Evidence - Case Digest
Evidence - Case Digest
1. Locsin vs. Sandiganbayan, G.R. No. ● Ultimate facts mean the The petitioners filed a complaint whether the Sandiganbayan The Court held that the proposed
134458, August 9, 2007 important and substantial against the PCGG seeking for the committed grave abuse of discretion in amendments were substantial and
facts which either directly nullification of its actions, denying the admission of the would result in delay, and that the trial
form the basis of the sequestration orders, and damages of amended complaint. court has sound discretion to grant or
plaintiff's primary right and their corporation and the issuance of deny the admission of proposed
duty or directly make up the TRO and/or WPI. However, the substantial amendments to a pleading.
wrongful acts or omissions of Sandiganbayan denied the injunctive
the defendant. writ. They then filed an amended The court emphasized that the
● "Evidentiary facts" are those complaint but later filed a Notice of petitioners had the opportunity to
which are necessary to prove Dismissal which was approved by the present detailed evidence during
the ultimate fact or which Sandiganbayan. pre-trial, despite the denial of their
furnish evidence of the The petitioners filed a new complaint amended complaint. This indicates
existence of some other with the Sandiganbayan which that while the ultimate facts establish
facts. They are not proper as impleads additional plaintiffs and the basis of their claims, the
allegations in the pleadings respondents. The new complaint evidentiary facts are crucial for proving
as they may only result in sought to state more fully their those claims in court. The denial of the
confusing the statement of averments in express terms which amended complaint did not preclude
the cause of action or the were only implied from the ultimate the petitioners from presenting
defense. They are not facts in their original Complaint. evidence to support their allegations
necessary therefor, and their The Sandiganbayan denied the during the proceedings.
exposition is actually admittance of petitioners’ amended
premature as such facts complaint since the Answers have
must be found and drawn already been filed and the amended
from testimonial and other complaint seeks to allege additional
evidence. facts in order to supply the missing or
omitted data which omission had
resulted in the denial by the Court for
the issuance of the writ or preliminary
injunction.
2. Tantuico, Jr. vs. Republic, G.R. No. The Court explained that a complaint The PCGG filed a complaint against whether the allegations in the The Supreme Court ruled in favor of
89114, [December 2, 1991] must contain a concise statement of Tantuico, Jr. and others for complaint are sufficient to inform Tantuico, Jr., stating that the
the ultimate facts constituting the reconveyance, reversion, accounting, Tantuico, Jr. of the claims made Sandiganbayan acted with grave
plaintiff's cause of action. The restitution, and damages, alleging that against him and enable him to prepare abuse of discretion in denying his
allegations of the complaint must be they accumulated ill-gotten wealth his responsive pleading and prepare motion for a bill of particulars. The
sufficient to inform the defendant through various illegal acts, including for trial. Court found that the allegations
clearly and definitely of the claims misappropriation and theft of public against Tantuico, Jr. were vague and
made against him so that he may be funds, plunder, extortion, blackmail, unsupported by factual premises, and
prepared to meet the issues at the bribery, embezzlement, and other acts that he was entitled to a bill of
trial. of corruption. Tantuico, Jr. was particulars to enable him to prepare
included as a defendant in the
Case Title Doctrine Facts Issue/s Ruling
complaint on the theory that he acted his responsive pleading and prepare
in unlawful concert with the principal for trial.
defendants, facilitated and made
possible the withdrawals,
disbursements, and questionable use
of government funds, and acted as a
dummy, nominee, or agent in
accumulating ill-gotten wealth.
3. Lagman vs. Medialdea, G.R. Nos. These are consolidated petitions Whether there exists sufficient factual The Court found the government's
243522, 243677, 243797, [February challenging the constitutionality of the basis for the extension of martial law presented facts sufficient,
19, 2019] third extension of martial law in and the suspension of the privilege of demonstrating a continuing state of
Mindanao and the suspension of the the writ of habeas corpus in Mindanao. rebellion and a significant threat to
privilege of the writ of habeas corpus. public safety that justified the
Pres. Duterte declared Martial Law on extraordinary measures. The Supreme
May 23, 2017 in response to the Court found that there is a sufficient
rebellion by the Maute Group in factual basis for the extension of
Marawi City which was subsequently martial law and the suspension of the
extended. privilege of the writ of habeas corpus
On December 4, 2018, The President in Mindanao. The Court determined
requested for a third extension for 1 that rebellion persists in the region,
year or until December 31, 2019 supported by reports from the military
because of the continuous rebellion and police indicating ongoing violence
and threats from various groups. The and threats to public safety. The Court
COngress then approved the emphasized that rebellion is a
extension for 1 year. continuing crime and does not cease
Petitioners contend that the with the cessation of actual fighting,
government did not sufficiently prove thus justifying the extension.
an ongoing rebellion nor justify such
and that the extension would further
violate citizen’s political, civil, and
human rights, and among others.
4. Boaz vs. Woodward, G.R No. The liberal construction of the Rules Woodward filed a complaint for a sum The Supreme Court granted the
Did the Court of Appeals err in ruling
147793, December 11, 2003 of Court is resorted to only to of money and damages against the petition, set aside the August 9, 1999
that Judge Ibay acted within his
promote substantial justice, not to petitioners. The petitioners filed an Order of the RTC, and nullified the
jurisdiction and without grave abuse of
delay or undermine legal processes. answer to the complaint along with a reinstatement of Woodward's
discretion when he granted
The Rules are designed to assure the third-party complaint against North complaint. The Court emphasized that
orderly and predictable course of Front Shipping Services, Inc. The RTC the Rules of Court must be followed to
justice. Unduly relaxing them would scheduled a pre-trial conference for ensure the orderly and predictable
Case Title Doctrine Facts Issue/s Ruling
be an injustice to the innocent parties November 4, 1997, which was Woodward's Motion to Reinstate course of justice, and that undue
who honor and obey them, and postponed multiple times to allow for Complaint? relaxation of these rules would be an
unfairly reward those who neglect or amicable settlement discussions. On injustice to parties who comply with
fail to follow them. the scheduled pre-trial conference, them.
neither Woodward nor its counsel
appeared, prompting the petitioners to The case emphasizes that while liberal
request that Woodward be declared construction of the Rules of Court is
non-suited and that their complaint be intended to promote substantial
dismissed. The RTC granted this justice, it should not undermine the
motion, dismissing both Woodward's orderly and predictable course of
complaint and the third-party justice. The Court found that a liberal
complaint against North Front. interpretation was not warranted in
Woodward's counsel later filed an this case, as the rules on pre-trial are
urgent ex-parte motion to reconsider designed to ensure efficient resolution
the dismissal, which was denied for of cases. Woodward's argument for a
being filed out of time. Subsequently, liberal interpretation failed because it
on June 25, 1999, Woodward filed a did not demonstrate how such an
motion to reinstate its complaint, which interpretation would lead to a just
the RTC granted on August 9, 1999. outcome, especially given its violations
The petitioners then elevated the case of procedural rules. Thus, adherence
to the Court of Appeals (CA), claiming to procedural rules is crucial to
grave abuse of discretion by the RTC. maintaining the integrity of the judicial
process.
5. The Heritage Hotel, Manila vs. Sio, Substantial Evidence: The findings of Lilian Sio, who was employed as a did the CA correctly determine that the The CA ruled that the evidence
G.R. No. 217896 June 26, 2019 the LA and NLRC were supported by Service Agent at The Heritage Hotel, NLRC's decision upholding the presented by The Heritage Hotel,
substantial evidence, including written Manila, since September 1, 1995. Sio suspensions was tainted with grave particularly the complaints from
complaints, administrative hearing faced two separate suspensions due abuse of discretion? guests, was hearsay and lacked
minutes, and Sio’s own admissions to incidents involving guests. corroborating testimony, thus
(apologies) during the hearings. Sio allegedly responded arrogantly to undermining the validity of the
Technical Rules of Evidence: a guest, Erlinda Tiozon, regarding the suspensions.
Administrative bodies like the NLRC Player Tracking System (PTS) needed
are not bound by strict rules of for processing her order. After an In contrast, the NLRC and the Labor
evidence. Hearsay evidence may still investigation, Sio was found guilty of Arbiter found that there was
be considered if it is supported by discourtesy and was suspended for substantial evidence supporting the
other substantial evidence. one week from June 7 to June 14, 2011. claims against Sio, including her own
Sio made a disrespectful remark to admissions during the administrative
another guest, Mussa Mendoza, after hearings and the procedural due
an order was canceled. Following a process afforded to her. The Supreme
complaint, Sio was again found guilty Court ultimately ruled that the NLRC's
findings were supported by substantial
Case Title Doctrine Facts Issue/s Ruling
and suspended for two weeks from evidence and that the suspensions
October 18 to November 2, 2011. were a valid exercise of management
Sio filed a complaint for Unfair Labor prerogative, emphasizing that
Practice and illegal suspension with administrative bodies are not strictly
the National Labor Relations bound by technical rules of evidence.
Commission (NLRC), but the Labor
Arbiter dismissed her complaint,
affirming the validity of her
suspensions. The Court of Appeals
later annulled the NLRC's rulings,
citing lack of corroborating evidence.
However, the Supreme Court
ultimately reinstated the NLRC's
findings, emphasizing the validity of
the suspensions based on substantial
evidence and the importance of
employer discretion in disciplinary
matters.
6. Clemente vs. Status Maritime Clemente was hired as a fitter by (1) Whether or not the respondents 1) When there is no post-employment
Corp., G.R. No. 238933, [July 1, 2020] Status Maritime on August 7, 2015. complied with their obligation of medical examination by a company-
Months later, Clemente’s shoulder referral to a company-designated designated physician, the evaluation
snapped and was dislocated while he physician; and of the chosen physician is considered
was allegedly lifting a heavy object. He by law as binding between the parties.
was repatriated and reported to the (2) Whether or not petitioner is Respondents' refusal to submit
company designated physician who disqualified from claiming disability petitioner to a medical examination is
advised him to undergo an MRI but benefits due to fraudulent a contravention of their responsibility
Status Maritime disapproved of the concealment. under the POEA Standard Employment
procedure and rejected his claim for Contract. Thus, the permanent
sickness allowance. disability rating of Dr. Ticman stands.
Clemente consulted another physician 2) However, petitioner's benefits claim
and was diagnosed that his condition must be denied due to fraudulent
is a permanent disability and declared concealment.
him unfit to work as seafarer. He filed a Section 20 (E) of the POEA Standard
complaint for permanent total disability Employment Contract states that "[a]
before the LA with damages. seafarer who knowingly conceals a
Status MAritime contented that pre-existing illness or condition" is
Clemente is not entitled to disability disqualified from claiming
benefits because he fraudulently compensation and benefits.
concealed his history of shoulder Intentional concealment of a
dislocation. It further alleged that pre-existing illness or injury is a
Clemente disclosed such information ground for disqualification for
Case Title Doctrine Facts Issue/s Ruling
with his crewmates and that compensation and benefits under the
Clemente’s injury is not work-related. POEA Standard Employment Contract.
LA dismissed the case due to While our laws give ample protection
Clemente’s failure to prove how the to our seafarers, this protection does
nature of his work aggravated or not condone fraud and dishonesty.
contributed to his injury and was still Petitioner cannot feign ignorance and
disqualified from claiming disability downplay the concealment of his
benefits because of the non-disclosure medical condition. Clearly, the
of his medical history during the petitioner knew that he had a recurring
pre-employment medical examination. shoulder dislocation. He never denied
NLRC affirmed the ruling of the LA. this fact. Hence, his disability claim
The CA upheld the ruling of the labor must be denied.
tribunals.
Case Title Doctrine Facts Issue/s Ruling
7. Office of the Court of Administrator Judge Lerma violated Supreme Court The case involves Judge Alberto L. Did Judge Alberto L. Lerma violate The Court found Judge Lerma guilty of
vs. Judge A. Lerma, A.M. No. directives, engaged in misconduct, Lerma, who served in the Regional Supreme Court directives by violating a Supreme Court directive
RTJ-07-2076, October 12, 2010 ignored the law, abused authority, and Trial Court (RTC), Branch 256, dismissing a criminal case beyond his and imposed a fine of P15,000.00 in
delayed cases, resulting in fines and Muntinlupa City. Five administrative authority? A.M. No. RTJ-07-2076.
dismissal. cases were filed against him by Did Judge Lerma commit violations by In A.M. No. RTJ-07-2080, Judge Lerma
various complainants, including the playing golf during work hours without was fined P15,000.00 for violations
Office of the Court Administrator proper leave? related to playing golf during work
(OCA), Atty. Lourdes A. Ona, Jose Mari Was Judge Lerma guilty of gross hours without leave.
L. Duarte, and Ret. General Meliton D. negligence and misconduct in issuing In A.M. No. RTJ-07-2077, Judge Lerma
Goyena, for multiple violations of conflicting orders in a case? was found guilty of gross misconduct
Supreme Court rules, directives, and Did Judge Lerma exhibit gross and dismissed from service with
circulars. The complaints included ignorance of the law by assuming forfeiture of benefits.
allegations of making untruthful jurisdiction over a case that was not In A.M. No. RTJ-07-2078, he was found
statements in his certificates of under his purview? guilty of gross ignorance of the law
service, gross ignorance of the law, Did Judge Lerma abuse his authority and fined P40,000.00.
gross negligence, delay in rendering and cause undue delay in rendering a In A.M. No. RTJ-07-2079, Judge Lerma
orders, abuse of judicial authority, and decision in a criminal case? was found guilty of abuse of authority
serious irregularity. The OCA, under and undue delay, resulting in a fine of
the leadership of then Court P21,000.00.
Administrator Christopher O. Lock,
referred these cases to the Supreme RATIO:
Court, which redocketed them as A.M. The Supreme Court emphasized the
Nos. RTJ-07-2076, RTJ-07-2077, importance of adherence to its
RTJ-07-2078, RTJ-07-2079, and directives and the responsibilities of
RTJ-07-2080. judges to maintain the integrity of the
judiciary. In A.M. No. RTJ-07-2076, the
The first case, A.M. No. RTJ-07-2076, Court highlighted that Judge Lerma
stemmed from a criminal case where exceeded his authority by dismissing a
the accused, Ruperto Pizarro y Bruno, case that he was only authorized to
was charged with a violation of arraign, which constituted a violation
Presidential Decree No. 1866. The of the Supreme Court's directive. The
case was transferred to Judge Lerma's Court noted that judges must exercise
court, where he erroneously dismissed diligence and caution in their rulings,
it for insufficiency of evidence, despite especially in criminal cases where the
being limited to arraigning the stakes are high.
accused and taking testimony.
In A.M. No. RTJ-07-2080, the Court
In A.M. No. RTJ-07-2080, Judge Lerma found that Judge Lerma's failure to
was accused of playing golf during declare absences while playing golf
work hours without filing the during work hours constituted
necessary leave of absence, violating dishonesty and a violation of Supreme
several Supreme Court directives. Court rules. The Court reiterated that
Case Title Doctrine Facts Issue/s Ruling
8. People vs. Valdez, G.R. No. Appellant convicted for illegal sale The case involves the appellant, Did the Court of Appeals err in The Supreme Court affirmed the
129296, September 25, 2000 and possession of marijuana; buy-bust Roberto F. Valdez, who was charged affirming the trial court's verdict of decision of the Court of Appeals,
operation upheld despite minor with violations of Section 5 and conviction against Roberto F. Valdez which upheld the trial court's
procedural lapses; chain of custody Section 11, Article II of Republic Act No. for violations of the Comprehensive conviction of Roberto F. Valdez for
preserved. 9165, also known as the Dangerous Drugs Act? illegal sale and possession of
Comprehensive Dangerous Drugs Act marijuana.
of 2002. The events leading to the
charges occurred on July 25, 2009, in Ratio:
Panabo City, Davao del Norte. The The Supreme Court emphasized that
prosecution's case stemmed from a in drug-related cases, the prosecution
buy-bust operation initiated after an must prove not only the elements of
informant reported that Valdez was the offense but also the integrity and
selling illegal drugs. The operation was identity of the corpus delicti, which in
coordinated by PO3 Adonis Estenzo this case were the seized marijuana
and involved PCPAG Glen B. Abellana items. The Court noted that the
as the poseur buyer. During the prosecution established a clear chain
operation, Abellana purchased two of custody, demonstrating that the
packs of marijuana from Valdez for drugs seized from Valdez were the
P200, using marked money. Upon same ones presented in court.
arrest, police recovered the marked Although there were minor
bills from Valdez and discovered two inconsistencies in witness testimonies
bundles of marijuana in his and discrepancies in the weight and
possession. The trial court found description of the drugs, these did not
Valdez guilty of both charges, undermine the overall credibility of the
sentencing him to life imprisonment for prosecution's case. The Court
the sale of marijuana and a lengthy highlighted that the procedural
prison term for possession. Valdez safeguards outlined in Section 21 of
appealed the decision, arguing that RA 9165 were substantially complied
the prosecution failed to establish the with, and the integrity of the evidence
integrity and identity of the seized was preserved. The Court also ruled
items, among other claims. that the differences in terminology
used to describe the marijuana did not
affect the identity of the corpus delicti.
Ultimately, the Court found no
reversible error in the Court of
Appeals' decision to affirm the
conviction.
Case Title Doctrine Facts Issue/s Ruling
9. People vs. Cogaed G.R. No. Police intercepted Cogaed based on a The case involves Victor Cogaed y Was there a valid search and seizure The Supreme Court reversed and set
200334, July 30, 2014 tip, finding marijuana in his bag. SC Romana as the accused-appellant and the of marijuana against the appellant? aside the decisions of the Regional
acquitted him, ruling the warrantless People of the Philippines as the Trial Court and the Court of Appeals. It
respondent-appellee. The events leading
search unconstitutional, rendering Should the evidence obtained through acquitted Victor Cogaed y Romana
to the case unfolded on November 25,
evidence inadmissible and violating the search be admitted? due to the lack of admissible evidence
2005, in San Gabriel, La Union. Police
his rights. Senior Inspector Sofronio Bayan received against him.
a text message from an unidentified Was there sufficient evidence to
informant indicating that Marvin Buya sustain the conviction of the accused? Ratio:
would be transporting marijuana from The Supreme Court emphasized the
Barangay Lun-Oy to the Poblacion of San fundamental right to privacy enshrined
Gabriel. Following this tip, PSI Bayan in Article III, Section 2 of the 1987
organized checkpoints to intercept the Philippine Constitution, which protects
suspect. At a checkpoint, the driver of a
individuals from unreasonable
passenger jeepney signaled to police
searches and seizures. The Court
officer SPO1 Jaime Taracatac, indicating
two male passengers, Cogaed and found that the police officers lacked
Santiago Dayao, as suspicious. Cogaed reasonable suspicion to justify the
was carrying a blue bag and a sack, while warrantless arrest and subsequent
Dayao had a yellow bag. Upon search of Cogaed. The identification of
questioning, both denied knowledge of the Cogaed as suspicious was based
contents, claiming they were merely solely on the jeepney driver's signal,
helping a friend named Marvin. SPO1 not on any personal observation by
Taracatac then asked Cogaed to open his
the police officers. The Court
blue bag, which revealed three bricks of
highlighted that a valid "stop and frisk"
what appeared to be marijuana. Cogaed
was arrested along with Dayao and taken requires the police officer to have
to the police station, where further personal knowledge of facts that
searches revealed more marijuana in their would lead to a reasonable suspicion
bags. The total weight of the seized of criminal activity, which was absent
marijuana was 17,429.6 grams. Cogaed in this case. The Court also noted that
was charged with illegal possession of Cogaed's alleged waiver of rights was
dangerous drugs under Republic Act No. not made knowingly or intelligently, as
9165. During the trial, the Regional Trial
it occurred under coercive
Court found Cogaed guilty and sentenced
circumstances. Consequently, the
him to life imprisonment and a fine of one
million pesos. The trial court initially evidence obtained from the illegal
acknowledged the illegality of the arrest search was inadmissible under the
but claimed Cogaed waived his right to exclusionary rule, leading to Cogaed's
object by not protesting when asked to acquittal.
open his bag. Cogaed appealed the
decision, which was affirmed by the Court
of Appeals, leading to the current appeal.
Case Title Doctrine Facts Issue/s Ruling
10. Office of the Court Administrator A court clerk, acquitted of drug This administrative case originated from a Whether Hermogenes M. Guico, Jr. The Court absolved Guico of any
vs. Guico, Jr., A.M. No. P-12-3049, charges due to illegal arrest, was letter dated September 23, 2011, written by may be held administratively liable for administrative liability, ruling that the
[June 29, 2021] absolved of administrative liability as Atty. Jose C. Corales, Clerk of Court VI of testing positive for methamphetamine evidence obtained against him was
the Regional Trial Court (RTC) in Batangas
the drug test result was inadmissible hydrochloride in the absence of inadmissible due to the illegal nature
City, to the Office of the Court
under the exclusionary rule. incriminating evidence against him. of his arrest, search, and seizure.
Administrator (OCA). The letter sought
guidance on the appropriate actions to
take following the filing of a criminal case Ratio:
against Hermogenes M. Guico, Jr., who The Court's decision was grounded in
served as Clerk III in the same court. On the constitutional protections against
September 23, 2011, the Assistant City unreasonable searches and seizures
Prosecutor of Batangas City charged Guico as enshrined in Article III, Section 2 of
with violating Article II, Section 11 of the 1987 Philippine Constitution. It
Republic Act (R.A.) No. 9165, known as the
emphasized that any evidence
"Comprehensive Dangerous Drugs Act of
obtained in violation of these rights is
2002." The charge stemmed from an
incident on September 21, 2011, when inadmissible in any proceeding, as
police officers responded to a shooting stated in Article III, Section 3(2). The
incident in Barangay Sta. Clara, Batangas Court highlighted that Guico's positive
City. During their operation, they attempted drug test result was a "fruit of the
to intercept Guico, who fled on his poisonous tree," meaning it was
motorcycle. After a chase, he was derived from the illegally obtained
apprehended, and a search yielded a evidence of the methamphetamine
packet believed to contain
seized during his unlawful arrest. The
methamphetamine hydrochloride (shabu),
Court referenced previous rulings that
along with other items. Subsequent
laboratory tests confirmed the substance established the exclusionary rule,
was indeed shabu, and Guico tested which applies not only to direct
positive for drug use following a drug test evidence obtained from illegal
conducted on September 22, 2011. The searches but also to any secondary
criminal case against him proceeded in evidence that stems from such
Branch 7 of the RTC-Batangas City, which violations. The Court noted that
convicted him on October 22, 2014, Guico's arrest lacked probable cause,
sentencing him to 12 to 14 years of
as the police had no reasonable basis
imprisonment and a fine of P300,000.
to believe he was committing a crime
However, on appeal, the Court of Appeals
acquitted Guico on April 22, 2016, ruling at the time of his apprehension.
that the evidence against him was Consequently, the positive drug test
inadmissible due to the illegal nature of his result could not be used against him in
arrest and search. Following this, the OCA the administrative proceedings. The
recommended that Guico be found guilty Court ultimately accepted Guico's
of grave misconduct and dismissed from resignation, declaring his position
service, citing his positive drug test as vacant, while issuing a stern warning
grounds for administrative liability. The
regarding future conduct.
case was then referred to the Supreme
Court En Banc for resolution.
Case Title Doctrine Facts Issue/s Ruling
11. Office of the Court Administrator Judge Atillo, Jr. posted inappropriate This administrative matter involves Did Judge Romeo M. Atillo, Jr. violate The Court found Judge Atillo, Jr. guilty of
vs. Atilla, Jr., A.M. No. RTJ-21-018, half-dressed photos on Facebook, Judge Romeo M. Atillo, Jr., the Executive the New Code of Judicial Conduct and violating the New Code of Judicial Conduct
[September 29, 2021] violating judicial conduct standards. Judge and Presiding Judge of the OCA Circular No. 173-2017 through his and OCA Circular No. 173-2017.
Regional Trial Court, Branch 31, Agoo, La The Court held that Judge Atillo, Jr. was
His hacking defense was rejected; he social media posts?
Union. The case arose from social media liable for conduct unbecoming of a judge.
was admonished for conduct
posts made by Judge Atillo, Jr. on his The Court imposed a penalty of
unbecoming of a judge. Is Judge Atillo, Jr. liable for conduct admonition and sternly warned Judge
Facebook account, which were deemed unbecoming of a judge based on the Atillo, Jr. that any repetition of similar acts
inappropriate under the New Code of content of his Facebook posts? would result in more severe
Judicial Conduct and in violation of
consequences.
Office of the Court Administrator (OCA)
What is the appropriate penalty for
Circular No. 173-2017 regarding the Ratio:
Judge Atillo, Jr. given the
proper use of social media. The OCA The Court affirmed the findings of the
received printed copies of images circumstances of the case?
OCA, emphasizing that judges must
showing Judge Atillo, Jr. half-dressed conduct themselves with integrity and
and displaying tattoos on his upper propriety, both in their official duties and
body, which were used as cover and personal lives. The Court reiterated that
profile pictures on his Facebook page. In judges are subject to higher standards of
a letter dated January 28, 2020, the conduct due to their role as
OCA requested Judge Atillo, Jr. to representatives of the law and justice. The
comment on these pictures concerning Court highlighted that the appearance of
potential violations of judicial conduct. In impropriety can undermine public
his response dated February 11, 2020, confidence in the judiciary, which is critical
Judge Atillo, Jr. claimed that his for maintaining the integrity of the judicial
Facebook account had been hacked on system. The Court clarified that the
August 11, 2019, resulting in a change of impropriety in this case stemmed from
Judge Atillo, Jr.'s decision to post the
privacy settings from private to public.
pictures on social media, not from his
He argued that the pictures were
choice to have tattoos. The Court rejected
intended solely for personal viewing and
Judge Atillo, Jr.'s defense regarding the
not for public consumption, asserting privacy of his Facebook account, noting
that they were inadmissible as evidence that even with privacy settings, content can
due to being illegally obtained, thus still be shared and viewed by a broader
violating his right to privacy under audience. The Court also dismissed his
Section 3, Article III of the Constitution. argument regarding the inadmissibility of
The OCA's report, dated July 14, 2020, the pictures, stating that the exclusionary
found Judge Atillo, Jr. guilty of violating rule does not apply to private individuals
the New Code of Judicial Conduct and and that the OCA's actions were not
OCA Circular No. 173-2017, state-involved. Ultimately, the Court
recommending a fine of P15,000 and a deemed that Judge Atillo, Jr.'s actions
reprimand for conduct unbecoming of a constituted conduct unbecoming of a
judge. The case was then elevated to judge, warranting an admonition as a first
the Supreme Court for final resolution. offense, while reminding all judges to
exercise caution in their social media
interactions to uphold the dignity of their
office.
Case Title Doctrine Facts Issue/s Ruling
12. Manotok Realty, Inc. vs. CLT Dispute over Maysilo Estate titles The case involves two consolidated 1. Which of the Certificates of The Supreme Court ruled that the titles of
Realty Development Corp., G.R. Nos. derived from OCT No. 994; Supreme petitions: G.R. No. 123346, filed by Title of the contending parties CLT Realty and the heirs of Dimson are
123346 & 134385, December 14, Court upheld 3 May 1917 OCT as valid, Manotok Realty, Inc. and Manotok Estate are valid? valid, while the titles of the Manotok
Corporation against CLT Realty Corporations and the Araneta Institute are
2007 voided 19 April 1917 OCT, and affirmed 2. Can this Court overturn its
Development Corporation, and G.R. No. void.
prior rulings. previous decisions in
134385, filed by Araneta Institute of The Court declined to overturn its previous
Agriculture, Inc. against the heirs of Jose B. Metropolitan Waterworks and decisions regarding the validity of OCT No.
Dimson. The controversy centers around Sewerage System v. Court of 994, affirming that only one valid OCT No.
properties covered by Original Certificate Appeals and Heirs of Luis J. 994 exists, registered on May 3, 1917.
of Title (OCT) No. 994, which encompasses Gonzaga v. Court of Appeals The Court determined that the Reports of
a vast area of 1,342 hectares of the Maysilo regarding the validity of OCT the Department of Justice and the Senate
Estate, located in Malabon, Caloocan City, No. 994? Fact-Finding Committee do not necessitate
and Quezon City. The properties have 3. How do the Reports of the a remand of the cases, as they do not
been embroiled in disputes over their provide new evidence that would alter the
Department of Justice and the
titles, with allegations of fraud and findings of the lower courts.
Senate Fact-Finding
irregularities in the issuance of various Ratio:
transfer certificates of title (TCTs). Committee affect the The Supreme Court emphasized the
disposition of these cases? importance of the integrity of the Torrens
In G.R. No. 123346, CLT Realty filed a system of land registration, which is
complaint on August 10, 1992, seeking designed to provide certainty and security
recovery of possession of Lot 26 of the in land titles. The Court found that the titles
Maysilo Estate, claiming ownership through held by CLT Realty and the heirs of Dimson
TCT No. T-177013, which was derived from were validly derived from the sole OCT No.
a deed of sale from Estelita Hipolito, who in 994, which was registered on May 3, 1917.
turn obtained her title from Jose Dimson. The Court rejected the notion of two OCTs,
The Manotoks contested the validity of affirming that the earlier date of April 19,
CLT's title, asserting that their own titles, 1917 referenced in some documents was
which traced back to OCT No. 994, were merely the date of the decree of
legitimate. registration, not the date of actual
registration.
In G.R. No. 134385, the heirs of Jose B. The Court also noted that the titles of the
Dimson filed a complaint against the Manotok Corporations and the Araneta
Araneta Institute on December 18, 1979, Institute were tainted by irregularities and
claiming ownership of a portion of the could not be traced back to a valid source.
Maysilo Estate covered by TCT No. The findings of the trial courts, which were
R-15169. The Araneta Institute countered affirmed by the Court of Appeals, were
that Dimson's title was void, as it was given great weight, as they were based on
derived from a spurious OCT No. 994. thorough examinations of the evidence
presented. The Court concluded that the
The trial courts ruled in favor of CLT and integrity of the Torrens system must be
the heirs of Dimson, leading to appeals preserved, and any titles derived from a
that were subsequently affirmed by the non-existent mother title are void. Thus,
Court of Appeals. The Supreme Court, in the motions for reconsideration were
its 2005 Decision, upheld the findings of denied, and the cases were remanded to
the lower courts, leading to motions for the Court of Appeals for further
reconsideration from the petitioners. proceedings to determine the validity of
the claims based on the established facts.
Case Title Doctrine Facts Issue/s Ruling
13. Surtida vs. Lesaca, G.R. No. Election protest filed via mail within The case involves Joaquin Surtida, Juan The Supreme Court ruled that the
1. Was the motion of protest filed
46191, [September 12, 1938] two-week period; docketing fees sent de la Riva, Alfonso Pantino, Eusebio motion of protest was indeed filed
Talion, and Eduardo Gianan as within the prescribed period
later. SC upheld jurisdiction, ruling within the period prescribed by law,
petitioners against Juan G. Lesaca, the according to the Election Law?
mailing date as filing date, with and thus the court had jurisdiction to
Judge of the First Instance of Albay, and 2. Did the court have jurisdiction
substantial compliance on fees. hear the case. The petition for a writ of
respondents Jose F. Arcilla, Primo Panti, to hear the motion of protest
Dissent argued Election Law governs, certiorari was denied, with costs
Julio Guerrero, and Ariston Sarmiento. despite the timing of the
not procedural rules. against the petitioners.
The events leading to the case began on docketing fees?
December 15, 1937, when the petitioners
and respondent Ariston Sarmiento were Ratio:
proclaimed councilors-elect of the
municipality of Virac, Catanduanes, The court's decision hinged on the
Province of Albay. On December 29, interpretation of the filing date of the
1937, respondent Primo Panti filed a motion of protest. It established that
motion of protest against the election the date of mailing the motion is
results, which was sent via registered considered the date of filing, as per
mail to the clerk of the Court of First Rule 13 of the Supreme Court. This rule
Instance in Legaspi. On December 31, is grounded in principles of justice and
1937, Panti also sent a telegraphic equity, ensuring that litigants in remote
transfer of P39 to cover the docketing areas are not disadvantaged
fees and sheriff's fees for the service of
compared to those in more accessible
summons. Both the motion of protest
locations. The court emphasized that
and the payment were received by the
the purpose of legal rules is to
clerk on January 4, 1938, and the motion
was subsequently docketed. The promote justice rather than to defeat it
petitioners filed a demurrer, arguing that through technicalities. The court noted
the court lacked jurisdiction because the that the petitioners suffered no
motion of protest was not filed within the prejudice from the timing of the
two-week period mandated by the docketing fees, which were sent by
Election Law. The court overruled this telegraphic transfer and received
demurrer on February 15, 1938, asserting simultaneously with the motion of
that the motion was timely filed. On May protest. The ruling underscored the
23, 1938, the petitioners filed a motion to importance of substantial compliance
dismiss based on the same jurisdictional with procedural rules, asserting that
argument, claiming that the docketing technical objections should not
fees were sent two days after the motion override substantial rights when no
was mailed. This motion was also harm is demonstrated.
denied, prompting the petitioners to
seek a writ of certiorari to quash the
proceedings on the grounds of lack of
jurisdiction.
Case Title Doctrine Facts Issue/s Ruling
14. Municipal Board of the City of Election inspectors' appointment The case G.R. No. 45844, decided on 1. Did the Court of Appeals err in 1. The Supreme Court ruled that
Manila vs. Agustin, G.R. No. 45844, contested; Frente Popular failed to November 29, 1937, involves a petition reviewing and altering the the Court of Appeals did not
[November 29, 1937 prove party formation date, Partido for a writ of certiorari filed by the factual conclusions of the err in reviewing and altering
Radical retained rights under Election Municipal Board of the City of Manila Court of First Instance without the factual conclusions of the
Law. and Alfonso E. Mendoza, as President a motion for a new trial? Court of First Instance, given
of the Partido Radical, against 2. Did the Court of Appeals err in the urgent nature of
Segundo Agustin, the representative assuming the date of the election-related proceedings.
of the Frente Popular. The Municipal formation of the Sakdalista 2. The Supreme Court found that
Board appointed election inspectors Party without sufficient the Court of Appeals erred in
and substitute inspectors for the evidence? concluding that the Frente
upcoming December 1937 elections, Popular was entitled to an
granting the Partido Radical one inspector and substitute
inspector and one substitute inspector inspector based on an
for each election precinct in Manila. unproven assumption
The Frente Popular, claiming a regarding the Sakdalista
superior right as an opposition party, Party's formation date.
initiated mandamus proceedings in the Ratio:
Court of First Instance of Manila (Civil The Supreme Court emphasized the
Case No. 51940) to compel the urgency of resolving election-related
Municipal Board to appoint inspectors disputes, allowing the Court of
for their party. The Court of First Appeals to review the lower court's
Instance ruled in favor of the Partido factual findings without a motion for a
Radical, stating it was the oldest active new trial. The Court noted that the
opposition party in the locality, thus nature of election proceedings
entitled to the appointments. The necessitates prompt resolution to
Frente Popular appealed to the Court avoid discord, thus justifying the
of Appeals, which reversed the lower appellate court's actions. However, the
court's decision, ordering the Court criticized the Court of Appeals
Municipal Board to revoke the for basing its decision on an
appointments for the Partido Radical assumption regarding the Sakdalista
and appoint inspectors for the Frente Party's formation date, which was not
Popular instead. The Partido Radical substantiated by evidence. The
then sought a writ of certiorari from Supreme Court held that legal
the Supreme Court, alleging various conclusions must be supported by
errors of law committed by the Court established facts, and in this case, the
of Appeals. Frente Popular failed to prove its claim
to representation based on the priority
of organization. Consequently, the
Supreme Court reversed the Court of
Appeals' decision, reinstating the
ruling of the Court of First Instance,
which favored the Partido Radical.
Case Title Doctrine Facts Issue/s Ruling
15. State Prosecutors vs. Muro, A.M. Judge Muro dismissed 11 criminal The complainants, State Prosecutors 1. Did Judge Manuel T. Muro 1. Yes, the court found that
No. RTJ-92-876, [September 19, cases against Imelda Marcos based on Nilo C. Mariano, George C. Dee, and commit gross ignorance of the Judge Muro committed gross
1994] unverified newspaper reports, ignoring Paterno V. Tac-an, filed a law by dismissing the cases ignorance of the law.
due process and official legal letter-complaint on August 19, 1992, based solely on newspaper 2. Yes, the court ruled that Judge
procedures, leading to a Supreme against Judge Manuel T. Muro, who reports? Muro violated the
Court ruling of gross ignorance of the presided over the Regional Trial Court 2. Did Judge Muro violate the complainants' right to due
law and judicial misconduct. (RTC) of Manila, Branch 54. The complainants' right to due process.
complaint alleged that Judge Muro process by dismissing the 3. Yes, the court concluded that
exhibited ignorance of the law, grave cases without giving them an the dismissal of the cases
misconduct, and violations of the Code opportunity to be heard? indicated bias and partiality
of Judicial Conduct. The events 3. Was the dismissal of the cases towards the accused.
leading to the complaint began on indicative of bias or partiality Ratio:
August 13, 1992, when Judge Muro towards the accused? The Supreme Court emphasized that a
issued an order dismissing eleven judge has a continuous duty to know
criminal cases against Mrs. Imelda the law and that ignorance of the law
Romualdez Marcos, which were is inexcusable, especially for someone
related to violations of Central Bank in a judicial position. The court found
Foreign Exchange Restrictions as that Judge Muro's reliance on
outlined in CB Circular No. 960. The newspaper reports, rather than waiting
dismissal was based solely on for the official publication of the
newspaper reports regarding an Central Bank Circular, demonstrated a
announcement made by the President lack of diligence and understanding of
of the Philippines on August 10, 1992, the law. The court highlighted that
which stated that the government had judicial notice cannot be taken of a law
lifted all foreign exchange restrictions. that is not yet in effect, and the judge's
The judge claimed that this actions were deemed hasty and
announcement had the effect of indicative of a failure to adhere to due
repealing the existing Central Bank process. Furthermore, the court noted
Circular, thus depriving the court of that the judge's failure to allow the
jurisdiction over the cases. The prosecution to present its case before
complainants argued that the judge dismissing the charges raised serious
acted prematurely and without due concerns about his impartiality and
process, as he did not wait for the integrity. The court ultimately ruled
official publication of the relevant that Judge Muro's actions undermined
Central Bank Circular or allow the public confidence in the judiciary,
prosecution to present its case. The leading to his dismissal from service,
case was subsequently appealed to along with the forfeiture of his
the Court of Appeals, which found that retirement benefits and disqualification
Judge Muro had acted with grave from reemployment in government
abuse of discretion and reinstated the service.
criminal cases.
Case Title Doctrine Facts Issue/s Ruling
16. Ofracio vs. People, G.R. No. Raul Ofracio acquitted as prosecution The case involves Raul Ofracio as the The Supreme Court granted Ofracio's
petitioner and the People of the Philippines 1. Should Raul Ofracio be held
221981, [November 4, 2020] failed to prove reckless imprudence in petition, reversing the decisions of the
as the respondents, with the decision liable under the doctrine of
fatal tricycle collision; last clear chance lower courts and acquitting him of the
rendered by the Supreme Court on last clear chance despite the
doctrine inapplicable. charges due to the prosecution's
November 4, 2020. The incident occurred circumstances surrounding
failure to prove his guilt beyond
on May 29, 2002, in Bibincahan, Sorsogon the collision?
City, where Ofracio was driving a tricycle reasonable doubt.
2. Did the lower courts err in
loaded with 46 pieces of lumber. During their application of the
the late hours of the night, his tricycle Ratio:
doctrine of last clear chance in
collided with another tricycle driven by Roy The Supreme Court clarified that the
determining Ofracio's liability? doctrine of last clear chance applies only
Ramirez, resulting in Ramirez's
instantaneous death and damage to his when both parties are negligent, and the
vehicle. Following the incident, a complaint negligent act of one occurs appreciably
for reckless imprudence resulting in later than that of the other. In this case,
homicide with damage to property was the Court found that the lower courts
filed against Ofracio in the Municipal Trial incorrectly applied this doctrine, as the
Court in Cities, Branch 2, Sorsogon City. evidence indicated that Ramirez was
The court found probable cause and driving erratically in a zigzagging
issued a warrant for Ofracio's arrest. On manner, which was a significant factor in
August 7, 2002, Ofracio pleaded not guilty.
the accident. Ofracio had testified that
During the pre-trial, both parties admitted
he was driving slowly due to the heavy
the essential facts surrounding the
load and that he had limited time to react
incident, including the identity of the
parties and the occurrence of the vehicular upon seeing Ramirez's tricycle
accident. The prosecution presented approaching. The Court noted that the
several witnesses, including police officers distance of 4 to 5 meters was insufficient
and medical experts, who testified about for Ofracio to take evasive action,
the accident and its aftermath. Ofracio, especially given the speed at which
along with a passenger, testified that he Ramirez was driving. Furthermore, the
was driving slowly due to the heavy load Court recognized that transporting
and claimed he saw a bright light from lumber on a tricycle is a common
Ramirez's tricycle shortly before the practice in the Philippines, and Ofracio's
collision. The Municipal Trial Court found actions did not constitute negligence per
Ofracio guilty of reckless imprudence se. The prosecution failed to establish a
resulting in homicide and sentenced him to direct causal connection between
an indeterminate penalty, along with Ofracio's actions and the resulting harm,
monetary compensation to Ramirez's heirs. leading to the conclusion that he did not
Ofracio's appeal to the Regional Trial Court act with reckless imprudence as defined
and subsequently to the Court of Appeals
under Article 365 of the Revised Penal
was unsuccessful, leading him to file a
Code. The Court emphasized the
Petition for Review on Certiorari before the
importance of proving guilt beyond
Supreme Court.
reasonable doubt, ultimately determining
that Ofracio was not liable for the
accident and should be acquitted.
Case Title Doctrine Facts Issue/s Ruling
17. People vs. Tundag, G.R. Nos. Tomas Tundag convicted of raping his The case involves the People of the 1. Did the trial court err in 1. The Supreme Court affirmed the
135695-96, [October 12, 2000] 13-year-old daughter; Supreme Court Philippines as the plaintiff-appellee convicting Tomas Tundag of trial court's conviction of Tomas
modified charges to simple rape due against Tomas Tundag, the incestuous rape despite the Tundag for two counts of simple
to unproven age, sentencing him to accused-appellant. The judgment under presence of reasonable rape, finding no reasonable
reclusion perpetua and awarding review originates from the Regional Trial doubt? doubt regarding his guilt.
damages. Court of Mandaue City, Branch 28, in 2. Was the penalty of death 2. The Supreme Court modified
Criminal Cases Nos. DU-6186 and imposed on Tomas Tundag the penalty from death to
DU-6203, with the decision rendered on appropriate given the reclusion perpetua, stating that
August 31, 1998. The case centers the prosecution failed to
circumstances of the case?
around two separate complaints for sufficiently prove the victim's
incestuous rape filed by Mary Ann age beyond reasonable doubt.
Tundag, the private complainant and Ratio:
daughter of the accused, on November The Supreme Court upheld the trial
18, 1997. The first complaint, Criminal court's findings, emphasizing that the
Case No. DU-6186, alleged that on credibility of the complainant is
September 5, 1997, Tomas Tundag, paramount in rape cases. The victim's
being the father of the 13-year-old Mary testimony was detailed, consistent, and
Ann, forcibly had sexual intercourse with unwavering, even when faced with the
her against her will. The second potential death penalty for her father.
complaint, Criminal Case No. DU-6203, The Court noted that the defense of
involved a similar incident that occurred denial and alibi presented by Tomas
on November 7, 1997, also in Mandaue Tundag was weak and self-serving,
City. failing to counter the compelling
evidence provided by the prosecution.
During the arraignment, Tomas Tundag However, regarding the imposition of the
pleaded "Not Guilty" to both charges, death penalty, the Court found that the
and the cases were consolidated for a prosecution did not adequately establish
joint trial. The defense presented a bare the victim's age, which is a critical
denial, claiming that the charges were element for qualifying the crime as
fabricated due to a quarrel between him incestuous rape under the law. The
and his daughter regarding her behavior. victim's testimony about her age was not
The trial court found the complainant's corroborated by independent evidence,
testimony credible, detailing the such as a birth certificate, which is
incidents where Tomas allegedly necessary to meet the legal standard for
threatened Mary Ann with a knife to proving minority in cases involving the
prevent her from screaming during the death penalty. Consequently, the Court
assaults. The court also noted that Mary modified the sentence to reclusion
Ann had a low IQ and was unable to perpetua, while affirming the awards for
read or write, which further emphasized civil indemnity and moral damages,
her vulnerability. The trial court ultimately recognizing the gravity of the crime and
convicted Tomas Tundag of two counts the need for deterrence against such
of incestuous rape, sentencing him to heinous acts.
death for each count and ordering him to
pay damages to the victim.
Case Title Doctrine Facts Issue/s Ruling
18. Expertravel & Tours Inc. vs. Court KAL sued ETI for unpaid fees; ETI The case involves Expertravel & Tours, Inc. Did the Court of Appeals err in its The Supreme Court granted the
of Appeals, G.R. No. 152392, [May contested Atty. Aguinaldo's authority (ETI) as the petitioner and Korean Airlines decision and resolution by failing to petition, reversed the decision of the
26, 2005] to file the complaint. SC ruled KAL (KAL) as the respondent. The events recognize the lack of authority of Atty. Court of Appeals, and ordered the
leading to the case began on September
failed to prove authorization, Aguinaldo to execute the verification dismissal of KAL's complaint against
6, 1999, when KAL, represented by its
dismissing the case due to and certification against forum ETI without prejudice.
general manager in the Philippines, Suk
non-compliance with procedural rules. Kyoo Kim, and its counsel, Atty. Mario shopping, thereby departing from the
Aguinaldo, filed a complaint against ETI in accepted and usual course of judicial Ratio:
the Regional Trial Court (RTC) of Manila. proceedings? The Supreme Court held that the
The complaint sought to collect a principal requirement for a certification against
amount of P260,150.00, along with forum shopping is mandatory and must
attorney's fees and exemplary damages. be executed by a party with actual
Atty. Aguinaldo signed the verification and knowledge of the facts. In this case, Atty.
certification against forum shopping, Aguinaldo, while being KAL's resident
claiming to be KAL's resident agent and agent, was not specifically authorized to
legal counsel. ETI contested the validity of execute the certification as required by
the complaint, arguing that Atty. Aguinaldo Section 5, Rule 7 of the Rules of Court.
lacked the authority to execute the The Court emphasized that the authority
verification and certification as mandated to sign such documents must come from
by Section 5, Rule 7 of the Rules of Court. a duly passed resolution of the
KAL countered that Atty. Aguinaldo was
corporation's board of directors, which
duly registered with the Securities and
was not adequately established in this
Exchange Commission (SEC) as KAL's
case.
resident agent and corporate secretary.
During a hearing on January 28, 2000,
Atty. Aguinaldo asserted that he had been The Court found that KAL's claims
authorized to file the complaint through a regarding the teleconference and the
resolution from KAL's Board of Directors subsequent resolution were not credible,
during a teleconference on June 25, 1999. particularly since KAL failed to provide
The RTC allowed KAL ten days to submit a any written record of the resolution
copy of this resolution. KAL later submitted despite claiming it was in the custody of
an affidavit from Suk Kyoo Kim, stating that its main office in Korea. The Court noted
the board had indeed approved the that the RTC and CA's acceptance of the
resolution during the teleconference, teleconference as a valid means of
although no written record of the conducting board meetings was flawed,
resolution existed. The RTC denied ETI's as there was no legal basis for such a
motion to dismiss the case, accepting the practice at the time. The Court
claims made by KAL. ETI subsequently underscored that judicial notice could
filed a petition for certiorari and mandamus not be taken of the teleconference
against the RTC's orders. The Court of
without proper evidence and that the
Appeals (CA) dismissed ETI's petition,
absence of a written resolution further
affirming the RTC's decision that Atty.
undermined KAL's position. Ultimately,
Aguinaldo's actions were valid. ETI then
sought a review from the Supreme Court, the Court concluded that the procedural
raising the issue of whether the CA had requirements were not met, leading to
deviated from accepted judicial the dismissal of KAL's complaint.
procedures.
Case Title Doctrine Facts Issue/s Ruling
19. Republic vs. Science Park of the SPPI sought land registration, claiming The case involves the Republic of the Was the Court of Appeals correct in The Supreme Court granted the petition,
Philippines, Inc., G.R. No. 237714, alienable land with possession since Philippines as the petitioner and Science upholding the MCTC's grant of SPPI's reversing and setting aside the decisions
[November 12, 2018 1945. SC denied, citing insufficient Park of the Philippines, Inc. (SPPI), application for land registration? of the Court of Appeals and the MCTC. The
represented by its Executive Court denied SPPI's application for original
proof of continuous, exclusive
Vice-President and General Manager, Mr. registration of the subject land.
possession and reliance on Did SPPI provide sufficient evidence to
Richard Albert I. Osmond, as the
inadequate tax declarations. respondent. The events leading to this prove that the subject land is alienable Ratio:
case began on November 20, 2014, when and disposable and that it and its In its ruling, the Supreme Court
SPPI filed an application for original predecessors-in-interest had been in emphasized that the burden of proof lies
registration of a 7,691-square meter parcel open, continuous, exclusive, and with the applicant in land registration cases
of land, designated as Lot 5809, Psc-47, notorious possession of the land since to establish, through clear and convincing
Malvar Cadastre, located in Barangay Luta June 12, 1945, or earlier? evidence, that the land in question is
Norte, Malvar, Batangas. SPPI asserted that alienable and disposable and that they
the land was part of the alienable and have possessed it in the manner required
disposable land of the public domain and by law. The Court reiterated that under
claimed to have been in open, continuous, Section 14(1) of Presidential Decree No.
exclusive, and notorious possession of the 1529, the applicant must demonstrate that
land under a bona fide claim of ownership the land has been classified as alienable
prior to June 12, 1945. The company also and disposable and that they and their
stated that the land was not mortgaged or predecessors have been in open,
encumbered and was acquired from continuous, exclusive, and notorious
Cenen D. Torizo through a Deed of possession since June 12, 1945, or earlier.
Absolute Sale dated October 17, 2013.
The Court found that while SPPI presented
To substantiate its claims, SPPI presented a a certification from the DENR, it failed to
certification from the Department of adequately prove the nature and duration
Environment and Natural Resources of its possession. The evidence presented,
(DENR) confirming that the land was including the testimony of a witness
classified as alienable and disposable. claiming knowledge of ownership since
Additionally, SPPI provided evidence of its 1943, was deemed insufficient to establish
predecessors' ownership and possession the required possession. The Court noted
of the land, tracing back to Gervacio Lat, that actual possession must be
who had a tax declaration from 1955. The demonstrated through specific acts of
Municipal Circuit Trial Court (MCTC) of ownership, which were not sufficiently
Malvar-Balete, Batangas, ruled in favor of evidenced by SPPI. The earliest tax
SPPI on August 10, 2016, granting the declaration presented dated back only to
application for original registration. The 1955, which did not meet the requirement
Republic of the Philippines, represented by of possession since June 12, 1945.
the Office of the Solicitor General, filed a Consequently, the Court concluded that
motion for reconsideration, which was SPPI's claims of possession were
denied, leading to an appeal to the Court unsubstantiated and self-serving, leading
of Appeals (CA). The CA affirmed the to the determination that the CA erred in
MCTC's decision on October 12, 2017, affirming the MCTC's decision.
prompting the Republic to file a petition for
review on certiorari.
Case Title Doctrine Facts Issue/s Ruling
20. Spouses Binarao vs. Plus Spouses Binarao failed to pay property The case involves the spouses Jose N. Did the petitioners admit their liability The Supreme Court ruled against the
Builders, Inc., G.R. No. 154430, [June balance; courts ruled their judicial Binarao and Preciosisima Binarao as under the proposed payment plan petitioners, affirming the decision of
16, 2006] admission of liability in pleadings was petitioners against Plus Builders, Inc. as dated July 6, 1998, in their answer to the Court of Appeals. The Court held
binding, affirming payment obligation. the respondent. The events leading to the complaint? that the petitioners had indeed
the case began on April 19, 1990, when admitted their liability in their answer
the petitioners purchased a house and Are the petitioners bound by their to the complaint, and their admissions
lot in the Bahayang Pag-asa Subdivision judicial admissions made in the course were binding. The petition was
located in Cavite City for a total price of of the proceedings? dismissed for lack of merit.
P327,491.95. Jose Binarao executed an
Affidavit of Undertaking on Equity,
Ratio:
agreeing to pay the respondent
The Court's decision was grounded in
P96,791.95, with an initial payment of
P5,000.00 upon signing the contract and the principles of judicial admissions as
the remaining balance within 15 days. outlined in Section 4, Rule 129 of the
However, the petitioners failed to fulfill Revised Rules of Court. It stated that
this obligation. Following a demand admissions made by a party in the
letter from the respondent's counsel, the course of the proceedings do not
petitioners made a partial payment of require proof and can only be
P20,000.00 on July 6, 1998, leaving a contradicted by showing that they
balance of P65,571.22, which they were made through palpable mistake.
agreed to pay in three installments. In this case, the petitioners explicitly
admitted in their answer that they had
On March 10, 1999, after the petitioners paid P20,000.00, acknowledged a
refused to pay despite another demand remaining balance of P65,571.22, and
letter, Plus Builders, Inc. filed a complaint agreed to pay this balance in three
for a sum of money against them in the installments. The Court emphasized
Metropolitan Trial Court (MTC), Branch that such admissions are conclusive
25, Manila, which was docketed as Civil against the admitting party and cannot
Case No. 163822-CV. The MTC ruled in
be retracted without demonstrating a
favor of the respondent on June 11, 2001,
palpable mistake, which the
ordering the petitioners to pay the
petitioners failed to do. Therefore, the
outstanding balance along with interest
and liquidated damages. The petitioners Court upheld the lower courts'
appealed to the Regional Trial Court decisions, confirming the petitioners'
(RTC), Branch 7, Manila, which affirmed liability to the respondent.
the MTC's decision on November 23,
2001. The petitioners' motion for
reconsideration was denied on January
15, 2002. Subsequently, the petitioners
filed a petition for review with the Court
of Appeals, which upheld the RTC's
decision on July 19, 2002, leading to the
present petition for review on certiorari.
Case Title Doctrine Facts Issue/s Ruling