that the Comelec failed to properly
distinguish between the special and regular senatorial elections and failed to comply with certain
provisions in the Republic Act 6645 and the Omnibus Election Code. The petitioners sought the
nullification of the Comelec's Resolution No. 01-005, which provisionally claimed 13 candidates
as elected senators. The court required the Comelec to comment on the petition and later required
the petitioners to file an amended petition impleading the 12th and 13th placed senators, Ralph
Recto and Gregorio Honasan. The Comelec, Honasan, and Recto claimed that the special
election was valid, while Honasan raised a preliminary issue on the standing of the petitioners
and Recto claimed that he was not a proper party.

ISSUE: Whether or not a special election to fill a vacant 3-year term Senate seat was validly held
on May 14, 2001.

RULING: No. A quo warranto proceeding is one to determine the right of a public officer in the
exercise of his office and to ouse him from its enjoyment if his claim is not well-founded.
Petitioners are questioning the validity of the special election on May 14, 2001. The petitioner
does not seek to determine Honasan’s right in the exercise of his office as senator. Petitioners’
prayer for annulment of Honasan’s proclamation and election is merely incidental to petitioners’
cause of action. Consequently, the Court can properly exercise jurisdiction over the instant
petition. Under Section 9 Article VI of the Constitution, a special election may be called to fill
any vacancy in the Senate and the House of Reps in the manner prescribed by law. To implement
this provision, Congressed passed RA 6445. Section 4 of RA 7166 subsequently amended
Section 2 of RA 6645. Thus, in case of a vacancy in Congress at least 1 year before the
expiration of the term, Section 2 of RA 6645 requires Comelec.

PROVINCE OF NORTH COTABATO VS. GRP PEACE PANEL ON ANCESTRAL

DOMAIN
G.R. No. 183591
October 14, 2008

FACTS:

The Memorandum of Agreement on the Ancestral Domain (MOA-AD) is an agreement between

the Government of the Republic of the Philippines (GRP) and the Moro Islamic Liberation Front
(MILF) to be signed. The agreement references the Tripoli Agreement, the organic act of the
Autonomous Region in Muslim Mindanao (ARMM), the Indigenous People's Rights Act,
international laws such as the ILO Convention 169 and the UN Charter, and the principle of
Islam. The MOA-AD defines the Bangsamoro people as the indigenous peoples of Mindanao
and its adjacent islands with the right to self-governance and exclusive ownership of their
ancestral domain and ancestral lands. The Bangsamoro Juridical Entity (BJE) is established with
authority and jurisdiction over the ancestral domain and ancestral lands. The BJE territory
encompasses the Mindanao-Sulu-Palawan region and parts of the ARMM, with some territories
subject to plebiscite. The BJE has the right to enter into economic cooperation and trade relations
with foreign countries, participate in international events and official missions, and explore its
resources with a sharing arrangement of 75:25 in favor of the BJE. The relationship between the
GRP and MILF is associative, characterized by shared authority and responsibility, with details
to be discussed in the Comprehensive Compact. The BJE will have the right to build and
maintain its own institutions.

ISSUE: Whether or not the contents of the MOA-AD violated the Constitution and the laws.

RULING:
The SC declared the MOA-AD contrary to law and the Constitution. The power of judicial
review is limited to actual cases or controversy, that is the court will decline on issues that are
hypothetical, feigned problems or mere academic questions. Related to the requirement of an
actual case or controversy is the requirement of ripeness. The contention of the SolGen is that
there is no issue ripe for adjudication since the MOA-AD is only a proposal and does not
automatically create legally demandable rights and obligations. Such was denied. The SC
emphasized that the petitions are alleging acts made in violation of their duty or in grave abuse
of discretion. Well-settled jurisprudence states that acts made by authority which exceed their
authority, by violating their duties under E.O. No. 3 and the provisions of the Constitution and
statutes, the petitions make a prima facie case for Certiorari, Prohibition, and Mandamus, and an
actual case or controversy ripe for adjudication exists. When an act of a branch of government is
seriously alleged to have infringed the Constitution, it becomes not only the right but in fact the
duty of the judiciary to settle the dispute. This is aside from the fact that concrete acts made
under the MOA-AD are not necessary to render the present controversy ripe and that the law or
act in question as not yet effective does not negate ripeness.

AIR TRANSPORTATION OFFICE VS. SPOUSES DAVID AND ELISEA RAMOS

G.R. No. 159402
February 23, 2011

FACTS:
Spouses David and Elisea Ramos (respondents) discovered that a portion of their land registered
under Transfer Certificate of Title No. T-58894 of the Baguio City land records with an area of
985 square meters, more or less, was being used as part of the runway and running shoulder of
the Loakan Airport being operated by petitioner Air Transportation Office (ATO). On August
11, 1995, the respondents agreed after negotiations to convey the affected portion by deed of sale
to the ATO in consideration of the amount of ₱778,150.00. However, the ATO failed to pay
despite repeated verbal and written demands. Thus, on April 29, 1998, the respondents filed an
action for collection against the ATO and some of its officials in the RTC (docketed as Civil
Case No. 4017-R and entitled Spouses David and Elisea Ramos v. Air Transportation Office,
Capt. Panfilo Villaruel, Gen. Carlos Tanega, and Mr. Cesar de Jesus). In their answer, the ATO
and its co-defendants invoked as an affirmative defense the issuance of Proclamation No. 1358,
whereby President Marcos had reserved certain parcels of land that included the respondents’
affected portion for use of the Loakan Airport. They asserted that the RTC had no jurisdiction to
entertain the action without the State’s consent considering that the deed of sale had been entered
into in the performance of governmental functions. On November 10, 1998, the RTC denied the
ATO’s motion for a preliminary hearing of the affirmative defense. After the RTC likewise
denied the ATO’s motion for reconsideration on December 10, 1998, the ATO commenced a
special civil action for certiorari in the CA to assail the RTC’s orders. The CA dismissed the
petition for certiorari, however, upon its finding that the assailed orders were not tainted with
grave abuse of discretion.

ISSUE: The only issue presented for resolution is whether the ATO could be sued without the
State’s consent.

RULING:
The petition for review has no merit. The immunity of the State from suit, known also as the
doctrine of sovereign immunity or non-suability of the State, is expressly provided in Article
XVI of the 1987 Constitution. With the CAAP having legally succeeded the ATO pursuant to
R.A. No. 9497, the obligations that the ATO had incurred by virtue of the deed of sale with the
Ramos spouses might now be enforced against the CAAP. We further observe the doctrine of
sovereign immunity cannot be successfully invoked to defeat a valid claim for compensation
arising from the taking without just compensation and without the proper expropriation
proceedings being first resorted to of the plaintiffs’ property.

DAVID ET AL VS. ARROYO ET AL.

G.R. No. 171396
May 3, 2006

FACTS:
Arroyo issued PP 1017 declaring a state of national emergency and call upon AFP and the to
prevent and suppress acts of terrorism and lawless violence in the country. Permits to hold rallies
issued earlier by the local governments were revoked. Rallyists were dispersed. The police
arrested petitioner David and Llamas without a warrant. President Arroyo issued PP 1021
declaring that the state of national emergency has ceased to exist. Petitioners filed petitions with
the SC, impleading Arroyo, questioning the legality of the proclamation.
ISSUE: Whether or not Presidential Proclamation No. 1017 is unconstitutional.

RULING:
No. PP 1017 is constitutional insofar as it constitutes a call by the President for the AFP to
prevent or suppress lawless violence whenever becomes necessary as prescribe under Section 18,
Article VII of the Constitution. However, the SC ruled that under Section 17, Article XII of the
Constitution, the President, in the absence of legislative legislation, cannot take over
privatelyowned public utility and private business affected with public interest. Therefore, the PP
No. 1017 is only partly unconstitutional.

DERAMAS VS. COURT OF AGRARIAN RELATIONS

G.R. No. L-19555
May 29, 1964
FACTS:
A tenant, Geronimo B. Ramos, and a petitioner, Mateo de Ramas, had a verbal share tenancy
contract on a 2.5-hectare land. Ramos requested to change the contract to leasehold tenancy, but
the petitioner refused, leading Ramos to file a petition with the Court of Agrarian Relations.
During the proceedings, the respondent moved to suspend the proceedings due to the
constitutionality of Section 14 of Republic Act No. 1199 being raised in another case. However,
the court denied the motion and proceeded with the case. The Supreme Court ruled that the fact
that the constitutionality of a law is being raised in another case is not a valid reason to suspend
proceedings in this case, as laws are considered valid until declared unconstitutional. The aim of
the Constitution and the State is to promote social justice and well-being for all people, which
includes encouraging small landholdings and protecting agricultural laborers. The Philippine
Rice Share Tenancy Act regulates the relationship between landlords and tenants, allowing
freedom of tenancy contracts so long as they are not contrary to existing laws. The absence of a
contract results in a share tenancy where the crop is divided equally between the landlord and
tenant.
ISSUE: Is Section 14 of Republic Act No. 1199 legally justified in impairing the obligation of an
existing contract between the tenant and the landlord.

RULING:
The right granted to the tenant to change the contract from share tenancy to that of leasehold
tenancy cannot be considered unreasonable or oppressive, because by the landlord's giving up of
5% of the harvest (the change from share to leasehold tenancy reduces the landlord's... share
from 30% to 25%) the tenant becomes more responsible, more competent, and financially
prepared to comply with his obligations under the lease, to the ultimate benefit of the landlord,
with the consequent improvement of a lot of a big segment of the population and thereby...
giving full meaning to the social justice directive contained in the Constitution. Wherefore, in
view of the above considerations We hold the disputed Section 14 of Republic Act No.
1199constitutional and valid. The Judgment appealed from is affirmed. Without costs.

PEOPLE VS. LAVA

G.R. No. L-4974
May 16, 1969

FACTS:
In. GR. No. L-4974, in the course of the trial in the RTC, the evidence relied upon were only
documents that were seized during raids on different places were Lava had been. Some of these
documents were Lava's handwriting, or were signed by him using his alias names. These were
clearly established by the testimony of a handwriting expert that was presented by the
prosecution. The conclusion of the handwriting expert was based on the specimens of Lava's
handwriting which were used as standards in comparing with the handwriting and/or signature
(in alias) of the appellant that appear in the documents that were presented as evidence against
him. Some documents were presented for comparison on Lava’s signature are: An application for
employment signed by Jose Lava. The signature thereon was testified to by witness Eduardo
Romualdez (now Secretary of Finance) as looking "like the signature of Jose Lava." Eduardo
Romualdez was acquainted with the handwriting of Jose Lava, having received reports, parts of
which were in the handwriting of Jose Lava "not less than three or four times" while Jose Lava,
was a bank examiner; and a cardboard containing a list of books requested by Jose Lava while
the latter was detained in Bilibid Prison. Buenaventura Villanueva, to whom the list was given,
testified that he saw Lava writing the list on the cardboard. Lava’s counsel contended that no
genuine specimen of Lava's handwriting was presented as standard for comparison.

ISSUE: Whether or not the reconstituted documents be admitted as evidence and would the
conclusion of the handwriting expert that it was Lava’s handwriting suffices?

RULING:
Yes. The reconstitution was made in accordance with the provisions of Act 3110, which
provides for the procedure in the reconstitution of court records. Section 59 of said act provides
that destroyed documentary evidence shall be reconstituted by means of secondary evidence
which may be presented to any Justice of the Supreme Court or any other officer commissioned
by the Court. Section 14 of the act provides that the destroyed or lost documentary evidence shall
be replaced by secondary evidence. A photostatic copy of an original document is admissible as
a secondary evidence of the contents of the originals and they constitute evidence of a
satisfactory nature. The handwriting of a person may be proved by any witness who believes it to
be the handwriting of such person, and has seen the person write. Evidence respecting the
handwriting may also be given by comparison, made by the witness or the court, with writings
admitted or treated as genuine by the party against whom the evidence is offered, or proved to be
genuine to the satisfaction of the judge. The handwriting expert who made the comparison in this
case positively identified the handwriting of Jose Lava on the documents presented as evidence
against Lava, especially the handwritten names of Gregorio Santayana, Gaston, Gaston Silayan,
Gavino and Greg.

MARCOS VS. COMELEC

G.R. No. 119976
September 18, 1995

FACTS:
Petitioner Imelda Marcos, whose alleged legal residence is in Tacloban, Leyte, ran for Congress
representing the 1st district of Leyte. Her adversary, Montejo, sought to disqualify her candidacy
on the ground that, among others, she is not a resident of at least 1 year of Tacloban and
therefore she did not satisfy the residency requirement mandated by Art VI, Sec 6 of the
Constitution as she in fact wrote in her Certificate of Candidacy that she resided “in the
constituency where” she sought “to be elected” for only “seven months”. She later claimed it to
be an honest mistake brought about by confusion and asserted that it is in fact her domicile
“since childhood”. However, COMELEC resolved in favor of Montejo and contended that
Imelda’s domicile ought to be any place where she lived in the last few decades except Tacloban.
In its resolution, COMELEC cited San Juan, Metro Mla. and San Miguel, Mla. as places where
she resided and served certain positions. Mention was even made of her residence in Malacañang
and Honolulu, Hawaii.

ISSUE: Is Tacloban, Leyte the legal residence of Imelda thereby satisfying the residence
requirement mandated by Art VI, Sec 6 of the Constitution?

RULING:
Yes. The honest mistake in the Certificate of Candidacy regarding the period of residency does
not negate the fact of residence if such fact is established by means more convincing than a mere
entry on a piece of paper. It is settled that when the Constitution speaks of “residence” in election
law, it actually means only “domicile.” It was held that Tacloban, Leyte was in fact the domicile
of origin of Imelda by operation of law for a minor follows the domicile of her parents (which
was the same). In its Resolution, COMELEC was obviously referring to Imelda’s various places
of actual residence, not her domicile (legal residence). An individual does not lose her domicile
even if she has lived and maintained residences in different places. Successfully changing
residence requires an actual and deliberate abandonment,* and Imelda has clearly always chosen
to return to her domicile of origin. Even at the height of the Marcos Regime’s powers, she kept
her close ties to her domicile of origin by establishing residences in Tacloban, celebrating
important personal milestones there, instituting well-publicized projects for its benefit and
establishing a political power base where her siblings and close relatives held positions of power
always with either her influence or consent.

OPOSA ET AL VS. FACTORAN JR.

G.R. No. 101083
July 30, 1993

FACTS:
A taxpayer’s class suit was initiated by the Philippine Ecological Network, Inc. (PENI) together
with the minors Juan Antonio Oposa et al represented by their parents. They claimed that as
taxpayers they have the right to the full benefit, use and enjoyment of the natural resources of the
country’s rainforests. It was claimed that with the rate of deforestation that time (1990), the
Philippines will lose its rainforests in a decade. Oposa et al anchored their case, among others, on
the Constitutional provision that it is the State’s policy to protect and advance the right of the
people to a balanced and healthful ecology in accord with the rhythm and harmony of nature
They prayed that a judgment be rendered ordering Secretary Fulgencio Factoran, Jr., his agents,
representatives, and other persons acting in his behalf to cancel all existing timber license
agreements in the country and cease and desist from receiving, accepting, processing, renewing
or approving new timber license agreements, Factoran being the Secretary of the Department of
Environment and Natural Resources (DENR). Secretary Factoran filed a motion to dismiss
averring that Oposa et al had no cause of action and that the issue is a political question.

ISSUE: Whether or not Oposa et al have a cause of action?

RULING:
Yes, petitioners have a cause of action. The case at bar is of common interest to all Filipinos. The
right to a balanced and healthy ecology carries with it the correlative duty to refrain from
impairing the environment. The said right implies the judicious management of the country’s
forests. This right is also the mandate of the government through DENR. A denial or violation of
that right by the other who has the correlative duty or obligation to respect or protect the same
gives rise to a cause of action. All licenses may thus be revoked or rescinded by executive action.
The judgment of the RTC was reversed and the case was remanded to the lower court.

ANG LADLAD VS. COMELEC

G.R. No. 190582
April 8, 2010

FACTS:
The COMELEC refused to accredit Ang Ladlad as a party-list organization under R.A. 7941,
otherwise known as the Party-List System Act, on the ground that the LGBT sector is neither
enumerated in the Constitution and R.A. 7941, nor is it associated with or related to any of the
sectors in the enumeration. Ang Ladlad is an organization composed of men and women who
identify themselves as lesbians, gays, bisexuals, or trans-gendered individuals (LGBTs). In
denying Ang Ladlad’s registration, the Comelec’s Second Division ruled: “Until the time comes
when Ladlad is able to justify that having mixed sexual orientations and transgender identities is
beneficial to the nation, its application for accreditation under the party-list system will remain
just that. x x x x Even if society’s understanding, tolerance, and acceptance of LGBT’s is
elevated, there can be no denying that Ladlad constituencies are still males and females, and they
will remain either male or female protected by the same Bill of Rights that applies to all citizens
alike. x x x x As a society, the Philippines cannot ignore its more than 500 years of Muslim and
Christian upbringing, such that some moral precepts espoused by said religions have seeped into
society and these are not publicly accepted moral norms.”

ISSUES: Whether or not there is legal basis for Comelec’s refusal to accredit Ang Ladlad as a
party-list group.

RULING:
There is none. Respondent mistakenly opines that our ruling in Ang Bagong Bayani stands for
the proposition that only those sectors specifically enumerated in the law or related to said
sectors (labor, peasant, fisherfolk, urban poor, indigenous cultural communities, elderly,
handicapped, women, youth, veterans, overseas workers, and professionals) may be registered
under the partylist system. The enumeration of marginalized and under-represented sectors is not
exclusive. The crucial element is not whether a sector is specifically enumerated, but whether a
particular organization complies with the requirements of the Constitution and R.A. 7941. Our
Constitution provides in Article III, Section 5 that, “no law shall be made respecting an
establishment of religion, or prohibiting the free exercise thereof.” At bottom, what our
nonestablishment clause calls for is “government neutrality in religious matters.” Clearly,
governmental reliance on religious justification is inconsistent with this policy of neutrality. We
thus find that it was grave violation of the non-establishment clause for the Comelec to utilize the
Bible and the Koran to justify the exclusion of Ang Ladlad. Moral disapproval, without more, is
not a sufficient governmental interest to justify exclusion of homosexuals from participation in
the party-list system. The denial of Ang Ladlad’s registration on purely moral grounds amounts
more to a statement of dislike and disapproval of homosexuals, rather than a tool to further any
substantial public interest.
CRUZ AND EUROPA VS. SECRETARY OF NATURAL RESOURCES ET AL.
G.R. No. 135385
December 6, 2000

FACTS:
Petitioners Isagani Cruz and Cesar Europa filed a suit for prohibition and mandamus as citizens
and taxpayers, assailing the constitutionality of certain provisions of Republic Act No. 8371,
otherwise known as the Indigenous People’s Rights Act of 1997 (IPRA) and its implementing
rules and regulations (IRR). The petitioners assail certain provisions of the IPRA and its IRR on
the ground that these amount to an unlawful deprivation of the State’s ownership over lands of
the public domain as well as minerals and other natural resources therein, in violation of the
regalian doctrine embodied in section 2, Article XII of the Constitution.

ISSUE: Do the provisions of IPRA contravene the Constitution?

RULING:
No, the provisions of IPRA do not contravene the Constitution. Examining the IPRA, there is
nothing in the law that grants to the ICCs/IPs ownership over the natural resources within their
ancestral domain. Ownership over the natural resources in the ancestral domains remains with
the State and the rights granted by the IPRA to the ICCs/IPs over the natural resources in their
ancestral domains merely gives them, as owners and occupants of the land on which the
resources are found, the right to the small scale utilization of these resources, and at the same
time, a priority in their large scale development and exploitation. Additionally, ancestral lands
and ancestral domains are not part of the lands of the public domain. They are private lands and
belong to the ICCs/IPs by native title, which is a concept of private land title that existed
irrespective of any royal grant from the State. However, the right of ownership and possession by
the ICCs/IPs of their ancestral domains is a limited form of ownership and does not include the
right to alienate the same.

OFFICE OF THE COURT ADMINISTRATOR VS. FLORO

A.M. No. RTJ-99-1460
March 31, 2006

FACTS: Atty. Florentino V. Floro, Jr. applied for a judgeship in 1995 but was deemed unfit for
the job based on a psychological evaluation that showed evidence of ego disintegration and a
developing psychotic process. When he applied again in 1998, he was found to have problems
with selfesteem, mood swings, confusion, social/interpersonal deficits, paranoid ideations,
suspiciousness, and perceptual distortions. He was given a second opinion and was eventually
appointed as a judge. An administrative complaint was filed against him for alleged partiality in
criminal cases, which he denies. The court administrator recommended his suspension during the
investigation. Judge Floro's clerk of court claimed he admitted to being "pro-accused" during a
staff meeting.

ISSUE:
Whether or not Judge Floro violated Canon 3 of the New Code of Judicial Conduct.

RULING:
Yes. Canon 2.01 of the Code of Judicial Conduct states: "A judge should so behave at all times
as to promote public confidence in the integrity and impartiality of the judiciary." This means
that a judge whose duty is to apply the law and dispense justice "should not only be impartial,
independent and honest but should be believed and perceived to be impartial, independent and
honest" as well. Judge Floro, by broadcasting to his staff and the PAO lawyer that he is
proaccused, opened himself up to suspicion regarding his impartiality. Prudence and judicial
restraint dictate that a judge should reserve personal views and predilections to himself so as not
to stir up suspicions of bias and unfairness. Irresponsible speech or improper conduct of a judge
erodes public confidence in the judiciary. On a more fundamental level, what is required of
judges is objectivity if an independent judiciary is to be realized. And by professing his bias for
the accused, Judge Floro is guilty of unbecoming conduct as his capacity for objectivity is put in
serious doubt, necessarily eroding the public’s trust in his ability to render justice.
IMBONG VS. OCHOA
G.R. No. 204819
April 8, 2014

FACTS:
Due to the uncontrolled growth of the population in the country, the executive and legislative
branches deemed existing measures insufficient and enacted the Responsible Parenthood and
Reproductive Health Act of 2012 (RH Law) to provide Filipinos, particularly the poor and
marginalized, access to modern family planning methods and ensure the right to reproductive
health. The RH Law aims to reinforce existing laws on contraception, women’s health, and
population control. After its implementation, the RH Law faced challenges from various sectors
questioning its constitutionality, particularly its compliance with the one subject-one title rule.
The implementation was temporarily suspended by a Status Quo Ante Order. Petitioners argue
that the RH Law is unconstitutional as it conceals its true intent as a population control measure
and violates the one subject-one title rule. Respondents, however, assert that the RH Law is not a
population control measure and that the concepts of “responsible parenthood” and “reproductive
health” are interrelated and inseparable.

ISSUE: Whether or not RH Law violated the one subject-one title rule under the Constitution.

RULING:
The RH Law is primarily seen as a population control measure by the Court, despite being
marketed as a reproductive health law. The law aims to reduce the country's population by
providing Filipinos with access to family planning information and methods. The petitioners
argue that the RH Law is unconstitutional, violating the one subject-one title rule, but the Court
disagrees, stating that the title is comprehensive enough to include the general object of the law
and that both "reproductive health" and "responsible parenthood" are closely related to the goal
of controlling population growth. The Court declared some provisions of the RH Law
unconstitutional but lifted the Status Quo Ante Order for the constitutional provisions.