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Jurisdiction Digests

The document outlines various legal cases involving different government agencies, including the Commission on Audit and the Insurance Commission, focusing on jurisdictional issues and rulings. It highlights significant rulings such as the COA's authority over disallowances and the Insurance Commission's lack of jurisdiction over agency contracts. Additionally, it discusses cases related to labor disputes and the jurisdiction of civil courts versus labor tribunals.
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0% found this document useful (0 votes)
11 views33 pages

Jurisdiction Digests

The document outlines various legal cases involving different government agencies, including the Commission on Audit and the Insurance Commission, focusing on jurisdictional issues and rulings. It highlights significant rulings such as the COA's authority over disallowances and the Insurance Commission's lack of jurisdiction over agency contracts. Additionally, it discusses cases related to labor disputes and the jurisdiction of civil courts versus labor tribunals.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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GROUP 1 ( Atos, Ravalo, Crucis, Bejer, Cajandab, Laura, Magpantay, Lawenko)

1. LAND REGISTRATION AUTHORITY


GOMEZ v. CA (G.R. No. 77770, 1988)
ANGELES v. SOJ (G.R. No. 142549, 2010)
BARANDA v. GUSTILO (G.R. No. 81163, 1988)
ROD v. CAIJI (G.R. No. L-7261, 1956)
GABRIEL v. ROD-Rizal (G.R. No. L-17956, 1963)
ALMIROL v. ROD-Agusan (G.R. No. L-22486)
CALALANG v. ROD-Quezon City (G.R. No. L-76265, 1994)
2. COMMISSION ON AUDIT
BAYANI F. FERNANDO vs. COA G.R. Nos. 237938 and 237944-45. December 04, 2018
FACTS:
The CoA issued an order authorizing the Fraud Audit and Investigation Office to
conduct a special audit on the disbursements of the Executive Committee of the
MMFF for year 2002-2008. It then found that petitioner Fernando receive payments
from the executive committee of the MMFF for the Special Projects/Activities of the
Metro Manila Development Authority (MMDA) sourced from the advertising
sponsorship of the MMFF on different dates which was sourced from nontax
revenues from the said Executive Committee. The COA then issued notices of
disallowance against petitioner covering the amounts stating that the amount
receive by the petitioner is disallowed because the check was encashed and not
issued an official receipt by the collecting officer of the MMDA which constitutes an
irregular transaction.
Petitioner contends that the COA has no jurisdiction over the Executive Committee
of the MMFF, an organization composed of private individuals from the movie
industry, and whose funds come from non-tax revenues and private donations while
respondent argues that he Executive Committee of the MMFF is a government
instrumentality created under Proclamation No. 145910 dated July 9, 1975,
performing a public purpose. It also argues that the committee's funds are public in
nature considering the public purpose it serves, which is to provide fund assistance
to film-related organizations.
Issue: WoN the Executive Committee of the MMFF is subject to COA’s jurisdiction
Ruling:
Yes. Section 2, Article IX-D of the 1987 Constitution provides for the COA's audit
jurisdiction, includes “SECTION 2. (1) The Commission on Audit shall have the power,
authority, and duty to examine, audit, and settle all accounts pertaining to the
revenue and receipts of, and expenditures or uses of funds and property, owned or
held in trust by, or pertaining to, the Government, or any of its subdivisions,
agencies, or instrumentalities, including government-owned or controlled
corporations with original charters, and on a post-audit basis: (a) constitutional
bodies, commissions and offices that have been granted fiscal autonomy under t4is
Constitution; (b) autonomous state colleges and universities; (c) other government-
owned or controlled corporations and their subsidiaries; and (d) such non-
governmental entities receiving subsidy or equity, directly or indirectly, from or
through the Government, which are required by law or the granting institution to
submit to such audit as a condition of subsidy or equity. However, where the internal
control system of the audited agencies is inadequate, the Commission may adopt
such measures, including temporary or special pre-audit, as are necessary and
appropriate to correct the deficiencies. It shall keep the general accounts of the
Government and, for such period as may be provided by law, preserve the vouchers
and other supporting papers pertaining thereto.

COA v FERRER
FACTS:
This case involves the Commission on Audit (COA) challenging the orders of the
Regional Trial Court (RTC) of Pili, Camarines Sur, which denied the dismissal of
petitions filed by Luis Raymund F. Villafuerte, Jr., the former Governor of Camarines
Sur. The controversy began during Villafuerte’s term, wherein several disbursements
for provincial projects were audited by the COA and found to be deficient, non-
compliant with the Government Procurement Act, and categorized as unnecessary
expenditures. The COA issued ten Notices of Disallowance (NDs) for various
transactions ranging from engagements for services to mobilization fees paid to
contractors. Villafuerte did not contest these NDs, leading to Notices of Finality of
Decision (NFDs). Subsequently, Villafuerte filed petitions for certiorari and
prohibition with the RTC, which issued and extended a temporary restraining order
(TRO) against the COA’s implementation of the NDs. Petitioners, represented by the
Office of the Solicitor General (OSG), opposed the issuance of a writ of injunction,
arguing the RTC’s lack of jurisdiction, the finality of the NDs, failure to exhaust
administrative remedies, and the absence of requisites for the writ. Despite
opposing motions, the RTC proceeded, leading the petitioners to escalate the matter
to the Supreme Court (SC).
ISSUE:
Whether the RTC committed grave abuse of discretion in denying the motion to
dismiss the petitions for certiorari and prohibition filed by Villafuerte.
RULING: The Supreme Court ruled in favor of the COA and the provincial auditors.
The COA has primary jurisdiction over issues involving disallowances. The RTC does
not have the authority to directly determine questions on COA's alleged grave abuse
of discretion. Allowing trial courts to issue writs of certiorari against NDs issued by
provincial auditors would cause unnecessary delay in the audit process and burden
the already saturated trial court dockets. The NDs issued by the COA had become
final and executory as Villafuerte failed to file an appeal within the reglementary
period. The RTC could no longer alter the disallowances and should have dismissed
Villafuerte's petitions. The doctrine of immutability of judgments bars courts from
modifying decisions that have already attained finality.
3. COMMISSION ON ELECTION

4. INSURANCE COMMISSION
Almendras Mining Corporation v. Office of the Insurance Commission, G.R. No.
72878, April 15, 1988
FACTS: Private respondent Ramon Montilla Paterno, Jr. and petitioner Philamlife
entered into a Contract of Agency.
Thereafter, private respondent sent a letter-complaint dated April 17, 1986 to the
public respondent Insurance Commissioner (Comissioner) alleging some problems in
the implementation of the subject Contract of Agency.
Later, the respondent Commissioner requested petitioner Philamlife to comment on
said letter-complaint to which the latter replied to particularize the allegations of the
letter-complaint so that it can intelligently answer the allegations.
After some procedural niceties, a hearing was held by respondent Commissioner on
the letter-complaint.
Later, private respondent submitted a letter of specification detailing the allegations
in his letter-complaint. It prayed that the provisions on charges and fees in the
Contract of Agency, and its implementing provisions, be declared null and void.
The respondent Commissioner then furnished petitioner a copy of the letter of
specification.
Later, petitioner asked the respondent Commission to first rule on the question of
jurisdiction over the subject matter of the letter-complaint and the legal standing of
private respondent.
Thereafter, the respondent Commissioner notified both parties for another hearing.
Petitioner then filed a Motion to Quash Subpoena/Notice on the grounds of, among
others, lack of jurisdiction over the subject matter.
However, the respondent Commissioner denied the Motion to Quash.
Hence, this petition for certiorari filed by the petitioner directly with the SC. Hence,
this petition.
ISSUE: Whether the Insurance Commission has jurisdiction over the subject matter of
the letter-complaint filed by private respondent.
HELD: The Court ruled in the negative. It ratiocinated in this wise:
“The main issue to be resolved is whether or not the resolution of the legality of the
Contract of Agency falls within the jurisdiction of the Insurance Commissioner.
Private respondent contends that the Insurance Commissioner has jurisdiction to
take cognizance of the complaint in the exercise of its quasi-judicial powers. The
Solicitor General, upholding the jurisdiction of the Insurance Commissioner, claims
that under Sections 414 and 415 of the Insurance Code, the Commissioner has
authority to nullify the alleged illegal provisions of the Contract of Agency.
The general regulatory authority of the Insurance Commissioner is described in
Section 414 of the Insurance Code, to wit:
[The Court then quoted Sec. 414.]
On the other hand, Section 415 provides:
[The Court also quoted Sec. 415.]
A plain reading of the above-quoted provisions show that the Insurance
Commissioner has the authority to regulate the business of insurance, which is
defined as follows:

[The Court quoted Sec. 2(2) of the Insurance Code.]


Since the contract of agency entered into between Philamlife and its agents is not
included within the meaning of an insurance business, Section 2 of the Insurance
Code cannot be invoked to give jurisdiction over the same to the Insurance
Commissioner. Expressio unius est exclusio alterius.
With regard to private respondent's contention that the quasi-judicial power of the
Insurance Commissioner under Section 416 of the Insurance Code applies in his case,
we likewise rule in the negative. Section 416 of the Code in pertinent part, provides:
[The Court then quoted Sec. 416.]
A reading of the said section shows that the quasi-judicial power of the Insurance
Commissioner is limited by law "to claims and complaints involving any loss, damage
or liability for which an insurer may be answerable under any kind of policy or
contract of insurance, . . ." Hence, this power does not cover the relationship
affecting the insurance company and its agents but is limited to adjudicating claims
and complaints filed by the insured against the insurance company.
While the subject of Insurance Agents and Brokers is discussed under Chapter IV,
Title I of the Insurance Code, the provisions of said Chapter speak only of the
licensing requirements and limitations imposed on insurance agents and brokers.
The Insurance Code does not have provisions governing the relations between
insurance companies and their agents. It follows that the Insurance Commissioner
cannot, in the exercise of its quasi-judicial powers, assume jurisdiction over
controversies between the insurance companies and their agents.
We have held in the cases of Great Pacific Life Assurance Corporation v. Judico, 180
SCRA 445 (1989), and Investment Planning Corporation of the Philippines v. Social
Security Commission, 21 SCRA 904 (1962), that an insurance company may have two
classes of agents who sell its insurance policies: (1) salaried employees who keep
definite hours and work under the control and supervision of the company; and (2)
registered representatives, who work on commission basis.
Under the first category, the relationship between the insurance company and its
agents is governed by the Contract of Employment and the provisions of the Labor
Code, while under the second category, the same is governed by the Contract of
Agency and the provisions of the Civil Code on the Agency. Disputes involving the
latter are cognizable by the regular courts.”
WHEREFORE, the petition is GRANTED. The Order dated November 6, 1986 of the
Insurance Commission is SET ASIDE.
5. PHILIPPINE ATOMIC ENERGY COMMISSION

GROUP 2 ( BELEN, BURCE, DENSO, JIMENEZ, LABAYEN, RAZAL, URETA)


6. Civil Service Commission
OLANDA V. BOGAYONG G.R. No. 140917, 10 October 2003
BUENAFLOR V. RAMIREZ JR. G.R. No. 201607, 15 February 2017
7. Office of the President
GO, Jr. v. COURT OF APPEALS and OFFICE OF THE PRESIDENT, G.R. No. 172027, July
29, 2010
CATANES, et al. v. ATIENZA JR., DENR, et al., G.R. No. 191537, September 14, 2016
BARAIRO v. OFFICE OF THE PRESIDENT, G.R. No. 189314, June 15, 2011
MORAN v. OFFICE OF THE PRESIDENT, AS REPRESENTED BY THE EXECUTIVE
SECRETARY HON. EDUARDO ERMITA AND PGA CARS, INC., G.R. NO. 192957
SEPTEMBER 29 2014
PEÑAFRANCIA SHIPPING CORPORATION, et al. v. 168 SHIPPING LINES, INC., G. R. NO.
188952 September 21 2016

8. National Labor Relations Commission


Halagueña et al. vs. Philippine Airlines Inc. G.R. No. 172013. October 02, 2009
Doctrine: Jurisdiction of a court over a case is determined by the material allegations
and the character of the relief sought irrespective of whether the plaintiff is entitled
to such relief. Not all disputes involving employer-employee relationships are within
the exclusive jurisdiction of labor tribunals, those requiring the application of general
civil law are for the regular courts. The Voluntary Arbitrator or panel of Voluntary
Arbitrators lack the power to decide constitutional issues. Moreover, provisions of
law, especially peremptory provisions dealing with matters heavily impressed with
public interest, are deemed written into the contract and may not be contracted
away
Facts: A group of female flight attendants, members of the Flight Attendants and
Stewards Association of the Philippines (FASAP), challenged the compulsory
retirement age of 55 for females and 60 for males stipulated in the Collective
Bargaining Agreement (CBA) between their labor union and Philippine Airlines (PAL).
On July 11, 2001, the PAL-FASAP CBA established the disputed provisions. The
petitioners considered it discriminatory and demanded equal treatment with male
counterparts. Despite written protests and demands, the provision remained.
Consequently, the petitioners filed a Special Civil Action for Declaratory Relief with
the RTC of Makati City, which resulted in the issuance of a TRO against the
enforcement of the discriminatory retirement age. PAL moved to question the RTC’s
jurisdiction and to lift the TRO. The RTC maintained its jurisdiction and issued a
preliminary injunction, halting the implementation of the discriminatory CBA
provision. Dissatisfied, PAL appealed to the CA, which held that the RTC had no
jurisdiction, annulling its orders and directing it to dismiss the case, considering the
issue a labor dispute. Petitioners then sought recourse in the Supreme Court.
Issues: 1. Whether the RTC has jurisdiction over an action challenging the legality or
constitutionality of provisions in a CBA. 2. Whether the CA erred in considering the
subject matter as a labor dispute and subsequently annulling the orders of the RTC.
Ruling: The Supreme Court found that the RTC has jurisdiction over the petitioners’
action as it involves a question of constitutionality, not merely labor law exclusively
cognizable by labor tribunals. The issue at hand required the application of the
Constitution, labor statutes, and international treaties rather than merely a labor
dispute under the Labor Code or CBA. The Court remanded the case to the RTC to
ascertain the facts and adjudicate the merits of the petition for declaratory relief.
The CA’s decision was reversed and set aside, and the RTC was directed to proceed
with the case with deliberate dispatch.
Tolosa vs. National Labor Relations Commission et al., G.R. No. 137691, April 10,
200
Facts: Evelyn Tolosa, the widow of Captain Virgilio Tolosa, filed a claim after
her husband, Captain Tolosa, a ship master employed by Qwana-Kaiun through its
manning agent Asia Bulk Transport Phils. Inc., passed away. Captain Tolosa had a
salary of US$1700 with a US$400 monthly overtime allowance. He commenced his
contract on November 1, 1992, in Yokohama, Japan.In her complaint, she alleged
that while leaving Yokohama on November 6, 1992, Captain Tolosa was soaked in
rain during ‘channeling activities.’ The day after, he developed a slight fever, which
worsened over ten days leading to his death on November 18, 1992. Between
November 11-15, Captain Tolosa experienced high fever and was debilitated by
diarrhea. Despite preventive measures, his condition worsened, leading to his
untimely death. His colleagues sought medical advice from the U.S. Coast Guard in
Honolulu due to his deteriorating condition. Upon the death of Captain Tolosa,
Evelyn Tolosa sought legal action against Qwana-Kaiun, Asia Bulk Transport, Pedro
Garate, and Mario Asis by filing a complaint with the POEA (later transferred to the
National Labor Relations Commission (NLRC) due to jurisdiction changes), alleging
negligence on the ship staff’s part.
Labor Arbiter Vladimir Sampang ruled in favor of Evelyn Tolosa, awarding a
total computed damage of P6,737,200, inclusive of damages and legal interest. On
an appeal by private respondents, the NLRC overturned the Labor Arbiter’s decision
citing lack of jurisdiction, concluding that the claim arose from torts, not within the
ambit of labor tribunals’ jurisdiction. The Court of Appeals upheld the NLRC’s
determination that the case did not arise from an employer-employee relationship,
dismissing it without prejudice to refiling in the correct court.
Issue: Whether the labor arbiter and NLRC have jurisdiction over the
petitioner’s action which is purportedly based on an employment-related claim but
filed on damages typically under tort law.
Ruling: The Court focused on the distinction between torts and claims arising
from an employer-employee relationship. Upon analysis, it ruled that the action was
based on quasi-delict (tort), outside the jurisdiction of NLRC. Labor laws primarily
cover actions directly related to employment conditions and payments, not tort
actions resulting from negligence unconnected to these factors.
The Court reiterated that claims must stem directly from labor relations for
labor tribunals to possess jurisdiction. As Evelyn Tolosa’s claims were based on
tortious acts observed from negligence by colleagues not employer-related, it rightly
belonged to regular civil courts which handle tort claims.
CORAZON C. SIM, vs. NLRC and EQUITABLE PCI-BANK G,R. NO. 157376 : October 2,
2007
Facts: Petitioner Corazon Sim filed a case for illegal dismissal with the Labor
Arbiter. She was initially employed by respondent Equitable PCI Bank as Italian
Remittance Marketing Consultant to the Frankfurt Representative Office and later as
Manager. She was dismissed due to loss of trust and confidence based
mismanagement and misappropriation of funds. Equitable, a Philippine corporation,
denied any employer-employee relationship between them and sought the dismissal
of the complaint.
In 2001, Labor Arbiter dismissed the case for want of jurisdiction and lack of
merit. With regard to jurisdiction, stated that, “the labor relations system in the
Philippines has no extra-territorial jurisdiction. It is limited to the relationship
between labor and capital within the Philippines. Since complainant was hired and
assigned in a foreign land, although by a Philippine Corporation, it follows that the
law that govern their relationship is the law of the place where the employment was
executed and her place of work or assignment. On this premise, the Italian law
allegedly provides severance pay which was applied and extended to herein
complainant.
NLRC, on appeal: affirmed Labor Arbiter’s decision and dismissed the appeal
for lack of merit. Without filing a motion for reconsideration with NLRC, petitioner
went to the Court of Appeals via petition for certiorari. NLRC dismissed petition due
to petitioner’s non-filing of a motion for reconsideration.
Issue: Whether or not the Labor Arbiter has jurisdiction over a labor dispute
between a Philippine corporation and its employee which it assigned to work for a
foreign land.
Ruling: Yes. Labor arbiters have original and exclusive jurisdiction over claims
arising from employer-employee relations, including termination disputes involving
all workers, among whom are overseas Filipino workers. Whether employed locally
or overseas, all Filipino workers enjoy the protective mantle of Philippine labor and
social legislation, contract stipulations to the contrary notwithstanding. This
pronouncement is in keeping with the basic public policy of the State to afford
protection to labor, promote full employment, ensure equal work opportunities
regardless of sex, race or creed, and regulate the relations between workers and
employers. For the State assures the basic rights of all workers to self-organization,
collective bargaining, security of tenure, and just and humane conditions of work
[Article 3, Labor Code of the Philippines].
Moreover, Section 10 of Republic Act (R.A.) No. 8042, or the Migrant Workers
and Overseas Filipinos Act of 1995, provides:
SECTION 10. Money Claims. - Notwithstanding any provision of law to the
contrary, the Labor Arbiters of the National Labor Relations Commission (NLRC) shall
have the original and exclusive jurisdiction to hear and decide, within ninety (90)
calendar days after the filing of the complaint, the claims arising out of an employer-
employee relationship or by virtue of any law or contract involving Filipino workers
for overseas deployment including claims for actual, moral, exemplary and other
forms of damages.
Also, Section 62 of the Omnibus Rules and Regulations Implementing R.A. No.
8042 provides that the Labor Arbiters of the NLRC shall have the original and
exclusive jurisdiction to hear and decide all claims arising out of employer-employee
relationship or by virtue of any law or contract involving Filipino workers for
overseas deployment including claims for actual, moral, exemplary and other forms
of damages, subject to the rules and procedures of the NLRC.
9. Bureau of Patents, Trademarks and Technology Transfer
MANUEL T. ZULUETA VS. CYMA GREEK TAVERNA CO., G.R. No. 205699, January 23,
2023
10. Government Service Insurance System
PHILIPPINE NATIONAL BANK, PETITIONER, VS. DEANG MARKETING CORPORATION
Facts:
1. Background: The respondents, Deang Marketing Corporation and Berlita Deang,
entered into a restructured loan agreement with the Philippine National Bank (PNB),
allegedly transforming an outstanding loan to a dacion en pago as part of a February
21, 2005 Consolidation and Restructuring Agreement.
2. Filing of Complaint: The respondents filed a complaint against PNB on April 20,
2006, before the RTC of Angeles City, Branch 57, seeking reformation of the contract
and specific performance, arguing the agreement was intended to be a dacion en
pago with the consideration of a 7-year term loan of P36,483,699.45.
3. Service and Responses: PNB was served summons on April 20, 2006. The due date
for the bank to file an Answer or other pleading was May 5, 2006. On May 14, 2006,
PNB filed a Motion for Extension of Time to File Answer, which was received on May
15, 2006, late by ten days from the deadline. The Motion for Extension was drafted
misleadingly to appear timely.
4. Procedural Motions: On May 15, 2006, respondents filed a Motion to Declare
Defendant in Default, which was set for hearing on May 24, 2006. Despite the
respondents’ motion, on May 16, 2006, the RTC granted PNB’s Motion for Extension
and dismissed the respondents’ motion for default. Respondents filed a Motion for
Reconsideration against this order, which was later denied.
5. Court of Appeals Involvement: Dissatisfied, the respondents sought a certiorari to
the Court of Appeals. The CA, on February 26, 2007, reversed the RTC, declaring PNB
in default and expunging its Answer from the records. PNB’s Motion for
Reconsideration was denied by the CA on May 16, 2007.
6. Supreme Court Intervention: Seeking relief, PNB filed a Petition for Review with
the Supreme Court challenging the CA’s decision to declare it in default and remove
its Answer from the case records.
Issues:
1. Was the Motion for Extension of Time to File Answer untimely filed, and should
PNB have been declared in default?
2. Did the RTC exercise correct discretion in granting PNB’s late Motion for
Extension?
3. Is there a necessity for the Supreme Court to exercise leniency in procedural rules
in favor of PNB?
Court’s Decision:
1. On Timeliness and Default:
– The Supreme Court upheld the decision of the CA that PNB’s Motion for Extension
was untimely. The extension must be filed before the prescribed period lapses unless
an excusable justification is provided. Here, PNB filed the Motion 10 days late
without sufficient reason, and thus, the default declaration by the CA was deemed
proper.
2. RTC’s Exercise of Discretion:
– The Court identified the trial court’s action granting a belated extension as
arbitrary since there was no valid discretion exercised when a motion is filed post-
deadline without proper justification. The trial court failed to heed the procedural
rules and was misled by PNB’s non-compliance narratives.
3. Leniency in Procedural Rules:
– While generally favoring substantive adjudication over procedural technicalities,
the Court found PNB’s counsel engaged in a series of misrepresentations and
procedural missteps amounting to bad faith. The leniency could not be applied
without effectively condoning these actions. Thus, the Court denied relief sought by
PNB.
BERLITA DEANG G.R. No. 177931, December 08, 2008

GROUP 3 (BITANCUR, SALANDO, DE LEON, TAYO, SERTAN, BOLATA, PALOMAR,


TABUZO)
11. Philippine Competition Commission
Court of appeals decision
12. Employees Compensation Commission
SALMONE vs ECC G.R. No. 142392, September 26, 2000
Salmone was employed as sewer by Paul Geneve Entertainment Corp. engaged in
the business of sewing costumes, gowns and casual and formal dresses. Eventually,
she started to feel chest pains. She then filed a leave of absence from work as the
chest pains became unbearable. After subjecting herself to medical examination, she
was found to be suffering from Atherosclerotic heart disease, Atrial Fibrillation, and
Cardiac Arrhythmia. Upon recommendation of her doctor, she resigned from her
work hoping that with a much-needed complete rest, she will be cured. She later
filed a disability claim with the SSS. SSS denied her claim of EC benefit. ECC affirmed
the denial of SSS on the ground that there was no substantial evidence that her
illness was occupational or work-related. There was no substantial evidence showing
that her illness was occupational or work-connected in her position as overall
custodian and officer in charge of the sewing department. CA dismissed Salmone’s
appeal on the same ground.
Issue: Whether or not Salmone’s sickness was compensable.
Held: The Supreme Court held in the affirmative. It held that the Salmone’s sickness
was compensable. SC orders SSS to pay Salmone full disability benefits as provided
under P.D. 626. In order for the employee to be entitled to sickness or death
benefits, the sickness or death resulting therefrom must be or must have resulted
from either (a) any illness definitely accepted as an occupational disease listed by the
ECC, or (b) any illness caused by employment, subject to proof that the risk of
contracting the same is increased by working conditions. In this case, Salmone has
shown by substantial evidence that in the course of her employment, due to work-
related stress, she suffered from severe chest pains which caused her to take a rest,
per physician's advice, and ultimately to resign from her employment. She was
diagnosed as suffering from "atherosclerotic heart disease, atrial fibrillation, and
cardiac arrhythmia" which is included within the term of cardiovascular diseases as
listed in compensable occupational diseases in Board Resolution No. 12009-18, s.
2012. Hence, no further proof of casual relation between the disease and claimant’s
work is necessary. What the law requires is a reasonable work-connection and not a
direct causal relation. It is enough that the hypothesis on which the workmen's claim
is based in probable, not certainty.
LAZO vs ECC G.R. No. 78617, June 18, 1990
Salvador Lazo is a security guard at the Central Bank of the Philippines, who worked
from 2PM to 10PM. On June 18, 1986, since the reliever or the substitute guard was
not around, Lazo rendered overtime duty until 5AM of the following day. He sought
permission to leave early to take home a sack of rice to Binangonan, Rizal.
On his way home, around 6AM on June 19, 1986, the jeepney he was riding on
flipped due to slippery roads, causing him injuries. Lazo filed a claim for disability
benefits under PD 626, as amended, but was denied by GSIS, stating that the
accident occurred while he was not at his workplace performing duties. Upon denial,
he filed an appeal with the ECC. The ECC affirmed the denial, emphasizing that the
accident occurred far from his workplace and while attending to a personal matter.
Lazo then appealed to the Supreme Court saying that the injuries sustained on his
way from work should be compensable under the “arising out of or in the course of
employment” principle.
Issue: Whether Lazo's injury sustained while traveling home after work comes within
the meaning of and intendment of the phrase ‘arising out of and in the course of
employment.’
Ruling: The Supreme Court ruled in the affirmative. The injuries Lazo sustained due
to the vehicular accident on his way home from work should be construed as "arising
out of or in the course of employment" and thus, compensable. For the injury to
compensable, the injury must be the result of accident arising out and in the course
of the employment. If it can be proven that, at the time of the contingency, the
employee was acting within the scope of employment and performing an act
reasonably necessary or incidental to it, then the injuries sustained by reason of
employment are compensable regardless of the place where the incident occurred.
In the case at bar, it can be seen that Lazo left his station at the Central Bank several
hours after his regular time off, because the reliever did not arrive, and so Lazo was
asked to go on overtime. After permission to leave was given, he went home. Lazo
was acting within the scope of employment and performing an act reasonably
necessary or incidental to it. There is no evidence on record that Lazo deviated from
his usual, regular homeward route or that interruptions occurred in the journey.
Hence, The phrase "arising out of or in the course of employment" includes a
reasonable time and space for travel to and from the workplace. As agent charged by
the law to implement social justice guaranteed and secured by the Constitution, the
ECC should adopt a liberal attitude in favor of the employee in deciding claims for
compensability, especially where there is some basis in the facts for inferring a work
connection to the accident. In consonance to the spirit of the law, 'all doubts in the
implementation and interpretation of the provisions of the Labor Code including its
implementing rules and regulations shall be resolved in favor of labor.'
13. Social Security Commission
REPUBLIC OF THE PHILIPPINES, v. ASIAPRO COOPERATIVE G.R. No. 172101
November 23, 2007
Facts:
Respondent Asiapro Cooperative is composed of owners-members with
primary objectives of providing them savings and credit facilities and livelihood
services. In discharge of said objectives, Asiapro entered into several service
contracts with Stanfilco. Sometime later, the cooperative owners-members
requested Stanfilco’s help in registering them with SSS and remitting their
contributions.
Petitioner SSS informed Asiapro that being actually a manpower contractor
supplying employees to Stanfilco, it must be the one to register itself with SSS as an
employer and remit the contributions. Respondent continuously ignoring the
demand of SSS the latter filed before the SSC. Asiapro alleges that there exists no
employer-employee relationship between it and its owners-members. SSC ruled in
favor of SSS. On appeal, CA reversed the decision.
Issue:
Whether or not the Petitioner SSC has jurisdiction over the case filed by
Petitioner SSS against the Respondent.
Ruling:
Yes. The Supreme Court ruled that the allegations in the complaint, and not
the defenses set up in the Answer or the Motion to Dismiss, determine which court
has jurisdiction over an action. The said principle applies even to quasi-judicial
bodies. Further, the Court held that the Labor Code provides that the NLRC’s
jurisdiction on money claims is not exclusive. In fact, the question on the existence of
an employer-employee relationship for the purpose of determining coverage of the
SSS is explicitly excluded from the jurisdiction of the NLRC, and falls within the
jurisdiction of the SSC, which is primarily charged to settle disputes arising under the
Social Security Law.

SOCIAL SECURITY SYSTEM vs. ATLANTIC GULF AND PACIFIC COMPANY OF MANILA,
INC. G.R. No. 175952 April 30, 2008
Facts:
On February 13, 2004, Atlantic Gulf and Pacific Company of Manila, Inc. (AG&P) and
Semirara Coal Corporation (SEMIRARA) filed a complaint for specific performance
and damages against the Social Security System (SSS) before the RTC of Batangas
City. They alleged that in 2000, AG&P acknowledged its delinquency in SSS
contributions and proposed to settle via dacion en pago using real property, a
proposal SSS approved in 2001 for both AG&P and SEMIRARA’s combined obligations
of P29.26 million.
Despite AG&P’s compliance, SSS delayed execution and later demanded over P40M
due to added penalties. The RTC dismissed the case for lack of jurisdiction, ruling it
involved a dispute over SSS contributions under the exclusive jurisdiction of the
Social Security Commission.
The Court of Appeals reversed the dismissal, holding that the complaint was for
specific performance regarding the execution of the previously approved dacion en
pago, thus falling under the RTC’s jurisdiction as a case incapable of pecuniary
estimation. SSS’s motion for reconsideration was denied, prompting them to elevate
the jurisdictional issue before the Supreme Court.

Issue:
Whether or not the Social Security Commission has jurisdiction to entertain a
controversy arising from the non-implementation of a dacion en pago agreed upon
by the parties as a means of settlement of private respondents’ liabilities.

Ruling:
No. The Supreme Court ruled that the RTC has jurisdiction because the case is an
action for specific performance of the dacion en pago agreement. An action for
specific performance is classified as one incapable of pecuniary estimation.

The pertinent provision of law detailing the jurisdiction of the Commission is Section
5(a) of R.A. No. 1161, as amended by R.A. No. 8282, otherwise known as the Social
Security Act of 1997, to wit:
SEC. 5. Settlement of Disputes. (a) Any dispute arising under this Act with respect to
coverage, benefits,
contributions and penalties thereon or any other matter related thereto, shall be
cognizable by the Commission, and any case filed with respect thereto shall be heard
by the Commission, or any of its members, or by hearing officers duly authorized by
the Commission and decided within the mandatory period of twenty (20) days after
the submission of the evidence.
The filing, determination and settlement of disputes shall be governed by the rules
and regulations promulgated by the Commission." The law clearly vests upon the
Commission jurisdiction over "disputes arising under this Act with respect to
coverage, benefits, contributions and penalties thereon or any matter related
thereto..." Dispute is defined as "a conflict or controversy."

Hence, once a dacion en pago agreement is reached and approved by the SSS to
settle delinquencies, a subsequent dispute regarding the implementation or
enforcement of that agreement is not a "dispute arising under (the SSSJ Act with
respect to coverage, benefits, contributions and penalties thereon" falling under the
exclusive jurisdiction of the Social Security Commission. Instead, it is a contractual
dispute for specific performance, an action incapable of pecuniary estimation, which
is properly cognizable by the Regional Trial Court.

14. Central Board of Assessment Appeal


Alejandro B. Ty vs. Hon. Aurelio C. Trampe et al., GR. NO. 117577 December 1, 1995
National Power Corporation vs. Provincial Government of Bulacan G.R. No. 207140
January 30, 2023
15. Construction Industry Arbitration Commission
(1)Chua v. De Castro -G.R. No. 235894, 5 February 2024
(2) WYETH PHILIPPINES, INC., PETITIONER, VS. CONSTRUCTION INDUSTRY
ARBITRATION COMMISSION ET.AL G.R. No. 220045-48, June 22, 2020

GROUP 4 (BANEZ, BONOS, BIGOL, DELOS SANTOS, BORSIGUE, DURAN, FORESCAL)


16. Human Settlements Adjudication Commission
VELASQUEZ V. LISONDRA LAND G.R. NO. 231290, AUGUST 27, 2020
FACTS:
Perfecto Velasquez, Jr. entered a joint venture with Lisondra Land, Inc. to develop a
memorial park, but due to various alleged breaches—including failure to secure
permits, financial mismanagement, and unauthorized transactions—Perfecto sued
for breach of contract. The RTC initially assumed jurisdiction, but the CA ruled the
HLURB had exclusive jurisdiction under PD No. 1344. Perfecto then filed a case
before the HLURB, which ruled in his favor. Lisondra Land appealed up to the Office
of the President, then to the CA, which reversed the decision, holding that the
HLURB only had jurisdiction over cases filed by buyers of subdivision or
condominium units—not business partners like Perfecto. The Supreme Court
clarified that HLURB’s jurisdiction is limited to specific disputes involving real estate
buyers and does not extend to business partners alleging unsound practices. Hence,
the dispute should be resolved by regular courts, not the HLURB.
ISSUE:
Whether or not the HLURB has jurisdiction.
RULING:
The jurisdiction of the HLURB to hear and decide cases is determined by the nature
of the cause of action, the subject matter or property involved and the parties.
The scope and limitation of the HLURB's jurisdiction is well-defined. Its precursor, the
National Housing Authority (NHA), was vested under PD No. 957 with exclusive
jurisdiction to regulate the real estate trade and business. Thereafter, the NHA's
jurisdiction was expanded under Section 1 of PD No. 1344 to include adjudication of
the following cases: (a) unsound real estate business practices; (b) claims involving
refund and any other claims filed by subdivision lot or condominium unit buyer
against the project owner, developer, dealer, broker or salesman; and (c) cases
involving specific performance of contractual and statutory obligations filed by
buyers of subdivision lot or condominium unit against the owner, developer, broker
or salesman. In 1981, Executive Order (EO) No. 648 transferred the regulatory and
quasi-judicial functions of the NHA to Human Settlements Regulatory Commission. In
1986, EO No. 90 changed the name of the Commission to HLURB.
Notably, the cases before the HLURB must involve a subdivision project, subdivision
lot, condominium project or condominium unit. Otherwise, the HLURB has no
jurisdiction over the subject matter. Similarly, the HLURB's jurisdiction is limited to
those cases filed by the buyer or owner of a subdivision or condominium and based
on any of the causes of action enumerated under Section 1 of PD No. 1344. The
following cases are instructive.
Here, it is undisputed that Perfecto is a business partner of Lisondra Land and is not
a buyer of land involved in development. Applying the above case doctrines,
Perfecto has no personality to sue Lisondra Land for unsound real estate business
practices before the HLURB. The regular courts have authority to decide their
dispute.
FRANCISCO V. DEL CASTILLO G.R. NO. 236726, SEPTEMBER 14, 2021
FACTS:
Atty. Pablo B. Francisco, a board member of Brookside Residents Association, Inc.
(BRAI), sought to inspect the association's financial records from 2008 to 2013.
When denied access by fellow board members Melanio Del Castillo and Sandra
Bernales, he filed a criminal complaint for violating Section 7(b) of R.A. No. 9904. The
RTC proceeded with the case despite the respondents’ claim that the matter fell
under the jurisdiction of the HLURB. The CA reversed the RTC's rulings, holding that
the dispute was an intra-association matter under HLURB’s exclusive jurisdiction.
Petitioner elevated the issue to the Supreme Court.
ISSUE:
Whether the RTC or HLURB has jurisdiction over the dispute regarding a
homeowner's right to inspect association records.
RULING:
The Supreme Court ruled that the dispute is an intra-association controversy
governed by R.A. No. 9904, falling under the exclusive jurisdiction of the HLURB (now
HSAC). The violation concerned the internal rights and relations among members of
the association. HLURB has authority to impose administrative sanctions for such
violations, but not criminal penalties. Since no other criminal offense under the RPC
or Civil Code was alleged, the RTC had no jurisdiction.

17. Board of Investments


Garcia vs BOI G.R. No. 88637 September 7, 1989
Facts:
Bataan Petrochemical Corporation (BPC) formed by Taiwanese investors applied with
the Board of Investments (BOI) an application for registration as a new export
producer of petrochemicals. Its application specified Limay, Bataan as the plant site
and the use of "naphtha cracker" and "naphtha" as feedstock or fuel for its
petrochemical plant.
On February 24, 1988, BOI issued a Certificate of Registration to BPC and together
with incentives, such as exemptions from tax on raw materials, repatriation of the
entire proceeds of liquidation of investments and remittance of earnings on
investments.
On April 11, 1989, BPC filed a request for an approval of an amendment of its
investment application in the BOI, concerning the increase of the investment amount
from US$220 million to US$320 million, increase of the production capacity of its
naphtha cracker, polyetheylene plant and polypropylene plant, change of the
feedstock from naphtha only to "naphtha and/or liquefied petroleum gas and the
transfer the job site from Bataan to Batangas.
Vigorously opposing the transfer of the proposed petrochemical plant to Batangas,
the petitioner sent a letter to the Department of Trade and Industry (DTI), through
BOI, requesting for a copy together with attachments of the amendment and the
original application. The Taiwanese investors declined to give their consent to the
release of the documents requested.
On May 25, 1989, the BOI approved the revision of the registration of BPC's
petrochemical project
Issues:
Whether or not the respondents violated due process and extra limitation of power
and discretion on the part of the public respondents in approving the transfer of the
project to Batangas without giving due notice and an opportunity to be heard to the
vocal opponents of that move.
Ruling:
The petition for certiorari was granted.
The BOI's failure to publish such notice and to hold a hearing on the amended
application deprived the oppositors, like the petitioner, of due process and
amounted to a grave abuse of discretion on the part of the BOI.
According to the Omnibus Investments Code of 1987 (Executive Order No. 226) there
shall be a publication of applications for registration and a holding of consultations
with affected communities whenever necessary. Since the BPC's amended
application (particularly the change of location from Bataan to Batangas) was in
effect a new application, it should have been published so that whoever may have
any objection to the transfer may be heard. And, when the BOI approved BPC's
application to establish its petrochemical plant in Limay, Bataan, the inhabitants of
that province, particularly the affected community in Limay, and the petitioner
herein as the duly elected representative of the Second District of Bataan acquired
an interest in the project which they have a right to protect. Their interest in the
establishment of the petrochemical plant in their midst is actual, real, and vital
because it win affect not only their economic life but even the air they will breathe.
Hence, they have a right to be heard or "be consulted" on the proposal to transfer it
to another site for the Investments Code does require that the "affected
communities" should be consulted.
The Board of Investments is ordered comply with the law and its own rules and
regulations: (1) to publish the amended application for registration of the Bataan
Petrochemical Corporation, (2) to allow petitioner to have access to its records on
the original and amended applications for registration, excluding trade secrets; and
(3) to set for hearing petitioner's opposition to the amended application.

National Federation of Hog Farmers Inc. et al vs Board of Investments et al GR No.


205835 June 23, 2020
Facts:
The Petitioner National Federation of Hog Farmers Inc, et al. assailed the registration
before the SEC of Charoen Charoen Pokphand Foods Philippines Corporation
(Charoen for brevity) for being 100% foreign owned company from Thailand to do
business in the Philippines. On March 7, 2013, the National Federation of Hog
Farmers, Abono Party-list, Alyansa ng mga Grupong Haligi ng Agham at Teknolohiya
Para sa Mamamayan, Inc., Agricultural Sector Alliance of the Philippines, Inc., Pork
Producers Federation of the Philippines, Inc., Sorosoro Ibaba Development
Cooperative, and Association of Philippine Aqua Feeds Millers, Inc., jointly filed
before this Court a Petition for Certiorari with prayer for a temporary restraining
order. They mainly claim that the Board Resolutions of public respondent Board of
Investments, which granted private respondent Charoen's applications for
registration, were issued with grave abuse of discretion. Petitioners allege that the
assailed Board Resolutions violated their constitutional right to be protected against
unfair foreign competition and trade practices.
Issue:
Whether or not Charoen, a 100% foreign company can be registered before the SEC
and can enter business in the Philippines relative to agriculture/agribusinesses.
Ruling:
As such, the State imposes certain conditions and restrictions on foreign
investments operating within the Philippine jurisdiction. For instance, no foreign
enterprise is allowed to venture into the mass media industry. This absolute
restriction also extends to the use of natural resources found in the archipelagic
waters, territorial sea, and exclusive economic zone of the Philippines. Further, the
practice of all professions in the Philippines is reserved for Filipino citizens, save for
statutory exceptions. While foreign participation is absolutely prohibited in some
industries, the Constitution allows foreign participation in certain industries, such as
advertising, public utilities, educational institutions, ownership of private lands, and
the exploration, development, and utilization of natural resources. The agribusiness
was, and still is, not a nationalized or partly nationalized industry. Hence, in this case,
private respondent's status as a 100% foreign-owned corporation would not cause
the denial of its applications for registration with public respondent. The Charoen
Pokphand Foods Philippines Corporation, a 100% foreign owned is approved to be
registered before the SEC and to engaged in agriculture/agribusiness in the
Philippines.
18. Securities and Exchange Commission
Facts:
The case stems from a series of legal and administrative actions initiated against the
Commissioners of the Energy Regulatory Commission (ERC), including Alfredo J. Non,
Gloria Victoria C. Yap-Taruc, Josefina Patricia A. Magpale-Asirit, and Geronimo D. Sta.
Ana (collectively referred to as the petitioners). The issues originated from the ERC’s
issuance of Resolution No. 13, Series of 2015, and the subsequent Resolution No. 1,
Series of 2016, which adjusted the implementation date of the Competitive Selection
Process (CSP) requirement for power supply agreements (PSAs) from November 6,
2015, to April 30, 2016. This adjustment period was perceived to be a strategic move
to favor certain private entities, particularly the Manila Electric Company (Meralco),
allowing them to file PSAs without undergoing the mandated CSP. Alyansa Para sa
Bagong Pilipinas, Inc. (ABP) acted as the respondent, challenging the resolutions
issued by the ERC.
A series of legal challenges ensued, including a petition filed by ABP with the
Supreme Court (G.R. No. 227670) and a complaint with the Office of the
Ombudsman accusing the ERC commissioners of violating Section 3(e) of R.A. No.
3019. The Ombudsman found probable cause to indict the petitioners, leading to the
filing of criminal information against them. The petitioners then filed the present
Petition for Certiorari (G.R. No. 239168), challenging the Ombudsman’s resolutions.
Issues:
1. Whether the Ombudsman committed grave abuse of discretion in finding
probable cause to indict the petitioners for violating Section 3(e) of R.A. No. 3019.
2. Whether the principle of non-interference is applicable in this case, particularly
concerning the Ombudsman’s determination of probable cause.
3. Whether the actions of the petitioners in issuing ERC Resolution No. 1-2016 were
performed with manifest partiality, evident bad faith, or gross inexcusable
negligence.
4. Whether the trial court already acquired jurisdiction over the case due to the
arraignment of the petitioners, and if so, whether the Supreme Court should still
intervene.
Ruling:
The Supreme Court granted the petition, reversing and setting aside the resolutions
of the Ombudsman and ordering the dismissal of the Information against the
petitioners for lack of probable cause. The Court held that:
1. The principle of non-interference does not apply in this case due to the
Ombudsman’s grave abuse of discretion, which constitutes an exception to the
general rule.
2. The Ombudsman’s determination that the issuance of Resolution No. 1-2016 was
a mere ploy to favor Meralco and its affiliates was unsupported by substantial
evidence, especially considering that the resolution was intended to address
legitimate concerns from various power industry stakeholders.
3. The Court emphasized the distinction between administrative errors and criminal
offenses, noting that the error in issuing Resolution No. 1-2016 should not
automatically be deemed criminal.
4. Despite the arraignment of the petitioners, the Court exercised its authority to
order the dismissal of the case due to the lack of probable cause, underscoring its
duty to intervene upon proof of grave abuse of discretion by the Ombudsman.
Doctrine:
The Supreme Court reinforced the doctrine that while it generally upholds the policy
of non-interference with the Ombudsman’s determination of probable cause, it will
intervene and review the Ombudsman’s actions in cases where there is a charge of
grave abuse of discretion. Grave abuse of discretion constitutes an act that is
performed in a capricious, whimsical, arbitrary, or despotic manner, stemming from
personal hostility or a patent and gross evasion of positive duty or a virtual refusal to
perform the duty enjoined by law.

SEC vs. Court of Appeals and Omico Corporation G.R. No. 187702. October 22, 2014
Facts:
Omico Corporation, a publicly listed company, scheduled its annual stockholders’
meeting for November 3, 2008. The company set an October 23, 2008 deadline for
proxy submissions and validated proxies on October 25, 2008. Astra Securities
Corporation, which owned 18% of Omico’s shares, objected to proxies in favor of
Tommy Kin Hing Tia, representing 38% of Omico’s stock. Astra argued that these
proxies violated SRC Rule 20(11)(b)(xviii) because brokers issued proxies without
their clients’ express written authorization. Astra also claimed that Tia had over 19
proxies, which under SRC Rule 20(2)(B)(ii)(b), presumed solicitation, violating Section
20.1 of the Securities Regulation Code.
Despite objections, Omico’s Board of Inspectors validated the proxies. Astra filed a
complaint with the SEC to invalidate these proxies and requested a cease and desist
order to stop Omico’s annual meeting. The SEC issued the CDO. However, the CDO
was not served in time, and the meeting proceeded with 52.3% attendance, electing
directors by proxy upon a motion.
Astra filed an indirect contempt complaint against Omico with the SEC. Meanwhile,
Omico sought certiorari and prohibition from the CA, alleging grave abuse of
discretion by the SEC in issuing the CDO. The CA ruled in favor of Omico, declaring
the CDO null and void. Astra then petitioned the Supreme Court, and the SEC also
filed a Petition for Certiorari. Both petitions were consolidated.
Issue:
1. Whether or not the SEC have jurisdiction over controversies arising from the
validation of proxies for the election of directors of a corporation?
Ruling:
No. The Supreme Court ruled that the SEC does not have jurisdiction over the
validation of proxies when related to the election of corporate directors. This ruling
aligns with the Supreme Court’s GSIS v. CA decision, reiterated that, with the
passage of the Securities Regulation Code (SRC), jurisdiction over intra-corporate
controversies, including election-related disputes, was transferred to the regular
courts. The SEC’s authority to regulate proxies remains for non-election matters.

Pilipinas Bank vs. Court of Appeals G.R. No. 117079 Feb 22, 2000
FACTS:
In 1991, Pilipinas Bank (petitioner) filed a Complaint for Sum of Money against
private respondent Ricardo C. Silverio, Sr. The complaint sought the collection of two
loans totaling P4,688,233, 071 taken in 1981. Silverio, who was at the time the
bank’s majority stockholder, was simultaneously involved in other suits before the
Securities and Exchange Commission (SEC) involving his rights and equity interests in
Pilipinas Bank.
Silverio had instituted a separate suit before the SEC for specific performance,
breach of contract, annulment of sale, injunction/prohibition, and damages. His
capital infusion of P 25 million had been credited as paid-in surplus but later written
off against the bank’s losses pursuant to Monetary Board Resolution 595. Based on
these admissions, Silverio moved to dismiss and/or suspend the proceedings.
Then, the lower court of Makati granted the Motion to Dismiss/Suspend
Proceedings, and denied Pilipinas Bank’s pleading for reconsideration. A petition for
review (certiorari) was subsequently filed before the Court of Appeals, which
dismissed the petition on jurisdictional grounds— primarily relying on the exclusive
jurisdiction of the SEC over intra-corporate controversies as provided in P.D. No. 902-
A.
Thus, this petition for review was filed by Pilipinas Bank against the Court of
Appeals' decision affirming the dismissal of a collection case against Ricardo C.
Silverio Sr.
ISSUE/S:
● Whether the dispute—an action for collection intermingled with intra-
corporate controversies—should be filed in the regular courts or within the exclusive
jurisdiction of the SEC. (SEC)
● Whether the intra-corporate elements (shareholder issues, write-off of
capital infusion, and concurrent SEC cases) automatically vest jurisdiction in the SEC.
(YES)
RULINGS:
● The Supreme Court affirmed the decision of the Court of Appeals, concluding
that the SEC has jurisdiction over the case. It established that the nature of the
dispute was intrinsically tied to corporate governance and stockholder relations,
justifying SEC jurisdiction.
● In order that the SEC can take cognizance of a case, the controversy must
pertain to any of the following relationships: [a] between the corporation,
partnership or association and the public; [b] between the corporation, partnership
or association and its stockholders, partners, members or officers; [c] between the
corporation, partnership or association and the state in so far as its franchise, permit
or license to operate is concerned, and [d] among the stockholders, partners or
associates themselves.
19. Energy Regulatory Board
ALFREDO J. NON VS. OFFICE OF THE OMBUDSMAN G.R. No. 239168. September 15,
2020
ALYANSA PARA SA BAGONG PILIPINAS, INC. (ABP) vs. ENERGY REGULATORY
COMMISSION G.R. No. 227670, May 3, 2019
20. National Electrification Administration

GROUP 5 (DIAZ, SAYSON, MARCAIDA, PEREZ, ZAMORA, BARRAMEDA, VOLANTE)


21. Civil Aeronautics Board
PHILIPPINE AIRLINES, INC., VS. CIVIL AERONAUTICS BOARD AND GRAND
INTERNATIONAL AIRWAYS, INC. G.R. NO. 119528, MARCH 26, 1997
FACTS:
Grand International Airways Inc. applied with the CAB for a CPCN to operate a
domestic air transportation sercvices. PAL, a holder of a legislative franchise,
opposed GrandAir’s application, arguing that GrandAir’s lack of legislative franchise
was a fatal flaw, since such franchise was mandatory before the CAB could grant any
operating permit. PAL further alleged that CAB is without jurisdiction to issue a CPCN
or a Temporary Operating Permit, since Grand Air lacked the required legislative
franchise
ISSUE:
The primary issue in this case is whether or not CAB had the authority or jurisdiction
to entertain GrandAir’s application for a CPCN and issue a Temporary Operating
Permit, despite the lack of legislative franchise?
HELD:
Yes. The Civil Aeronautics Board has jurisdiction over GrandAir's Application
for a CPCN and a Temporary Operating Permit. The Board is expressly authorized by
Republic Act 776 to issue a temporary operating permit or Certificate of Public
Convenience and Necessity, and nothing contained in the said law negates the
power to issue said permit before the completion of the applicant's evidence and
that of the oppositor thereto on the main petition. Indeed, the CAB's authority to
grant a temporary permit "upon its own initiative" strongly suggests the power to
exercise said authority, even before the presentation of said evidence has begun.
Assuming arguendo that a legislative franchise is prerequisite to the issuance of a
permit, the absence of the same does not affect the jurisdiction of the Board to hear
the application, but tolls only upon the ultimate issuance of the requested permit.
The power to authorize and control the operation of a public utility is admittedly a
prerogative of the legislature, since Congress is that branch of government vested
with plenary powers of legislation.
The issue in this petition is whether or not Congress, in enacting Republic Act
776, has delegated the authority to authorize the operation of domestic air transport
services to the respondent Board, such that Congressional mandate for the approval
of such authority is no longer necessary. Congress has granted certain administrative
agencies the power to grant licenses for, or to authorize the operation of certain
public utilities. With the growing complexity of modern life, the multiplication of the
subjects of governmental regulation, and the increased difficulty of administering
the laws, there is a constantly growing tendency towards the delegation of greater
powers by the legislature, and towards the approval of the practice by the courts. It
is generally recognized that a franchise may be derived indirectly from the state
through a duly designated agency, and to this extent, the power to grant franchises
has frequently been delegated, even to agencies other than those of a legislative
nature. In pursuance of this, it has been held that privileges conferred by grant by
local authorities as agents for the state constitute as much a legislative franchise as
though the grant had been made by an act of the Legislature. Given the foregoing
postulates, we find that the Civil Aeronautics Board has the authority to issue a
Certificate of Public Convenience and Necessity, or Temporary Operating Permit to a
domestic air transport operator, who, though not possessing a legislative franchise,
meets all the other requirements prescribed by the law. Such requirements were
enumerated in Section 21 of R.A. 776.
Civil Aeronautics Board (CAB) vs. Philippine Air Lines, Inc. (PAL) GR No.: L-40245 ;
April 30, 1975
FACTS:
On May 12, 1970, a Philippine Air Lines (PAL) flight from Tuguegarao to
Manila made an unscheduled stop in Baguio City to accommodate additional
passengers. The Civil Aeronautics Board (CAB) found that PAL did not secure prior
permission for this "flagstop," which was deemed a violation of Republic Act No. 776,
the Civil Aeronautics Act of the Philippines, and its implementing rules and
regulations. Consequently, the CAB issued a Resolution imposing a fine of P5,000.00
on PAL. PAL filed a motion for reconsideration, arguing that the CAB lacked the
authority to impose such a fine, contending that this was a judicial function
belonging to the regular courts.
ISSUE:
Does the Civil Aeronautics Board (CAB) have the authority under Republic Act No.
776 to impose administrative fines for violations of its rules and regulations?
HELD:
The Supreme Court held that the CAB possesses the power to impose administrative
fines as a regulatory agency. It reasoned that Section 36 of Republic Act No. 776
grants the CAB the power to "investigate, upon complaint or upon its own initiative,
whether any individual or air carrier, domestic or foreign, is violating any provision of
this Act, or the rules and regulations issued thereunder, and shall take such action,
consistent with the provisions of this Act, as may be necessary to prevent further
violation." This includes the power to impose civil penalties to ensure compliance
with its regulations. The Court distinguished administrative fines from criminal fines,
which are exclusively within the jurisdiction of the courts. The fine imposed by the
CAB was deemed a civil penalty necessary for the effective regulation of air carriers.
22. Department of Agrarian Reform
Luz Farms v. Department of Agrarian Reform G.R. No. 86889 December 4, 1990
FACTS:
Luz Farms, a private corporation, was engaged in livestock raising, specifically cattle,
hogs, and poultry. It challenged the constitutionality of Section 3(b) of Republic Act
No. 6657 (Comprehensive Agrarian Reform Law or CARL), which included livestock,
poultry, and swine raising under the definition of "agricultural activity" and therefore
subject to agrarian reform coverage. Luz Farms argued that including livestock
raising under CARL violates its right to due process and equal protection, and that
such inclusion was not intended under the Constitution.
ISSUE:
Whether or not livestock, poultry, and swine raising are covered under the agrarian
reform program as defined by Section 3(b) of R.A. No. 6657.
HELD:
No. The Supreme Court ruled in favor of Luz Farms. The Supreme Court declared
Section 3(b) of R.A. No. 6657 unconstitutional insofar as it included the raising of
livestock, poultry, and swine in the definition of "agricultural activity" subject to
agrarian reform. The Court explained that agrarian reform under the Constitution
refers specifically to the relationship between farmers and landowners concerning
agricultural lands. Livestock and poultry raising are industrial, not agricultural,
enterprises for purposes of agrarian reform, as they are not dependent on the tilling
of the soil. The Court emphasized that agrarian reform is meant to redistribute land
to landless farmers and farmworkers who till the land, not to affect industrial
enterprises engaged in animal husbandry. Agrarian reform as contemplated under
the 1987 Constitution pertains only to the distribution of agricultural lands to
landless farmers and farmworkers who directly till the soil. Industrial enterprises like
livestock, poultry, and swine raising are not covered.
Department of Agrarian Reform vs. Cuenca G.R. NO. 154112; September 23, 2004
FACTS:
Private respondent, Roberto J. Cuenca is the registered owner of a parcel of land
designated as Lot No. 816-A and covered by TCT No. 1084, containing an area of
81.6117 hectares, situated in Brgy. Haguimit, La Carlota City and devoted principally
to the planting of sugar cane. On 21 September 1999, Noe Fortunado, Municipal
Agrarian Reform Officer (MARO) of La Carlota City issued and sent a NOTICE OF
COVERAGE to private respondent Cuenca placing the above-described landholding
under the compulsory coverage of R.A. 6657 On 29 September 1999, private
respondent Cuenca filed with the Regional Trial Court, Branch 63, La Carlota City, a
complaint against Noe Fortunado and Land Bank of the Philippines for ‘Annulment of
Notice of Coverage and Declaration of Unconstitutionality of E.O. No. 405, Series of
1990, With Preliminary Injunction and Restraining Order.’ On 05 October 1999,
MARO Noe Fortunado filed a motion to dismiss the complaint on the ground that the
court a quo has no jurisdiction over the nature and subject matter of the action,
pursuant to R.A. 6657.On 12 January 2000, the respondent Judge issued a
Temporary Restraining Order directing MARO and LBP to cease and desist from
implementing the Notice of Coverage. On 14 January 2000, MARO Fortunado filed a
Motion for Reconsideration of the order granting the TRO contending inter alia that
the DAR, through the MARO, in the course of implementing the Notice of Coverage
under CARP cannot be enjoined through a Temporary Restraining Order in the light
of Sections 55 and 68 of R.A. 6657. The motion was denied. The Department of
Agrarian Reform (DAR) [thereafter filed before the CA] a petition for certiorari under
Rule 65 of the 1997 Rules of Civil Procedure, assailing the writ of preliminary
injunction issued by respondent Judge on the ground of grave abuse of discretion
amounting to lack of jurisdiction. "It is the submission of the petitioner that the
assailed order is ‘in direct defiance… of Republic Act 6657, particularly Section 55
and 68’ thereof, which read:
‘SECTION 55. NO RESTRAINING ORDERS OR PRELIMINARY INJUNCTIONS – No court in
the Philippines shall have jurisdiction to issue any restraining order or writ of
preliminary injunction against the PARC or any of its duly authorized or designated
agencies in any case, dispute or controversy arising from, necessary to, or in
connection with the application, implementation, or enforcement or interpretation
of this Act and other pertinent laws on agrarian reform.’
‘SECTION 68 – IMMUNITY OF GOVERNMENT AGENCIES FROM COURT’S
INTERFERENCE – No injunction, Restraining Order, prohibition or mandamus shall be
issued by the lower court against the Department of Agrarian Reform (DAR), the
Department of Agriculture (DA), the Department of Environment and Natural
Resources (DENR), and the Department of Justice (DOJ) in the implementation of
their program.’ Petitioner contends that by virtue of the above provisions, all lower
courts, such as the court presided over by respondent Judge, ‘are barred if not
prohibited by law to issue orders of injunctions against the Department of Agrarian
Reform in the full implementation of the Notice of Coverage which is the initial step
of acquiring lands under R.A. 6657.’ Petitioner also contends that the nature and
subject matter of the case below is purely agrarian in character over which the court
a quo has no jurisdiction and that therefore, it had no authority to issue the assailed
injunction order. Stressing that the issue was not simply the improper issuance of
the Notice of Coverage, but was mainly the constitutionality of Executive Order No.
405, the CA ruled that the Regional Trial Court (RTC) had jurisdiction over the case.
ISSUE:
Whether or not the issues raised in the complaint filed by the private respondent,
which seeks to exclude his land from the coverage of the CARP, is an agrarian reform
matter and within the jurisdiction of the DAR, not with the trial court.
HELD:
Yes. All controversies on the implementation of the Comprehensive Agrarian Reform
Program (CARP) fall under the jurisdiction of the Department of Agrarian Reform
(DAR), even though they raise questions that are also legal or constitutional in
nature. All doubts should be resolved in favor of the DAR, since the law has granted
it special and original authority to hear and adjudicate agrarian matters. Two basic
rules have guided this Court in determining jurisdiction in these cases. First,
jurisdiction is conferred by law. And second, the nature of the action and the issue of
jurisdiction are shaped by the material averments of the complaint and the character
of the relief sought. The defenses resorted to in the answer or motion to dismiss are
disregarded; otherwise, the question of jurisdiction would depend entirely upon the
whim of the defendant.
23. National Police Commission
MELVIN G. SAN FELIX V. CIVIL SERVICE COMMISSION G.R. No. 198404, October 14,
2019
FACTS:
On Mach 8, 2001, the CSC of Iloilo City charged San Felix with dishonesty for allegedy
conspiring with and allowing another person to take, in his behalf, the Police officer
Examination held on March 29, 1988. It noted that the picture and signature in the
application form and seat plan were not identical with petitioner’s Personal Data
Sheet. the CSC arrived at a conclusion that San Felix conspired with another by
allowing the latter to impersonate him and take the examination in his behalf.
Petitioner then filed a Motion to Dismiss citing the ruling in CSC V. CA wherein the SC
ordered the CSC to desists from further conducting any promotional examination for
police officers and senior police officer. However, the petitioner’s Motion to Dismiss
was denied. The CSC Regional office found petitioner guilty of dishonesty and meted
him the penalty of dismissal. The CA also affirmed in toto CSC’s Resolution and
sustained the jurisdiction of the CSC to investigate the alleged examination taken by
petitioner and to impose upon him the appropriate penalty or sanction. Petitioner
argues that although the CSC was formerly vested with authority to administer the
qualifying entrance examinations for police officers, the same was withdrawn with
the enactment of R.A. No. 8551 which took effect on March 6, 1998 and mandated
the NPC to administer both the entrance and promotional examinations for police
officers.
ISSUE:
Whether the CSC retained jurisdiction to investigate and discipline a civil servant for
anomalies committed in an examination it no longer had the authority to conduct
due to R.A. No. 8551 transferring that function to the NPC.
HELD:
Yes, the CSC undoubtedly, has jurisdiction to take cognizance of cases involving
examination anomalies and irregularities which the commission itself administered.
However, it bears noting that on March 6, 1998, R.A. No. 8551, which amended R.A.
No. 6975, became effective transferring the power to administer and conduct
entrance and promotional examinations to police officers from the CSC to the NPC
on the basis of the standards set by the latter. Thus, as of March 6, 1998, the CSC
had no more authority to administer entrance and promotional examinations for
police officers. However, the lack of authority of the CSC to conduct the
examinations for Police Officer I on March 29, 1998 should not be used as a shield to
petitioner's wrongdoing as he was not in good faith. As appropriately held by the
Court of Appeals: "To rule otherwise would be tantamount to condoning petitioner's
dishonesty during the March 29, 1998 Police Officer I Examination and allowing him
to continue benefiting from the eligibility he acquired fraudulently."
To reiterate, as of March 6, 1998, the CSC had no more authority to conduct
entrance and promotional examinations for police officer and senior police officer
positions by virtue of R.A. No. 8551, which amended R.A. No. 6975. In effect, the CSC
then had no power to grant police officer eligibility in order for an applicant to be
appointed in a police officer and senior police officer position. Consequently, the said
examination conducted on March 29, 1998 was without legal effect and conferred
no rights in view of the effectivity of R.A. No. 8551 amending R.A. No. 6975. The
records show that petitioner committed an act of dishonesty when he allowed
another person to take in his behalf the Police Officer I Examination dated March 29,
1998 which resulted in the conferment of eligibility upon him and later an
appointment to a permanent status police officer position.Petitioner cannot
challenge the CSC's authority to conduct said examination and at the same time rely
on its effects only when the same redound to his benefit.
24. National Telecommunications Commission
BONIFACIO COMMUNICATIONS CORPORATION AND PHILIPPINE LONG DISTANCE
TELEPHONE COMPANY, PETITIONERS, VS. NATIONAL TELECOMMUNICATIONS
COMMISSION G.R. No. 201944, April 19, 2023
25. Tariff Commission
SOUTHERN CROSS CEMENT CORPORATION, vs. THE PHILIPPINE CEMENT
MANUFACTURERS CORP., THE SECRETARY OF THE DEPARTMENT OF TRADE &
INDUSTRY, THE SECRETARY OF THE DEPARTMENT OF FINANCE, and THE
COMMISSIONER OF THE BUREAU OF CUSTOMS G.R. No. 158540. July 8, 2004
FACTS:
Petitioner Southern Cross Cement Corporation (Southern Cross) is a domestic
corporation engaged in the business of cement manufacturing, production,
importation and exportation. Its principal stockholders are Taiheiyo Cement
Corporation and Tokuyama Corporation, purportedly the largest cement
manufacturers in Japan. Private respondent Philippine Cement Manufacturers
Corporation (Philcemcor) is an association of domestic cement manufacturers.

Respondent Department of Trade and Industry (DTI) accepted an application from


Philcemcor, alleging that the importation of gray Portland cementin increased
quantities has caused declines in domestic production, capacity utilization, market
share, sales and employment; as well as caused depressed local prices. Philcemcor
sought the imposition at first of provisional, then later, definitive safeguard
measures on the import of cement pursuant to the SMA.After preliminary
investigation, the Bureau of Import Services of the DTI, determined that critical
circumstances existed justifying the imposition of provisional measures. DTI issued
an Order, imposing a provisional measure

The Tariff Commission, on 19 November 2001, received a request from the DTI for a
formal investigation to determine whether or not to impose a definitive safeguard
measure on imports of gray Portland cement, the Tariff Commission issued its
Formal Investigation Report stating that the elements of serious injury and imminent
threat of serious injury not having been established, it is hereby recommended that
no definitive general safeguard measure be imposed on the importation of gray
Portland cement. DTI Secretary disagreed with the conclusion of the Tariff
Commission, DTI requested an opinion from the Department of Justice.

The DOJ Secretary rendered an opinion stating that the DTI that it was bound by the
negative finding of the Tariff Commission. The DTI has no alternative but to abide by
the [Tariff] Commission’s recommendations. Thus the DTI issued an order that the
application for safeguard measures against the importation of gray Portland cement
filed by PHILCEMCOR (Case No. 02-2001) is hereby denied.

Philcemcor received a copy of the DTI Decision on 12 April 2002. Ten days later, it
filed with the Court of Appeals a Petition for Certiorari, Prohibition and Mandamus,
likewise applied for a Temporary Restraining Order/Injunction to enjoin the DTI and
the BOC from implementing the questioned Decision and Report. The CA granted the
writ sought. The two-hundred (200)-day period for the imposition of the provisional
measure expired. Despite the lapse of the period, the BOC continued to impose the
provisional measure on all importations of Portland cement made by Southern Cross.
Sothern Cross file a MR alleging that Philcemcor was not entitled to provisional
relief, Southern Cross likewise sought a clarificatory order as to whether the grant of
the writ of preliminary injunction could extend the earlier imposition of the
provisional measure beyond the two hundred (200)-day limit imposed by law. CA
rendered its decision held that the DTI Secretary is not bound by the factual findings
of the Tariff Commission since such findings are merely recommendatory and they
fall within the ambit of the Secretary’s discretionary review. It determined that the
legislative intent is to grant the DTI Secretary the power to make a final decision on
the Tariff Commissions recommendation. But it refused to annul the findings of the
Tariff Commission, citing the rule that factual findings of administrative agencies are
binding upon the courts and its corollary, that courts should not interfere in matters
addressed to the sound discretion and coming under the special technical knowledge
and training of such agencies. Thus Southern Cross filed an appeal to the Supreme
Court arguing that the Court of Appeals has no jurisdiction over Philcemcors petition,
the proper remedy being a petition for review with the CTA conformably with the
SMA, and; that the factual findings of the Tariff Commission on the existence or non-
existence conditions warranting the imposition of general safeguard measures are
binding upon the DTI Secretary.

ISSUE:
1. Whether or not the CA has jurisdiction over the case.
2. Whether or not the DTI Secretary may impose general safeguard measures in
the absence of a positive final determination by the Tariff Commission.

Held :
As to the issue of jurisdiction the SC held that;
Under Section 29 of the SMA, there are three requisites to enable the CTA to acquire
jurisdiction over the petition for review contemplated therein: (i) there must be a
ruling by the DTI Secretary; (ii) the petition must be filed by an interested party
adversely affected by the ruling; and (iii) such ruling must be in connection with the
imposition of a safeguard measure. The first two requisites are clearly present. The
third requisite deserves closer scrutiny.
This theoretical quandary need not come to pass. Section 29 of the SMA is worded
in such a way that it places under the CTAs judicial review all rulings of the DTI
Secretary, which are connected with the imposition of a safeguard measure. This is
sound and proper in light of the specialized jurisdiction of the CTA over tax matters.
In the same way that a question of whether to tax or not to tax is properly a tax
matter, so is the question of whether to impose or not to impose a definitive
safeguard measure.
On another note, the second paragraph of Section 29 similarly reveals the legislative
intent that rulings of the DTI Secretary over safeguard measures should first be
reviewed by the CTA and not the Court of Appeals. It reads:”The petition for review
shall comply with the same requirements and shall follow the same rules of
procedure and shall be subject to the same disposition as in appeals in connection
with adverse rulings on tax matters to the Court of Appeals.” This is the only passage
in the SMA in which the Court of Appeals is mentioned. The express wish of Congress
is that the petition conform to the requirements and procedure under Rule 43 of the
Rules of Civil Procedure. Since Congress mandated that the form and procedure
adopted be analogous to a review of a CTA ruling by the Court of Appeals, the
legislative contemplation could not have been that the appeal be directly taken to
the Court of Appeals.
On the issue of Binding Effect of TariffCommissions Factual Determinationon DTI
Secretary.
Court of Appeals relied upon Section 13 of the SMA in ruling that the findings
of the Tariff Commission do not necessarily constitute a final decision. Section 13
details the procedure for the adoption of a safeguard measure, as well as the steps
to be taken in case there is a negative final determination. The implication of the
Court of Appeals holding is that the DTI Secretary may adopt a definitive safeguard
measure, notwithstanding a negative determination made by the Tariff Commission.
Undoubtedly, Section 13 prescribes certain limitations and restrictions before
general safeguard measures may be imposed. However, the most fundamental
restriction on the DTI Secretarys power in that respect is contained in Section 5 of
the SMAthat there should first be a positive final determination of the Tariff
Commissionwhich the Court of Appeals curiously all but ignored. The plain meaning
of Section 5 shows that it is the Tariff Commission that has the power to make a
positive final determination. This power lodged in the Tariff Commission, must be
distinguished from the power to impose the general safeguard measure which is
properly vested on the DTI Secretary.
Section 5 plainly evinces legislative intent to restrict the DTI Secretary’s power to
impose a general safeguard measure by preconditioning such imposition on a
positive determination by the Tariff Commission. Such legislative intent should be
given full force and effect, as the executive power to impose definitive safeguard
measures is but a delegated powerthe power of taxation, by nature and by
command of the fundamental law, being a preserve of the legislature. Section 28(2),
Article VI of the 1987 Constitution confirms the delegation of legislative power, yet
ensures that the prerogative of Congress to impose limitations and restrictions on
the executive exercise of this power:
The Congress may, by law, authorize the President to fix within specified limits, and
subject to such limitations and restrictions as it may impose, tariff rates, import and
export quotas, tonnage and wharfage dues, and other duties or imposts within the
framework of the national development program of the Government. This
delegation of the taxation power by the legislative to the executive is authorized by
the Constitution itself. At the same time, the Constitution also grants the delegating
authority (Congress) the right to impose restrictions and limitations on the taxation
power delegated to the President. The restrictions and limitations imposed by
Congress take on the mantle of a constitutional command, which the executive
branch is obliged to observe.The DTI Secretary authority is derived from the SMA; it
does not flow from any inherent executive power. Thus, the limitations imposed by
Section 5 are absolute, warranted as they are by a constitutional fiat.
WHEREFORE, the petition is GRANTED. The assailed Decision of the Court of Appeals
is DECLARED NULL AND VOID and SET ASIDE. The Decision of the DTI Secretary dated
25 June 2003 is also DECLARED NULL AND VOID and SET ASIDE. No Costs.

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