1. Radiowealth Fice Co. vs.

Spouses Del Rosario

Summary:

A finance company files a complaint against a couple for defaulting on their

monthly installments, leading to a dismissal by the trial court, but the Supreme Court
grants the petition and orders the couple to pay the outstanding amount plus penalty
charges and attorney's fees.

Facts:

Radiowealth Finance Company filed a complaint against Spouses Vicente and Ma.
Sumilang Del Rosario for defaulting on their monthly installments. The couple executed a
promissory note in favor of the finance company but failed to pay their obligations
despite repeated demands. The trial court dismissed the complaint for lack of evidence.
The Court of Appeals reversed the decision and remanded the case for further
proceedings.

Issue:

Whether the Court of Appeals erred in remanding the case for further proceedings
instead of rendering judgment based on the evidence submitted by the petitioner

Rulings:

The Court of Appeals erred in remanding the case and should have rendered
judgment based on the evidence submitted by the petitioner. The respondents are
ordered to pay the outstanding amount plus penalty charges and attorney's fees.

When a demurrer to evidence is granted by a trial court and reversed on appeal, the
defendant loses the right to present evidence and the appellate court should render
judgment on the merits. The Court of Appeals had sufficient evidence on record to decide
the collection suit, and a remand was unnecessary. The obligation of the respondents
had already become due and demandable, as evidenced by the promissory note and the
default on the monthly installments.

The respondents' argument that a period for payment should be fixed by the court is
rejected, as the intention of the parties was clear from the promissory note. Interest was
not granted because it was not expressly stipulated in the promissory note, but it should
be deemed included in the late payment penalty. Liquidated damages should not be
imposed as they were unconscionable. Attorney's fees should be limited to a reasonable
amount.
2. GMA Network, Inc. vs. Central CATV, Inc

Summary:

A dispute arises between GMA Network and Central CATV regarding the showing of
advertisements in the respondent's cable television system, leading to a legal battle that
ultimately determines that the respondent is not prohibited from showing advertisements
under the relevant executive orders and regulations

Facts:

GMA Network, Inc. (petitioner) and Central CATV, Inc. (respondent) are in a dispute
over the showing of advertisements in the respondent's cable television system.
Petitioner, along with other complainants, filed a complaint with the National
Telecommunications Commission (NTC) against the respondent, alleging that the
showing of advertisements in the CATV system infringes on the television and broadcast
markets, as prohibited by Executive Order (EO) No. 205. Respondent argued that EO No.
436 allows CATV providers to carry advertisements with the consent of their program
providers.

After petitioner presented evidence, respondent filed a motion to dismiss by

demurrer to evidence, claiming that the evidence failed to show how the respondent's
acts infringed upon the television and broadcast market. NTC granted respondent's
demurrer to evidence and dismissed the complaint, ruling that EO No. 436 clarified the
term "infringement" in EO No. 205 and allowed CATV operators to show advertisements
with consent. Petitioner appealed to the Court of Appeals (CA), which upheld the NTC
ruling, stating that EO No. 436 did not modify or amend EO No. 205, but filled in the
details of the prohibition on infringement. Petitioner filed a petition for review on
certiorari with the Supreme Court.

Issue:

Whether the CA erred in affirming the NTC's grant of the respondent's motion to
dismiss by demurrer to evidence.

Whether the respondent is prohibited from showing advertisements under EO No.

205, in relation to EO No. 436.

Ruling:

The Supreme Court denied the petition for lack of merit

The NTC and the CA erred in considering EO No. 436 as a law, when it is actually an
executive issuance. EO No. 205 is a law, while EO No. 436 is an executive order. The
NTC and the CA failed to correctly appreciate EO No. 205 and its implementing rules and
regulations, MC 4-08-88. MC 4-08-88 sufficiently resolved the issue on whether the
respondent could show advertisements in its CATV networks. The must-carry rule, as
provided in MC 4-08-88, is the governing rule and does not prohibit CATV operators from
showing advertisements. The NTC erred in considering the respondent's evidence
attached to its demurrer to evidence, as it violated the petitioner's due process rights.
The Supreme Court affirmed the decision of the CA, ruling in favor of the respondent. The
respondent is not prohibited from showing advertisements in its CATV networks under
EO No. 205 and its implementing rules and regulations. EO No. 436 did not amend the
must-carry rule under MC 4-08-88
3. Casent Realty Development Corp. vs. Philbanking Corp

Summary:

A realty development corporation is held liable to pay a banking corporation for

outstanding promissory notes, as a dacion en pago and confirmation statement did not
sufficiently prove the extinguishment of the corporation's obligation

Facts:

Casent Realty Development Corp. executed two promissory notes in favor of Rare
Realty Corporation in 1984. The promissory notes were later assigned to Philbanking
Corporation through a Deed of Assignment. Casent Realty Development Corp. failed to
pay the promissory notes upon maturity, resulting in an outstanding obligation of Php
5,673,303.90 as of July 15, 1993.

Philbanking Corporation filed a complaint for the collection of the said amount.
Casent Realty Development Corp. raised the defense that their obligation was
extinguished through a Dacion en Pago and Confirmation Statement. They argued that
the Dacion intended to totally extinguish their outstanding accounts and presented a
Confirmation Statement issued by Philbanking Corporation stating that they had no loans
with the bank as of December 31, 1988.

The trial court ruled in favor of Casent Realty Development Corp. and dismissed the
complaint. On appeal, the Court of Appeals reversed the decision of the trial court,
finding that the promissory notes were not covered by the Dacion and that Philbanking
Corporation had the right to proceed against the promissory notes assigned by Rare
Realty.

Issue:

Whether the failure of Philbanking Corporation to file a Reply and deny the Dacion
and Confirmation Statement under oath constitutes a judicial admission of the
genuineness and due execution of these documents.

Whether Casent Realty Development Corp. is liable to pay Philbanking Corporation.

Ruling:

The failure of Philbanking Corporation to file a Reply and deny the Dacion and
Confirmation Statement under oath constitutes a judicial admission of the genuineness
and due execution of these documents. However, the Dacion and Confirmation
Statement did not sufficiently prove that Casent Realty Development Corp.'s liability was
extinguished.

The Dacion only covered petitioner's loan from the bank, not the obligation arising from
the promissory notes. Therefore, Casent Realty Development Corp. is still liable to pay
the outstanding amount.

The failure of Philbanking Corporation to file a Reply and deny the Dacion and
Confirmation Statement under oath constitutes a judicial admission of the genuineness
and due execution of these documents. This means that the court can consider these
documents as valid and authentic.

However, the court found that the Dacion and Confirmation Statement did not sufficiently
prove that Casent Realty Development Corp.'s liability was extinguished. The Dacion only
covered petitioner's loan from the bank, not the obligation arising from the promissory
notes.

The court held that for the Dacion to extinguish the obligation arising from the
promissory notes, it should have explicitly included these notes in its terms. Since it did
not, the obligation remains. Therefore, Casent Realty Development Corp. is still liable to
pay the outstanding amount of the promissory notes to Philbanking Corporation.
4. Heirs of Pasag vs. Spouses Parocha

Summary:

The Heirs of Pasag file a complaint against the Parocha family, seeking a share in
their deceased grandparents' properties, but their failure to comply with court orders and
provide sufficient evidence leads to the dismissal of their complaint, which is affirmed by
the Supreme Court.

Facts:

Heirs of Pedro Pasag filed a complaint against the Parocha family, claiming a share
in properties owned by their deceased grandparents, Benito and Florentina Pasag. Benito
and Florentina Pasag died intestate, leaving their properties to their eight children. One
of the children, Severino, claimed to be the sole heir and appropriated the properties for
himself. Severino sold some of the properties to his daughter, respondent Florentina
Parocha.

Heirs of Pedro Pasag filed a complaint seeking nullity of documents and titles,
recovery of possession and ownership, reconveyance, partition, and damages. Trial
began in 1996 and the heirs rested their case in 1999. Heirs failed to submit their formal
offer of evidence within the required period, despite several extensions.

Trial court deemed their right to make a formal offer of evidence waived. Heirs
moved for the admission of their offer of evidence, but the trial court denied it. Trial
court granted the demurrer to evidence filed by the respondents and dismissed the
complaint. Heirs appealed to the Court of Appeals (CA), but the CA affirmed the trial
court's ruling.

Issue:

Whether the alleged gross negligence of the heirs' counsel deprived them of due
process.

Whether the dismissal of the complaint instead of remanding the case for further
proceedings was proper.

Ruling:

The petition had no merit. Heirs waived their right to make a formal offer of
evidence by failing to comply with court orders and delaying the submission of the offer.
Importance of a formal offer of evidence in ensuring a fair and efficient trial process.
Dismissal of the complaint on a demurrer to evidence was proper.

Heirs failed to sufficiently prove their allegations. Allegation of fraud by Severino

was not supported by concrete evidence. Testimony of one of the heirs contradicted
their claim that the estate was never partitioned among the heirs. Supreme Court
affirmed the dismissal of the complaint.
Heirs waived their right to make a formal offer of evidence by failing to comply with court
orders and delaying the submission of the offer. This is important in ensuring a fair and
efficient trial process.

Dismissal of the complaint on a demurrer to evidence was proper because the heirs
failed to sufficiently prove their allegations. Allegation of fraud by Severino was not
supported by concrete evidence and the testimony of one of the heirs contradicted their
claim that the estate was never partitioned among the heirs.

Compliance with court orders and the need for concrete evidence to support allegations
of fraud are emphasized.
5. Republic of the Philippines vs. De Borja

Summary:

The Republic of the Philippines files a complaint for the recovery of ill-gotten
assets allegedly amassed by the individual respondents during the administration of
President Ferdinand Marcos, but fails to present sufficient evidence to prove the liability
of respondent Alfredo De Borja, resulting in the granting of his Demurrer to Evidence.

Facts:

Complaint filed by the Republic of the Philippines for the recovery of ill-gotten
assets allegedly amassed by the individual respondents during the administration of
President Ferdinand Marcos. Specific respondent in this case is Alfredo R. De Borja.
Complaint filed before the Sandiganbayan (SB) and sought "Accounting, Reconveyance,
Forfeiture, Restitution, and Damages”. Allegations that De Borja collected address
commissions on behalf of Geronimo Z. Velasco, President and Chairman of the Board of
Directors of the Philippine National Oil Company (PNOC). Instead of remitting the address
commissions to PNOC, Velasco instructed that they be remitted to Decision Research
Management Company (DRMC), a defendant corporation in the case. Republic claimed
that De Borja acted as Velasco's dummy, nominee, and/or agent for corporations he
owned and/or controlled, such as DRMC.

Issue:

Whether the evidence presented by the Republic is sufficient to prove De Borja's

liability.

Ruling:

The Supreme Court affirmed the Sandiganbayan's decision to grant De Borja's

Demurrer to Evidence.

A demurrer to evidence is a motion to dismiss on the ground of insufficiency of evidence.

The question in a demurrer to evidence is whether the plaintiff has been able to establish
a prima facie case. The Court defers to the factual findings of the trial court and is not a
trier of facts. The evidence presented by the Republic was insufficient to prove De
Borja's liability. The only evidence presented against De Borja was the testimony of a
witness, Epifanio F. Verano, and the affidavit of another witness, Jose M. Reyes.

Verano's testimony was found to be insufficient as he did not know the contents of the
envelopes he claimed to have delivered to De Borja and did not confirm whether De Borja
actually received them. Reyes' affidavit was deemed inadmissible as hearsay due to his
untimely demise. The Republic failed to show any right to the relief sought and therefore,
the Demurrer to Evidence was properly granted.
6. Basbas vs. Sayson

Summary:

A petition for the revival of a judgment in a land registration case is contested by

the petitioners, who seek to prevent the enforcement of a previous decision rendered in
favor of the respondents more than two decades ago

Facts:

The case involves a petition for the revival of a judgment in a land registration
case. The petitioners, Eugenio Basbas and others, seek to prevent the revival of a
judgment rendered in favor of the respondents, Beata Sayson and Roberto Sayson, more
than two decades ago.

On September 2, 1976, Beata Sayson and her husband Roberto Sayson filed a
Petition for Registration of an agricultural land located in Leyte. The application was
opposed by the petitioners.

On March 22, 1979, the Court of First Instance (CFI) rendered a decision in favor of
the Saysons, adjudicating the land to them and approving its registration under their
names. The decision was affirmed by the Court of Appeals (CA) in 1985 and became final
and executory. However, the writ of possession was never implemented due to the
refusal of the petitioners to vacate the property. In 1989, a relocation survey was
conducted, and the RTC ordered the petitioners to vacate the property. owever, this
order was not implemented within the five-year period.

In 1995, the respondents filed a complaint for the revival of judgment, seeking to
enforce the previous decision and order. The petitioners filed a motion to dismiss, but it
was denied. They then filed an answer with counterclaim, admitting most of the
allegations in the complaint but denying that the respondents were the proper parties
and that the complaint stated a cause of action. The RTC granted the respondents'
motion for judgment on the pleadings and/or summary judgment, ordering the revival of
the previous judgment and the issuance of a writ of possession.

The petitioners appealed to the CA, but their appeal was denied. They then filed a
petition for review on certiorari before the Supreme Court.

Issue:

Whether a summary judgment is appropriate in this case.

Whether the complaint states a cause of action.

Ruling:

The Supreme Court ruled in favor of the respondents, affirming the decision of the
CA.

The Court held that a summary judgment is appropriate in this case because the issues
raised by the petitioners are not genuine issues and can be resolved based on the facts
established by the pleadings. The Court also held that the complaint states a cause of
action because it seeks the enforcement of a judgment and the order of the RTC is part
of the process to enforce that judgment. The Court further held that any perceived defect
in the special power of attorney executed by Beata Sayson is not a bar to the case
proceeding because Roberto Sayson, as a co-owner of the property, can bring the action
on behalf of himself and his mother.
7. Iloilo Jar Corp. vs. Comglasco Corp.

Summary:

The Supreme Court ruled in favor of Iloilo Jar Corporation in a civil action for
breach of contract and damages against Comglasco Corporation/Aguila Glass, ordering
Comglasco to pay unpaid rentals and clarifying that Article 1267 of the Civil Code does
not apply to lease contracts.

Facts:

Iloilo Jar Corporation (Iloilo Jar) and Comglasco Corporation/Aguila Glass

(Comglasco) entered into a lease contract for a warehouse building in Iloilo City on
August 16, 2000. The lease was for a period of three years.

On December 1, 2001, Comglasco requested for the pre-termination of the lease,

which Iloilo Jar rejected. Despite the rejection, Comglasco removed all its stock,
merchandise, and equipment from the leased premises and stopped paying rent. Iloilo
Jar sent demand letters, but Comglasco ignored them. As a result, Iloilo Jar filed a civil
action for breach of contract and damages.

Issue:

Whether or not a defense raised in the answer that is not applicable to the case
can be considered as appropriately tendering an issue that needs to be tried by the trial
court.

Whether or not a judgment on the pleadings is appropriate and valid when the
defense interposed by the defendant in the answer is not applicable as a defense to the
cause of action stated in the complaint.

Rulings:

The Supreme Court ruled in favor of Iloilo Jar. The Court held that Comglasco's
defense, which relied on Article 1267 of the Civil Code, was not applicable to lease
contracts. Article 1267 applies to obligations to do, not obligations to give, which
includes the obligation to pay rent in a lease contract. The Court also noted that the
economic crisis was not an absolute exceptional change of circumstances that would
justify relief from contractual obligations. Therefore, Comglasco was ordered to pay the
unpaid rentals. However, the Court modified the award of damages and interest rate.

The Court ruled that judgment on the pleadings was improper because Comglasco's
answer raised an affirmative defense. Although a full-blown trial was not necessary,
summary judgment could have been granted since no genuine issue for trial was raised.
The Court also clarified that Article 1267 of the Civil Code does not apply to lease
contracts. The Court emphasized that financial difficulties due to an economic crisis are
not enough reason to be relieved from contractual obligations. The Court further
admonished Iloilo Jar's counsel for repeatedly failing to comply with the rules of
procedure.