Title:

Ayala Corporation vs. Rosa-Diana Realty and Development Corporation

Case No. GR. No. 134284
Ponente DE LEON, JR., J
Plaintiff/ AYALA CORPORATION
Petitioner
Respondent/ ROSA-DIANA REALTY AND DEVELOPMENT CORPORATION
Defendant
Mode of Appeal/ Petition for review on certiorari seeking the reversal of a decision rendered
Review to the SC by the Court of Appeals
Facts: Ayala Corporation sold a parcel of land to Manuel Sy and Sy Ka Kieng with
special conditions of sale and deed restrictions.
The buyers failed to construct the building as required by the agreement.
They later sold the land to Rosa-Diana Realty with Ayala's approval.
Ayala released the title to Rosa-Diana upon the execution of an Undertaking.
Rosa-Diana submitted building plans for a condominium project that
exceeded the height and floor area limits set by the deed restrictions.
Ayala filed a case for specific performance, which was denied by the trial
court.
Issue: Whether or not Rosa Diana committed a breach of Contract
Ruling: Yes, Rosa Diana committed a breach of Contract
The Court found that Rosa-Diana was in gross violation of the deed
restrictions by constructing a building that exceeded the approved height and
floor area limits. The Court held that contractual obligations have the force of
law between parties and must be complied with in good faith. Since the
remedy of specific performance was no longer feasible, the Court ordered
Rosa-Diana to pay development charges as compensatory damages and
awarded exemplary damages and attorney's fees to Ayala. The Court reversed
the decision of the Court of Appeals and ruled in favor of Ayala.)
Rosa-Diana was in violation of the deed restrictions and acted in bad faith by
submitting different building plans.
Rosa-Diana is liable for violating the deed restrictions.
Rosa-Diana is ordered to pay compensatory damages, development charges,
exemplary damages, and attorney's fees to Ayala.
Title:
Locsin II vs. Mekeni Food Corp.
Case No. GR. No. G.R. No. 192105
Ponente DEL CASTILLO, J
Plaintiff/ Antonio Locsin II
Petitioner
Respondent/ Mekeni Food Corporation
Defendant
Mode of Appeal/ Petition for Certiorari with the CA assailing the NLRC's February 27, 2009
Review to the SC Decision, saying that the NLRC committed grave abuse of discretion in
holding it liable to petitioner as it had no jurisdiction to resolve petitioner's
claims, which are civil in nature. AIcECS
Facts: • Locsin was offered a position as Regional Sales Manager by Mekeni,
which included a car plan as part of his compensation package.
• Locsin accepted the offer and began his employment with Mekeni.
• Locsin began his employment with Mekeni on March 17, 2004, and
was provided with a used Honda Civic car as a service vehicle.
• Locsin made monthly salary deductions of P5,000.00 to cover his
share of the car plan payments.
• Locsin resigned from his position on February 25, 2006, and offered
to purchase the service vehicle by paying the outstanding balance.
• The parties could not agree on the terms of the purchase, and Locsin
returned the vehicle to Mekeni on May 2, 2006.
• Locsin made follow-ups regarding his unpaid salaries, commissions,
benefits, and offer to purchase the service vehicle, but Mekeni claimed
that the car plan benefit only applied to employees who had been with
the company for five years.
• On May 3, 2007, Locsin filed a complaint against Mekeni for the
recovery of monetary claims, including unpaid salaries, commissions,
and the reimbursement of his car plan payments.
• The case was docketed as NLRC NCR CASE NO. 00-05-04139-07 in the
National Labor Relations Commission (NLRC).
• The Labor Arbiter rendered a decision on October 30, 2007, ordering
Mekeni to turn over the service vehicle to Locsin upon payment of
P100,435.84.
• The NLRC reversed the Labor Arbiter's decision in a February 27,
2009 decision, ordering Mekeni to pay Locsin unpaid salary,
sick/vacation leave pay, commissions, and reimbursement of his car
plan payments.
• The NLRC held that Mekeni's claim that the car plan benefit only
applied to employees who had been with the company for five years
was not substantiated.
• Mekeni filed a petition for certiorari with the Court of Appeals (CA) to
challenge the NLRC's decision.
• The CA modified the NLRC's decision, deleting the reimbursement of
Locsin's car plan payments and Mekeni's share in the car plan.
• The CA held that Locsin's payments should be considered as rentals
for the use of the service vehicle and should not be refunded.
 • Locsin filed a petition for review on certiorari with the Supreme
Court, arguing that the car plan privilege should be considered part of
his compensation package.
• Mekeni filed a petition for certiorari with the Court of Appeals (CA) to
challenge the NLRC's decision.
• The CA modified the NLRC's decision, deleting the reimbursement of
Locsin's car plan payments and Mekeni's share in the car plan.
• The CA held that Locsin's payments should be considered as rentals
for the use of the service vehicle and should not be refunded.
• Locsin filed a petition for review on certiorari with the Supreme
Court, arguing that the car plan privilege should be considered part of
his compensation package.

Summary (facts)
• Locsin then filed a complaint against Mekeni for unpaid salaries,
commissions, and benefits, as well as reimbursement of his payments
towards the car plan. The Labor Arbiter ruled in favor of Locsin,
ordering Mekeni to turn over the vehicle upon payment of a certain
amount. The NLRC reversed this decision, but the CA later modified
the ruling, holding that Locsin's payments on the car plan should be
considered as rentals for the vehicle's use and not required to be
refunded.

Issue: Whether Locsin is entitled to a refund of the payments made under the car
plan agreement with Mekeni.
Ruling: The Court held that in the absence of specific terms and conditions governing
the car plan arrangement, a quasi-contractual relationship was created
between Locsin and Mekeni. Locsin should be refunded his payments under
the car plan, as Mekeni cannot enrich itself by charging him for the use of a
necessary work tool that primarily benefited the company. However, Locsin
cannot recover Mekeni's contribution to the car plan, as it was not intended to
be part of his compensation package and would unjustly enrich him at
Mekeni's expense. The Court modified the CA decision and ordered Mekeni to
refund Locsin's payments under the car plan agreement.)
Doctrine:
Quasi-Contract
Doctrine:Article 2142 of the Civil Code clarifies that there are certain lawful,
voluntary and unilateral acts which give rise to the juridical relation of quasi-
contract,to the end that no one shall be unjustly enriched or benefited at the
expense of another.
Title:
Bermudez Sr. vs. Melencio-Herrera
Case No. GR. No. L-32055
Ponente Yap, J
Petitioner/ REYNALDO BERMUDEZ, SR., and ADONITA YABUT BERMUDEZ
Appelant
Respondent/ JUDGE A. MELENCIO-HERRERA, DOMINGO PONTINO y TACORDA and
Appelle CORDOVA NG SUN KWAN
direct appeal on pure questions of law
Facts: • A cargo truck, driven by Domingo Pontino and owned by Cordova Ng
Sun Kwan, bumped a jeep on which Rogelio, a six-year old son of
plaintiffs-appellants, was riding. The boy sustained injuries which
caused his death.
• The couple filed a criminal case for Homicide Through Reckless
Imprudence against Domingo Pontino.
• The couple also filed a civil case for damages against Domingo
Pontino and Cordova Ng Sun Kwan.
• The couple reserved their right in the criminal case to file an
independent civil action.
• The trial court dismissed the couple's complaint in the civil case,
stating that they had already elected to treat the accident as a "crime"
by reserving their right to file a separate civil action.
• The trial court ordered the dismissal of the complaint against Cordova
Ng Sun Kwan and suspended the hearing of the case against Domingo
Pontino until after the criminal case is finally terminated.
• The couple appealed the trial court's decision, stating that the civil
action is based on quasi-delict and should proceed independently of
the criminal case.
• The main issue in the case is whether the civil action is founded on
crime or on quasi-delict.
• The trial court treated the case as an action based on a crime due to
the reservation made by the offended party in the criminal case.
• The doctrine in the case of Joaquin vs. Aniceto, which states that the
employer cannot be subsidiarily liable without the conviction of the
employee, is deemed inapplicable to the present case.
• In cases of negligence, the injured party or their heirs have the choice
between an action to enforce the civil liability arising from crime or an
action for quasi-delict.
• The injured party may hold the employer solidarily liable for the
negligent act of their employee if they choose to file an action for
quasi-delict.
• The appellants made a reservation to file an independent civil action
in accordance with the provisions of Section 2 of Rule 111, Rules of
Court.
• Even without such a reservation, the injured party in a criminal case
resulting in the acquittal of the accused can still recover damages
based on quasi-delict.
• The judgment of acquittal extinguishes the civil liability of the accused
 only when it includes a declaration that the facts from which the civil
liability might arise did not exist.
• The petition was granted, and the appealed orders of the trial court
were annulled and set aside. The case was remanded for further
proceedings.

Issue: Whether the civil action filed by the couple is based on quasi-delict and can
proceed independently of the criminal case for reckless imprudence.
Ruling: The court ruled in favor of the couple, stating that in cases of negligence, the
injured party has the choice between an action to enforce the civil liability
arising from crime or an action for quasi-delict. If the injured party chooses
the latter, they may hold the employer solidarily liable for the negligent act of
their employee. The fact that the couple reserved their right in the criminal
case did not preclude them from choosing to file a civil action for quasi-delict.
The court also cited the provisions of Rule 111 of the Rules of Court, which
allow for an independent civil action to be brought by the injured party
during the pendency of the criminal case, provided the right is reserved. The
court emphasized that a person who is not criminally liable may still be held
civilly liable, and the judgment of acquittal in a criminal case does not
extinguish the civil liability of the accused unless it includes a declaration that
the facts from which the civil liability might arise did not exist.
Law
Such civil action shall proceed independently of the criminal prosecution, and
shall require only a preponderance of evidence."
Article 2177 of the Civil Code, cited in Section 2, of Rule 111, provides that
"Article 2177. Responsibility for fault or negligence under the preceding
article is entirely separate and distinct from the civil liability arising from
negligence under the Penal Code. But the plaintiff cannot recover damages
twice for the same act or omission of the defendant."
Title:
People vs Relova
Case No. GR. No. G.R. No. L-45129. March 6, 1987.
Ponente FELECIANO, J
Plaintiff/ PEOPLE OF THE PHILIPPINES
Petitioner
Respondent/ THE HONORABLE BENJAMIN RELOVA, in his capacity as Presiding Judge
Defendant of the Court of First Instance of Batangas, Second Branch, and MANUEL
OPULENCIA,
Facts: • Police conducted a search of a business owned by Manuel Opulencia
and found unauthorized electrical devices installed to lower electric
consumption.
• Opulencia admitted to installing these devices to lower his electric
meter readings.
• Charges were filed against Opulencia for violation of a Batangas City
ordinance and later for theft of electric power under the Revised
Penal Code.
• The first charge was dismissed due to prescription of the offense, and
a second charge of theft was filed.
• Opulencia filed a motion to quash the second charge on double
jeopardy grounds.

Issue: Whether the two offenses charged against Manuel Opulencia - one for
violation of a city ordinance and another for theft under the Revised Penal
Code - arose from the same act or set of acts and therefore fall under the
protection against double jeopardy.
Ruling: The Supreme Court denied the petition for certiorari and mandamus, holding
that while Opulencia should be protected against double jeopardy, the civil
liability aspect of the case should be remanded to the Court of First Instance
of Batangas City for further proceedings to determine the amount or value of
the stolen electric power. The Court also pointed out that the civil liability
arising from the offense charged in the criminal action does not extinguish
with the dismissal of the criminal case.
Doctrine The protection against double jeopardy is available where the second
prosecution is for the same offense, even if the charges are under different
laws or ordinances, as long as the acts constituting the offenses are related in
time, space, and intent. The civil liability arising from an offense is separate
from criminal liability and may still be pursued even after the criminal
charges have been dismissed.
Title:
Manantan vs. CA
Case No. GR. No. 107125
Ponente QUISUMBING, J.:
Petitioner GEORGE MANANTAN
Respondent THE COURT OF APPEALS, SPOUSES MARCELINO NICOLAS and MARIA
NICOLAS
Mode of Appeal Petition for review of the decision dated January 31, 1992 of the Court of
Appeals in CA-G.R. CV No. 19240, modifying the judgment of the Regional
Trial Court of Santiago, Isabela, Branch 21, in Criminal Case No. 066.
Petitioner George Manantan was acquitted by the trial court of homicide
through reckless imprudence without a ruling on his civil liability.
Facts: George Manantan was acquitted by the trial court of homicide through
reckless imprudence without a ruling on his civil liability. On appeal from the
civil aspect of the judgment, the Court of Appeals found petitioner Manantan
civilly liable and ordered him to indemnify the Nicolas spouses for the death
of their son, Ruben Nicolas.
Issue: Whether the he acquittal of petitioner foreclose any further inquiry by the
Court of Appeals as to his negligence or reckless imprudence?
Ruling: The acquittal of petitioner was based on reasonable doubt, allowing the civil
action for damages to proceed even though the criminal liability was not
proven. The Court of Appeals had jurisdiction to review the civil aspect of the
case and award damages and indemnity. The filing fees for the damages
awarded are a first lien on the judgment, ensuring that proper fees were paid.
Therefore, the petition was dismissed, and the decision of the Court of
Appeals was affirmed.)
Basis: The acquittal of the defendant in the criminal case does not automatically
foreclose any further inquiry into his civil liability. Civil and criminal liabilities
are separate and distinct, and the acquittal in the criminal case based on
reasonable doubt does not preclude the determination of civil liability. The
Court of Appeals had jurisdiction to review the civil aspect of the case and
award damages and indemnity to the plaintiffs. Additionally, the filing fees for
the damages awarded are considered a first lien on the judgment to ensure
that proper fees were paid. Ultimately, the judgment of the Court of Appeals
was affirmed.