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Obligations and Contracts Digest: George W. Batchelder vs. The Central Bank of The Philippines
Obligations and Contracts Digest: George W. Batchelder vs. The Central Bank of The Philippines
GEORGE W. BATCHELDER vs. THE CENTRAL military bases in the Philippines to surrender to the Central
BANK OF THE PHILIPPINES Bank their dollar earnings under their respective contracts but
were entitled to utilize 90% of their surrendered dollars for
G.R. No. L-25071 March 29, 1972 importation at the preferred rate of commodities for use
within or outside said U.S. military bases. Resolution 695
DOCTRINES: moreover, denies their right to reacquire at the preferred rate
ninety per cent (90%) of the foreign exchange the sold or
surrendered earnings to Central Bank for the purpose of
determining whether the imports against proceeds of
contracts entered into prior to April 25, 1960 are classified as
dollar-to-dollar transactions or not.
Issue:
Held:
CMC VS CA
OBLIGATIONS AND CONTRACTS DIGEST
Facts:
subscriber could make a call to a PLDT subscriber in the may required, subject to the payment of just compensation to
same way that the latter could make a call to the former. be determined by the court.
BOT entered into an agreement with RCA Communications The Republic’s cause of action is predicated upon the radio
(an American Co. party not in interest of the case), Inc. for a telephonic isolation of the BOT facilities from the outside
joint telephone service whereby the BOT would convey world if the severance of interconnection were to be carried
radio-telephone overseas call received by RCA to and from out by the PLDT, thereby preventing the BOT from properly
local residents. discharging its functions, to the prejudice of the general
public. The case should be for the compulsory rendering of
PLDT complained that BOT violated conditions since BOT interconnection of services by the telephone company upon
had used the trunk lines not only for government offices but such terms and conditions as the court may determine to be
even to serve private persons or the general public in just.
competition with the business of PLDT. PLDT sever the
telephone connections of BOT resulting to isolation of the Since the lower court should have proceeded to treat the
Philippines on telephone services from the rest of the world case as one of condemnation of such services independently
except the US. of contract and proceeded to determine the just and
reasonable compensation for the same, instead of dismissing
The BOT had proposed that both enter into an the petition.
interconnecting agreement, with the government paying (on a
call basis) for all calls passing through the interconnecting Under Section 79 of EO 94 paragraph (b)
facilities from the GTS to the PLDT. 18 The PLDT replied
that it was willing to enter into an agreement on overseas To investigate, consolidate, negotiate for, operate and
telephone service to Europe and Asian countries provided maintain wire-telephone or radio telephone communication
that the BOT would submit to the jurisdiction and regulations service throughout the Philippines by utilizing such existing
of the Public Service Commission and in consideration facilities in cities, towns, and provinces as may be found
sharing of the gross revenues. The proposals were not feasible and under such terms and conditions or arrangements
accepted by either party. with the present owners or operators thereof as may be
agreed upon to the satisfaction of all concerned.
The plaintiff commenced suit against the defendant, praying
in its complaint for judgment; (1) commanding the PLDT to Under Section 6 Article XIII 1935 Constitution
execute a contract with plaintiff, through the BOT, for the use “Conservation and Utilization of Natural Resources.”
of the facilities of defendant's telephone system throughout
the Philippines under such terms and conditions as the court The State may, in the exercise of national welfare and
might consider reasonable, and; (2) for a writ of preliminary defense, establish and operate industries and means of
injunction against the defendant company to restrain the transportation and communication, and upon payment of just
severance of the existing telephone connections and/or compensation, transfer to public ownership, utilities and other
restore those severed. private enterprises to be operated by the government.
After trial, the lower court rendered judgment that it could Charter of PLDT expressly provides that Section 14.
not compel the PLDT to enter into an agreement with the
The rights therein granted shall not be exclusive, and the
Bureau because the parties were not in agreement;
rights and power to grant to any corporation, association or
Issue/s: person other than the grantee franchise for the telephone or
electrical transmission of message or signals shall not be
Whether or not interconnection of Government Telephone impaired or affected by the granting of this franchise.
System and PLDT can be subject for expropriation.
PLDT’s right to just compensation for the services rendered
Ruling: to the GTS and its users is herein recognized and preserved.
To uphold PLDT’s contention is to subordinate the needs of
Yes. the general public to the right of the PLDT to deprive profit
from the future expansion of its services under its non
The Republic of the Philippines through Bureau of exclusive franchise.
Telecommunications may in the exercise of the sovereign
power of eminent domain, require the Telephone Company to The acceptance by the defendant of the payment of rentals,
permit interconnection of the Government Telephone System despite its knowledge that the plaintiff had extended the use
and that of the PLDT, as the needs of the government service of the trunk lines to commercial purposes, continuously since
OBLIGATIONS AND CONTRACTS DIGEST
HELD:
RULING:
HELD/RATIO: NO!
LEAL VS IAC
Doctrines:
OBLIGATIONS AND CONTRACTS DIGEST
Sept. 27, 1983: The June 28, 1978 decision of the CA was
reversed. The petitioners were to accept P5,600 for re-
purchase of Land and they should pay rental of P3,087.50 as
rental from 1967-1968 and the same amount every year after.
The Transfer Certificate of Title No. 42535 was ordered to be
in the names of V. Santiago & Luis Santiago and to issue
another TCT to S. Santiago.
ISSUE/S:
-Reversal of IAC in its Resolution dated Sept. 27, 1983 of the HELD:
earlier decision dated June 28, 1978 penned by Justice Paras
of the Court of Appeals, in the same case, affirming the trial The Resolution dated Sept. 27, 1983 was SET ASIDE and the
court’s dismissal of the private respondent’s complaint. Decision promulgated on June 28, 1978 is Reinstated. The
annotations of the prohibition to sell at the back of TCT Nos.
March 21, 1941: Vicente Santiago and Cirilio Leal entered 138837-138842 were cancelled – cost against respondent.
into a contract which was called the “Compraventa” where V.
Santiago sold to the latter three parcels of land. Cited in the For the following reasons:
contract was: ‘En caso deventa, no podran vender a
otrosdichos tres lotes de terrenosino al aqui rendedor Vicente -In IAC’s resolution : repurchase was given birth by the
Santiago, o los herederos o sucesores de estepor el niismo phrase “siempre y cuando ultimos pueden hacer la compra”
(when the buyer has money to buy). Under Article 1508 (2nd
OBLIGATIONS AND CONTRACTS DIGEST
Facts:
• The students who were not given failing marks but DE LUNA VS ABRIGO
denied reenrollment were refused reenrollment without just
cause. the denial for readmission of students with failing DOCTRINE:
marks was also found to be a mere afterthought not relevant
to the actual cause i.e. their participation in mass actions.
OBLIGATIONS AND CONTRACTS DIGEST
The children and only heirs of the late De Luna (died after
the donation) filed a complaint with the RTC for the
cancellation of the donation on the ground that the terms
were violated. The Foundation defended itself by saying that
it had partially and substantially complied with the conditions
and that the donor granted it an indefinite extension of time to
complete construction.
ISSUE:
RULING: 10 years
LLORIN VS CA
OBLIGATIONS AND CONTRACTS DIGEST
PALANCA VS CA
OBLIGATIONS AND CONTRACTS DIGEST
DOCTRINES:
Facts
The issue
HELD:
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Article 19. Every person must, in the exercise of his rights • Thus on the examination dates, she was not
and in the performance of his duties, act with justice, give allowed by her two teachers, Gamurot and Balalad, to take
everyone his due, and observe honesty and good faith. her final exam on statistics and logic.
Article 21. Any person who wilfully causes loss or injury to • The next day, the teacher announced to the whole
another in a manner that is contrary to morals, good customs class that khristine and another student was not permitted to
or public policy shall compensate the latter for the damage. take the exam because of the failure to buy the tickets then
subsequently ejected the two from class.
Article 26. Every person shall respect the dignity, personality,
privacy and peace of mind of his neighbors and other • Khristine continued to plead with the teachers to
persons. The following and similar acts, though they may not allow her but they kept their stand and defended their
constitute a criminal offense, shall produce a cause of action position saying that they were complying with PCST’s
for damages, prevention and other relief: policy.
(1) Prying into the privacy of anothers residence; • Khristine filed in the RTC as a pauper litigant
against PCST and her two teachers for damages.
(2) Meddling with or disturbing the private life or family
relations of another; • The respondents filed a motion to dismiss based on
the khristine’s failure to exhaust administrative remedies as
(3) Intriguing to cause another to be alienated from his they are contending that the case should’ve been filed in the
friends; CHED (commission of higher education) and not in the RTC
(4) Vexing or humiliating another on account of his beliefs, • Khristine on the other hand says that prior
lowly station in life, place of birth, physical defect, or other exhaustion of administrative remedies was unnecessary,
personal condition. because her action was not administrative in nature, but one
purely for damages arising from respondents breach of the
FACTS: laws on human relations
school allow her to take the final examinations (considering that it is protected by the constitution and by a legislative act
that she was already enrolled in a different school). The acts called the Education Act of 1982.
of the respondent can no longer be reversed and even if it was
reversed, it would not be adequate to redress her grievances b. Liability for Tort
The Supreme Court also held that the doctrine can only be In her complaint, Khristine wrote that she was inhumanly
applied when there is competence on the part of the punished by reason only of their poverty, religious practive or
administrative body to act upon the matter complained of. lowly station I life which inculcated feelings of guilt,
Thus in the case at bar, the CHED does not have the power to disgrace and unworthiness and as a result she was unable to
award damages to the petitioner. finish her subjects for the second semester and had to lag her
studies for a full year. The acts caused her extreme
And lastly, the doctrine cannot be applied when the issue is humiliation and mental agony and she asks for compensation
purely legal and well within the jurisdiction of the trial court. as the respondents violated Article 19, 21, and 26 of the Civil
The petitioner’s action for damages calls for the application Code.
of the Civil Code which falls within the jurisdiction of the
courts. The court held that generally, tort arises only between partieis
not otherwise bound by a contract. But in the case of PSBA
2. Yes vs. CA an academic institution may be held liable for tort
even if it has an existing contract with its students, since the
a. Breach of Action act that violated the contract may also be a tort.
In the case of Alcuaz v. PSBA, the court characterized the The Respondent CANNOT use the right to academic freedom
relationship between the school and the student as a contract, as a defense because According to present jurisprudence,
where the student, once admitted by the school is considered academic freedom encompasses the independence of an
enrolled for one semester. And in a succeeding case (Non v. academic institution to determine for itself (1) who may
Dames), the court ruled that it is not merely for one semester teach, (2) what may be taught, (3) how it shall teach, and (4)
but an entire period that the student is expected to complete who may be admitted to study.
it. Thus it can be seen that when it comes to the court, the
relationship between the school and the student is contractual
in nature.