Digests

The subject property was covered by a TCT originally issued in 1917. Following the loss or destruction of records, the title was administratively reconstituted on October 18, 1960, pursuant to R.A. No. 26. The reconstituted TCT carried two annotations: (1) a mandatory encumbrance under Section 7 of R.A. No. 26, reserving the rights of any party whose interest was noted on the original title but omitted from the reconstituted one; and (2) an adverse claim. The Republic filed a petition to cancel both annotations.

The mandatory encumbrance on an administratively reconstituted certificate of title, required under Section 7 of R.A. No. 26, may be cancelled via an ex parte motion if two years have elapsed from the date of reconstitution and no petition to annotate an omitted interest has been filed within that period.

Petitioners Anthony Arnaldo Lo and Alwin Borilla Nagallo were charged with violations of Sections 5 (illegal sale) and 12 (illegal possession of paraphernalia) of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act) for allegedly selling 0.039 gram of shabu. They filed a motion to plea bargain, proposing to plead guilty to the lesser offenses of Section 12 (possession of paraphernalia) and Section 15 (use of dangerous drugs) under the same law. The prosecution opposed, citing DOJ Department Circular No. 027, which prescribes a different, harsher plea bargain for Section 5 charges. The Regional Trial Court (RTC) approved the plea bargain, convicted the petitioners of the lesser offens…

In plea bargaining for drug cases, a trial court may approve an accused's proposal that conforms to the Court-issued Plea Bargaining Framework (A.M. No. 18-03-16-SC) even over the prosecution's objection, if the objection is based solely on inconsistency with internal DOJ guidelines and the prosecution fails to raise and substantiate valid grounds such as the accused's criminal history or the strength of the evidence of guilt.

Respondent Atty. Editha R. Hechanova was a partner and head of the Intellectual Property (IP) Department at the law firm VERA LAW (Del Rosario Bagamasbad & Raboca). Prior to her expulsion from the partnership in December 2005, she undertook several preparatory acts for her departure, including registering a competing company, "Hechanova & Co., Inc.," with the Securities and Exchange Commission and leasing office space. Following her departure, VERA LAW filed a disbarment complaint, alleging she used firm resources to promote herself, poached clients, made disparaging statements, and represented conflicting interests.

A lawyer who, while still a partner, clandestinely recruits colleagues from the firm to join a competing venture commits simple misconduct in violation of the duty to act with courtesy, civility, fairness, and candor toward fellow members of the bar. Furthermore, a lawyer intentionally violates the rule against conflict of interests by representing a new client in a matter materially adverse to a former client's interests, regardless of whether confidential information was disclosed.

Venustriano B. Chavez, Jr., et al. (Chavez et al.), inherited two adjacent lots in Quezon City. They decided to sell the properties and, through a broker, were introduced to Spouses Joselito and Adriana Gopez (Spouses Gopez). The parties reached an understanding on the sale terms, including a purchase price of PHP 31.5 million, with the Spouses Gopez undertaking to handle documentation, taxes, and estate settlement. To signify commitment, the Spouses Gopez issued a check for PHP 200,000.00 as earnest money, for which Chavez et al. issued an Acknowledgement Receipt. Disputes arose over the preparation of documents and the payment of a PHP 5 million downpayment, leading Chavez et al. to termi…

An Acknowledgement Receipt that merely acknowledges earnest money and lists preparatory documents to be drafted by the buyer, without any undertaking by the seller to transfer ownership, constitutes a Contract to Sell, not a Contract of Sale. The absence of an express reservation of title is not determinative; the controlling factor is the lack of the seller's consent to transfer ownership at that stage. Non-fulfillment of the suspensive conditions by the buyer renders the contract ineffective.

Filipino Society of Composers and Publishers (FILSCAP), a collective management organization, holds the exclusive public performance and communication rights to a repertoire of musical works. Wolfpac Communications, Inc. (Wolfpac) aggregates and distributes mobile content, including ringback tones, for telecom operators. Wolfpac entered into memoranda of agreement with certain composers, members of FILSCAP, to convert their musical works into downloadable ringtones. On its website, Wolfpac provided a "pre-listening function" allowing potential customers to listen to a 20-second sample of a ringtone before downloading. FILSCAP demanded licensing fees and royalties, alleging this constituted …

The act of providing a "pre-listening function" for copyrighted song samples on a commercial website constitutes "communication to the public" under the Intellectual Property Code, as it makes the work available for public access at a time and place of the user's choosing. However, such use qualifies as fair use, as it serves a transformative, informational purpose for consumer decision-making and does not act as a market substitute for the copyrighted work.

In 1993, Atty. Mario P. Panganiban, as signatory for MLP Construction, issued post-dated checks to spouses Ceferino and Azucena Palaganas in connection with a loan or rediscounting transaction. The checks were subsequently dishonored due to a closed account. After demands for payment went unheeded, the spouses filed a civil case for collection of sum of money in 2003 and later an administrative complaint against Atty. Panganiban before the IBP, alleging violations of the Lawyer's Oath and the Code of Professional Responsibility.

An administrative disciplinary proceeding against a lawyer is sui generis and is confined to determining the lawyer's fitness to continue membership in the Bar; it is not the proper forum to adjudicate and enforce purely civil liabilities, such as the collection of an unpaid debt.

Petitioner Silvestre Corpuz obtained free patents and corresponding titles over two lots in Ilocos Sur. The Republic, through the Office of the Solicitor General, sought the cancellation of the patents and reversion of the lands, alleging they were part of the old riverbed of the Irene River and thus inalienable public domain. The Republic contended that Corpuz's applications contained material misrepresentations regarding his alleged continuous, open, and exclusive possession and cultivation of the land.

An abandoned riverbed remains property of public dominion and is not susceptible to private ownership or disposition unless the abandonment was caused by a natural change in the river's course. Where abandonment results from artificial means or human intervention, the riverbed remains inalienable public land under Articles 420(1) and 502(1) of the Civil Code.

Medical Plaza Makati Condominium Corporation (MPMCC) is the condominium corporation of Medical Plaza Makati Condominium (MPMC). Its by-laws provide that only registered unit-owners are members and that directors must be elected from among members in good standing. Several units are owned by corporations — Pastorfide Land Corporation and Maxicare Health Corporation — which are themselves members in good standing. The by-laws also contain a representation clause: when a unit is owned by a corporation, its authorized officers shall designate a representative, and that representative shall be considered a member for all purposes, in all matters related to the corporation. The by-laws separately…

A designated authorized representative of a corporate member of a condominium corporation, appointed under by-laws that confer authority for all purposes and treat the representative as a member, may sit on the board of directors even without being a unit-owner in his own right; the member-corporation is deemed the actual director. The rule in Lim v. Moldex Land, Inc. — which bars a proxy from being elected director unless the proxy is a member in his own right — does not govern where the representative’s authority extends beyond voting and includes the right to be elected to the board.

A father was charged with raping and attempting to rape his 16-year-old daughter in January 2013 while the mother was working abroad. The case reached the SC on appeal after the RTC and CA convicted him of rape and unjust vexation (downgrading the attempted rape charge).

When an accused appeals a criminal conviction, they waive the safeguard against double jeopardy, allowing the appellate court to review the entire case and modify the judgment to include a conviction for a more severe offense.

The complainants are the heirs of Spouses Leoncio Cuizon and Mamerta Seno, whose parcels of land in Lapu-Lapu City, Cebu, were expropriated by the Export Processing Zone Authority (EPZA, later PEZA) in 1981. The respondent, Atty. Demosthenes S. Tecson, was engaged as counsel for the spouses in the expropriation proceedings. In 2015, the Regional Trial Court fixed the total just compensation, including interest, at PHP 134,341,965.15, which PEZA paid to Atty. Tecson on December 23, 2015.

A lawyer's duty of fidelity to the rule of law and his concomitant duty to account for client funds require that he utilize client money only for lawful purposes; advising a client to use funds for an illicit purpose, or acceding to such a client instruction, constitutes a violation of these duties, rendering the lawyer liable for misappropriation and subject to disciplinary action, including disbarment.

Mabuhay Educational Center, Inc. (MECI) was a family corporation founded by Custodios J. Teng, Sofronio J. Teng, and Patricio J. Teng, each holding 30% of its shares. Petitioner Alvin Clark Y. Teng and respondents Pearly Y. Teng, Albert Y. Teng, Paul T. Teng, and Cheryl Ann T. Hao each owned 2%. Alvin served as a director and corporate secretary and managed daily operations until a special stockholders’ meeting on December 20, 2017, at which respondents were elected as directors and officers. Disputes arose over the continued operation of MECI, with Alvin alleging that respondents orchestrated his removal and planned to close the school and sell its Quezon City property, while respondents m…

Cessation of business operations is a management prerogative of the board of directors and does not require compliance with the statutory requirements for voluntary dissolution under Section 118 of the Old Corporation Code. An action that seeks to nullify a stockholders’ meeting on the ground of defective notice and to invalidate the election of directors constitutes an election contest and must be filed within 15 days from the date of the election; failure to do so bars the challenge.

Petitioner Atty. Fred L. Bagbagen was a city councilor of Baguio City. He and one Frank Leo Telintelo were charged with estafa against respondent Anna May F. Perez. After trial, the Regional Trial Court (RTC), Branch 61, Baguio City, acquitted both accused on reasonable doubt but found them civilly liable and ordered them to pay Perez and her co-heirs PHP 308,000.00, solidarily, with six percent (6%) legal interest per annum from finality until full payment. The decision became final and executory, and a writ of execution was issued. Pursuant to that writ, the RTC served a Notice of Garnishment dated August 29, 2019 on Philippine Veterans Bank, Baguio City Branch, where Bagbagen’s salaries …

The salaries of a public official are subject to garnishment because no law exempts them from execution, and the exemption from execution for wages and salaries under Rule 39, Section 13(i) of the Rules of Court and Article 1708 of the Civil Code is confined to laborers whose work is manual.

In 2006, Jeffery A. Green, a United States Navy retiree, met Rowena Manlutac in a bar in Angeles City. They developed a relationship, during which Jeffery was aware Rowena had two children from a previous relationship and Rowena knew Jeffery's divorce was still pending. In 2008, Rowena gave birth to a daughter, Abigail, whom Jeffery acknowledged as his own. They married on May 8, 2010. Following the marriage, Jeffery discovered Rowena's infidelity, pathological gambling, deceitfulness regarding finances and the paternity of Abigail, and accumulation of significant debt, which led him to file a petition to have their marriage declared void.

Psychological assessments based on the testimonies of the petitioner, respondent, respondent's mother, and a mutual friend can be given credence in proving psychological incapacity, especially when there is no reason to believe the testimonies are fabricated. The declaration of nullity of marriage is warranted as long as the totality of the evidence clearly and convincingly establishes one spouse's psychological incapacity to perform essential marital obligations.

Respondent Atty. Rejoice S. Subejano, a founding partner of Subejano & Ditucalan (SD Law), was the retained legal counsel for Megamitch Financial Resources Corporation. In January 2015, respondent and a business partner applied for a PHP 15 million loan from Megamitch to augment the capitalization of their sand and gravel business. Megamitch, engaged in the lending business, released PHP 11,679,900.00 to the respondent. A dispute later arose when Megamitch deemed the submitted loan contract unacceptable and allegedly discovered the respondent had no business records in Iligan City, contrary to his representations. Megamitch demanded repayment and filed a criminal case for Estafa and the pre…

A lawyer is not administratively liable for borrowing from a client if the transaction qualifies as a "standard commercial transaction" within the client's ordinary business, or if there is an existing or prior business relationship between the lawyer and client, as provided under Canon III, Section 52 of the Code of Professional Responsibility and Accountability (CPRA).

Respondent Rossana Balcom-Döring, a Filipino, filed a complaint for unlawful detainer against petitioner Klaus Peter Neunzig, a German national, alleging failure to pay monthly rentals under a lease contract. Neunzig countered that he was the true owner of the property, having provided the funds for its purchase, and that the title was placed in Balcom-Döring's name only because of the constitutional prohibition on alien land ownership. The Municipal Trial Court (MTCC) dismissed the complaint, but the Regional Trial Court (RTC) and Court of Appeals (CA) reversed, ordering Neunzig to vacate and pay rentals.

Contracts entered into to circumvent the constitutional prohibition on foreign ownership of land are void ab initio and cannot be the source of any right or cause of action, including for unlawful detainer. Where both parties knowingly participate in such an illegal scheme, they are in pari delicto, and the courts will not grant relief to either party.

Complainant Denis Guy Martin, a French national, was formerly married to the sister of respondent Atty. Leticia E. Ala. Following their legal separation, the parties engaged in multiple cases against each other, with respondent representing her sister. In a prior administrative case (A.C. No. 10556), respondent was admonished for using offensive language in pleadings. The present disbarment complaint arose from two subsequent incidents: (1) an altercation on April 17, 2017, where respondent allegedly instructed police officers to shoot her nephew, Jean Marc; and (2) the filing of a deportation case against complainant before the Bureau of Immigration (BI), wherein respondent allegedly used …

A lawyer's duty to uphold the law and maintain the dignity of the profession is breached by conduct that disregards legal processes and by the use of intemperate language in pleadings, even when such acts are committed in a personal capacity or under emotional distress.

By Executive Order No. 156, series of 1968, President Ferdinand E. Marcos, Sr. constituted the Fund for Assistance to Private Education (FAPE) as a permanent trust fund from war damage compensation granted by the United States Government (USD 6,154,000.00) for the purpose of financing programs of assistance to private education. The Private Education Assistance Committee (PEAC) was simultaneously created to serve as trustee, with power to administer, manage, and supervise FAPE operations. PEAC was composed of the Secretary of Education, Culture and Sports (or a representative) as Chairperson, a representative from NEDA, and representatives of the Catholic Educational Association of the Phil…

Funds from private sources become public funds the moment they are received and held by officers of a government instrumentality; however, the mere performance of ministerial acts in processing loans does not establish manifest partiality or gross inexcusable negligence under Section 3(e) of R.A. No. 3019, nor criminal negligence for malversation, absent clear proof of malicious intent or want of even slight care.

The dispute arose when the mother, Sheena, sought to regain custody of her minor child, Yuno, from the father, Jeffrey, and his parents (the Empuertos) after the child's summer vacation stay was extended due to the COVID-19 lockdown. After failed attempts to retrieve the child and a breached barangay agreement, Sheena filed a petition for a writ of habeas corpus.

A trial court may only issue a provisional order awarding custody of a minor after an answer has been filed or the period to file it has expired, as mandated by Section 13 of the Rule on Custody of Minors and Writ of Habeas Corpus in Relation to Custody of Minors. A compromise agreement between parents cannot substitute for a judicial determination based on evidence and the best interests of the child.

Linney Jean Tangarorang filed a petition to declare her marriage to Ramer Tangarorang void based on his psychological incapacity. The couple had a daughter, Sharemahlyne, born prior to their marriage. While the trial court granted the petition for nullity, it simultaneously declared Sharemahlyne an illegitimate child because she was born before the marriage and the marriage was deemed never to have existed. The Office of the Solicitor General (OSG) challenged this specific portion of the ruling to protect the child's legitimate status.

Children legitimated by the subsequent marriage of their parents retain their legitimate status even if said marriage is later declared void ab initio on the ground of psychological incapacity under Article 36 of the Family Code, pursuant to the explicit exception provided in Article 54 of the same Code.

The dispute concerns a 243.50-square meter parcel of land with improvements located at No. 20, Corregidor Street, Bago Bantay, Quezon City. The property was originally part of a government housing project administered by the People's Homesite and Housing Corporation (PHHC), later the National Housing Authority (NHA). The conflicting claims of ownership arose between the heirs of Maria Nuñez (petitioners) and her son, Oscar Nuñez, and his wife Norma (respondents). The petitioners alleged the property was their mother's and thus co-owned by her heirs, while the respondents claimed Oscar was the sole awardee and purchaser from the NHA.

In an action for reconveyance, the burden of proving ownership and the fraudulent or wrongful registration of the property lies with the plaintiff. A mere photocopy of an alleged prior title, unsupported by proof of its original's loss or existence and contradicted by a clear chain of documentary evidence from the defendant, is insufficient to overcome the legal presumption of validity and indefeasibility of the defendant's certificate of title.

Ybo Lastimosa was charged with Murder for the fatal shooting of Ildefonso Vega, Jr. on November 17, 2012, in Talisay City, Cebu. The prosecution's evidence, primarily from two eyewitnesses, established that Lastimosa shot the victim three times while the latter was on his motorcycle outside a cockpit. The Regional Trial Court (RTC) convicted Lastimosa of Homicide, finding treachery and evident premeditation not proven. The Court of Appeals (CA) modified the conviction to Murder, appreciating treachery. Lastimosa appealed to the Supreme Court, challenging the sufficiency of evidence, the admissibility of the death certificate photocopy, and the finding of treachery.

A photocopy, as a duplicate, is admissible to the same extent as an original document under the 2019 Revised Rules on Evidence unless a genuine question is raised as to the authenticity of the original or it would be unjust or inequitable to admit the duplicate in lieu of the original.

The case involves the prosecution of an 18-year-old man for having sexual intercourse with his 14-year-old girlfriend. The prosecution alleged the act was accomplished through coercion (threatening to release a video), while the defense claimed it was consensual based on their romantic relationship.

The "sweetheart defense" in rape cases requires compelling proof not only of a romantic relationship but also of the victim's actual consent to the specific sexual act in question; a love affair does not justify sexual intercourse obtained through force or intimidation.

Ruiz, as outgoing Mayor of Dapitan City after losing the 2001 elections, sought to obtain the entire 2001 CIF allocation despite having multiple unliquidated prior cash advances—a violation of COA rules. He directed Police Inspector Pepe E. Nortal to request the cash advance, assured him of liquidation, and later received and misappropriated most of the funds.

A public officer who, through evident bad faith, causes undue injury to the government by facilitating and misappropriating public funds—using a subordinate to circumvent legal prohibitions on cash advances—is guilty of violating Section 3(e) of R.A. 3019 and Malversation under Article 217 of the RPC.

The case arose from the recruitment of two minor victims (AAA and BBB, both 14 years old) by the accused-appellant, who was the mother of a friend of the victims. The accused-appellant offered them employment as massage therapists at a spa in another location, but with the underlying purpose of exploiting them through prostitution under the guise of "extra services."

In cases of trafficking in persons involving minor victims, the crime is consummated by the acts of recruitment and transportation for the purpose of exploitation without requiring actual sexual exploitation to occur, and the victim's consent is immaterial and cannot be raised as a defense.

Spouses Nilo and Nenita Delos Santos obtained a loan from Planters Development Bank (PDB), secured by a real estate mortgage over their properties. They later executed a promissory note for the same loan amount. Upon the spouses' default, PDB extrajudicially foreclosed the mortgage. The heirs of the spouses (respondents) filed a complaint to annul the mortgage and foreclosure, alleging, among others, that no prior demand was made.

An express waiver of demand in a promissory note is valid and renders a prior demand unnecessary for the debtor to be considered in default, thereby allowing the creditor to exercise remedies such as extrajudicial foreclosure. A contractual stipulation in a mortgage requiring notice of "any judicial or extra-judicial action" is satisfied by furnishing the debtor with a copy of the petition for extrajudicial foreclosure prior to the auction sale.

Leoncio Melocoton married Susan Jimenez in 1981. In 1987, while that marriage was allegedly subsisting, he married Jennifer Pring. In 2005, Melocoton filed a petition to nullify the second marriage on grounds of bigamy, lack of authority of the solemnizing officer, and forgery. He also sought to remove Pring's name from the titles of properties he claimed were exclusively his.

In an action to declare a marriage void for bigamy, the burden of proof lies with the party alleging it. A mere marriage certificate of the prior marriage is insufficient to prove that it was still valid and subsisting at the time of the second marriage; more convincing evidence is required.

The case arose from a 2007 incident where a student, Rhys Palaganas, was repeatedly punched by two classmates at school. The school's handling of the incident was deemed grossly negligent by the courts. The victim's parents sought damages from the school and the teachers involved.

A school's liability for failing to protect a student from harm by another student arises from its contractual obligation (culpa contractual) to provide a safe learning environment, not from a quasi-delict (culpa aquiliana). Consequently, the school cannot invoke the defense of having exercised due diligence in the selection and supervision of its employees, a defense available only in quasi-delicts.

Spouses Nilo and Nenita Delos Santos obtained a loan from Planters Development Bank (PDB), secured by a real estate mortgage over their properties. They later executed a promissory note for the same loan obligation. Upon default, PDB extrajudicially foreclosed the mortgage. The Spouses Delos Santos filed a complaint to nullify the foreclosure, which was later re-filed by their heirs after Nilo's death.

The express waiver of demand in a promissory note is valid and binding, making a prior demand unnecessary for the debtor to be considered in default and for the creditor to initiate extrajudicial foreclosure proceedings.

Ericson Cabutaje and Romelia Cabutaje married in 2003 and had a daughter. To provide for their family, both spouses eventually worked abroad in Taiwan, but their relationship deteriorated due to distance and Romelia's inconsistent financial support. After her contract ended, Romelia returned to the Philippines, took their daughter, but then left the child in her sister's care to work in Hong Kong. She ceased providing financial support and entered into another romantic relationship. These events prompted Ericson to file a petition to have their marriage declared void, alleging that both he and Romelia were psychologically incapacitated to fulfill their essential marital obligations.

The marriage is declared void ab initio on the ground of respondent Romelia A. Cabutaje's psychological incapacity, which was sufficiently established through the totality of evidence, including expert testimony based on collateral interviews and testimonies of witnesses who knew the respondent, without the need for the respondent's direct personal examination.

Petitioner Dante Padayao, representing the Heirs of Mario Padayao, claimed continuous, open, and adverse possession of Pitogo Island (covering Lot Nos. 6972 and 6973) in Caramoan, Camarines Sur, since the 1920s. His predecessor obtained a survey plan in 1934, and real property taxes were paid from 1945 to 2009. In 2009, the Provincial Government of Camarines Sur, through its officials (respondents), ordered the residents to vacate, claiming the island was a protected area and danger zone. Upon the residents' refusal, armed men demolished structures on the island on February 4, 2009. Petitioner filed a complaint for recovery of possession and damages.

In an accion publiciana, a claimant's prior, uncontested physical possession of alienable and disposable public land, coupled with a pending application for a free patent, establishes a better right of possession against a party who dispossessed them without legal authority, even if a certificate of title has not yet been issued for a portion of the land.

MaxBank, a thrift bank, suffered from chronic capital deficiencies and failed to meet minimum capital requirements for several years. Despite multiple changes in ownership and directives from the BSP to infuse capital and correct unsafe banking practices, the bank's financial health continued to deteriorate, prompting regulatory intervention.

The Monetary Board's authority to summarily close a bank is a discretionary, police power measure that may only be assailed via a petition for certiorari filed by stockholders representing the majority of the capital stock within 10 days from receipt of the closure order.

The case arose from a conflict between local autonomy and national law. The Province of Occidental Mindoro and the Municipality of Abra de Ilog enacted ordinances and resolutions declaring a 25-year moratorium on all large-scale mining activities, citing environmental protection and the general welfare of their constituents. This directly conflicted with the FTAA granted by the national government to Agusan Petroleum, which authorized large-scale mining exploration in areas including Occidental Mindoro.

Local government units cannot enact ordinances that impose a total ban on large-scale mining activities, as such measures contravene the national policy established by the Philippine Mining Act (RA 7942) and exceed the scope of their delegated legislative and police powers.

The case involves a dispute between neighboring beach resort operators in Matabungkay, Batangas. The Goños (owners of Villa Alexandra) sought the demolition of the Calimlims' structures, which were built on public foreshore land without title or lease, lacked necessary permits, and operated in a manner that allegedly caused noise, odor, safety hazards, and loss of income to the Goños' business.

Structures illegally built on public foreshore land without a DENR lease agreement, which obstruct public use and pose immediate safety hazards (e.g., fire risk, unsanitary conditions), constitute a public nuisance and a nuisance per se that may be abated through court action.

In August 2015, Beverly Hills Medical Group, Inc. (BHMGI), through its in-house dentist Dr. Maria Theresa Mendoza, purchased dental and cosmetic merchandise from Dio Implant Philippines Corporation (DIPC). BHMGI, acting through its finance officer and authorized signatory George Rebujio, issued Security Bank Check No. 0000072006 in the amount of PHP 297,051.86 as payment. The check was drawn on BHMGI’s account and signed by Rebujio. Upon presentment, the check was dishonored for having been drawn against insufficient funds. DIPC made demands for payment, which were not heeded. DIPC then filed a criminal complaint against Rebujio for violation of Batas Pambansa Bilang 22.

An acquittal for violation of Batas Pambansa Bilang 22 extinguishes the civil liability of the person who actually signed the dishonored corporate check, without regard to whether that person qualifies as a “corporate officer” as defined by the Revised Corporation Code. Section 1 of B.P. 22 imposes liability on “the person or persons who actually signed the check in behalf of such drawer” and does not incorporate the Corporation Code’s enumeration of corporate officers; upon acquittal, any surviving civil obligation belongs to the corporation alone, consistent with the doctrine of separate juridical personality.

Pacific Hub Corporation (Pacific Hub) had unremitted withholding and value-added taxes for taxable years 2005-2006. In 2008, it expressed willingness to pay the basic taxes but requested abatement of penalties and interest. It subsequently paid the basic deficiency taxes in 2010. On January 10, 2014, the CIR issued a Notice of Denial for the abatement application. On September 12, 2014, the CIR issued a Warrant of Distraint and/or Levy to collect the penalties and interest. Pacific Hub challenged these issuances before the CTA.

The CTA's "other matters" appellate jurisdiction extends to reviewing the CIR's exercise of discretionary powers, such as denying an abatement application, when the action is attended by grave abuse of discretion. A warrant of distraint and/or levy is void if issued without a prior final assessment determining the taxpayer's actual liability, as such assessment is a prerequisite for valid tax collection.

Spouses Kaw owned a 3,040 sq.m. lot. They sold a 2,000 sq.m. portion to respondents via two separate "Deeds of Conditional Sale." After paying the down payment, respondents took possession, built cottages, and began operating "Diwata Imacoto Beach Resort." Spouses Kaw filed for rescission, claiming violations of the contracts.

In a contract to sell, the vendor's obligation to execute a deed of absolute sale arises only upon the vendee's full payment of the purchase price. The remedy of rescission under Article 1191 of the Civil Code is available for substantial breaches of a contract to sell other than non-payment of the price, but not for slight or casual breaches.

The case involves a claim for damages based on quasi-delict. A minor student, under the instruction and supervision of his school principal during a school-organized community clean-up drive (pintakasi), cut down a banana plant located beside a national highway. The falling plant struck and killed a passing motorist. The central legal question revolved around the civil liability of the school principal for the tortious act of the student in his custody.

A school principal who directly supervises and instructs a minor student during a school activity is vicariously liable as a "teacher-in-charge" for the student's negligent acts that cause damage to third parties, unless the principal proves they exercised the diligence of a good father of a family to prevent such damage.

Harbor Star Shipping Services, Inc. and Davao Tugboat and Allied Services, Inc. (DATASI) were competitors in the tugboat and towage business in Davao. Petitioner Captain Ramon R. Verga, Jr. was a shareholder of DATASI and of Davtug Multi‑Purpose Cooperative (DAVTUG), which had been organized by DATASI’s shareholders to acquire more tugboats. Beginning in November 2006, Harbor Star repeatedly sought business collaboration with DATASI, proposing merger, partnership, or a joint venture. Negotiations eventually narrowed to Harbor Star’s acquisition of the DATASI shares held by Verga and two other pilots.

An oral contract for the sale of corporate shares is perfected by mere consent, and the price need not be fixed at the time of contracting if it can be determined by a third‑party audit under Article 1469 of the Civil Code; the seller’s failure to deliver the stock certificates because of a subsequent divestment constitutes a substantial breach that justifies rescission and obligates the seller to return the purchase price received, with interest at six percent per annum from extrajudicial demand under Article 2209, not the higher rate for forbearances of money.

The case stems from a tort action for damages filed by the heirs of a deceased motorist against a school principal. The incident occurred during a community school activity (pintakasi) on a Saturday, where the principal instructed a minor student to cut vegetation near a highway without implementing safety precautions, resulting in the motorist's death.

A teacher or school head is vicariously liable for the quasi-delicts committed by students in their custody if they fail to prove they exercised the diligence of a good father of a family to prevent the damage. The award of damages for loss of earning capacity requires competent proof, typically documentary evidence; where such proof is lacking, temperate damages may be awarded.

The case involves the prosecution of an adult for child abuse under Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act) for violent physical acts committed against a minor in a school setting.

Physical acts of maltreatment against a child that are intrinsically cruel and excessive inherently debase, degrade, or demean the child's intrinsic worth and dignity as a human being, constituting child abuse under Section 10(a) of R.A. 7610, without need for proof of a separate, specific intent to debase.

The Bureau of Internal Revenue (BIR) conducted investigations into the tax liabilities of Fort 1 Global City Center, Inc. (FGCCI) for the taxable years 2009 and 2012. This led to the issuance of Preliminary Assessment Notices (PANs), Final Assessment Notices (FANs), and a Final Decision on Disputed Assessment (FDDA) for 2009, collectively assessing deficiency income tax, value-added tax, withholding tax, and documentary stamp tax totaling approximately ₱1.732 billion. FGCCI contested these assessments, primarily arguing that the BIR served the notices at incorrect addresses and to unauthorized persons, thereby violating its right to due process.

A tax assessment is void if the BIR fails to strictly comply with the procedural due process requirements for serving assessment notices, specifically by delivering them to the taxpayer's registered or known address and to the taxpayer or its duly authorized representative whose name, signature, designation, and authority are indicated. The taxpayer's act of protesting the assessment does not ratify or cure the defective service.

The disciplinary action stemmed from criminal complaints for plunder, graft, and falsification filed before the Office of the Ombudsman (OMB) concerning the misuse of the PHP 900 million Malampaya Fund. Among the allegations was that various documents were "notarized" by Ben Hur Luy, who forged the signatures of respondents Attys. Talaboc, Agcaoili, and Oliveros and used their notarial registers, stamps, and seals. The OMB, in a Joint Resolution, found insufficient proof that the respondents had knowledge of or were part of the scheme but recommended disciplinary action for violating notarial rules by allowing the use of their paraphernalia for a fee. The matter was referred to the Integrat…

In administrative proceedings against lawyers, the burden of proof rests on the complainant, who must establish the allegations by substantial evidence. Failure to discharge this burden, coupled with evidence suggesting forgery and identity theft rather than the lawyer's negligence, warrants the dismissal of the complaint for violation of the Notarial Rules.

Petitioner Godofredo V. Arquiza and private complainant Francisco G. Datol, Jr. were both nominees of the Senior Citizen Party‑List for the 2013 elections. On September 11, 2012, Arquiza filed before the COMELEC a Petition to Deny Due Course or Cancel the Certificate of Nomination of Party List Nominees. The petition contained statements describing Datol as having “a string of criminal cases showing his propensity and predisposition to commit illegal and unlawful acts” and as “a fugitive from justice.” Datol learned of the petition when another nominee, Santos, showed him a copy; he then complained that the imputations caused him worry, cast dishonor upon him, and led Santos to doubt his in…

A defamatory statement made in the course of a quasi‑judicial proceeding, or in a step necessarily preliminary to such a proceeding, is absolutely privileged and cannot give rise to criminal liability for libel, so long as (1) the document containing the statement was filed as a necessarily preliminary step to or during a quasi‑judicial proceeding; (2) the proceeding affords procedural protections similar to those of the judicial process; (3) the statement is relevant and pertinent to the proceeding; and (4) the document was communicated by the author only to persons who have a duty to perform with respect to it and to those legally required to be served a copy.

The case involves an administrative complaint filed by the siblings of the late Ma. Esperanza A. Ledonio-Aurelio against her husband, Atty. Leonardo A. Aurelio. The complaint alleged two main grounds: gross immorality for having an extramarital affair and siring a child, and professional negligence related to his handling of a will and a separate property case.

A lawyer's gross negligence in performing fiduciary duties, such as unreasonably delaying the probate of a will as an executor, constitutes a serious offense under the CPRA and warrants disbarment, especially when compounded by prior administrative infractions.

The case arose from the issuance of Executive Order No. 30 in 2017, which sought to harmonize and expedite the regulatory approval process for major energy projects. Environmental groups and affected residents challenged the EO, claiming it prioritized energy development over environmental protection and community rights by imposing unrealistic timelines and presumptions that could bypass critical permits like Environmental Compliance Certificates (ECC) and Free, Prior, and Informed Consent (FPIC).

Executive Order No. 30 is a valid administrative issuance as it falls within the President's power of control over the executive branch and his duty to ensure the faithful execution of laws. It merely establishes procedural baselines to streamline government processes without altering substantive legal requirements.

In the May 13, 2019 National and Local Elections, petitioner Peter Bascon Miguel was elected Vice Mayor and respondent Eliordo Usero Ogena was elected Mayor of Koronadal City, South Cotabato. Both were proclaimed on May 15, 2019 and assumed office on June 30, 2019. On August 29, 2019, Miguel filed a Complaint for Quo Warranto under Rule 66 of the Rules of Court with the Regional Trial Court of Koronadal City, alleging that Ogena was disqualified from holding elective office because of penalties imposed by the Supreme Court in Administrative Case No. 9807—a two-year suspension from the practice of law and a permanent ban from being commissioned as a notary public—which Miguel argued constitu…

For elected public officials, the remedy of quo warranto under Rule 66 of the Rules of Court is limited to disqualifications, ineligibilities, or defects in title that arise or are discovered during the official’s incumbency; where the alleged disqualification existed before or at the time of the election and affects the validity of the election, the exclusive remedy is a petition for quo warranto under Section 253 of the Omnibus Election Code filed with COMELEC within ten days from proclamation.

Maria Lina P. Quirit-Figarido was married to Ho Kar Wai in 1989 in Hong Kong and again in 1994 in the Philippines. While this marriage was subsisting, she married Edwin L. Figarido in 2003 in Quezon City. In 2007, Ho Kar Wai obtained a divorce decree in Hong Kong, which was later recognized by a Philippine Regional Trial Court in 2009. Maria Lina and Edwin separated in 2014. In 2017, Maria Lina filed a petition before the Family Court to declare her marriage to Edwin void ab initio on the ground of bigamy under Article 35(4) of the Family Code, praying also for a declaration of her legal capacity to remarry.

Only the aggrieved or injured innocent spouse of either the prior or the subsequent marriage has the legal personality to petition for the declaration of nullity of a bigamous marriage; the spouse who is guilty of contracting the bigamous union lacks such standing.

The case involves a petition for declaration of nullity of marriage based on psychological incapacity. The petitioner, Ronald, claimed he suffered from Passive-Aggressive Personality Disorder due to a strict upbringing, which prevented him from fulfilling his marital obligations, particularly emotional support and love. The Republic opposed, arguing the evidence was insufficient and that Ronald’s prior conduct showed he was capable of performing marital duties.

Psychological incapacity under Article 36 may manifest after the marriage and need not be proven by medical experts; it is sufficient to show, through ordinary witnesses or other evidence, that a durable aspect of a spouse’s personality structure—existing at the time of the marriage—makes it impossible to comply with essential marital obligations, such as the obligation to love one’s spouse.

Joemarie Ubanon y Man-an (Joemarie) and Amirah Macadatar were charged with qualified trafficking in persons for recruiting and transporting three minors (AAA270934, BBB270934, and CCC270934) under the pretext of onion-peeling jobs, only to have them deployed as unpaid domestic helpers in Marawi City and Lanao del Sur. The victims, aged 14 and 15, were approached by Joemarie, who insisted they leave immediately without parental permission. He then introduced them to Amirah's daughter (DDD) and instructed them to board a bus with her. After a multi-leg journey, the victims were separated and forced to work without compensation until they were eventually recovered.

Conspiracy to commit qualified trafficking in persons may be inferred from a chain of circumstances demonstrating a unity of purpose and action, even absent direct evidence of a prior agreement, where the accused's acts of recruitment, facilitation of transport, and handover of minor victims to a co-actor unmistakably indicate a common criminal design to subject them to exploitation.

AAA270003, a 14-year-old female, first received a phone call in November 2017 from an unknown person asking her to meet at a certain location. The caller was later identified as Ria Liza Bautista y Cariaga (Bautista). AAA270003 met Bautista on November 23, 2017 at the latter’s boarding house. Over the following days, Bautista arranged for AAA270003 to engage in sexual acts with different men in exchange for money, transporting her to a police camp and hotels, and receiving a share of the payments. AAA270003 eventually disclosed the incidents to her mother, who reported the matter to the police.

When the trafficked person is a child, the recruitment, transportation, transfer, harboring, or receipt for the purpose of exploitation need not involve threat, force, coercion, deception, or other similar means; the child’s consent is immaterial and the crime of qualified trafficking is committed even if the minor participated willingly. The elements of trafficking are: (1) the act of recruitment, obtaining, hiring, providing, offering, transportation, transfer, maintaining, harboring, or receipt of persons; (2) the use of threat, force, coercion, abduction, fraud, deception, abuse of power or position, taking advantage of vulnerability, or the giving or receiving of payments or benefi…