G.R. No. L-19650.

September 29, 1966 (Case Brief / Digest)

TITLE : CALTEX (Philippines) Inc. Vs Enrico Palomar , Postmaster

General

FACTS:

Caltex Philippines established a sales marketing campaign in 1960 known as

the "Caltex Hooded Pump Contest". It challenges participants to estimate the
number of hooded gas pumps at Caltex stations with no purchase necessary.
This is in accordance with postal law, which prohibits the establishment of
lotteries and gift enterprises that employ mail for promotional purposes. Caltex
requested approval from postal authorities.

On the contrary, a person named Enrico Palomar, the acting Postmaster

General, declined their request upon his due, leading to defining the contest
as a lottery or a gift enterprise through the basis of the Revised Administrative
Code sections 1954, 1984, and 1985, which led to denying their request of
using mail for the promotional purposes.

Hence, Caltex filed a petition for reconsideration but it was denied again ,
leading the warning from Palomar for an issuance of fraud order if the contest
proceed.In response , Caltex filed a petition for declaratory relief , seeking a
judgement to allow the use of mail for the promotional , asserting that the
contest did not violate the Postal Law.

ISSUE/S :

1. Wether the petition for declaratory relief presented a sufficient in action .

2. Wether the “ Caltex Hooded Pump Contest “ violated the Postal Law by
being classified as lottery or gift enterprise.

RULING

The Supreme Court affirmed the trial’s decision , holding ;

1. The petition of Caltex for declaratory relief was sufficient in action as it

presented the justiciable contriversy of people and adverse interest ,
predominantly on the legal issue over the applicability of the Postal Law to
Caltex’s contest.

2.The "Caltex Hooded Pump Contest" did not violate the Postal Law because
it was not a lottery or gift enterprise due to the lack of consideration, which
distinguishes it from banned schemes. The contest, which was open to
everyone and did not require a purchase or a charge, lacked any sort of
consideration, therefore it was not a lottery. Similarly, it was not a gift
enterprise, which required the sale of products as an inducement, that the
contest required none.
 G.R. No. L-10520. February 28, 1957 (Case Brief /
Digest)

Title: Lorenzo M. Tañada and Diosdado Macapagal vs. Mariano Jesus

Cuenco, Francisco A. Delgado, Alfredo Cruz, Catalina Cayetano, Manuel
Serapio, Placido Reyes, and Fernando Hipólito

FACTS :

Petitioner Lorenzo M. Tañada, a senator and president of the Citizens Party,

and petitioner Diosdado Macapagal, a member of the House of
Representatives and official candidate of the Liberal Party, challenged the
election of certain senators to the Senate Electoral Tribunal. The elections
were held in November 1955, resulting in the proclamation of several
senators, whose election Macapagal, along with others, contested before the
Senate Electoral Tribunal.

The Senate, by nomination of its members primarily from the Nacionalista

Party, chosen Senators Jose P. Laurel, Fernando Lopez, and Cipriano
Primicias, and petitioners Lorenzo M. Tañada to be part of the Tribunal. On
behalf of the Senate Committee on Rules, Senator Primicias nominated
Senators Mariano J. Cuenco and Francisco A. Delgado as Tribunal members,
which was objected to by Senators Tañada and Sumulong. These
nominations extended to the appointment of technical assistants and
secretaries for Cuenco and Delgado, contested by Tañada and Macapagal
through petitions and motions to oust the appointments and prevent Cuenco
and Delgado from exercising powers in the Tribunal.

Hence, Senator Tañada and Congressman Macapagal petitioned the

Supreme Court of the Philippines against Senators Cuenco and Delgado,
among others, challenging their nomination and election to the Tribunal as
unconstitutional. They also sought a preliminary injunction to restrain their
appointments. The respondents recognized the factual claims but challenged
the petition's legal legitimacy.

ISSUE/S :

1. Whether the nominations of Senators Cuenco and Delgado as members of

the Senate Electoral Tribunal were valid under the Constitution.
2. Whether the petitions presented a political question beyond the court’s
jurisdiction.
3. Whether Tañada’s refusal to nominate two additional members constituted
a waiver of the minority party’s right to nominate three members to the
Tribunal.

RULING:
The courts decision , holding ;
1. The court ruled that Senators Cuenco and Delgado's nominations were
unlawful. The Constitution requires the minority party to designate three
members to the Tribunal. The Citizens Party, led by Tañada, received the
second-largest number of votes and had sole authority to nominate the
remaining members. Cuenco and Delgado were nominated and elected by
the majority party, which violates this clause.

2. The court concluded that the case at hand was justiciable rather than a
political concern because it required interpreting Constitutional provisions
governing the composition and selection process of Tribunal members. The
court ruled that monitoring the Tribunal's compliance with the Constitution was
within judicial jurisdiction, distinguishing this case from those involving internal
legislative procedures.

3.The court ruled that Tañada's refusal to nominate additional members did
not violate the minority party's constitutional rights. Tañada's denial was
based on upholding the Tribunal's Constitutional framework and ensuring
equitable representation.

Doctrine:
The court confirmed that under Article VI, Section 11 of the Constitution, the
party with the second-largest representation in the Senate has the exclusive
right to nominate three members to the Senate Electoral Tribunal. If such
nomination process is violated, nominations from other parties cannot replace
those constitutionally reserved for the minority party.
 G.R. No. L-43575 May 31, 1935

JUAN TAÑADA, petitioner,

vs.
JOSE YULO, Secretary of Justice,
EDUARDO GUTIERREZ DAVID, Judge of First Instance of the Thirteenth
Judicial District,
and SANTIAGO TAÑADA, Justice of the Peace of Alabat, Tayabas,
respondents.

FACTS
On December 4, 1911, the Governor-General appointed Juan Tañada, the
petitioner, as justice of the peace at Alabat, Tayabas, with the advice and
permission of the Philippine Commission. He continued in that position until
September 8, 1934, when, at his own request, "Pursuant to the provisions of
section 206 of the Revised Administrative Code," he was "transferred from the
position of justice of the peace for the municipality of Alabat, Province of
Tayabas, to the same position in the municipality of Perez, same province," by
a communication signed by the Governor-General from which the foregoing is
quoted. Tanada completed the age of sixty-five years on October 5 1934.

The applicable law is found in the last proviso to section 203 of the
Administrative Code, as inserted by Act No. 3899, and in the proviso to
section 206 of the same Code as last amended by Act No. 2768, which read
as follows:

"Sec. 203. Appointment and distribution of justices of the peace. * * *.

Provided, further, That the present justices and auxiliary justices of the peace
who shall, at the time this Act takes effect, have completed sixty-five years of
age, shall cease to hold office on January first, nineteen hundred and thirty-
three; and the Governor-General, with the advice and consent of the
Philippine Senate, shall make new appointments to cover the vacancies
occurring by operation of this Act."

"SEC. 206. Tenure of office Transfer from one municipality to another. A

justice of the peace having the requisite legal qualifications shall hold office
during good behavior unless his office be lawfully abolished or merged in the
jurisdiction of some other justice: Provided, That in case the public interest
requires it, a justice of the peace of one municipality may be transferred to
another."

ISSUE :
In Act No.3899 ,the natural and reasonable meaning of the language used
allows for no other deduction than that a justice of the peace appointed prior
to the Act's approval and who reached the age of sixty-five on September 13,
1934, subsequent to the Act's approval on November 16, 1931, and the date
fixed for cessation from office on January 1, 1933, is unaffected by the Act.
To reinforce what has just been said, it is obvious that determining legislative
purpose is the most important issue. However, it is as important that
legislative intent be determined from the language of the act itself. This
principle must be followed even if the court is convinced by circumstantial
evidence that the Legislature meant to pass something significantly different
than what it did. An obscurity cannot be manufactured to be cleaned up by
construction, and hidden meanings that contradict the language employed
cannot be discovered. Attempting to do so is a risky endeavor that is likely to
result in a statute being amended through judicial construction.

Counsel argued that the language of the proviso in question is somewhat

defective and does not clearly convey the legislative intent", and what the
Government desired was for the court to insert words and phrases in the law
in order to supply an intention for the legislature. . That we cannot do. By
liberal construction of statutes, courts from the language used, the subject
matter, and the purposes of those framing them are able to find out their true
meaning.

RULING

Act No. 3899 does not apply to a justice of the peace appointed prior to the
Act's approval who turned sixty-five years old after January 1, 1933, and a
transfer of a justice of the peace does not constitute an appointment, we
conclude that the Solicitor-General's special defenses must be rejected. As a
result, the writ will be granted, and the petitioner, Juan Tanada, will be
appointed justice of the peace in Perez, Tayabas.
 G.R. No. 180016. April 29, 2014 (Case Brief / Digest)

Title: Lito Corpuz vs. People of the Philippines

FACTS

Danilo Tangcoy, a private plaintiff, gave Lito Corpuz P98,000 in jewels to sell
on commission at the Admiral Royale Casino in Olongapo City on May 2,
1991.The agreement required Corpuz to either repay the selling profits or
return the unsold items within 60 days. Corpuz failed to accomplish either and
did not pay Tangcoy despite repeated demands. As a result, he was charged
with estafa under Article 315, paragraph (1), subparagraph (b) of the Revised
Penal Code.
Corpuz pled not guilty, claiming that the receipt in question was for a loan
taken from a third party in 1989, which had been erroneously dated and used
against him. Nonetheless, the RTC convicted him of estafa and issued a
penalty of imprisonment and indemnification.

In that, the Court of Appeals upheld the conviction with a change to the prison
term. Corpuz then appealed to the Supreme Court, raising concerns about the
admission of evidence, the claimed fault in the information, the proof of
demand, and the reliability of the private complainants.

ISSUE/S:

1. Whether photocopies of prosecution evidence admitted by the lower courts

violate the
best evidence rule.
2. Whether the criminal information for estafa was fatally defective.
3. Whether the prosecution proved the element of demand essential for
estafa.
4. Whether the prosecution’s case was proven beyond reasonable doubt.

RULING/S :

1. The photocopies of prosecution evidence admitted by the lower courts did

not violate the bnest evidence rule .Hence , Corpuz waived his objection to
the acceptance of photocopies by failing to raise it on time.
2. The criminal information for estafa was basically full, with objections to its
form and substance. The issue could not be presented for the first time on
appeal.
3. The prosecution provided sufficient evidence to support the offended
party's demand.
4. The accuracy of the private complaint was upheld, and the evidence was
adequate to establish the prosecution's case beyond a reasonable doubt.
Doctrine:
The elements of estafa with abuse of confidence under Article 315, paragraph
1 (b) of the
G.R. No. 180016. April 29, 2014 (Case Brief / Digest)
© 2024 - batas.org | 2
Revised Penal Code are: (a) the receipt of money or property by the offender
in trust or on
commission for administration; (b) misappropriation, conversion, or denial of
such receipt;
(c) the prejudice of another; and (d) the demand by the offended party.
 G. R. No. 116719. January 18, 1996 (Case Brief / Digest)

TITLE : People of the Philippines vs. Patricio Amigo alias “Bebot”

FACTS

In this case , verbal altercation due to vehicle collision resulted to a henious

crime on December 29, 1989, Benito Ng Suy and his children were driving a
Ford Fiera in Davao City when they collided with Virgilio Abogada's orange
Toyota Tamaraw. Patricio Amigo, alias "Bebot," a passenger in the Tamaraw,
had a verbal altercation with Benito following the incident. During the
altercation, Patricio questioned Benito if he was Chinese, which he affirmed.

Consequently, Patricio then departed, but returned with a five-inch knife,

which he used to stab Benito several times. Despite Benito's attempts to flee,
Patricio resumed the attack, causing thirteen knife wounds. Benito's daughter,
Jocelyn Ng Suy, attempted to get out of their vehicle to aid but was unable to
do so owing to a closed door, so she called for help. Bystanders did not
intervene, and Patricio fled. Benito was taken to a hospital, but died of sepsis
after being transferred to Manila for treatment.

Under Art. 248 of the Revised Penal Code, the trial court convicted Patricio of
murder and sentenced him to reclusion perpetua which originally the accused
was only charge with frustrated murder but resulted with the following death of
Benito that causes his charges to be accelerated.

ISSUE/S

1. Was the trial court correct in imposing the penalty of reclusion perpetua
given the constitutional provision abolishing the death penalty?
2. Did the trial court err in its computation of the penalty given the absence of
aggravated circumstances?
3. Is reclusion perpetua a cruel and harsh penalty in this context?

RULING/S

The Supreme Court affirmed the trial court’s decision.

Issue 1:
The complainant asserted that because the death penalty was abolished by
the 1987 Constitution, the penalty range should be reclusion temporal in its
medium length, which is 17 years, 4 months, and 1 day to 20 years. The
Supreme Court ruled that Section 19(1) of Article III of the Constitution does
not abolish the death sentence, but rather bans its installation and limits it to
reclusion perpetua. This approach aligns with the ruling in *People vs.
Muñoz*, which noted that Article III, Section 19(1) did not change the initial
penalty ranges except for the elimination of the death sentence.
 Issue 2:
The Court cited the *People vs. Muñoz* ruling, which stated that murder under
Article 248 of the Revised Penal Code, without any modifying conditions, is
penalized by reclusion perpetua for the medium duration. This idea was
strengthened in subsequent decisions, such as *People vs. Parojinog* and
*People vs. De la Cruz*, which established that the punishments imposed
must match the statutory intent.

Issue 3:
Penalties are established by legislative statute, and any changes or clemency
should be addressed by executive clemency or parliamentary reforms.The
Court declared that its accountability is to apply the law impartially and not to
hear appeals for pity. Hence , appaillant context of the decision on the charge
or reclusion perpetua was dismissed.

Doctrine
The Supreme Court reiterated the doctrine established in *People vs. Muñoz*
that Section 19(1) of Article III of the 1987 Constitution merely prohibits the
imposition of the death penalty and reduces it to reclusion perpetua, without
altering the other penalty periods prescribed by Article 248 of the Revised
Penal Code.
 G.R. No. 179334. April 21, 2015 (Case Brief / Digest)

TITLE : Secretary of the Department of Public Works and Highways v.

Spouses Heracleo and Ramona Tecson

The Department of Public Works and Highways (DPWH) acquired possession

of a block of property held by Heracleo and Ramona Tecson in 1940 in order
to build the MacArthur Highway. This was accomplished without any
expropriation processes. Years later, on December 15, 1994, the Tecsons
sought fair recompense for their land. The DPWH, through District Engineer
Celestino R. Contreras, offered P0.70 per square meter, citing a 1950
Provincial Appraisal Committee resolution. The Tecsons were dissatisfied and
demanded either the return of their property or compensation based on
current market value. They filed a complaint seeking recovery of possession
and damages. They received favorable verdicts in both the Regional Trial
Court (RTC) and the Court of Appeals (CA), which placed the land value at
P1,500.00 each.

In accordance to the DPWH's appeal, the Supreme Court partially permitted

the petition on July 1, 2013, altering the CA's ruling. It established a
compensation rate of P0.70 per square meter based on the 1940 land
valuation, with interest beginning in 1940 and continuing until complete
payment. The Tecsons, dissatisfied with the Supreme Court's judgment, filed
a Motion for Reconsideration, requesting that the Court reconsider the
compensation deemed just. The opposing opinions on the motion in the
Supreme Court's Third Division prompted the subject to be referred to the En
Banc. The Supreme Court revisited its decision from July 1, 2013, citing
substantial historical and procedural intricacies.

ISSUE/S

1. Whether the valuation for just compensation should be based on the land
value at the time of taking in 1940 or at a later time considering the prolonged
period before compensation.
2. Whether the awarded amount of P0.70 per square meter from 1940, with a
6% per annum interest, cnstitutes just compensation.
3. Whether the DPWH’s lack of formal expropriation proceedings and delayed
compensation constitutes a violation of the Tecsons’ rights, warranting
reconsideration of the compensation amount.

RULING

The court’s decision upheld that after assessing the different legal and
equitable aspects, the Supreme Court decided to uphold its determinations on
the amount of appropriate compensation, with revisions to the interest
awarded, and gave further compensation in the form of exemplary damages
and attorney's fees. The Court maintained that compensation should be
based on the property's value at the time of taking in 1940, citing legal
precedents to support this notion. Furthermore, it cited the DPWH's overreach
in seizing the property without formal expropriation proceedings as grounds
for imposing exemplary damages and attorney's costs.

*Doctrine:**This case reiterates the doctrine that just compensation for

expropriated property is to be based on the value at the time of taking.
Additionally, it underscores the principle that the lack of timely expropriation
proceedings and compensation can lead to additional damages beyond the
property’s market value to address the property owner’s loss of beneficial use.
 G.R. Nos. L-6355-56. August 31, 1953 (Case Brief / Digest)

Title: Endencia and Jugo vs. David: A Case on the Exemption of Judicial
Salaries from Income Tax in the Philippines

**Facts:**

This case consolidates the appeals of Justices Pastor M. Endencia and

Fernando Jugo against Saturnino David, the Collector of Internal Revenue,
challenging the constitutionality of Section 13 of Republic Act No. 590, which
authorizes the collection of income tax from judicial officers' salaries. The
appellants contended that this violates the constitutional guarantee that a
judge's compensation may not be reduced during their tenure in office.

Consequently, Justice Endencia sought a refund of P1,744.45 for income tax

collected on his 1951 salary as Associate Justice of the Court of Appeals,
while Justice Jugo requested a refund of P2,345.46 for taxes collected on his
salary while serving as Presiding Justice of the Court of Appeals and
Associate Justice of the Supreme Court in 1950.

The ruling was based on the Supreme Court's precedent in Perfecto vs.
Meer, which concluded that such taxation violated the Philippine
Constitution.The Court of First Instance of Manila ruled in favor of the justices,
ruling that the deduction of income tax from their salaries was an illegal
reduction in their compensation.

ISSUE/S

The legal issues examined included:

1. Whether the collection of income tax on the salaries of Justice Endencia
and Justice Jugo violated the constitutional safeguard against the diminution
of judicial salaries.
2. Whether Section 13 of Republic Act No. 590 could validly authorize the
taxation of judicial salaries without infringing upon the constitutional provision.
3. The broader question of the separation of powers, especially regarding the
extent of legislative power in relation to judicial interpretation and application
of the law.

RULING

The collection of income tax on the salaries of Justice Endencia and Justice
Jugo violated the constitutional safeguard against the diminution of judicial
salaries as in the provisions of income tax of judicial officers .It further
elaborated that legislative attempts to interpret or apply the Constitution—
through instruments like RA 590—encroached upon the judiciary’s exclusive
domain, thereby violating the principle of separation of powers entrenched in
the governance framework.
Lopez vs Court of Appeals

FACTS

The case Lopez vs. Court of Appeals (G.R. No. 104158), decided on
November 6, 1992, involves the retirement benefits of Galicano Manapat, who
retired from government service and later sought additional retirement
benefits after reemployment.