Chapter I: The Case for Law

▪ Pio Duran v. Salvador Abad Santos (GR No. L-99, Nov. 16, 1945)
Fact/s: Issue/s:

Pio Duran, a Filipino political prisoner detained for over three

months without formal charges, petitioned the People’s Court
for bail. The Solicitor General recommended provisional bail 1. Whether the detainee’s right to bail
of P35,000, while Special Prosecutor V. D. Carpio, citing was unconstitutionally denied.
confidentiality, discussed Duran's known actions during the 2. Whether Section 19 of
Japanese occupation. Judge Salvador Abad Santos denied the Commonwealth Act No. 682 grants
bail petition due to the severity of the charges, which could the People’s Court discretion to
result in capital punishment. Duran then challenged this deny bail to political detainees
denial in the Supreme Court, arguing it violated the Philippine unconditionally.
Constitution and Commonwealth Act No. 682, which allows
bail for political prisoners.

Rulings:

The Supreme Court ruled that the People’s Court did not violate Duran’s right to bail. Citing Section 19
of Commonwealth Act No. 682, the Court noted that bail is discretionary unless strong evidence
suggests a capital offense. In Duran’s case, the Special Prosecutor’s account of serious offenses
indicated that capital punishment might apply, justifying the denial of bail. The Court confirmed that
while political prisoners may be granted bail, the People’s Court had discretion to deny it if evidence of
a capital offense was strong.

Doctrine:
The Supreme Court ruled that the People’s Court did not violate Duran’s right to bail. Citing Section 19
of Commonwealth Act No. 682, the Court noted that bail is discretionary unless strong evidence
suggests a capital offense. In Duran’s case, the Special Prosecutor’s account of serious offenses
indicated that capital punishment might apply, justifying the denial of bail. The Court confirmed that
while political prisoners may be granted bail, the People’s Court had discretion to deny it if evidence of
a capital offense was strong.

Dissenting Opinion:

Perfecto - The petitioner is being detained without due process, violating the Philippine Constitution’s
Bill of Rights, as no charges have been filed. His detention lacks legal authorization, entitling him to
immediate, unconditional release. His offer to post bail strengthens his case. Section 19 of
Commonwealth Act No. 682 requires the People’s Court to grant bail unless strong evidence of a
capital offense is presented. Mere statements by the prosecutor do not constitute evidence. Without
such evidence, the court should grant bail according to established Supreme Court doctrines. Denying
bail without evidence contravenes both the Philippine Constitution and the United Nations Charter.
Chapter II: Legal and Philosophical Issues
▪ Felixberto C. Sta Maria v. Salvador P. Lopez, et al. GR No. L-30773, Feb. 18, 1970
Fact/s: Issue/s:

Felixberto C. Sta. Maria, appointed Dean of the College of

1. Whether Sta. Maria’s transfer
Education at the University of the Philippines on May 16,
constituted a removal which required
1967, faced disruption in early 1969 due to student
due process of law.
dissatisfaction with the college’s program and facilities. After
2. Whether the conditions under
failed negotiations, students boycotted classes and demanded
which Sta. Maria was transferred met
his resignation, leading to a campus-wide shutdown on July
the requirements for security of
23, 1969. President Lopez transferred Sta. Maria to a Special
tenure.
Assistant role, and Nemesio R. Ceralde was appointed acting
3. Whether the transfer was
Dean. Sta. Maria contested his removal as unjust and
conducted in the interest of the
unconstitutional and, after exhausting administrative
service and thus justified without prior
remedies, filed a petition for certiorari, prohibition, and
hearing.
mandamus with the Supreme Court.

Rulings:

The Court ruled that Sta. Maria’s transfer effectively constituted a removal, requiring due process
protections. The employment contract's ambiguous term did not permit removal without cause or due
process. The Court affirmed that Sta. Maria, with a fixed term, could not be removed without proper
cause and investigation. Procedural irregularities in his transfer highlighted due process deficiencies.
The Court also rejected the claim that the transfer was in the “interest of the service,” stating that
emergencies do not bypass procedural rules or constitutional rights.

Doctrine:
The Court reiterated the principle that security of tenure is a constitutional right for public officials and
employees. A public official with a fixed term may only be removed for cause and after due process,
which includes notice, hearing, and investigation. The decision highlighted that administrative actions,
even under emergent situations, must conform strictly to procedural due process requirements.

Concurring and Dissenting Opinion:

Barredo - Before concluding, I want to stress that the support for the respondents’ position is not
meant to condone or encourage mob rule. The focus should be on whether the students’ demands had
a substantial basis to justify university actions within constitutional and educational principles. The
urgency of addressing student unrest should not overshadow the need for a solid basis in their
demands. The university must act legally and appropriately to address issues, whether or not there is
student unrest, ensuring fair and permanent solutions.
Chapter II: Legal and Philosophical Issues
▪ ▪ Jorge B. Vargas v. Emilio Rilloraza, et al. (GR No. L-1612, Feb. 26, 1948)
Fact/s: Issue/s:
During the Japanese occupation, Jorge B. Vargas served as 1. Does Section 14 of Commonwealth
Chairman of the Executive Commission and later in the Act No. 682, which disqualifies certain
puppet Philippine Republic. After liberation, Commonwealth Supreme Court Justices from presiding
Act No. 682 was enacted to try collaborators, disqualifying over specific cases involving alleged
any Supreme Court Justice who served under the Japanese collaborators, violate the Philippine
from handling such cases. Vargas, facing trial as a Constitution?
collaborator, challenged the constitutionality of Section 14 of 2. Can Congress enact legislation that
this Act, arguing it imposed new qualifications, created an effectively changes the composition of
alternate Supreme Court, and violated constitutional the Supreme Court temporarily by
principles. appointing judges without Presidential
appointment and without the consent
of the Commission on Appointments?
3. Does Section 14 of the People’s
Court Act infringe upon the
independence of the judiciary and the
constitutional provisions requiring
judges to serve during good behavior
until a set age?
Rulings:
The Supreme Court ruled Section 14 unconstitutional for adding new disqualifications for Supreme
Court Justices not outlined in the Constitution, undermining judicial independence. It also found the
section invalid for allowing judges not appointed and confirmed by the President to serve, violating
constitutional appointment procedures. Additionally, Section 14 infringed on judicial independence
and separation of powers by enabling Congress to alter the Supreme Court’s composition, breaching
the principle that Justices should remain in office based on good behavior, without Congressional
interference.
Doctrine:
**Judicial Independence and Separation of Powers:** The case reiterates that legislative measures
cannot alter the composition or disqualifications of Justices provided under the Constitution. The
judiciary must remain an independent branch, free from undue influence by the legislature.
– **Strict Interpretation of Constitutional Qualifications for Justices:** Any additions to the
qualifications or disqualifications of Supreme Court Justices must strictly follow the Constitution’s
explicit provisions, which outline the necessary criteria and appointment procedures.

No Concurring and Dissenting Opinion:

Chapter II: Legal and Philosophical Issues
▪ Jose Jesus M. Disini, Jr., et al. v. The Secretary of Justice,et (GR No. 203335, Feb. 11, 2014)
al.
Fact/s: Issue/s:
Petitions were filed with the Philippine Supreme Court 1. Whether specific provisions of R.A.
challenging the constitutionality of Republic Act 10175, the 10175 infringe upon the constitutional
Cybercrime Prevention Act of 2012. Internet users, rights to freedom of expression, due
journalists, and lawmakers argued that the Act violated free process, privacy, and equal protection.
speech, due process, equal protection, and privacy rights. The 2. Whether the law, in its entirety or
Act aimed to address online crimes but faced criticism for in specific questionable sections,
provisions that could suppress rights or lead to arbitrary suffers from overbreadth or
enforcement. Key concerns included illegal access, data vagueness, potentially chilling free
interference, online libel, and aiding cybercrimes. The speech or resulting in arbitrary
Supreme Court temporarily restrained the law’s enforcement.
implementation while deliberating its implications.

Rulings:
The Philippine Supreme Court ruled several provisions of R.A. 10175 unconstitutional, including those
on unsolicited commercial communications, real-time traffic data collection without court approval,
and DOJ authority to block computer data. It found Section 4(c)(4) on online libel partially
unconstitutional, applicable only to the original author, not those reacting to posts. The Court upheld
other sections targeting illegal access, data interference, cybersquatting, and child pornography,
balancing effective cybercrime control with constitutional rights to free speech and privacy.

Doctrine:
The decision reinforced the doctrine of striking a balance between addressing modern challenges
posed by cybercrimes and respecting constitutional rights, particularly freedom of expression and
privacy. It clarified the extent to which legislation could go in regulating online behavior without
overstepping constitutional boundaries.

Concurring and Dissenting Opinion:

J Sereno - However, I dissent from the ponencia’s upholding of Section 6 as not unconstitutional in all
its applications. I find Section 6 to be unconstitutional insofar as it applies to cyberlibel because of its
"chilling effect." Hence, I am writing this Separate Opinion also to explain my dissent on this issue.
Carpio - I dissent, however, from the conclusion that (1) Article 354 of the Revised Penal Code (Code)
creating the presumption of malice in defamatory imputations, and (2) Section 4(c)(1) of RA 10175
penalizing "cybersex," are not equally violative of the constitutional guarantees of freedom of speech
and expression. I therefore vote to declare Article 354 of the Code, as far as it applies to public officers
and public figures, and Section 4(c)(1) of RA 10175, unconstitutional for violating Section 4, Article III of
the Constitution.
J. Brion – Concurred with both dissenting opinion of Sereno and Carpio
Chapter II: Legal and Philosophical Issues
▪ Cheryll Santos Leus v. St. Scholastica’s College Westgrove (GR No. 187226, Jan. 28, 2015)
Fact/s: Issue/s:
Cheryll Santos Leus, employed by St. Scholastica’s College 1. Whether the 1992 MRPS applies
Westgrove since May 2001, was asked to resign in 2003 after over the Labor Code regarding
becoming pregnant out of wedlock. The school, citing termination of employment in private
misconduct and the 1992 Manual of Regulations for Private educational institutions.
Schools, deemed her conduct disgraceful. Despite her 2. Whether pregnancy out of wedlock
subsequent marriage, SSCW terminated her employment. constitutes valid grounds for
Leus contested the dismissal as illegal, but the Labor Arbiter, termination of employment.
NLRC, and CA upheld the termination, finding valid grounds
for dismissal.

Rulings:
The Supreme Court overturned the CA's decision, ruling that Leus was illegally dismissed. It found that
the 1992 MRPS was improperly challenged late in the proceedings and that Leus’s pre-marital
pregnancy did not meet the standards of “disgraceful or immoral conduct” based on secular morality.
The Court criticized the labor tribunals and CA for failing to demand substantial evidence of Leus's
conduct harming the institution. It deemed SSCW's dismissal invalid and ordered full backwages and
attorney’s fees for Leus, opting against reinstatement due to impracticality.

Doctrine:
The Supreme Court reiterated the doctrine that in cases of illegal dismissal, when reinstatement is no
longer viable due to strained relationships, separation pay in lieu of reinstatement is appropriate. It
emphasized the principle of secular morality in employment, differentiating it from religious tenets,
and underscored that the burden of proof in dismissal cases lies with the employer.

Concurring and Dissenting Opinion:

Chapter II: Legal and Philosophical Issues
▪ Ferdinand R. Villanueva v. Judicial and Bar Council (GR No. 211833, April 7, 2015)
Fact/s: Issue/s:
Judge Ferdinand R. Villanueva, appointed as Presiding Judge
of the Municipal Circuit Trial Court in 2012, applied for 1. Whether the JBC’s policy requiring
Regional Trial Court (RTC) positions in 2013 but was excluded five years of service as judges of first-
due to a Judicial and Bar Council (JBC) policy requiring five level courts before qualification for
years of service in first-level courts. He contended that this second-level courts is constitutional.
requirement was unconstitutional. After his appeal to the JBC 2. Whether said policy violates the
was denied, Villanueva filed a petition with the Supreme equal protection, due process clauses,
Court challenging the policy’s constitutionality. and provisions under Social Justice
and Human Rights for Equal
Employment Opportunity of the
Constitution.
3. Whether the procedural remedies
sought by the petitioner were
appropriate in this context.

Rulings:
The Supreme Court dismissed the petition, affirming that the JBC’s five-year service policy was valid
and within its mandate to ensure judicial appointees are competent and independent. The Court found
the policy a rational classification that did not violate constitutional rights. It also ruled that the
remedies of prohibition, mandamus, certiorari, and declaratory relief were inappropriate for this issue.
However, the Court noted that the JBC’s policy should have been published due to its impact on
judicial candidates.

Doctrine:
The Supreme Court reiterates that the JBC has the prerogative to establish additional qualifications and
standards for judicial appointments beyond constitutional requirements as long as these are
reasonable, based on rational classification, and published accordingly.

Concurring and Dissenting Opinion:

Chapter II: Legal and Philosophical Issues
▪ Justa G. Guido v. Rural Progress Administration c/o
(GR No. L-2089, Oct. 31, 1949)
Faustino Aguilar
Fact/s: Issue/s:
Justa G. Guido owned two adjoining lots, totaling 22,655 1. Did the RPA act within its
square meters in Maypajo, Caloocan, Rizal. The Rural Progress jurisdiction and corporate powers in
Administration (RPA) sought to expropriate the land to filing the expropriation complaint and
subdivide and sell it under Commonwealth Act No. 539. Guido negotiating a loan?
challenged the expropriation, citing RPA’s lack of jurisdiction, 2. Is commercial land excluded from
the commercial nature of the land, the impact on existing the scope of the provisions of Act No.
tenant agreements, and inadequate valuation. After lower 539?
courts issued conflicting rulings, Guido petitioned the 3. Would the expropriation impair
Supreme Court to block the expropriation. existing contracts with tenants?
4. Was the provisional value of the
land correctly determined?

Rulings:
The Supreme Court addressed primarily whether the expropriation of commercial property falls within
the scope of Act No. 539. The opinion by Justice Tuason articulated:

The constitutional and statutory provisions focus on agrarian reform to redistribute large estates to
tenant-dwellers, not small urban commercial properties. The expropriation of Guido's land did not
fulfill the legal requirement for serving a public purpose or benefit, as it aimed to benefit a few tenants
without broader societal or economic advantages. Since expropriating commercial land does not align
with the constitutional mandate for addressing social inequities, the petition for prohibition was
granted, stopping the expropriation.

Doctrine:
1. **Public Use Doctrine in Expropriation:** Expropriation must serve a significant public benefit. Small
property expropriations benefiting limited private individuals without broader public interest are
unconstitutional.
2. **Social Justice and Agrarian Reforms:** Constitutional provisions for expropriation primarily
address large estates to alleviate agrarian issues, not minor urban properties.
3. **Restrictions on Governmental Expropriation Powers:** The government cannot expropriate
property merely to transfer its benefits to new private owners without clear public utility.
Concurring and Dissenting Opinion:
I fully agree with Justice Tuason's opinion. The Constitution's section 4 of Article XIII was not intended
to cover expropriation of private land by a government entity for resale on installments. Such an
interpretation would lead to problematic consequences. The framers intended the provision to address
historical land issues, not to allow government entities to expropriate and resell private land
indiscriminately. Without this restrictive interpretation, the government could engage in excessive land
acquisitions, leading to unintended socialism and undermining private initiative.
Chapter II: Legal and Philosophical Issues
▪ Pryce Corporation v. China Banking Corporation (GR No. 172302, Feb. 18, 2014)
Fact/s: Issue/s:
Pryce Corporation, incorporated on September 7, 1989, faced
financial distress from the 1997 Asian financial crisis, incurring whether the Court of Appeals erred in
significant losses. On July 12, 2004, it filed a petition with the denying the petition for rehabilitation
RTC for rehabilitation, seeking a receiver and a stay on claims. of petitioner Pryce Corporation.
The proposed plan included dacion en pago of assets to settle
debts, waiver of penalties, and other provisions for creditors.
Despite opposition from creditors, the RTC approved the plan
on January 17, 2005. The Court of Appeals later reversed this
decision, claiming it breached contractual obligations and
state policies.

Rulings:
Section 6 requires the petition to be "sufficient in form and substance." We concur with the Court of
Appeals that the rehabilitation petition fails to demonstrate a clear and imminent threat to the
petitioner’s corporate assets without a receiver. It does not meet the "serious situation test" from Rizal
Commercial Banking Corporation or show substantial compliance. Moreover, the RTC’s Stay Order
from July 13, 2004, does not indicate any serious threat to the petitioner’s assets.

Doctrine:
Rehabilitation requires serious prerequisites, including imminent danger of asset loss or business
paralysis and the need to protect creditors and parties involved. The stay order for rehabilitation is
issued only after these conditions are met and a management committee or receiver is appointed. In
this case, the commercial court appointed a receiver immediately after the petition was filed, raising
doubts about whether it had sufficient evidence to justify the appointment without holding a hearing.

Concurring and Dissenting Opinion:

Chapter II: Legal and Philosophical Issues

▪ SEC v. Interport Resources Corporation, et al. (GR No. 135808, Oct. 6, 2008)
Fact/s: Issue/s:
The case involves Interport Resources Corporation (IRC) and 1. Whether the absence of
its board allegedly failing to disclose material information implementing rules nullifies Sections
under the Revised Securities Act. On August 6, 1994, IRC’s 8, 30, and 36 of the Revised Securities
board approved a deal with Ganda Holdings Berhad (GHB) to Act.
acquire Ganda Energy Holdings, Inc. and invest in Philippine 2. The validity of the Court of Appeals’
Racing Club, Inc. This was announced on August 8, 1994. The injunction against the SEC preventing
SEC later alleged IRC’s non-disclosure of negotiations and actions against IRC and its directors.
insider trading. IRC contested the SEC’s authority and 3. The appropriateness of the
procedures, leading to an injunction by the Court of Appeals, procedural rules used by the SEC in its
which ruled against the SEC for due process violations. The investigations against IRC and its
SEC then appealed to the Supreme Court. officers.

Rulings:
The Supreme Court reversed the decision of the Court of Appeals, holding that the Revised Securities
Act’s Sections 8, 30, and 36 did not require implementing rules to be effective and binding. The lack of
implementing rules cannot invalidate provisions of law when a reasonable construction supporting the
law is possible. Furthermore, the Court clarified the investigation’s jurisdiction and procedures
concerning the SEC and Presidential Decree No. 902-A. The case was deemed to merit review,
correcting the Court of Appeals’ restrictions on the SEC’s authority to investigate violations related to
insider trading and disclosure requirements.
Doctrine:
The decision reiterates that statutory provisions, unless explicitly requiring implementing rules or
found to be vague, are binding and effective upon enactment. It underscores the principle that laws
are presumed valid and enforceable, and the absence of implementing rules does not render them
inoperative.

Dissenting Opinion:
Carpio - I dissent because the majority opinion contradicts Section 2 of Act No. 3326. The majority
incorrectly claims that the SEC’s administrative investigation interrupted the prescriptive period for
violations of the Securities Regulation Code. Section 2 specifies that the prescriptive period only pauses
with the institution of judicial, not administrative, proceedings. The SEC’s investigation alone does not
interrupt the prescriptive period, which has expired as no judicial proceedings were filed. Thus, I vote
to dismiss the petition.

Chapter II: Legal and Philosophical Issues

▪ Artemio Villareal v. People of the Philippines (GR No. 151258, Dec. 1, 2014)
Fact/s: Issue/s:
In February 1991, seven Ateneo de Manila University law 1. Whether the CA committed grave
freshmen were subjected to brutal hazing by the Aquila Legis abuse of discretion in dismissing the
Juris Fraternity. The severe physical and psychological abuse case against some respondents for
led to Leonardo “Lenny” Villa collapsing and dying despite violation of their right to speedy trial.
medical efforts. Criminal charges were filed against multiple 2. Whether the penalty imposed on
fraternity members. The Caloocan City RTC convicted many of some respondents should have been
homicide, but the Court of Appeals made distinctions, equivalent to that for intentional
convicting some and acquitting others. The Supreme Court felonies.
later modified the CA’s decision, finding primary respondents 3. Whether respondents who were
guilty of reckless imprudence resulting in homicide and granted probation and later
recommending changes to the Anti-Hazing Law. discharged had their criminal liability
already extinguished.

Rulings:
The Supreme Court upheld the Court of Appeals' dismissal of the case for speedy trial violations, ruling
there was no grave abuse of discretion. It also denied the Office of the Solicitor General’s request for
harsher penalties, emphasizing the distinction between intentional felonies and negligence.
Additionally, the SC nullified all probation proceedings for some respondents due to lack of jurisdiction
but stated that they, including Fidelito Dizon, can apply or reapply for probation under new guidelines.

Doctrine:
In cases of criminal liability due to fault or negligence (culpa) under Article 365 of the Revised Penal
Code, malicious intent is not required as it would be in intentional felonies or those committed by
means of deceit (dolo). The SC emphasizes the importance of distinguishing between dolo and culpa in
criminal liability and in the imposition of penalties.

Dissenting Opinion:

Chapter III: Theory of Law

▪ Republic of the Philippines v. Sandiganbayan (GR No. 104768, July 21, 2003)
Fact/s: Issue/s:
The case originated from the Presidential Commission on 1. Whether the PCGG had the
Good Government's (PCGG) efforts to recover ill-gotten jurisdiction to investigate and cause
wealth from former President Marcos and his associates. The the filing of a forfeiture petition
PCGG, established after the 1986 EDSA Revolution, against Ramas and Dimaano. 2. The
investigated Major General Josephus Q. Ramas for propriety of the Sandiganbayan’s
unexplained wealth. A raid on Elizabeth Dimaano’s residence dismissal of the case before the
led to the seizure of money and military equipment. The completion of the presentation of
PCGG filed a forfeiture petition under RA No. 1379 against evidence by the petitioner. 3. Legality
Ramas and Dimaano, but the Sandiganbayan dismissed the of the search and seizure conducted
case, citing jurisdictional issues and insufficient evidence. The on Dimaano’s residence.
Supreme Court then reviewed the case, focusing on the
PCGG’s jurisdiction and evidence admissibility.

Rulings:
The Supreme Court ruled that the PCGG lacked jurisdiction over Major General Ramas, as its mandate
was limited to recovering ill-gotten wealth from Marcos, his family, and those directly associated with
him, which was not proven in Ramas’s case. The Court upheld the Sandiganbayan’s dismissal, citing the
PCGG's failure to provide substantial evidence despite ample time. It also found that the search and
seizure at Dimaano’s residence exceeded the warrant's scope and ordered the return of improperly
seized items.

Doctrine:
The case reiterates the doctrine that the Presidential Commission on Good Government lacks
jurisdiction over military personnel, such as Major General Ramas, without directly establishing their
status as “subordinates” under the connotation of Executive Orders relevant to the commission’s
formation. Additionally, it upheld principles regarding the limits of search and seizure operations,
emphasizing adherence to the scope specified by judicial warrants.

Concurring and Dissenting Opinion:

Chapter III: Theory of Law

▪ William F. Peralta v. The Directors of Prisons (GR No. L-49, Nov. 12, 1945)
Fact/s: Issue/s:
William F. Peralta, a member of the Metropolitan 1. **Validity of the Court of Special
Constabulary, was convicted of robbery and sentenced to life and Exclusive Criminal Jurisdiction and
imprisonment by the Court of Special and Exclusive Criminal the Summary Procedure:** Was the
Jurisdiction in Japanese-occupied Philippines. This court, creation of these courts and the
established under Japanese rule with limited procedural procedures they followed valid under
rights, did not allow appeals except for death penalty cases. international and national law?
Peralta challenged his conviction through a habeas corpus 2. **Constitutional Rights and
petition, claiming the court was illegitimate and violated Legislative Acts:** Were the
constitutional rights. The Solicitor General supported this enactments of these courts and the
claim, while the City Fiscal argued that the court's creation specific legal processes they followed
and procedures were valid under the circumstances. validly formed, or were they in
violation of the Commonwealth’s
constitutional protections?
3. **Effect of Reoccupation and
Restoration:** With the reoccupation
by Allied forces and the restoration of
the Commonwealth Government, did
prior judgments from occupation
courts retain any validity?

Rulings:
The Supreme Court upheld the validity of courts created by the Japanese-occupied government, noting
they were a de facto government allowed to maintain order. However, it found that the court's
procedures violated constitutional rights, including due process and fair trial standards. Under the
principle of postliminium, which nullifies laws and sentences from occupying powers once a country is
reoccupied, Peralta’s sentence was deemed void following the Philippines' liberation and restoration of
the Commonwealth.

Doctrine:
– **De Facto Government:** The nature and legal powers of a de facto government established by a
belligerent occupant to administer occupied territory, including the creation of courts and alteration of
laws within the limits set by international law and military necessity.
– **Constitutional Rights:** Occupation-period laws that infringe on constitutional rights, especially
through unfair trial processes, lack long-term validity once legitimate government is restored.
– **Principle of Postliminium:** Legal nullification of all political acts created under a de facto
government upon reoccupation and restoration of legitimate sovereignty.
Concurring and Dissenting Opinion:

Chapter III: Theory of Law

▪ Alejandro Estrada v. Soledad Escritor (GR No. AM No. P-02-1651, August 4,
 2003)
Fact/s: Issue/s:
Alejandro Estrada filed a complaint against Soledad S. 1. **Primary Legal Issue:**
Escritor, alleging she was living with Luciano Quilapio, Jr., – Whether respondent Escritor should
outside of marriage. Judge Jose F. Caoibes, Jr. referred the be found guilty of “gross and immoral
complaint to Escritor, who denied the allegations and conduct” under civil service law.
requested Caoibes' recusal. At a preliminary conference, 2. **Sub-Issue of Constitutional
Escritor admitted her live-in relationship, which was Import:**
recognized by her Jehovah’s Witnesses faith. The complaint – Whether Escritor’s right to religious
was reviewed by Executive Judge Manuel B. Fernandez, Jr., freedom should exempt her from
and then by Judge Bonifacio Sanz Maceda, who found administrative liability for an illicit
Escritor’s claims credible and recommended dismissal based relationship, as her conjugal
on religious freedom. The Office of the Court Administrator arrangement is recognized and
agreed but found Escritor guilty of immorality due to her sanctioned by the religious practices
relationship with a married man. of Jehovah’s Witnesses.

Rulings:
The Supreme Court concluded that while the state’s interest in maintaining moral integrity among its
employees is compelling, Escritor’s religious freedom as a Jehovah’s Witness to live with Quilapio
under the “Declaration of Pledging Faithfulness” should prevail. Hence, she was exempted from
administrative liability for gross and immoral conduct.

Doctrine:
1. **Religious Freedom:**
– The state must accommodate religious beliefs and practices unless there is a compelling state
interest to override them, rooted in Sherbert v. Verner and refined in Employment Division v. Smith,
although the latter’s restrictions were sidestepped in this decision due to the religious context.
2. **Balancing Test:**
– Applying strict scrutiny, the state must show a paramount interest for limiting religious freedom and
demonstrate that no less restrictive means would suffice to achieve the state’s objective.
Dissenting Opinion:
Ynares-Santiago - ACCORDINGLY, I vote that respondent Soledad S. Escritor be found GUILTY of
immorality and disgraceful conduct and that she be SUSPENDED for a period of Six (6) months and One
day without pay, with a warning that the continuance of her illicit cohabitation with Luciano D.
Quilapio, Jr. shall be deemed a second offense which shall warrant the imposition of the appropriate
penalty.
Carpio - Penalizing Escritor for cohabiting with Quilapio, whom she considers her husband, seems
overly harsh, especially since no third party has been harmed. Instead of imposing a penalty, the issue
should be addressed by the legislature. I vote to suspend Escritor for six months and one day without
pay for conduct prejudicial to the service, with suspension lifting upon her cessation of cohabitation
with Quilapio. Continued cohabitation during or after the suspension, while Quilapio remains married,
will result in dismissal.
Chapter III: Theory of Law
▪ Joel G. Miranda v. Antonio M. Abaya and the Commission (G.R. No. 136351, July 28, 1999)
on Elections
Fact/s: Issue/s:
Involved parties are Joel G. Miranda and Antonio M. Abaya, 1. Jurisdiction and Abuse of
with the COMELEC as a respondent. On March 24, 1998, Discretion: Whether the
incumbent mayor Jose Miranda filed for re-election. Abaya's annulment of Joel Miranda's
petition to cancel Miranda's candidacy, citing term limits, was substitution and proclamation was
granted by COMELEC on May 5, 1998. Joel Miranda then issued without jurisdiction or with
substituted his father’s candidacy and won the election. grave abuse of discretion
Abaya contested the substitution on May 13, 1998, but the amounting to lack of jurisdiction.
COMELEC First Division initially dismissed his petition. The 2. Proclamation Order: Whether the
COMELEC En Banc later annulled Joel Miranda’s substitution. order of the COMELEC directing
Joel filed a petition with the Supreme Court, which issued a the proclamation of Antonio
temporary restraining order on December 11, 1998. Abaya was issued with grave
abuse of discretion amounting to
lack of jurisdiction.

Rulings:
The Supreme Court ruled that under Section 77 of the Omnibus Election Code, only a candidate from a
registered party can be substituted, making Jose Miranda ineligible for substitution after his certificate
of candidacy was canceled. A canceled certificate invalidates a candidacy. Certificates of candidacy are
essential for voter clarity. The COMELEC’s decision to annul Joel Miranda’s election was correct. The
COMELEC erred by reconvening the board of canvassers and should have followed succession laws,
which dictate that the vice mayor assumes the mayor’s position if vacant.

Doctrine:

Dissenting Opinion:
Romero (Puno and Vitug concurring with this opinion) - I disagree with the ruling that the private
respondent should be declared the Mayor of Santiago City from the May 11, 1998 elections. Joel G.
Miranda received the most votes, leading by 1,666 votes, and is thus entitled to serve as mayor. Even if
Jose Miranda were disqualified, the second-highest vote-getter cannot claim the office vacated by the
disqualified candidate. The petition should be granted, the COMELEC En Banc’s decision reversed, and
the First Division’s resolution reinstated.
Panganiban - While the Comelec Resolution may be imperfect and even confusing, such issues should
not undermine the will of the electorate. It is crucial that the Court resolves these matters in a way that
honors the people's choices, as upholding electoral decisions reflects sound public policy. The Court
should interpret election laws liberally to fully respect the voters' will. In Loong v. Comelec, the Court
emphasized that the people's sovereignty should not be disregarded through a literal interpretation of
the law. As stated in Frivaldo v. Comelec, prioritizing the people's choice over complex legalities is
essential. Imposing an unvoted candidate on the electorate undermines their democratic rights.
Chapter III: Theory of Law
▪ Co Kim Cham v. Eusebio Valdez Tan Keh and Arsenio P.
((GR No. L-5, Sept. 17, 1945)
Dizon
Fact/s: Issue/s:
The case of Co Kim Cham vs. Eusebio Valdez Tan Keh and 1. **Validity of Judicial Proceedings
Arsenio P. Dizon involves a petition to mandate the During Occupation:**
continuation of judicial proceedings started during the – Whether the judicial acts and
Japanese occupation. On January 2, 1942, Japanese forces proceedings under the Philippine
occupied Manila, and the next day, a military administration Executive Commission and the
was declared, maintaining Commonwealth laws and officials Republic of the Philippines were valid
temporarily. The Philippine Executive Commission was during the Japanese occupation and
established on January 23, 1942, with Jorge B. Vargas as remained valid post-liberation.
Chairman, continuing judicial functions. On October 14, 1943, 2. **Effect of General MacArthur’s
the Japanese created the Republic of the Philippines, Proclamation:**
maintaining the existing judicial system. After General – Whether MacArthur’s October 1944
Douglas MacArthur's October 23, 1944, proclamation, which proclamation invalidated all
declared the Commonwealth government as the sole judgments and judicial acts of the
legitimate authority and nullified wartime laws, the wartime courts.
Commonwealth was restored on February 27, 1945. Co Kim 3. **Jurisdiction Post-Liberation:**
Cham petitioned the Supreme Court to compel Judge Arsenio – If judicial acts were valid, whether
P. Dizon to resume hearings for a case filed during the the current Commonwealth courts
occupation. Judge Dizon refused, citing the proclamation and have jurisdiction to continue
questioning the legitimacy of wartime courts. proceedings pending during the
Japanese occupation without enabling
legislation.

Rulings:
First Issue: Validity of Judicial Proceedings During Occupation: The Court upheld that under
international law, judicial acts by de facto governments are valid unless inherently political. Both the
Philippine Executive Commission and the Republic of the Philippines, as de facto entities under
Japanese military control, had valid judicial acts.
Second Issue: Effect of General MacArthur’s Proclamation: The Court determined that MacArthur’s
proclamation, which referred to “processes,” did not nullify judicial acts but aimed to annul
administrative and legislative acts. Judicial processes remained intact, respecting international law.
Third Issue: Jurisdiction Post-Liberation: The Court ruled that Commonwealth courts, continuing from
before and during the occupation, maintain jurisdiction over pending cases and can resume
proceedings without new legislation, following the principle of postliminy.

Doctrine:
– The ruling reaffirmed the principle of **postliminy** under international law: judicial acts of de facto
governments during military occupation remain valid post-reoccupation by the legitimate sovereign
unless explicitly political.
– The decision emphasized **continuity of jurisdiction**: reinstated courts can resume pending
proceedings from occupation-era courts, ensuring legal consistency and preventing judicial chaos.
Dissenting Opinion:
Hilado -I dissent from the majority opinion and will explain my reasons. The case was initiated on
November 18, 1944, with a complaint in civil case No. 3012 filed in the Court of First Instance of
Manila. The record was destroyed during the Manila battle, and the case had not been heard on its
merits. Judge Dizon, in his June 6, 1945 order, ruled that all wartime laws and proceedings were void
following General MacArthur's proclamation. I believe the petition should be denied for several
reasons: the proceedings are invalid under MacArthur’s proclamation, the wartime government and its
courts were not de facto entities, and the Commonwealth government is not bound by acts of the
Japanese-sponsored governments. Practical considerations also support denying the petition.

Perfecto - General MacArthur had full authority to issue the October Proclamation, which aligns with
international law and corrects the actions of the Japanese military regime. The proclamation, which
nullified all laws and processes of the Japanese-sponsored governments, was consistent with U.S. and
Philippine policies and aimed to address wrongs committed by Japan. The term "all processes" clearly
includes judicial procedures, and we must adhere to the plain meaning of MacArthur’s statement.
Consequently, the judicial proceedings under the Japanese regime are invalid, and the Commonwealth
courts have no jurisdiction without specific enabling legislation. The petition should be denied, as the
majority's approach misinterprets international law and the proclamation, potentially undermining
legal principles and stability.

Chapter III: Theory of Law

▪ Teodoro Regala, et al. v. Sandiganbayan ((GR No. 105938, Sept. 20, 1996)
Fact/s: Issue/s:
Petitioners Teodoro Regala, Edgardo Angara, Avelino Cruz, The Honorable Sandiganbayan erred
Jose Concepcion, Rogelio Vinluan, Victor Lazatin, Eduardo by applying strict agency law to
Escueta, Paraja Hayudini, and respondent Raul Roco were petitioners' ACCRA lawyers, who acted
partners at ACCRA Law Firm. They provided legal services, as nominee-stockholders. It also
including organizing and acquiring companies, often acting as abused its discretion by not
incorporators or stockholders. ACCRA lawyers were involved recognizing that attorney-client
in setting up companies in Civil Case No. 0033, using coconut privilege protects the identity of
levy funds to establish corporations like UCPB and San Miguel. clients and certain documents from
Petitioners argue they are being prosecuted for activities as disclosure to the PCGG. The revelation
lawyers and are being pressured to disclose client identities. of a client's identity and documents
like deeds of assignment, which are
evidence of a nominee role, are not
covered by attorney-client
confidentiality in this case.
Rulings:
The Supreme court held in favor of Petitioner. Canon 17 of the Code of Professional Responsibility
requires lawyers to be faithful to their clients and maintain their trust, while Canon 15 of the Canons of
Professional Ethics also demands loyalty. However, there are important exceptions to this general rule.
In this case, the payment by clients to the government, acknowledging potential past tax deficiencies,
is linked to a possible criminal investigation. The clients' guilt and the circumstances surrounding their
payments make it crucial to uphold the lawyers' right to confidentiality. Revealing client identities and
documents could lead to criminal charges against the clients and expose the lawyers to litigation.
Therefore, the order for the lawyers to disclose client identities and documents should be annulled and
set aside.
Doctrine:
–

Dissenting Opinion:
Davide (CJ Narvasa, Regalado)- At this stage, petitioners have not demonstrated that they fall within
exceptions to the American jurisprudence rule on lawyer-client privilege. They will have the
opportunity to establish this at trial. Their request for exclusion is understandable but premature.
Lawyer-client privilege does not protect disclosure of a client's identity when both lawyer and client
conspire in committing a crime or fraud. Under Philippine law, lawyers are bound by ethical standards
to act within the law. Therefore, I vote to deny the petition for lack of merit.
Puno- In the Baird case, the facts were clear, but in this case, there is no evidence about the
consultation’s subject matter, nor proof that it involved criminal activity, aside from unsubstantiated
allegations. The majority ruling unfairly implies that revealing the client’s identity would link them to a
crime, which is unjust to both the petitioners, respected lawyers, and their client. The attorney-client
privilege issue should be resolved first, and there is no need to address the equal protection claim at
this stage. Therefore, I respectfully dissent from the majority opinion.
Chapter III: Theory of Law
▪ Cipriano P. Primicias v. Valeriano Fugoso (GR No. L-1800, Jan. 27, 1948)
Fact/s: Issue/s:
Cipriano P. Primicias, General Campaign Manager of the 1. Does the denial of a permit for
Coalesced Minority Parties, sought a permit from Manila holding a public meeting at Plaza
Mayor Valeriano E. Fugoso to hold a public meeting at Plaza Miranda by the Mayor of Manila
Miranda for redress of grievances. The permit, initially infringe upon the fundamental rights
granted by Vice Mayor Cesar Miraflor, was revoked by Mayor to freedom of speech, peaceful
Fugoso due to concerns about potential disturbances amid assembly, and petitioning the
high political tensions. Primicias argued this denial violated government for redress of grievances
his constitutional rights to freedom of speech, peaceful under the Philippine Constitution?
assembly, and petitioning the government. The issue was 2. Can the Mayor of Manila, under the
raised to the Supreme Court through a petition for mandamus delegated police power and existing
to compel the Mayor to issue the permit. ordinances, refuse to grant a permit
for a public assembly on grounds of
maintaining public order and safety?
Rulings:
The Supreme Court supported Primicias, affirming that the right to peaceful assembly for redress of
grievances is fundamental under the Philippine Constitution, though not absolute. It must be regulated
to avoid infringing on others' rights or public welfare. The Court found that the Mayor could not
arbitrarily deny the permit but could regulate the assembly’s time, place, and manner to maintain
public order. Revoking the permit on speculative grounds, without concrete evidence, improperly
infringed upon Primicias’s constitutional rights. The Court issued a writ of mandamus, requiring the
Mayor to issue the permit without violating constitutional rights.
Doctrine:
The Philippine Supreme Court reiterated the doctrine that the exercise of the fundamental rights to
freedom of speech, peaceful assembly, and petition for redress of grievances is subject to regulation in
a manner that does not abridge these rights. The regulation must be content-neutral, narrowly tailored
to serve a significant governmental interest, and leave open ample alternative channels for
communication.
Dissenting Opinion:
Hilado - The respondent mayor cited several reasons justifying his revocation of the permit,
emphasizing concerns about public peace and order. He argued that tensions were still high following
the recent elections and that the proposed rally, reported as an "indignation rally," could incite unrest,
especially with a diverse crowd of political factions. The mayor stressed that the revocation was not an
outright denial but a postponement until the official election results were announced, citing his duty to
maintain peace. He believed these reasons provided sufficient legal grounds for his decision.
Tuason-The mayor argued that revoking the rally permit was justified based on potential risks to public
order. He cited reports of lingering political tensions and possible violence if people with differing
views attended the event. He stressed that the revocation was a temporary postponement until after
the election results were officially announced. The mayor believed this decision was within his legal
discretion, grounded in maintaining peace and safety. He also emphasized that personal rights, like
free speech and assembly, must be balanced against public order and safety regulations.
Chapter III: Theory of Law
▪ Joseph Ejercito Estrada v. Sandiganbayan GR No. 148560, Nov. 19, 2001
Fact/s: Issue/s:
Joseph Ejercito Estrada, then President of the Philippines, was 1. Whether RA 7080 is
charged with Plunder under RA 7080, as amended by RA unconstitutional for being vague and
7659, and other corruption-related crimes. On April 4, 2001, thus violates an accused’s right to due
the Office of the Ombudsman filed charges before the process and to be informed of the
Sandiganbayan, accusing Estrada of amassing over P4 billion accusation against them.
in ill-gotten wealth through bribery, misappropriation of 2. Whether RA 7080 violates due
public funds, and improper investments. The Plunder Law process by requiring less evidence to
penalizes public officials who illicitly acquire at least P50 prove the predicate crimes that
million with life imprisonment or death. Estrada challenged establish the act of plunder.
the law's constitutionality, citing vagueness and issues with 3. Whether plunder, as defined in RA
proof standards and crime classification. 7080, is a malum prohibitum and, if
so, if Congress has the power to
classify it as such.

Rulings:
The Philippine Supreme Court upheld the constitutionality of the Plunder Law (RA 7080). First, it ruled
that the law is not vague, as it provides clear standards for defining "plunder" that can be understood
by common individuals. Second, the Court affirmed that proving a pattern of criminal acts does not
lower the standard of proof, as the prosecution must still establish guilt beyond reasonable doubt.
Lastly, the Court determined that plunder is a malum in se crime, requiring criminal intent, and its
classification as heinous does not violate due process.

Doctrine:
The decision reiterated the doctrine that all laws are presumed constitutional, and any challenge must
establish clear infringement of constitutional rights. Additionally, technical precision is not required in
penal statutes’ language as long as a person of ordinary intelligence can understand the prohibited
conduct—the doctrines of strict scrutiny, overbreadth, and vagueness are inapplicable to penal laws.
Dissenting Opinion:
Kapunan- The enactment of R.A. 7080 was a response to inadequate laws addressing severe corruption
from the previous regime. However, the law's ambiguity risks violating due process by making it
unclear what constitutes illegal conduct and potentially enabling arbitrary enforcement. This vagueness
could be exploited for political purposes or personal revenge. Given this, the charge against the
petitioner in Criminal Case No. 26558 does not fit the definition of "plunder" under R.A. 7080. The case
should be dismissed but with permission to file new charges under other relevant laws, without
invoking double jeopardy. I vote to GRANT the motion.

Chapter III: Theory of Law

GR No. 176951, June 28, 2011 and
▪ ▪ League of Cities, et al. v. COMELEC
GR 178056
Fact/s: Issue/s:
This case concerns the conversion of 16 municipalities into Issues: The principal legal issues raised
cities and the constitutionality of the individual Cityhood Laws in the Supreme Court’s decision were:
for each municipality. The League of Cities of the Philippines, 1. Whether RA No. 9009 can be
the City of Calbayog, and taxpayer Jerry P. Treñas challenged considered validly amended by the
these laws, claiming they violated the Local Government Code subsequent Cityhood Laws creating an
as amended by Republic Act No. 9009, which increased the exemption from its income
income requirement for cityhood to P100 million. Initially requirements for the 16
ruled unconstitutional by the Supreme Court in November municipalities. 2. Whether the
2008, this decision was reversed in December 2009, then Cityhood Laws violate the equal
reinstated in August 2010, and upheld again in February 2011. protection clause of the Constitution.
The final motion for reconsideration was denied in April 2011. 3. Whether the flip-flopping of the
Court’s decisions encounter any issues
with the legal doctrines of
immutability of final judgments and
res judicata.
Rulings:
1. The Court’s final ruling held that the Cityhood Laws did not violate the equal protection clause,
stating that the laws complied with the criteria prior to the amendment brought by RA 9009. 2. The
Court ultimately dismissed concerns over its changing decisions, concluding that the Cityhood Laws
were constitutional.
Doctrine:
The case touches upon the doctrine of immutability of final judgments, which postulates that a
decision that has acquired finality becomes immutable and unalterable and may no longer be modified
in any respect. Furthermore, it elucidates the limits of congressional power to amend laws and the
principle that laws should be free from arbitrariness to abide by the equal protection clause.
Dissenting Opinion:
Carpio - The Constitution mandates that Congress include all criteria for city creation, including
municipality conversions, in the Local Government Code to ensure uniformity and equality. The
Cityhood Laws, which are separate from the Local Government Code, exempt certain municipalities
from the income requirement under Section 450, as amended by RA No. 9009. These laws violate
Section 10, Article X of the Constitution, the equal protection clause, and the fair distribution of
national taxes as outlined in Section 6, Article X. Thus, the Cityhood Laws are unconstitutional, and I
vote to grant the League of Cities of the Philippines' motion for reconsideration.
CJ Sereno- The Constitution mandates that criteria for city creation, including municipality conversions,
must be set within the Local Government Code (LGC) to ensure uniformity and equality. Congress can
revise these standards but must do so through an amendatory LGC law, not by creating exemptions
through separate cityhood laws. The Cityhood Laws bypass these standards and undermine the LGC's
authority. This selective application threatens legal stability and predictability. The Court must avoid
repeatedly reconsidering these matters to uphold judicial consistency and the rule of law. Stability in
judicial decisions is essential to maintain public trust and the integrity of the legal system.

Chapter III: Theory of Law

▪ Republic of the Philippines v. Sandiganbayan (GR No. 104768, July 21, 2003)
 Fact/s: Issue/s:
The case originated from the Presidential Commission on 1. Whether the PCGG had the
Good Government's (PCGG) efforts to recover ill-gotten jurisdiction to investigate and cause
wealth from former President Marcos and his associates. The the filing of a forfeiture petition
PCGG, established after the 1986 EDSA Revolution, against Ramas and Dimaano. 2. The
investigated Major General Josephus Q. Ramas for propriety of the Sandiganbayan’s
unexplained wealth. A raid on Elizabeth Dimaano’s residence dismissal of the case before the
led to the seizure of money and military equipment. The completion of the presentation of
PCGG filed a forfeiture petition under RA No. 1379 against evidence by the petitioner. 3. Legality
Ramas and Dimaano, but the Sandiganbayan dismissed the of the search and seizure conducted
case, citing jurisdictional issues and insufficient evidence. The on Dimaano’s residence.
Supreme Court then reviewed the case, focusing on the
PCGG’s jurisdiction and evidence admissibility.

Rulings:
The Supreme Court ruled that the PCGG lacked jurisdiction over Major General Ramas, as its mandate
was limited to recovering ill-gotten wealth from Marcos, his family, and those directly associated with
him, which was not proven in Ramas’s case. The Court upheld the Sandiganbayan’s dismissal, citing the
PCGG's failure to provide substantial evidence despite ample time. It also found that the search and
seizure at Dimaano’s residence exceeded the warrant's scope and ordered the return of improperly
seized items.

Doctrine:
The case reiterates the doctrine that the Presidential Commission on Good Government lacks
jurisdiction over military personnel, such as Major General Ramas, without directly establishing their
status as “subordinates” under the connotation of Executive Orders relevant to the commission’s
formation. Additionally, it upheld principles regarding the limits of search and seizure operations,
emphasizing adherence to the scope specified by judicial warrants.

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
▪ Republic of the Philippines v. Sandiganbayan (GR No. 104768, July 21, 2003)
Fact/s: Issue/s:
The case originated from the Presidential Commission on 1. Whether the PCGG had the
Good Government's (PCGG) efforts to recover ill-gotten jurisdiction to investigate and cause
wealth from former President Marcos and his associates. The the filing of a forfeiture petition
PCGG, established after the 1986 EDSA Revolution, against Ramas and Dimaano. 2. The
investigated Major General Josephus Q. Ramas for propriety of the Sandiganbayan’s
unexplained wealth. A raid on Elizabeth Dimaano’s residence dismissal of the case before the
led to the seizure of money and military equipment. The completion of the presentation of
PCGG filed a forfeiture petition under RA No. 1379 against evidence by the petitioner. 3. Legality
Ramas and Dimaano, but the Sandiganbayan dismissed the of the search and seizure conducted
case, citing jurisdictional issues and insufficient evidence. The on Dimaano’s residence.
Supreme Court then reviewed the case, focusing on the
PCGG’s jurisdiction and evidence admissibility.

Rulings:
The Supreme Court ruled that the PCGG lacked jurisdiction over Major General Ramas, as its mandate
was limited to recovering ill-gotten wealth from Marcos, his family, and those directly associated with
him, which was not proven in Ramas’s case. The Court upheld the Sandiganbayan’s dismissal, citing the
PCGG's failure to provide substantial evidence despite ample time. It also found that the search and
seizure at Dimaano’s residence exceeded the warrant's scope and ordered the return of improperly
seized items.

Doctrine:
The case reiterates the doctrine that the Presidential Commission on Good Government lacks
jurisdiction over military personnel, such as Major General Ramas, without directly establishing their
status as “subordinates” under the connotation of Executive Orders relevant to the commission’s
formation. Additionally, it upheld principles regarding the limits of search and seizure operations,
emphasizing adherence to the scope specified by judicial warrants.

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
▪ Ateneo de Manila University, et al. v. Hon. Ignacio (GR No. 99327, May 27, 1993)
Capulong, et al.
Fact/s: Issue/s:
The case concerns the expulsion of students from Ateneo Law 1. Were the students afforded
School due to their role in hazing activities, which resulted in procedural due process in the
the death of Leonardo "Lennie" H. Villa and severe injury to disciplinary proceedings
Bienvenido Marquez. The hazing, conducted by the Aquila conducted by Ateneo de Manila
Legis fraternity, took place from February 8-10, 1991. A Joint University?
Investigating Committee was formed by Dean Cynthia del 2. Was the penalty of expulsion
Castillo to probe the incident, leading to the preventive imposed by the university
suspension of the involved students. The Disciplinary Board, appropriate under the
after hearings, recommended expulsion, a decision upheld by circumstances?
Fr. Joaquin Bernas, S.J., the University President. The students
challenged the decision in court, arguing due process
violations. The case was escalated to the Supreme Court to
review procedural fairness and the expulsion's
appropriateness.
Rulings:
The Supreme Court upheld that procedural due process was followed in the disciplinary action taken
by the university. The Court confirmed that the students were informed of the charges and evidence,
given the chance to respond with counsel, and allowed to present their own evidence. It noted that
academic disciplinary procedures need not match the rigor of criminal trials. The expulsion was
deemed appropriate due to the severe nature of the offense, which led to a student’s death and
another's injury. The decision reinforced the university's autonomy under the 1987 Philippine
Constitution to enforce its disciplinary rules.

Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
▪ Tomoyuki Yamashita v. Wilhelm D. Styer (GR No. L-129, Dec. 19, 1945)
Fact/s: Issue/s:
Tomoyuki Yamashita, a Japanese general who surrendered on  Does the Military Commission
September 3, 1945, in Baguio, was initially interned as a have jurisdiction to try Yamashita
prisoner of war at New Bilibid Prison. On October 2, 1945, he for war crimes?
faced war crime charges for atrocities committed by his  Can the Philippines be considered
command in the Philippines. His status was changed from an occupied territory, thereby
prisoner of war to accused war criminal, and a Military allowing the Military Commission
Commission was appointed to try him. Yamashita then sought to exercise jurisdiction?
a writ of habeas corpus to regain prisoner of war status and a  Is the trial invalid due to the lack
writ of prohibition to halt the trial. The case was reviewed by of notice to Spain, the "protecting
the Philippine Supreme Court under Chief Justice Moran. power" of Japan, as required by
the Geneva Convention?
 Are the charges against Yamashita
valid under the laws of war?
 Do the rules of procedure and
evidence used by the Military
Commission deny Yamashita a fair
trial?
Rulings:
The Military Commission has jurisdiction to try Yamashita for war crimes in the Philippines, which is
deemed an occupied territory. The trial remains valid despite the lack of notice to Spain, as Japan’s
unconditional surrender waived such requirements. The charges are legitimate under wartime laws,
and the procedures and evidence rules used by the Military Commission ensure that Yamashita
receives a fair trial.

Doctrine:

Concurring and Dissenting Opinion:

Ozaeta - I agree with dismissing the habeas corpus and prohibition petition, affirming that the Military
Commission is legally constituted and has jurisdiction to try the petitioner for war law violations.
However, I dissent from the Court's application of Raquiza vs. Bradford, which suggests that civil court
jurisdiction over the U.S. Army violates the country’s faith. I previously argued that international law
regarding foreign armies is not applicable here, as the U.S. Army is in the Philippines by sovereign right,
not mere permission. The U.S. has the same obligations and rights in the Philippines as in its own
states.
Perfecto-

Chapter IV: Natural Law, International Law, and the Classic Philosophers
▪ Jose Caraos v. Iñigo S. Daza (GR No. L-442, May 23,1946)
Fact/s: Issue/s:
Jose Caraos, the petitioner, entered into a lease agreement  The main legal issues in this case
with Inigo S. Daza, the respondent, for a parcel of land in included:
Manila. The lease was for a period of five years, with a  Whether the lease agreement was
stipulated monthly rental fee. However, disputes arose valid despite the alleged
regarding the payment of rent and the terms of the lease. unauthorized alterations made by
Caraos claimed that Daza failed to pay the agreed rent, while Caraos.
Daza contended that Caraos had violated the terms of the  Whether Daza was entitled to
lease by making unauthorized alterations to the property. recover possession of the
Subsequently, Daza filed a complaint for unlawful detainer property based on the claims of
against Caraos, seeking to recover possession of the property. non-payment of rent.
The Municipal Court ruled in favor of Daza, leading to an
appeal by Caraos to the Court of First Instance, which upheld
the lower court's decision.

Rulings:
The Supreme Court ruled in favor of Daza, affirming the lower courts' decisions. The Court held that:
 Validity of Lease Agreement: The lease agreement was deemed valid despite the alterations
made by Caraos. The Court emphasized that the alterations did not constitute a breach of the
lease that would justify termination.
 Non-Payment of Rent: The Court found that Caraos had indeed failed to pay the rent as
stipulated in the lease agreement. The evidence presented supported Daza's claim of non-
payment, which justified Daza's action to recover possession of the property.
 Right to Possession: Given the failure to pay rent and the validity of the lease agreement, Daza
was entitled to recover possession of the property.
Doctrine:

Concurring and Dissenting Opinion:

Paras-The case record shows that all Batangas provincial jail prisoners were released in December
1944 due to emergency conditions. However, the petitioner’s release on November 9 was due to
executive clemency, not the emergency. His release date is corroborated by his testimony and that of a
widow. I vote to grant his release.
Perfecto-The lack of case records in petitioner Caraos's criminal case means the lower court had no
jurisdiction to order his rearrest or recommitment. Without a clear, written decision specifying facts
and law, there is no basis to enforce imprisonment. I vote to grant his release.

Chapter IV: Natural Law, International Law, and the Classic Philosophers
▪ Maria Jeanette Tecson and Felix B. Desiderio, Jr. v. (G.R. No. 161434, March 3, 2004)
Commission on Elections
Fact/s: Issue/s:
Petitioners Maria Jeanette Tecson and Felix B. Desiderio, Jr.
filed a petition seeking to disqualify FPJ from the presidential Whether the Supreme Court had
elections, alleging that he misrepresented himself as a jurisdiction over the issue of FPJ's
natural-born citizen of the Philippines in his certificate of qualifications as a candidate for
candidacy. They contended that both of FPJ's parents were president.
foreigners, thus questioning his eligibility. Whether the COMELEC committed
The COMELEC dismissed the petition, asserting that FPJ was a grave abuse of discretion in ruling that
Filipino citizen. In response, Tecson and Desiderio challenged FPJ was a Filipino citizen.
the jurisdiction of the COMELEC, arguing that under Article
VII, Section 4, paragraph 7 of the 1987 Constitution, only the
Supreme Court has original and exclusive jurisdiction over
matters concerning the qualifications of candidates for the
presidency.

Rulings:
The Supreme Court ruled as follows:
Jurisdiction: The Court held that it did not have jurisdiction over questions regarding the qualifications
of candidates for the presidency before the elections. The provision in the Constitution refers to post-
election contests and not to the qualifications of candidates prior to the elections. Thus, the COMELEC
had the original jurisdiction to determine the eligibility of candidates.
No Grave Abuse of Discretion: The Court found that the COMELEC did not commit grave abuse of
discretion in determining that FPJ was a Filipino citizen. It considered the evidence presented, including
FPJ's paternal lineage, which traced back to his grandfather, who was a Filipino citizen. The Court noted
that the citizenship of FPJ was established based on the 1935 Constitution, which provided that
children of Filipino fathers are considered citizens regardless of the legitimacy of their birth.
The Court concluded that while the evidence might not conclusively establish FPJ's status as a natural-
born citizen, it was sufficient to support the COMELEC's ruling that he did not commit material
misrepresentation in his certificate of candidacy.
Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
(G.R. No. L-12462, December 20,
▪ The United States v. Simeon Guendia
1917)
Fact/s: Issue/s:
Simeon Guendia was convicted by the Court of First Instance Whether Guendia was criminally liable
of Iloilo for the crime of frustrated murder after he assaulted for the act of frustrated murder given
his "querida" (mistress) with the intent to kill. During the trial, his mental state at the time of the
evidence indicated that Guendia was insane at the time of the offense.
incident and had been committed to the San Lazaro Hospital Whether the trial court should have
for treatment by the Governor-General. The trial judge suspended proceedings due to
expressed doubts about Guendia's sanity, noting that he Guendia's apparent insanity
appeared to be insane during the proceedings.

Rulings:
The Supreme Court of the Philippines ruled in favor of Guendia, reversing the lower court's judgment.
The Court held that:
Insanity as a Defense: Guendia was found to be insane at the time of the commission of the crime,
which exempted him from criminal liability under Article 8, Section 1 of the Penal Code. The evidence
presented clearly indicated that he could not understand the nature of his actions due to his mental
condition.
Discretion of the Trial Court: The Court acknowledged that while it is the duty of the trial court to
investigate the sanity of an accused when there are indications of mental illness, it also has discretion
in determining whether such an investigation is necessary. In this case, the trial court's failure to
adequately address Guendia's mental state during the trial proceedings was a significant oversight.
Acquittal and Commitment: The Supreme Court acquitted Guendia of the charge of frustrated murder,
ordering that he be committed to a mental health facility for treatment rather than facing criminal
penalties.
Doctrine:

Concurring and Dissenting Opinion:

Carson- I concur to so much of the disposition of this case as provides for the detention of the accused
and his treatment in an insane asylum, so long as he continues of unsound mind; but I dissent from so
much of the majority opinion as solemnly declare that the accused committed the acts with which he is
charged, but without incurring criminal liability therefor because of his insanity at the time when those
acts were committed.

Chapter IV: Natural Law, International Law, and the Classic Philosophers
(G.R. No. L-12779, September 10,
The United States v. Dionisio Santos
1917)
Fact/s: Issue/s:
Dionisio Santos, a policeman in Pateros, Rizal, acted under Whether Santos was guilty of coercion
orders from his chief to patrol an area known for pilfering. or if he should be held liable for the
Around midnight, he observed two individuals in front of an lesser offense of arbitrary detention.
uninhabited house and subsequently arrested them without a The extent of a peace officer's
warrant, even though no crime had been committed. The authority to make arrests without a
individuals were taken to the municipal presidencia and warrant under Philippine law.
detained for six to seven hours before being released. Santos
was charged with coercion, but the trial court found him
guilty.

Rulings:
The Supreme Court of the Philippines reversed the lower court's decision, acquitting Santos. The Court
ruled that:
Authority of Peace Officers: The Court reaffirmed that peace officers in the Philippines have the same
powers as constables under Anglo-American common law, which includes the ability to make arrests
without a warrant under certain conditions. Specifically, they may arrest individuals found in suspicious
circumstances that reasonably suggest a crime is being committed or about to be committed.
Probable Cause: The Court emphasized that probable cause for an arrest without a warrant must be
based on reasonable grounds of suspicion supported by sufficient circumstances. Santos acted under
the belief that he was preventing a crime, which is a valid reason for making an arrest, even if it was
later determined that no crime had occurred.
Good Faith: The ruling highlighted the principle that peace officers should not be held liable for honest
mistakes made in good faith while performing their duties. The Court noted that the nature of police
work often requires quick decisions without the benefit of thorough investigation.
Acquittal: Given the circumstances, the Court concluded that Santos acted in good faith and within the
scope of his duties as a police officer. Therefore, he was acquitted of the charges against him.
Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
The People of the Philippine Islands v. Julio Pomar (G.R. No. L-22008, November 3, 1924)
Fact/s: Issue/s:
On October 26, 1923, the prosecuting attorney of Manila filed The primary issue in this case was
a complaint against Julio Pomar, the manager of La Flor de la whether the provisions of Sections 13
Isabela, a tobacco factory. The complaint alleged that Pomar and 15 of Act No. 3071 constituted a
failed to pay Macaria Fajardo, a female employee, her wages reasonable and lawful exercise of the
amounting to eighty pesos (P80) for the thirty days before police power of the state.
and after her confinement due to pregnancy, as mandated by
Section 13 of Act No. 3071 of the Philippine Legislature.
Pomar demurred, arguing that the allegations did not
constitute an offense and contended that the provisions of
Act No. 3071 were illegal, unconstitutional, and void. The trial
court overruled the demurrer and found Pomar guilty,
sentencing him to a fine of P50 and subsidiary imprisonment
in case of insolvency.

Rulings:
The Supreme Court ruled in favor of Pomar, stating that:
Unconstitutionality of the Provisions: The Court found that Sections 13 and 15 of Act No. 3071 were
unconstitutional. The law imposed conditions on employment contracts without the consent of both
parties, thereby infringing on the liberty to contract. The law's provisions effectively deprived
employers of their right to negotiate terms with their employees, which is protected under the
Philippine Constitution.
Police Power Limitations: While the state has the authority to enact laws for the welfare of its citizens,
such laws must not violate constitutional rights. The Court concluded that the provisions in question
were not a reasonable exercise of police power, as they imposed undue restrictions on the freedom of
contract.
Dismissal of the Complaint: As a result of the ruling, the Supreme Court dismissed the complaint
against Pomar, thereby revoking the lower court's decision and discharging him from custody.
Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
In the Matter of the Allegations Contained in the Columns of (AM No. 07-09-13-SC, August 8, 2008)
Mr. Amado P. Macasaet Published in Malaya
Fact/s: Issue/s:
The case stemmed from a series of articles written by Amado Whether the articles published by
P. Macasaet published in the newspaper Malaya, which Macasaet constituted contempt of
contained allegations against certain justices of the Supreme court.
Court and the judiciary in general. The articles criticized the The balance between freedom of
integrity and competence of the justices, suggesting that they expression and the need to protect
were corrupt and biased. This prompted the Supreme Court the integrity of the judiciary.
to take action against Macasaet for contempt, as the articles
were deemed to undermine the authority and dignity of the
court.
The Supreme Court issued a show-cause order to Macasaet,
requiring him to explain why he should not be held in
contempt for his writings. In his defense, Macasaet argued
that his articles were intended to express his opinions on the
judiciary and to promote public discourse on judicial
accountability.
Rulings:
The Supreme Court ruled in favor of holding Macasaet in contempt. The Court emphasized the
following points:
Contempt of Court: The articles were found to be contemptuous as they attacked the integrity of the
judiciary and discredited the justices without providing substantiated evidence. The Court underscored
that such publications could erode public confidence in the judicial system.
Freedom of Expression vs. Judicial Integrity: While the Court recognized the importance of freedom of
expression, it clarified that this right is not absolute. The judiciary must be protected from unfounded
attacks that could undermine its authority and the rule of law. The Court noted that the right to
criticize the judiciary must be exercised responsibly and with respect for the institution.
Sanctions: The Court imposed sanctions on Macasaet, which included a fine and a warning that future
similar conduct could lead to more severe penalties.
Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
People of the Philippines v. Hon. Tirso D.C. Velasco (G.R. No. 12744, September 13, 2000)
Fact/s: Issue/s:
The case arose from a violent incident in San Ildefonso, Can the State appeal the acquittal of
Bulacan, where gunfire resulted in the death of Alex Honorato Galvez without violating the
Vinculado and serious injuries to his twin brother, Levi, and constitutional protection against
their uncle, Miguel Vinculado, Jr. Honorato Galvez, the Mayor double jeopardy?
of San Ildefonso, and his alleged bodyguard, Godofredo Did the trial court commit grave abuse
Diego, were initially charged with homicide and frustrated of discretion in acquitting Galvez?
homicide. These charges were later upgraded to murder and
frustrated murder, along with a separate charge for illegal
carrying of a firearm.
After a trial, the Regional Trial Court (RTC) acquitted Galvez of
all charges due to insufficient evidence. The State, dissatisfied
with the acquittal, filed a petition for certiorari, seeking to
reverse the trial court's decision, arguing that the judge had
committed grave abuse of discretion.
Rulings:
The Supreme Court ruled that the State cannot appeal the acquittal of Honorato Galvez. The key points
of the ruling include:
Double Jeopardy: The Court emphasized that the constitutional protection against double jeopardy
prohibits the State from subjecting an individual to multiple prosecutions for the same offense. An
acquittal, whether by a trial court or on appeal, is final and unappealable.
Finality of Acquittal: The Court reiterated that acquittals are essential to protect the rights of the
accused and prevent government oppression. The finality of an acquittal is a fundamental principle in
criminal law, ensuring that individuals are not subjected to continuous legal jeopardy.
Grave Abuse of Discretion: The Court found no evidence of grave abuse of discretion by the trial judge.
The judge had properly evaluated the evidence presented during the trial, and any perceived errors in
judgment did not equate to a lack of jurisdiction.
Dismissal of the Petition: The Court dismissed the State's petition for certiorari, reaffirming the
principle that an acquittal cannot be challenged or reversed through such a petition.
Doctrine:

Concurring and Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
Anastacio Laurel v. Eriberto Misa (G.R. No. L-409, January 30, 1947)
Fact/s: Issue/s:
Anastacio Laurel was arrested and charged with treason for Can a Filipino citizen who aided the
allegedly aiding the Japanese forces during their occupation enemy during the Japanese
of the Philippines. He filed a petition for habeas corpus, occupation be prosecuted for
arguing that he could not be prosecuted for treason under treason?
Article 114 of the Revised Penal Code. Laurel contended that Was the sovereignty of the legitimate
the legitimate Philippine government’s sovereignty was Philippine government suspended
suspended during the Japanese occupation and that a change during the Japanese occupation?
in sovereignty occurred with the proclamation of the
Philippine Republic.
The lower court ruled against Laurel, leading him to appeal
the decision.

Rulings:
The Supreme Court ruled against Laurel, holding that:
Prosecution for Treason: A Filipino citizen who aided the enemy during the Japanese occupation can
indeed be prosecuted for treason under Article 114 of the Revised Penal Code. The Court emphasized
that allegiance to the government is absolute and permanent, and this allegiance is not abrogated by
enemy occupation.
Sovereignty of the Government: The Court found that the sovereignty of the legitimate Philippine
government was not suspended during the Japanese occupation. It maintained that the existence of
the government and the corresponding allegiance of its citizens continued despite the inability of the
government to exercise its powers fully during the occupation.
Permanent Allegiance: The Court rejected the notion of "suspended allegiance," stating that such a
theory would lead to disastrous consequences, allowing invaders to recruit inhabitants to fight against
their own government. The allegiance of citizens to their legitimate government remains intact,
regardless of the circumstances.
Change of Government: The Court noted that the change from a Commonwealth to a Republic did not
affect the prosecution of treason, as the crime is against the same government and sovereign people.
Doctrine:

Dissenting Opinion:
Paras-The suggestion that as treason may be committed against the Federal as well as against the
State Government, in the same way treason may have been committed against the sovereignty of the
United States as well as against the sovereignty of the Philippine Commonwealth, is immaterial
because, as we have already explained, treason against either is not and cannot be treason against the
new and different sovereignty of the Republic of the Philippines.

Chapter IV: Natural Law, International Law, and the Classic Philosophers
Anastacio Laurel v. Eriberto Misa (G.R. No. L-200, March 28, 1946)
Fact/s: Issue/s:
Anastacio Laurel, a Filipino citizen, was arrested in May 1945 Whether the provisions of
by the United States Army in Camarines Sur for alleged Commonwealth Act No. 682,
collaboration with the Japanese during their occupation of particularly Section 19, were
the Philippines. Following his arrest, he was interned under a constitutional.
commitment order and later handed over to the Whether Laurel's detention was lawful
Commonwealth Government in September 1945. Laurel was under the circumstances.
then placed under the custody of Eriberto Misa, the Director
of Prisons.
Laurel filed a petition for habeas corpus, challenging the
constitutionality of his arrest and detention. He specifically
targeted Section 19 of Commonwealth Act No. 682, which
established the People's Court and allowed for the detention
of individuals suspected of collaboration with the enemy.

Rulings:
The Supreme Court ruled in favor of upholding the constitutionality of Section 19 of Commonwealth
Act No. 682. The key points of the ruling include:
Constitutionality of the Law: The Court found that Section 19 did not violate the equal protection
clause, as it allowed for reasonable classification of individuals. The differentiation for political
detainees was deemed reasonable given the extraordinary circumstances following World War II.
Legitimate Government Action: The ruling emphasized that the law was enacted to address the unique
post-war conditions and was necessary for proper investigation and prosecution of those suspected of
collaboration with the enemy.
Procedural Safeguards: The Court noted that the provision for bail and the requirement for the
Solicitor General to file informations within a specified timeframe mitigated potential abuses of power.
Detention Validity: The Court concluded that Laurel's detention was lawful under the emergency
powers exercised during the post-war period, affirming that the government had the authority to
detain individuals suspected of aiding the enemy.
Doctrine:

Dissenting Opinion:
Perfecto-The moral hiatus in our national life is over, and in this hour of resumption of democratic
processes, there is an imperative need, as one of the cornerstones of our national structure, to
redefine and reaffirmed our pre-war concept of human freedom.
The petitioner is entitled to be immediately set free, and we vote for restoring him to his personal
freedom of which he was deprived without any legal process.

Chapter IV: Natural Law, International Law, and the Classic Philosophers
Simona Manzanares v. Rafael Moreta (G.R. No. L-12306, October 22, 1918)
Fact/s: Issue/s:
Simona Manzanares entered into a contract with Rafael Whether the contract between
Moreta for the sale of a parcel of land. The contract Manzanares and Moreta was valid and
stipulated that Moreta would pay a certain amount as a down enforceable.
payment and the remaining balance upon the execution of Whether Moreta was coerced into
the deed of sale. However, Moreta failed to pay the full signing the contract, thus affecting its
amount due, leading Manzanares to file a complaint for validity.
specific performance and damages.
Moreta contended that the contract was invalid due to a lack
of mutual consent, arguing that he was coerced into signing
the agreement. He claimed that he did not fully understand
the terms of the contract and that the down payment was not
sufficient to bind him to the agreement.

Rulings:
The Supreme Court ruled in favor of Simona Manzanares, holding that:
Validity of the Contract: The Court found that the contract was valid and enforceable. It emphasized
that both parties had agreed to the terms, and the down payment constituted consideration for the
contract. The Court noted that the law recognizes the validity of contracts as long as there is consent, a
lawful object, and a lawful cause.
Absence of Coercion: The Court ruled that there was no evidence to support Moreta's claim of
coercion. It stated that a party claiming coercion must prove that they were subjected to threats or
undue pressure that would negate their free will. The mere assertion of misunderstanding or regret
regarding the terms of the contract did not suffice to invalidate it.
Obligation to Perform: The Court ordered Moreta to comply with the terms of the contract and to pay
the remaining balance owed to Manzanares. It affirmed that parties to a contract are bound by their
obligations unless they can demonstrate valid grounds for non-performance.
Doctrine:

Dissenting Opinion:

Chapter IV: Natural Law, International Law, and the Classic Philosophers
Sunripe Coconut Products Co., Inc. v. Court of Industrial
(G.R. No. L-2009, April 30, 1949)
Relations and Sunshine Coconut Workers' Union
Fact/s: Issue/s:
Sunripe Coconut Products Co., Inc. (the petitioner) contested Whether the "parers" and "shellers"
a decision by the Court of Industrial Relations (CIR) that should be classified as independent
classified its "parers" and "shellers" as employees entitled to contractors or as employees of
benefits, including sick leave. The petitioner argued that these Sunripe Coconut Products Co., Inc.
workers were independent contractors operating under a Whether the CIR's decision regarding
"pakyaw" (piecework) system, and thus, should not be the workers' entitlement to benefits
entitled to the same benefits as regular employees. was justified.
The CIR found that the "parers" and "shellers" worked under
some degree of control and supervision from the company,
formed stable groups, and depended on their work with
Sunripe for their livelihood. The CIR ruled that these workers
should be classified as employees based on the economic
realities of their work relationship with the company.

Rulings:
The Supreme Court upheld the CIR's decision, ruling that:
Classification of Workers: The Court affirmed that the "parers" and "shellers" were indeed employees.
It emphasized that the economic facts of their relationship with Sunripe indicated more of an
employer-employee relationship than that of independent contractors. The Court noted the degree of
control exercised by the company over the workers, their stable grouping, and their reliance on the
company for their livelihood.
Entitlement to Benefits: The Court supported the CIR's ruling that the workers were entitled to
benefits, including sick leave. The definition of "employee" under the Workmen's Compensation Law
was interpreted broadly to include those who work under a service contract, which applied to the
"parers" and "shellers."
Finality of CIR's Findings: The Supreme Court reiterated that it could not review the factual findings of
the CIR, as these findings were binding and final. The Court emphasized that the determination of the
workers' status was a question of fact, not law, and thus, outside the scope of the Supreme Court's
review.
Doctrine:

Dissenting Opinion:
Feria-The Supreme Court lacks jurisdiction to review the Court of Industrial Relations' decision on
factual matters. Since such decisions are final and non-appealable, the petition for certiorari should
have been dismissed initially. We cannot review or alter the court’s factual findings.

Chapter V: Civil Law: The Roman Jurist

Marcial Kasilag v. Rafaela Rodriguez, et al. (G.R. No. 46623, December 7, 1939)
Fact/s: Issue/s:
1. Emiliana Ambrosio was granted a homestead patent on 1. Was the real intent of the contract
January 11, 1931, with Certificate between Kasilag and Ambrosio one of
of Title No. 325 issued on June 27, 1931. absolute sale
2. On May 16, 1932, Ambrosio and Kasilag executed a public disguised as a mortgage to circumvent
deed ostensibly encumbering the prohibitions under the Homestead
only the improvements on the land as a mortgage to secure a Law?
loan of P1,000 from Kasilig to 2. Is the petitioner (Kasilag) entitled to
Ambrosio, with clauses suggesting an eventual sale of the retain possession and improvements
land after a certain period. made on the
3. Ambrosio failed to pay interest and taxes following the land?
agreement. Consequently, they 3. Should the respondents
verbally modified their arrangement in 1933, allowing Kasilag (Ambrosio’s heirs) be compelled to
to take possession of the reimburse Kasilag for the
land, waive the collection of interest, pay land taxes, benefit improvements or be entitled to
from the land’s produce, and recover possession of the land
introduce improvements. without such payment?
4. Kasilag, upon taking possession, introduced improvements
valued at approximately
P5,000, transferred the tax declaration to his name, and
manipulated the land’s assessed
value.
5. The respondents, as Ambrosio’s heirs, initiated a civil case
to recover possession of the
land, asserting ownership and seeking cancellation of
Kasilag’s title, compensation for fruits
received by Kasilig, and transfer documentation.
6. Kasilag countered by asserting his claim based on the
mortgage contract, and if found
lesser in right, demanded compensation for his introduced
improvements valued at P5,000.
Rulings:
1. The Supreme Court found that the Court of Appeals erred in interpreting the agreement
as an absolute sale and voiding it entirely. It held that the primary contract was indeed a mortgage of
the improvements but recognized an intent for a subsequent sale, which was
void for intending to circumvent the Homestead Law’s prohibitions.
2. The verbal agreement entered into by Kasilag and Ambrosio, facilitating Kasilag’s
possession and improvement introductions to the land, was determined as a contract of
antichresis, which is illegal as it imposes a real burden on homestead property.
3. However, based on Kasilag’s good faith under Article 433 of the Civil Code and his
investments in improvements, the Court ruled that the respondents could either reimburse
Kasilag for the improvements or compel him to purchase the land at its market value.
Doctrine:
1. The principle that contracts must be interpreted according to the parties’ real intent and
that illegal terms aimed at circumventing the law render those specific provisions void but
not necessarily the whole contract if separable.
2. Contracts of antichresis involving homestead lands are illegal and void due to restrictions
under the Homestead Law against encumbrance or alienation within the prescribed period.
Dissenting Opinion:
Villa-real Concurring and dissenting: In view of the foregoing, I concur in the majority opinion except
insofar as it holds that the interest is set off against the fruits of the mortgaged improvements, because
as a result of the nullity of the contract of antichresis the petitioner should return to the respondents
the products of the mortgaged improvements, and the latter should pay to the petitioner the amount
of the loan plus interest due and unpaid at the rate of 12 per cent per annum from the date of the
contract until fully paid.
Concepcion Dissenting- In view of the foregoing, I am of the opinion that the decision of the Court of
Appeals should be reversed and that another should be entered against the respondents, requiring
them to execute the deed of sale of the land in favor of the petitioner, provided that if the sale, for any
reason, be not approved by the court, the petitioner may execute his credit upon the land and all its
improvements, after deducting the value of the improvements introduced by him upon the land.
Moran-Considering the social and economic ends of the Homestead Act, the courts should exercise
supreme care and strict vigilance towards faithful compliance with all its benign provisions and against
the defeat, directly or indirectly, of its highly commendable purposes. And it is my firm conviction that
where, as in the present case, a rich and clever man attempts to wrest a homestead granted to a poor
and ignorant woman, the slightest tokens of illegality should be enough to move the courts to apply
the strong arm of the law.
I dissent from the majority decision and vote for the affirmance of the decision of the Court of Appeals

Chapter V: Civil Law: The Roman Jurist

Wayne Jain v. the Intermediate Appellate Court and the (G.R. No. L-63129, September 28,
People of the Philippines 1984)
Fact/s: Issue/s:
Two informations were filed against Wayne Jain and Andres Whether Jain should be accused of
Tresfuentes for the crime of theft of sugar canes belonging to theft.
Tomasa Bermejo. Whether the Supreme Court erred in
Tresfuentes, a watchman employed by Bermejo, was accusing Jain of theft.
convicted as an accessory to the crime of simple theft.
Jain appealed, raising questions of fact in the Court of
Appeals. He later claimed he did not commit theft but rather
estafa.
Modus Operandi
After Bermejo's sugar canes were loaded onto cane cars, Jain
and Tresfuentes withdrew the trainman's receipts and
substituted them with receipts in Jain's name, making it
appear the canes belonged to Jain.
The canes reached the mill without Jain's intervention. He did
not physically take or steal the canes, only the receipts.
Rulings:
The Supreme Court granted Jain's petition, set aside the Court of Appeals judgment, and directed the
Provincial Fiscal to file an appropriate information against Jain for estafa or falsification of private
documents.
For theft, there must be physical handling of the property. Jain did not lay his hands on the sugar
canes, only the receipts. He committed estafa, not theft.

Doctrine:

Dissenting Opinion:

Chapter V: Civil Law: The Roman Jurist

(G.R. No. L-63129, September 28,
People of the Philippines v. Hon. Tirso D.C. Velasco
1984)
Fact/s: Issue/s:
The case arose from a violent incident in San Ildefonso, Whether Jain should be accused of
Bulacan, where gunfire resulted in the death of Alex theft.
Vinculado and serious injuries to his twin brother, Levi, and Whether the Supreme Court erred in
their uncle, Miguel Vinculado, Jr. Honorato Galvez, the Mayor accusing Jain of theft.
of San Ildefonso, and his alleged bodyguard, Godofredo
Diego, were initially charged with homicide and frustrated
homicide. These charges were later upgraded to murder and
frustrated murder, along with a separate charge for illegal
carrying of a firearm.
After a trial, the Regional Trial Court (RTC) acquitted Galvez of
all charges due to insufficient evidence. The State, dissatisfied
with the acquittal, filed a petition for certiorari, seeking to
reverse the trial court's decision, arguing that the judge had
committed grave abuse of discretion.
Rulings:
The Supreme Court ruled that the State cannot appeal the acquittal of Honorato Galvez. The key points
of the ruling include:
Double Jeopardy: The Court emphasized that the constitutional protection against double jeopardy
prohibits the State from subjecting an individual to multiple prosecutions for the same offense. An
acquittal, whether by a trial court or on appeal, is final and unappealable.
Finality of Acquittal: The Court reiterated that acquittals are essential to protect the rights of the
accused and prevent government oppression. The finality of an acquittal is a fundamental principle in
criminal law, ensuring that individuals are not subjected to continuous legal jeopardy.
Grave Abuse of Discretion: The Court found no evidence of grave abuse of discretion by the trial judge.
The judge had properly evaluated the evidence presented during the trial, and any perceived errors in
judgment did not equate to a lack of jurisdiction.
Dismissal of the Petition: The Court dismissed the State's petition for certiorari, reaffirming the
principle that an acquittal cannot be challenged or reversed through such a petition.
Doctrine:

Dissenting Opinion: