Philippine Supreme Court Decisions Digests

EDUARDO MANUEL vs. PEOPLE GR. No. 165842, November 29, 2005    Facts This case is a petition for review on certiorari of the decision of Court of Appeals affirming the decision of the Regional Trial Court of Baguio City, convicting the petitioner for the crime of bigamy.    Eduardo P. Manuel, herein petitioner, was first married to Rubylus Gaña on July 18, 1975, who, according to the former, was charged with estafa in 1975 and thereafter imprisoned and was never seen again by him after his last visit. Manuel met Tina B. Gandalera in January 1996 when the latter was only 21 years old. Three months after their meeting, the two got married through a civil wedding in BaguioCity without Gandalera‘s knowledge of Manuel‘s first marriage. In the course of their marriage, things got rocky and Gandalera learned that Eduardo was in fact already married when he married him. She then filed a criminal case of bigamy against Eduardo Manuel. The latter‘s defense being that his decla...

HOTEL NIKKO vs. REYES GR. No. 154259, February 28, 2005    Facts This case is a petition for review on certiorari regarding the reversing decision of the Court of Appeals in the decision of the Trial Court and thus, making the petitioners liable for damages through the abusive conduct of petitioner Lim, imposing upon them P200,000 as exemplary damages, P200,000 as moral damages, and P10,000 as attorney‘s fees.    Plaintiff Roberto Reyes (Amay Bisaya) was having coffee at the Nikko Hotel lobby on October 13, 1994 at around six in the morning when Dr. Violeta Filart, a long-time friend, approached him and invited him to a party at the penthouse where the hotel‘s former manager‘s birthday was being celebrated. He consented and carried the latter‘s present. At the party, when he was helping himself at the buffet table, Ruby Lim, one of the petitioners, approached him and asked him to leave in a loud voice enough to be heard by those around the buffet table. Then, a Makat...

EQUITABLE BANKING CORPORATION vs. CALDERON GR. No. 156168, December 14, 2004  Facts Jose T. Calderon is a businessman engaged in several business activities here and abroad, either in his capacity as President or Chairman of the Board thereon. He is also a stockholder of PLDT and a member of the Manila Polo Club, among others.  He is a seasoned traveler, who travels at least seven times a year in the U.S., Europe and Asia. On the other hand, Equitable Banking Corporation is one of the leading commercial banking institutions in the Philippines, engaged in commercial banking, such as acceptance of deposits, extension of loans and credit card facilities, among others.Sometime in September 1984, Calderon applied and was issued an Equitable International Visa card. The said Visa card can be used for both peso and dollar transactions within and outside the Philippines.   The credit limit for the peso transaction is twenty thousand pesos; while in the dollar ...

CUSTODIO vs. COURT OF APPEALS G.R. No. 116100, February 9, 1996  Facts Respondents owned a parcel of land wherein a two-door apartment was erected. Said property was surrounded by other immovables owned by petitioners, spouses Custodio and spouses Santos. As an access to P. Burgos Street from the subject property, there are two possible passageways. The first passageway is approximately one meter wide and is about 20 meters distant from Mabasa‘s residence to P. Burgos Street. Such path is passing in between the previously mentioned row of houses. The second passageway is about 3 meters in width and length from plaintiff Mabasa‘s residence to P. Burgos Street; it is about 26 meters. In passing thru said passageway, a less than a meter wide path through the septic tank and with 5-6 meters in length, has to be traversed. Petitioners constructed an adobe fence in the first passageway making it narrower in width. Said adobe fence was first constructed by defendants Santoses a...

ALFONSO T. YUCHENGCO vs. THE MANILA CHRONICLE PUBLISHING CORPORATION G.R. No. 184315, November 25, 2009  Facts In his Complaint, plaintiff Alfonso T. Yuchengco alleges that in the last quarter of 1994, Chronicle Publishing Corporation ("Chronicle Publishing" for brevity) published in the Manila Chronicle a series of defamatory articles against him. In two of the subject articles (November 10 and 12, 1993 issues), he was imputed to be a "Marcos crony" or a "Marcos-Romualdez crony," which term according to him is commonly used and understood in Philippine media to describe an individual who was a recipient of special and underserving favors from former President Ferdinand E. Marcos and/or his brother-in-law Benjamin "Kokoy" Romualdez due to special and extraordinary closeness to either or both, and which favors allowed an individual to engage in illegal and dishonorable business activities.  The subject articles insinuated that he pe...

TITUS B. VILLANUEVA vs. EMMA M. ROSQUETA G.R. No. 180764, January 19, 2010  Facts Respondent Emma M. Rosqueta (Rosqueta), formerly Deputy Commissioner of the Revenue Collection and Monitoring Group of the Bureau of Customs (the Bureau), tendered her courtesy resignation from that post on January 23, 2001, shortly after President Gloria MacapagalArroyo assumed office. But five months later on June 5, 2001, she withdrew her resignation, claiming that she enjoyed security of tenure and that she had resigned against her will on orders of her superior.   Meantime, on July 13, 2001 President Arroyo appointed Gil Valera (Valera) to respondent Rosqueta‘s position. Challenging such appointment, Rosqueta filed a petition for prohibition, quo warranto, and injunction against petitioner Titus B. Villanueva (Villanueva), then Commissioner of Customs, the Secretary of Finance, and Valera with the Regional Trial Court. Petitioner Villanueva, Valera, and the Secretary of F...

GO vs. CORDERO G.R. No. 164703, May 4, 2010  Facts Sometime in 1996, Mortimer F. Cordero, Vice-President of Pamana Marketing Corporation (Pamana), ventured into the business of marketing inter-island passenger vessels.  After contacting various overseas fast ferry manufacturers from all over the world, he came to meet Tony Robinson, an Australian national based in Brisbane, Australia, who is the Managing Director of Aluminium Fast Ferries Australia (AFFA).   After negotiations with Felipe Landicho and Vincent Tecson, lawyers of Allan C. Go who is the owner/operator of ACG Express Liner of Cebu City, a single proprietorship; Cordero was able to close a deal for the purchase of two (2) SEACAT 25 as evidenced by the Memorandum of Agreement dated August 7, 1997. Accordingly, the parties executed Shipbuilding Contract No. 7825 for one (1) high-speed catamaran (SEACAT 25) for the price of US$1,465,512.00.  Per agreement between Robinson and Cordero, the...

GF EQUITY, INC. vs. VALENZONA G.R. No. 156841, June 30, 2005  Facts GF Equity, represented by its Chief Financial Officer, W. Steven Uytengsu, hired Valenzona as head coach of the Alaska basketball team in the PBA under a contract of employment.  He was tasked to coach at all practices and games scheduled for the Alaska team, coach exhibition games, coach if invited to participate in any all-star game, attending every event conducted, play-off games, etc.  He was also tasked to comply with all requirements respecting to the conduct of its team and players, to implement. He also agreed to report from time to time as fixed by the corporation in good physical condition, give his best services, loyalty, to be neatly and fully attired in public and to conduct himself on and off the court according to the highest standards of honesty, morality, fair play and sportsmanship, and not to do anything detrimental to the best interest of the corporation.  He al...

UNIVERSITY OF THE EAST vs. ROMEO A. JADER G.R. No. 132344, February 17, 2000  Facts Romeo Jader graduated at UE College of law from 1984-19988.  During his last year, 1st semester, he failed to take the regular final examination in Practical Court 1where he was given an incomplete grade remarks. He filed an application for removal of the incomplete grade given by Prof. Carlos Ortega on February 1, 1988 which was approved by Dean Celedonio Tiongson after the payment of required fees.  He took the exam on March 28, 1988 and on May 30, 1988 the professor gave him a grade of 5.The commencement exercise of UE College of law was held April 16, 1988, 3PM.  In the invitation, his name appeared.  In preparation for the bar exam, he took a leave of absence from work from April 20- Sept 30, 1988.  He had his pre-bar class review in FEU.  Upon learning of such deficiency, he dropped his review classes and was not able to take the bar exam. Jader sued UE...

BANK OF AMERICA, NT and SA vs. AMERICAN REALTY CORPORATION G.R. No. 133876, December 29, 1999  Facts Petitioner Bank of America NT & SA (BANTSA) is an international banking and financing institution duly licensed to do business in the Philippines. As borne by the records, BANTSA and BAIL on several occasions granted three major multi-million United States (US) Dollar loans to the following corporate borrowers: (1) Liberian Transport Navigation, S.A.; (2) El Challenger S.A. and (3) Eshley Compania Naviera S.A., all of which are existing under and by virtue of the laws of the Republic of Panama and are foreign affiliates of private.   As security, the latter mortgaged a property located in the Philippines owned by herein respondent ARC. ARC is a third party mortgagor executed two real estate mortgages, dated 17 February 1983 and 20 July 1984, over its parcels of land including improvements thereon, located at Barrio Sto. Cristo, San Jose Del Monte, Bulaca...

ALICE REYES VAN DORN vs. HON. MANUEL V. ROMILLO, JR.  G.R. No. L-68470, October 8, 1985  Facts Petitioner Alice Reyes Van Dorn is a citizen of the Philippines while private respondent is a citizen of the United States; they were married in Hong Kong in 1972.  Thereafter, they established their residence in the Philippines and begot two children born on April 4, 1973 and December 18, 1975. Subsequently, they were divorced in Nevada, United States, in 1982, and that petitioner has remarried also in Nevada, this time to Theodore Van Dorn.  Dated June 8, 1983, private respondent filed suit against petitioner in Civil Case No. 1075-P of the Regional Trial Court, Branch CXV, in Pasay City, stating that petitioner‘s business in Ermita, Manila is their conjugal property; that petitioner he ordered to render accounting of the business and that private respondent be declared to manage the conjugal property. Petitioner moved to dismiss the case contending that th...

PHILIPPINE COMMERCIAL AND INDUSTRIAL BANK vs. ESCOLIN G.R. No. L-27860, March 29, 1974  Facts Linnie Jane Hodges, a married woman and a citizen of Texas, USA, was a domiciliary of the Philippines at the moment of her death. With respect to the validity of certain testamentary provisions she had made in favor of her husband, a question arose as to what exactly were the laws of Texas on the matter at the precise moment of her death (for while one group contended that the Texan law should result to renvoi, the other group contended that no renvoi was possible).  Issue Whether or not Texas Law should apply.  Ruling The Supreme Court held that for what the Texas law is on the matter, is a question of fact to be resolved by the evidence that would be presented in the probate court. Texas law at the time of her death (and not said law at any other time).  

BELLIS vs. BELLIS G.R. No. L-23678, June 6, 1967  Facts Amos Bellis was a citizen of the State of Texas, and of the United States. By his first wife whom he divorced he had five legitimate children, by his second wife, who survived him, he had three legitimate children, and three illegitimate children. Before he died, he made two wills, one disposing of his Texas properties and the other disposing his Philippine properties. In both wills, his illegitimate children were not given anything. The illegitimate children opposed the will on the ground that they have been deprived of their legitimates to which they should be entitled, if Philippine law were to be applied.  Issue Whether or not the national law of the deceased should determine the successional rights of the illegitimate children.  Ruling The Supreme Court held that the said children are not entitled to their legitimes under the Texas Law, being the national law of the deceased, there are...

AZNAR vs. GARCIA G.R. No. L-16749, January 31, 1963  Facts Edward Christensen was born in New York but he migrated to California where he resided for a period of 9 years. In 1913, he came to the Philippines where he became a domiciliary until his death. In his will, he instituted an acknowledged natural daughter, Maria Lucy Christensen (legitimate), as his only heir, but left a legacy sum of money in favor of Helen Christensen Garcia (illegitimate). Counsel for Helen claims that under Article 16, paragraph 2 of the Civil Code, California law should be applied; that under California law, the matter is referred back to the law of the domicile. On the other hand, counsel for Maria, averred that the national law of the deceased must apply, illegitimate children not being entitled to anything under California law.  Issue Whether or not the national law of the deceased should be applied in determining the successional rights of his heirs.  Ruling The ...

MICIANO vs. BRIMO G.R. No. L-22595, November 1, 1927  Facts Joseph G. Brimo, a citizen of Turkey, died and left a partition of the estate. Juan Miciano, the judicial administrator of the estate left filed a scheme of partition. However, Andre Brimo, one of the brothers of the deceased, opposed it. Brimo‘s opposition is based on the fact that the partition in question puts into effect the provisions of Joseph Brimo‘s will which are not in accordance with the laws of his Turkish nationality, for which reason they are void as being in violation of Article 10 of the Civil Code.  Issue Whether or not the national law of the testator is the one to govern his testamentary disposition.  Ruling Joseph Brimo, a Turkish citizen, though he declared in his will that Philippine laws must govern the disposition of his estate; however, it must not prejudice the heir or legatee of the testator. Therefore, the testator‘s national law must govern in accordance wit...

LLORENTE vs. COURT OF APPEALS G.R. No. 124371, November 23, 2000  Facts Petitioner Paula Llorente was married to a US Navy enlisted serviceman Lorenzo Llorente, in Nabua, Camarines Sur, on February 22, 1937. Before the outbreak of war, Lorenzo departed for the US and Paula stayed in the conjugal home in Nabua. Lorenzo became an American citizen on November 30, 1943. Upon the liberation of the Philippines (1945), Lorenzo was granted by the US Navy to visit his wife in the Philippines and found out that Paula was living in with Lorenzo‘s brother Ceferino. In December 1945, Paula gave birth to Crisologo with the birth certificate saying that the child was illegitimate, and the father‘s name was left blank.  On February 2, 1946, Paula and Lorenzo had a written agreement, dissolving their marital union, suspending his support upon her, and waiving his authority to file a case of adultery against her. Lorenzo returned to the US and filed for a divorce in 1951 which was ...

ASAALI vs. COMMISSION OF CUSTOMS G.R. No. L-24170, December 16, 1968  Facts The SC held that petitioner be acquitted of the crime charged. Time and again the SC has decreed that the statutes are to be construed in the light of the purposes to be achieved and the evil sought to be remedied. Thus in construing a statute the reason for its enactment should be kept in mind and the statute should be construed with reference to the intended scope and purpose. The court may consider the spirit and reason of the statute, where a literal meaning would lead to absurdity, contradiction, injustice, or would defeat the clear purpose of the law makers.  Issue Whether or not the interception and seizure by custom officials on the high seas is valid on the contention that the seizure was affected outside our territorial waters.  Ruling The SC held that it is a settled doctrine of International Law that a state has the right to protect itself and its revenues, a...

URSUA vs. COURT OF APPEALS G.R. No. 112170, April 10, 1996  Facts Petitioner Cesario Ursua was convicted for violation of Sec. 1 of CA No. 142, as amended by RA 6085 otherwise known as ―An Act to Regulate the Use of Aliases‖ by the RTC of Davao City which was affirmed by the CA. Allegedly petitioner when asked by his counsel to take his letter of request to the Office of the Ombudsman because his law firm‘s messenger Oscar Perez had personal matters to attend to, instead of writing his name wrote the name ―Oscar Perez‖ when he was requested to sign. However, Loida Kahulugan who gave him the copy of complaint was able to know through Josefa Amparo that petitioner is not Oscar Perez. Loida reported the matter to the Deputy Ombudsman who recommended that petitioner be accordingly charged. Petitioner comes for review of his conviction to the SC as he reasserts his innocence.  Issue Whether or not petitioner Cesario Ursua should be acquitted on the ground that he...

FLORESCA vs. PHILEX MINING CORP. G.R. No. L-30642, April 30, 1985  Facts Floresca et al are the heirs of the deceased employees of Philex Mining Corporation (hereinafter referred to as Philex), who, while working at its copper mines underground operations at Tuba, Benguet on June 28, 1967, died as a result of the cave-in that buried them in the tunnels of the mine. Specifically, the complaint alleges that Philex, in violation of government rules and regulations, negligently and deliberately failed to take the required precautions for the protection of the lives of its men working underground. Floresca et al moved to claim their benefits pursuant to the Workmen‘s Compensation Act before the Workmen‘s Compensation Commission. They also petitioned before the regular courts and sue Philex for additional damages. Philex invoked that they can no longer be sued because the petitioners have already claimed benefits under the WCA.  Issue Whether or not Floresca et al...

YAO KEE vs. SY GONZALES G.R. No. L-55960, November 24, 1988  Facts Sy Kiat, a Chinese national, died on January 17, 1977 leaving behind properties here in the Philippines.Thereafter, Aida Sy-Gonzales et al filed a petition for the grant of letters of administration alleging that they are the children of the deceased with Asuncion Gillego. The petition was opposed by Yao Kee et al alleging that Yao Kee is the lawful wife of the deceased whom he married in China. The trial court rendered decision in favor of the opposition. On appeal, the Court of Appeals rendered a decision, modifying the decision declaring the marriage of Sy Kiat to Yao Kee as not has been proven valid in accordance with the laws of China. Hence, both parties moved for reconsideration to which the Supreme Court granted.  Issue Whether or not the marriage of Yao Kee and Sy Kiat is valid in accordance with Philippine  laws.  Ruling Well-established in this jurisdiction is t...