CASE # 1 Hambon vs CA, G.R. No.

122150, March 17, 2003

FACTS: George Hambon, the petitioner, instituted a civil case for damages against Valentino U.
Carantes, the respondent, before the Regional Trial Court of Baguio (Branch 6) on June 6, 1989,
due to injuries sustained from a vehicular accident on December 9, 1985, when a truck driven by
the respondent bumped him. A criminal case, Criminal Case No. 2049 for Serious Physical
Injuries through Reckless Imprudence, was filed on January 8, 1986, but was provisionally
dismissed by the Municipal Trial Court of Tuba, Benguet on March 23, 1987, citing the
petitioner’s lack of interest to prosecute.
The trial court awarded damages to Hambon, holding that the dismissal of the criminal case did
not bar the civil case. In contrast, the Court of Appeals, upon the respondent’s appeal, reversed
the ruling and dismissed Hambon’s complaint on grounds that the civil action was impliedly
instituted with the criminal case, and the dismissal of the latter, without any reservation for a
separate civil action, also dismissed the civil case.
Hambon elevated the matter to the Supreme Court via a petition for review on certiorari under
Rule 45 of the Rules of Court, arguing for his right to pursue a separate civil action without the
need for reservation as upheld in the Abellana v. Marave case, and contending that the
requirement of reservation impairs substantive rights.

MTC / RTC RULING: The RTC ruled in favor of Hambon, awarding him actual damages
(P60,000 for hospitalization and medical expenses, P10,000 for native rituals), moral damages
(P10,000), exemplary damages (P5,000), and attorney’s fees (P5,000).

COURT OF APPEAL RULING: On appeal, the Court of Appeals (CA) reversed the RTC
decision, dismissing Hambon’s complaint. The CA held that since Hambon did not reserve the
right to file a separate civil action, the civil case was impliedly instituted with the criminal case.
The dismissal of the criminal case thus carried with it the dismissal of the civil case.

ISSUE: 1. Whether or not a civil case for damages based on an independent civil action under
Articles 32, 33, 34, and 2176 of the New Civil Code can be dismissed for failure to reserve the
right to file separately in a criminal case arising from the same act.
2. If the strict interpretation of Rule 111, Section 1 of the Rules of Court, which entails the
reservation requirement, infringes upon a substantive right contrary to law.

SUPREME COURT RULING: The Supreme Court denied the petition and affirmed the
decision of the Court of Appeals in toto. The Court upheld the procedural requirement set out in
Section 1, Rule 111 of the 1985 Rules on Criminal Procedure, as amended in 1988, which
necessitates reserving the right to bring separate civil actions for recovery of civil liability. The
Court emphasized that the requirement is procedural and does not impair, diminish, or defeat
substantive rights. It serves to avoid multiplicity of suits, prevent delays, and promote efficiency
in the justice system. Thus, Hambon should have reserved his right to institute the civil action
separately in Criminal Case No. 2049. Failing to do so, the civil case Hambon subsequently filed
was dismissed along with the criminal case upon its provisional dismissal.
CASE #2 Saludaga v. FEU, G.R. No. 179337, April 30, 2008

FACTS: Joseph Saludaga, a sophomore law student of Far Eastern University (FEU), was shot
by the school’s security guard, Alejandro Rosete, while on FEU’s premises on August 18, 1996.
Rosete, employed by Galaxy Development and Management Corporation (Galaxy), which
provided security services to FEU, claimed that the shooting was accidental. After the incident,
Rosete was taken into custody but released due to the absence of a formal complaint.
Saludaga initiated a Complaint for damages against FEU and its President, Edilberto C. De Jesus,
alleging breach of their obligation to ensure a safe educational environment. FEU and De Jesus
filed a Third-Party Complaint against Galaxy and Imperial, its President, seeking indemnity.
Galaxy and Imperial then filed a Fourth-Party Complaint against AFP General Insurance.
The Regional Trial Court of Manila sided with Saludaga, ordering FEU and De Jesus to pay
damages. FEU and De Jesus appealed to the Court of Appeals, which reversed the trial court’s
decision and dismissed Saludaga’s complaint. Saludaga sought reconsideration, which was
denied, prompting the filing of the Petition for Review on Certiorari with the Supreme Court

MTC / RTC RULING: The Regional Trial Court (RTC) of Manila ruled in favor of Saludaga,
ordering FEU and De Jesus to pay actual damages of ₱35,298.25 with 12% interest per annum
from the filing of the complaint until fully paid, moral damages of ₱300,000.00, exemplary
damages of ₱500,000.00, attorney's fees of ₱100,000.00, and the costs of the suit. The court also
ordered Galaxy and Imperial to indemnify FEU and De Jesus for the aforementioned amounts.
The fourth-party complaint against AFP General Insurance was dismissed for lack of cause of
action.

COURT OF APPEAL RULING: Respondents appealed the trial court's decision to the Court
of Appeals. On June 29, 2007, the Court of Appeals reversed the trial court's decision, dismissing
Saludaga's complaint. The appellate court ruled that the shooting incident was a fortuitous event
and that FEU was not liable for damages.

ISSUE:
1. Whether the shooting incident was a fortuitous event.
2. Whether FEU and De Jesus are liable for damages for the injury inflicted by their security
guard.
3. Whether the principle of relativity of contracts exempts FEU from liability given that Rosete
was an employee of Galaxy.
4. Whether FEU exercised due diligence in selecting Galaxy for security services.

SUPREME COURT RULING: The Supreme Court granted Saludaga's petition, reversing the
Court of Appeals' decision and reinstating the RTC's ruling with modifications. The Court held
that the shooting incident was not a fortuitous event, as FEU failed to prove that it exercised due
diligence in providing a safe learning environment. The Court emphasized that educational
institutions have an implicit obligation to ensure the safety of their students within campus
premises. FEU breached its contractual obligation by failing to ensure that Galaxy provided
qualified and competent security personnel. However, the Court found no basis to hold De Jesus
personally liable, as there was no evidence of personal fault or negligence on his part.
Consequently, the Court ordered FEU to pay Saludaga actual damages of ₱35,298.25 with 12%
interest per annum from the filing of the complaint until fully paid, moral damages of
₱200,000.00, exemplary damages of ₱100,000.00, attorney's fees of ₱50,000.00, and the costs of
the suit. This case underscores the responsibility of educational institutions to provide a safe and
secure environment for their students and highlights the importance of exercising due diligence
in the selection and supervision of service contractors.
CASE #3 CBK Power Co. Ltd., v. CIR, G.R. Nos. 198729-30, Jan.
15, 2014

FACTS: CBK Power Company Limited (CBK Power) operates hydroelectric power plants in
Laguna, Philippines. On December 29, 2004, CBK Power applied for and obtained approval from
the Bureau of Internal Revenue (BIR) for Value-Added Tax (VAT) zero-rating on its sales of
electricity to the National Power Corporation (NPC) for the period from January 1, 2005, to
October 31, 2005. Subsequently, CBK Power filed administrative claims for tax credit certificates
to recover unutilized input VAT for the first three quarters of 2005, submitting these claims on
June 30, September 15, and October 28, 2005, respectively. Due to the BIR's inaction on these
claims, CBK Power filed a Petition for Review with the Court of Tax Appeals (CTA) on April 18,
2007.
CTA Special Second Division Ruling:
The CTA Special Second Division found that CBK Power had timely filed its administrative
claims for the second and third quarters of 2005 but denied the claim for the first quarter as it
was filed late. The court granted a tax credit certificate amounting to ₱27,170,123.36 for the
second and third quarters.
CTA En Banc Ruling:
Upon appeal, the CTA En Banc reversed the Special Second Division's decision, ruling that all
judicial claims for the first three quarters of 2005 were filed beyond the prescribed period, leading
to the dismissal of CBK Power's claims.

MTC / RTC RULING:

COURT OF APPEAL RULING:

ISSUE: Whether CBK Power's judicial claims for a refund of unutilized input VAT for the first
to third quarters of 2005 were filed within the prescriptive period mandated by law.

SUPREME COURT RULING: The Supreme Court denied CBK Power's petition, affirming
the CTA En Banc's decision. The Court emphasized the mandatory nature of the 120+30 day
rule under Section 112 of the National Internal Revenue Code (NIRC). This provision requires
taxpayers to wait for 120 days from the filing of an administrative claim for a VAT refund
before seeking judicial relief, with an additional 30 days provided to appeal to the CTA if the
claim is denied or if the BIR fails to act. CBK Power's failure to adhere to this timeline resulted
in the dismissal of its claims.This case underscores the strict compliance required with
statutory timelines for filing tax refund claims, highlighting the importance of adhering to
procedural rules to preserve legal rights.
CASE#4 Pilipinas Petroleum v. Duque, G.R. 216467, Feb. 15, 2017

FACTS: Pilipinas Shell Petroleum Corporation (PSPC) subleased a portion of its property to
The Fitness Center (TFC). TFC later assigned its rights and obligations under the sublease to
Fitness Consultants, Inc. (FCI), with Carlos Duque as proprietor and Teresa Duque as corporate
secretary. FCI issued a postdated check amounting to ₱105,518.55 to PSPC to cover unpaid
rentals. Upon presentation, the check was dishonored due to the account being closed.
Consequently, PSPC filed a criminal complaint against the Duques for violation of Batas
Pambansa Blg. 22 (BP 22), the Bouncing Checks Law.
MTC / RTC RULING: The MTC of Makati City found the Duques guilty of violating BP 22,
imposing a fine and ordering them to pay civil indemnity to PSPC. On appeal, the RTC of
Makati City acquitted the Duques of the criminal charge but maintained the order for them to
pay civil indemnity to PSPC.

COURT OF APPEAL RULING: The Duques appealed to the CA, which reversed the RTC's
decision, ruling that their civil liability was extinguished upon acquittal, as the obligation was
corporate in nature, and no personal liability was established.

ISSUE: Whether the acquittal of corporate officers in a BP 22 case extinguishes

their civil liability arising from a corporate obligation.
SUPREME COURT RULING: The Supreme Court affirmed the CA's decision, holding that
the Duques' acquittal extinguished their civil liability. The Court emphasized that since the
obligation was corporate in nature and there was no evidence of personal involvement or bad
faith on the part of the Duques, they could not be held personally liable. The Court further
clarified that in the absence of a finding of bad faith or malice, corporate officers are generally
not personally liable for corporate obligations.

This case underscores the principle that corporate officers are not personally
liable for corporate debts unless there is clear evidence of personal fault or bad
faith.
CASE#5 6Abrogar v. Cosmos Bottling Corp., G.R. No. 164749,
March 15, 2017

FACTS: On June 15, 1980, the "1st Pop Cola Junior Marathon" was held in Quezon City,
organized by Intergames, Inc. and sponsored by Cosmos Bottling Company. Rommel Abrogar,
a minor, participated in the marathon after meeting all the requirements. During the race, he was
fatally struck by a passenger jeepney while running along the marathon route. His parents,
Romulo and Erlinda Abrogar, filed a claim for damages against Cosmos Bottling Company and
Intergames, Inc., alleging negligence in organizing the event.

MTC / RTC RULING: The Regional Trial Court (RTC) found both Cosmos Bottling
Company and Intergames, Inc. jointly and severally liable for damages. The court held that the
safeguards instituted by Intergames in conducting the marathon were inadequate, and that the
accident occurred due to their failure to exercise due diligence. The RTC also noted that the
waiver executed by Rommel and the permission given by his parents were only effective for
risks inherent in the marathon, not for incidents resulting from negligence.

COURT OF APPEAL RULING: Upon appeal, the Court of Appeals (CA) reversed the RTC's
decision, absolving both Cosmos Bottling Company and Intergames, Inc. of liability. The CA
concluded that the negligence of the jeepney driver was the proximate cause of Rommel's death,
and that the organizers had exercised due diligence in conducting the marathon.
ISSUE:
Whether Cosmos Bottling Company and Intergames, Inc. were negligent in organizing the
marathon.
Whether such negligence, if proven, was the proximate cause of Rommel's death.
Applicability of the doctrine of assumption of risk.
Entitlement of the heirs to damages for loss of earning capacity and other compensatory
claims.

SUPREME COURT RULING: The Supreme Court held that Intergames, Inc., as the
organizer of the marathon, was negligent in ensuring the safety of the participants. The Court
found that the measures taken were insufficient to protect the runners from vehicular accidents
along the route. However, the Court absolved Cosmos Bottling Company of liability, stating
that as a sponsor, it did not have direct control over the conduct of the event. Regarding the
claim for damages for loss of earning capacity, the Court denied it, noting that Rommel was a
minor with no proven earning capacity at the time of his death.
This case underscores the responsibility of event organizers to implement adequate safety
measures to protect participants and delineates the extent of liability between organizers and
sponsors in such events.
CASE#5 Orient Freight International v. Keihin-Everett
FACTS: On October 16, 2001, Keihin-Everett Forwarding Company, Inc. (Keihin-Everett)
entered into a Trucking Service Agreement with Matsushita Communication Industrial
Corporation of the Philippines (Matsushita) to provide trucking services. Keihin-Everett
subcontracted these services to Orient Freight International, Inc. (Orient Freight) through a
separate agreement executed on the same day. On April 17, 2002, a truck carrying Matsushita's
goods was hijacked, but the shipment was recovered. Orient Freight failed to promptly and
accurately report the incident to Keihin-Everett, leading Matsushita to lose trust and terminate
its contract with Keihin-Everett. Consequently, Keihin-Everett demanded indemnity from
Orient Freight for lost income, which Orient Freight refused to pay. This refusal led Keihin-
Everett to file a complaint for damages.

MTC / RTC RULING: The RTC found Orient Freight negligent for failing to properly
investigate and report the hijacking incident. The court ruled that this negligence resulted in
the termination of Keihin-Everett's contract with Matsushita, causing Keihin-Everett to suffer
income losses. The RTC awarded Keihin-Everett ₱1,666,667.00 in actual damages and
₱50,000.00 in attorney's fees but denied the request for exemplary damages.

COURT OF APPEAL RULING: Orient Freight appealed the RTC's decision. The CA affirmed
the RTC's ruling, agreeing that Orient Freight's negligence led to the damages suffered by
Keihin-Everett. The CA held that Orient Freight not only had knowledge of the hijacking but
also withheld this information from Keihin-Everett, which constituted negligence. The CA also
upheld the computation of the awarded damages.
ISSUE:
Whether Orient Freight was negligent in handling the hijacking incident and failing to
report it accurately.

Whether such negligence was the proximate cause of the termination of Keihin-Everett's
contract with Matsushita and the resulting damages.

SUPREME COURT RULING: The Supreme Court denied Orient Freight's petition and
affirmed the decisions of the lower courts. The Court held that Orient Freight's negligence in
failing to report and investigate the hijacking incident was the proximate cause of the
termination of Keihin-Everett's contract with Matsushita. The Court emphasized that while
Article 2176 of the Civil Code on quasi-delict does not apply when negligence occurs in the
performance of a contractual obligation, the negligent act in this case constituted a breach of
contract. Therefore, Orient Freight was liable for the damages resulting from its negligence.
This case underscores the importance of diligence and transparency in contractual
relationships, highlighting that negligence in performing contractual obligations can lead to
liability for resulting damages.