Almonte v.

People
GR 252117

Facts:
On April 6, 2020, the petitioners allege that they are prisoners and are among the
elderly, sick, and pregnant population of inmates exposed to the danger of contracting
COVID-19 where social distancing and self-isolation measures are purportedly
impossible. As such, they are invoking this Court's power to exercise "equity
jurisdiction" and are seeking "temporary liberty on humanitarian grounds" either on
recognizance or on bail. Moreover, they asked the Court to order the creation of a
"Prisoner Release Committee" to conduct a study and implement the release of
prisoners in congested penal facilities. For respondents' part who are represented by the
Office of the Solicitor General, they filed their comment opposing petitioners' plea for
their temporary release and for the creation of a Prisoner Release Committee.

Issues
Whether the instant petition filed directly before this Court may be given due course

Ruling:
The Supreme Court, after initial deliberations and exchanges of ideas, has collectively
realized that the instant case presents several complex issues making the interaction of
applicable principles ridden with far-reaching implications. The Court unanimously
arrived at the conclusion to treat the petition as petitioners' application for bail or
recognizance, as well as their motions for other practicable and suitable confinement
arrangements relative to the alleged serious threats to their health and lives.

Analysis:
In this case, petitioners have been charged with offenses punishable by reclusion
perpetua. As such, they are not entitled to bail as a matter of right. The foregoing holds
true with respect to the motions for other confinement arrangements which also
necessitate reception and evaluation of evidence by a trial court.

Conclusion:
The Court treats the present petition as petitioners' applications for bail or recognizance
as well as their motions for other confinement arrangements and REFERS the same to
the respective trial courts where their criminal cases are pending.
Lirag Textile Mills, Inc. v. SSS
GR L-33205

Facts: Lirag (debtor) and SSS (creditor) entered into a purchase agreement. Here, there
is a guarantee that Lirag will redeem the shares of stocks and pay the dividends.
However, Lirag Textilr Mills, Inc. and Basil L. Lirag comply with the terms of the
Purchase Agreement, hence, SSS filed an action for specific performance and damages
before the CFI. Lirag moved for the dismissal of the case but was denied. Lirag filed a
counterclaim denying the existence of any obligation on their part.

Issue: Whether Lirag Textile Mills Inc. is liable

Ruling: Yes. The purchase agreement defines the rights and obligations of the parties
and establishes liability in case of breach Certificates of preferred stocks serve as
additional evidence of the agreement

Analysis:
The Purchase Agreement constitutes the law between the parties and obligations arising
ex contractu must be fulfilled in accordance with the stipulations.

Conclusion:
the decision in Civil Case No. Q-12275 entitled "Social Security System vs. Lirag Textile
Mills, Inc. and Basilio L. Lirag" is hereby affirmed in toto. Costs against petitioners.
Ganaway vs. Quillen
GR No. 1861
Facts:
In the civil case Casey et al. v Ganaway, complainants sued Ganaway for breach of
contract. The said contract was related to some publication Forbes Memoirs.
Complainants asked for accounting and that Ganaway should pay them. The trial court
decided in favor for complainants. Ganaway was ordered to be imprisoned by the
Attorney-General.

Issue:
Whether one who is liable to pay damages arising from a breach of contract should be
imprisoned?

Ruling:
No. The constitutional prohibition in effect in the Philippine Islands is in the same
category as those States in which imprisonment for debt is absolutely prohibited. The
prohibition in the Philippine Bill, reproduced in the Jones Law, is "that no person shall
be imprisoned for debt."

Analysis:
In this connection, it may be said that the reason for the decision of, the Supreme Court
of Georgia in the case of Harris vs. Bridges ([1856], 57 Ga., 407), mainly relied upon by
the Attorney-General, will be found to be because the action was one in tort.

Conclusion:
In a minute order, directed the discharge from imprisonment of the petitioner, and this
decision is in explanation thereof.
Sumbilla v. Matrix Finance Corporation
GR 197582

Facts:
Sumbilla obtained a cash loan from Matrix Finance Crop and issued six checks with a
face value of 6,667 pesos. She was charged with six counts of violation of BP 22 and
found guilty. The MeTC meted her a fine of 80 000 PESOS with subsidiary
imprisonment, and her civil liability was computed in the total amount of 40,002 pesos.
She filed her Petition for Review on Certiorari with the SC.

Issue:
Whether the penalty imposed in the MeTC Decision, which is already final and
executory, may still be modified.

Ruling:
YES. Section 1 of BP 22 provides in SECTION 1. Checks without sufficient funds. Any
person who makes or draws and issues any check to apply on account or for value,
shall be punished by imprisonment of not less than thirty days but not more than one
(1) year or by a fine of not less than but not more than double the amount of the check
which fine shall in no case exceed Two hundred thousand pesos, or both such fine and
imprisonment at the discretion of the court.

Analysis:
Petitioner assailed the penalty for being out of the range of the penalty prescribed. The
SC ruled that the MeTC incorrectly computed the amount of the amount of fine using
the total value of the six checks (40,002 pesos). The fine of 80,000 pesos is more than 11
times the amount of the face value of each check that was dishonored. The maximum
penalty which could be imposed is only 13,334 pesos.

Conclusion:
The petition is granted. in the interest of justice, the decision of Branch 67, Metropolitan
Trial Court of Makati city is modified.
People v. Juego
GR 123162
Facts:
Nenita Juego and Wilfredo Gaerlan were charged with Illegal Recruitment in Large
Scale and Estafa. Nenita argued that her husband Abelardo was not engaged in
recruitment, but the Chief of the Licensing Branch of the Philippine Overseas
Employment Administration issued a certification that they were not licensed to recruit
workers for overseas employment. The RTC rendered judgment adverse to Nenita T.
Juego.

Issue:
Whether or not the trial court is correct in convicting the accused of the crime charged.

Ruling:
Yes. Article 13, par. (b), of the Labor Code defines recruitment as referring to any act of
canvassing, enlisting, contracting, transporting, utilizing, hiring, or procuring workers,
and includes referrals, contract services, promising or advertising for employment,
locally or abroad.

Analysis: whether for profit or not: Provided, that any person or entity which, in any
manner, offers or promises for a fee employment to two or more persons shall be
deemed engaged in recruitment and placement.

Conclusion:
The judgment appealed from finding accused-appellant Nenita T. Juego guilty of Illegal
Recruitment in Large Scale and two counts of Estafa is affirmed with modifications.
Tiomico v. Court of Appeals
GR 122539

Facts:
Jesus V. Tiomico opened a Letter of Credit with BPI to import two units of Forklifts,
Shovel loader and a truck mounted with crane. He failed to pay the balance amount or
deliver the machineries and equipments, leading to a violation of PD 115. A witness for
BPI testified and presented 6 exhibits to support her testimony. The prosecution rested
and the case was set for continuation of trial. The defense filed an Urgent Motion for
Postponement, which was denied and adjudged petitioner to have waived the right to
introduce evidence on his behalf. TC promulgated its decision finding petitioner guilty
of a violation of PD 115 and sentencing him accordingly.

Issue:
Whether the denial of the motion for postponement sent in by his lawyer violated
Petitioner’s constitutional right to due process.
RULING: No. The most basic tenet of due process is the right to be heard. Where a
party had been afforded an opportunity to participate in the proceedings but failed to
do so, he cannot complain of deprivation of due process.

Analysis:
The inadvertence of the defense counsel in failing to take note of the trial dates and in
belatedly informing the trial court of any conflict in his schedules of trial or court
appearances, constitutes inexcusable negligence.

Conclusion:
The petition is denied.
Yap v. Lutero, GR L-12669
Facts:
Atty. Mandagan filed a Verified Complaint with Prayer for Immediate Preventive
Suspension against former Mayor Josemarie L. Diaz and the members of the
Sangguniang Panlungsod of the City of Ilagan, Isabela for their alleged violation of
Republic Act No. (RA) 3019, RA 6713, Grave Abuse of Authority, and Grave
Misconduct. The Ombudsman dismissed Atty. Mandagan's complaint for lack of merit,
finding that she failed to prove that Mr. Diaz and the members of the Sangguniang
Panlungsod gravely abused their authority and violated RA 3019 and RA 6713. Mr.
Diaz then filed an administrative case against Atty. Mandagan, arguing that she
violated Section 27,11 Rule 138 and the Code of Professional Responsibility.

Issue:
Whether Atty. Mandagan violated the CPR when she filed before the Ombudsman her
unsubstantiated and meritless complaint against Mr. Diaz.

Ruling:
The Court agrees with the IBP Board of Governor's findings. In determining whether
Atty. Mandagan should be liable for transgressing the pertinent provisions of the CPR,
the Court first examines the soundness and reasonableness of the complaint filed by
Atty. Mandagan against Mr. Diaz for the latter's alleged violation of RA 3019, RA 6713,
Grave Abuse of Authority, and Grave Misconduct.

Analysis:
Apparently, the serious accusations hurled by Atty. Mandagan against Mr. Diaz were
baseless. With these groundless averments, it appears that Atty. Mandagan instituted
the criminal action against Mr. Diaz without due and proper investigation of the case
and without due regard to his rights.

Conclusion:
Atty. Maria Nympha C. Mandagan is found GUILTY of violating Rule 1.01, Canon 1,
and Rules 10.01 and 10.03, Canon 10 of the Code of Professional Responsibility.
Chiok v. People, GR 179814

Facts:
The Court of Appeals (CA) reversed and set aside the December 3, 1998 Decision of the
Regional Trial Court (RTC) of Pasig-Branch 165, and acquitted Wilfred Chiok (Chiok) of
the crime of estafa in Criminal Case No. 109927, but ordered him to pay civil liability to
Rufina Chua in the total amount of P9,500,000.00, plus interests. Chiok was charged
with estafa, defined and penalized under Article 315, paragraph 1(b) of the Revised
Penal Code, in an information that reads: that sometime in June 1995, the accused
received in trust from Rufina Chua the amount of P9,563,900.00 for him to buy
complainant shares of stocks, under the express obligation on the part of the accused to
deliver the documents thereon or to return the whole amount if the purchase did not
materialize.

Issue:
Whether or not Chua has a legal personality to file and prosecute this petition.

Ruling:
Chua lacks the personality or legal standing to question the CA Decision because it is
only the OSG, on behalf of the State, which can bring actions in criminal proceedings
before this Court and the CA.

Analysis:
In order to give life to the rule on double jeopardy, our rules on criminal proceedings
require that a judgment of acquittal, whether ordered by the trial or the appellate court,
is final, unappealable, and immediately executory upon its promulgation. 

Conclusion:
The court hereby absolves the accused from criminal as well as civil liability and orders
these cases dismissed for lack of evidence to support the charges levelled against him.
Villareal v. Aliga
G.R. No 166995  

Facts:
 The petition for review on certiorari under Rule 45 of the 1997 Revised Rules of Civil
Procedure challenges the April 27, 2004 Decision and August 10, 2004 Resolution of the
Court of Appeals in CA-G.R. R No. 25581, which acquitted respondent Consuelo C.
Aliga from the offense charged and reversed and set aside the July 12, 2001 Decision of
the Regional Trial Court (RTC). Aliga appealed to the CA, which reversed and set aside
the judgment of the RTC on the grounds that her admission or confession of guilt before
the NBI authorities is inadmissible in evidence and that the totality of the circumstantial
evidence presented by the prosecution is insufficient to overcome the presumption of
innocence of the accused.

Issue:
Whether a judgment of acquittal via petition for certiorari under Rule 45 of the Rules is
proper.

Ruling:
Petitioner also committed another procedural blunder. A petition for certiorari under
Rule 65 of the Rules should have been filed instead of herein petition for review on
certiorari under Rule 45.

Analysis:
In such case, the People is burdened to establish that the court a quo, in this case, the
Sandiganbayan, acted without jurisdiction or grave abuse of discretion amounting to
excess or lack of jurisdiction.

Conclusion:
The instant petition is dismissed.
Lacson v. Executive Secretary, GR 128096

Facts:
Eleven members of the Kuratong Baleleng gang were killed by the Anti-Bank Robbery
and Intelligence Task Group (ABRITG) headed by Chief Supt. Jewel Canson of PNP. A
review board recommended an indictment for multiple murder against 26 respondents,
including Lacson. The Office of the Special Prosecutor moved for a reconsideration, but
RA 8249 was enacted to delete the word "principal" from the phrase "principal accused".
Lacson now questions the constitutionality of Secs. 4 and 7 of R.A. 8249, but the OSG
asserts otherwise.

Issue:
Whether or not RA 8249 is constitutional.

Ruling:
Yes, The Court mainly stresses that the provisions are Constitutional

Analysis: (a) there is presumption of validity of laws and no showing that the Congress
pinpointed solely the petitioners which would amount to a violation of the
Constitution’s Equal Protection clause, (b) using the doctrine in Calder v. Bull, the same
is not an ex post facto legislation and lastly, (c) law’s title is comprehensive enough to fit
in the one-title-one-subject provision of the Constitution.

Conclusion:
The constitutionality of Sections 4 and 7 of R.A. 8249 is hereby sustained. The
Addendum to the March 5, 1997 Resolution of the Sandiganbayan is reversed.