ATCI OVERSEAS CORPORATION, AMALIA G.

IKDAL and MINISTRY OF PUBLIC HEALTH-KUWAIT

VS MA. JOSEFA ECHIN

Facts:

Respondent Echin was hired by petitioner ATCI as a medical technologist for the Ministry of
Public Health of Kuwait. Under their agreement, she will be on a one year probationary status with a
salary of US$1,200 and covered by Kuwait’s Civil Service Board Employment Contract. She was
deployed on February 17, 2000 but was dismissed on February 11, 2000, as she allegedly failed to pass
the probationary period. She returned to the Philippines, after her request for reconsideration was denied
by the Ministry, shouldering her airline expenses. Thereafter, she filed an illegal dismissal complaint to the
National Labor Relations Commission against the petitioners.

Issue:

Whether or not the doctrine of processual presumption applies in the present case.

Ruling:

The Supreme Court held that the petitioners failed to discharge the said doctrine. The Philippines
does not take judicial notice of foreign laws as they must be alleged and proved in court. To prove a
foreign law, the party invoking it must present a copy thereof and comply with the provisions of the Rules
of Court. The petitioners in the present case merely presented certifications attesting as to the
correctness of the translations of the Memorandum of Agreement and termination letter which in itself
does not prove that Kuwaiti Civil Service laws are different from the Philippine laws which would have
certified that the respondent was validly terminated.
FELIX CAMITAN, FRANCISCO CAMITAN, SEVERO CAMITAN and VICTORIA CAMITAN vs THE
HONORABLE COURT OF APPEALS and THE FIDELITY INVESTMENT CORPORATION

Facts:

The respondent Corporation acquired from spouses Mateo Camitan and Lorenza Alcazar a
parcel of land which is covered by a Transfer Certificate of Title and located in Calamba, Laguna. The
spouses delivered the owner’s copy of the TCT and from that time, the Corporation assumed all real
estate tax liabilities due on the property and remained in actual possession of the subject lot. Sometime
later, the spouses died and the petitioners in the present case filed a petition for the issuance of a new
owner’s copy of the TCT. However, the respondent was not given notice of the proceeding. The trial court
granted the petition. Upon learning of such, the respondent caused the annotation of notice of sale on the
title of the property and filed a notice of adverse claim with the Register of Deeds. The Corporation filed a
petition for annulment of judgment and cancellation of the title with the Court of Appeals, arguing that the
trial court did not acquire jurisdiction since the Owner’s copy of the TCT has been in its possession and
not lost as alleged by petitioners. The Court of Appeals granted the petition of the respondent.

Issue:

Whether or not the Court of Appeals erred in granting the petition even when respondent did not
attach the owner’s copy of the TCT in its possession as evidence.

Ruling:

The Supreme Court held that the Court of Appeals did not commit any error in rendering its
decision. A review of the case shows that petitioners never questioned respondent’s possession of the
owner’s copy, its actual possession of the property and its payment of real estate taxes due on the
property. Furthermore, the respondent alleged in its petition that the spouses Camitan sold the parcel of
land as evidenced by a Deed of Absolut Sale and upon the execution of the said document, the spouses
delivered to the Corporation the Owner’s copy of the TCT and the latter is in actual possession of the lot
and paid the real estate taxes due therein. The petitioners merely denied specifically such allegations due
to lack of information and knowledge. The Court stated that this denial, while labelled as specific, should
not be categorized as such as it is not within the purview of a specific denial within the Rules. When the
matters of whether the defendant alleges having no knowledge or information sufficient to form a belief,
are plainly and necessarily within the defendant’s knowledge, his alleged ignorance or lack information
will not be considered as a specific denial. Hence, it is deemed admitted. The result of which is that there
is an implied admission as to the sale of the property. An evidence is not necessary to prove this. Thus
the Court of Appeals is satisfied that the Owner’s Copy of the TCT is not lost, as admitted by petitioners, it
has been in the possession of another person.
REPUBLIC OF THE PHILIPPINES vs SANDIGANBAYAN

Facts:

Public respondent filed an action in the Sandiganbayan against defendants-respondents Eduardo

Cojuangco, Jr and 59 other defendants for allegedly using their association, influence and connection with
the late President Marcos, to misuse the coco levy funds to acquire majority of the outstanding shares of
stock of San Miguel Corporation through various companies with the assistance of ACCRA law offices.
The Sandiganbayan dismissed the complaint of the petitioner for failure to prove by preponderance of
evidence its causes of action against the defendants as to the 20% ownership of shares of stock of San
Miguel Corporation registered under their names. The Republic appealed the said decision to the
Supreme Court, arguing that the coco levy funds are public funds and therefore the shares of stock
acquired using the coco levy funds by Cojuangco and various companies are public in character.

Issue:

Whether or not Cojuangco acquired the shares of stock using coco levy funds is in violation of his
fiduciary obligation as a public officer.

Ruling:

The Supreme Court held that it is immaterial if respondent was a government official or employee
during the regime of former President Marcos. As much, there must be a prima facie showing that the
respondent unlawfully acquired the shares of stock by virtue of his influence and association with the
former President. The burden is upon the Republic to establish by preponderance of evidence that the
acquisition was illegal and such burden was not discharged. It is unreasonable to conclude that
Cojuangco breached his duties as an officer and member of the Board of Directors of UCPB without
presenting any competent evidence to support such allegations.
STATE PROSECUTORS vs JUDGE MANUEL MURO

Facts:

Judge Muro dismissed the eleven cases of violation of Central Bank Foreign Exchange
Restrictions filed by the prosecutors against the former First Lady Imelda Marcos. The petitioners alleged
that the respondent dismissed the aforementioned cases without determining the full intention of the
Monetary Board Resolution or the Central Bank Circular and only relied on the reports of the Philippine
Daily Inquirer and Daily Global as to the announcement of the President of the Philippines of lifting of all
foreign exchange restrictions and the arrival of such decision by the Monetary Board as per statement of
the Central Bank Governor. The respondent posited that the announcement made by the Executive
Department of the lifting of foreign exchange restriction on the two reputable newspapers has the effect of
repealing the Central Bank Circular No. 960. The complainants contends that the attitude of the Judge in
taking judicial notice of said announcement even before it was released by the Central Bank and its text
published as required by law is highly irregular and misplaced.

Issue:

Whether or not the judge erred in taking judicial notice of the announcement of the President
which was published in a newspaper.

Ruling:

The Supreme Court held that the respondent judge acted with grave abuse of discretion
amounting to lack of jurisdiction. The publication of a newspaper report does not constitute as the
publication required by law to the effectivity of a law. The Civil Code provides that laws take effect after
fifteen days following the completion of their publication in the Official Gazette or any newspaper of
general circulation unless it was otherwise provided. For the court to take judicial notice, three material
requisites should be present: (1) the matter must be one of common and general knowledge; (2) it must
be well and authoritatively settled and not doubtful or uncertain; (3) it must be known to be within the
limits of the jurisdiction of the court. The provincial guide in determining what facts may be assumed to be
judicially known is that of notoriety. Hence, it can be said that judicial notice is limited to facts evidenced
by public records and facts of general notoriety.

Things of “common knowledge,” of which courts take judicial notice, may be matters coming to
the knowledge of men generally in the course of the ordinary experiences of life, or they may be matters
which are generally accepted by mankind as true and are capable of ready and unquestioned
demonstration. Thus, facts which are universally known, and which may be found in encyclopedias,
dictionaries or other publications, are judicially noticed, provided they are of such universal notoriety and
so generally understood that they may be regarded as forming part of the common knowledge of every
person. The reason is simple. A law which is not yet in force and hence, still inexistent, cannot be of
common knowledge capable of ready and unquestionable demonstration, which is one of the
requirements before a court can take judicial notice of a fact.
PEOPLE OF THE PHILIPPINES vs ROMAN MENESES

Facts:

Ramon Meneses was charged with the murder of Cesar Victoria while the latter was sleeping in a
rented makeshift room located in Tondo, Manila together with his seven year old son, Christopher, at
around three o’clock in the morning of December 15, 1991. Christopher testified that he was awakened
from his sleep when his father was stabbed in the heart by a “veinte nueve.”

SPO3 Jaime Mendoza, the police investigator who went to the crime scene and presented as a
witness by the prosecution, testified that when he arrived at the house, he questioned Christopher if he
could identify or describe the attacker and the latter answered in the negative but he said he will
recognize if can see the attacker again.

The prosecution thereafter presented SPO3 Eduardo Gonzales, the police officer who arrested
the appellant and he testified that the arrest was him based on the report of Angelina Victoria, the wife of
the appellant who implicated him for the crime. The appellant was brought to the police precinct and was
identified by Christopher as the attacker during a confrontation.

The appellant interposed the defense of alibi and denial as he alleged that he was in Mexico,
Pampanga when the crime happened and he also denied that he has animosity with the victim, his
brother-in-law. In fact, he helped the victim when he was stabbed when he got out of prison and even
sent Christopher to school. The trial court found the appellant guilty.

Issue:

Whether or not the testimony of the witness, Christopher, is credible.

Ruling:

No. The Supreme Court held that the trustworthiness of the identification of appellant by the
witness is dubious, raising reasonable doubt in the mind of the Court as to appellant’s culpability. It was
established that the crime took place early in the morning, at around three o’clock in a December, when
such hours is still dark and daylight comes rather late during that time of the year. The court can take
judicial notice of the “laws of nature.” The testimony of witness SPO3 Mendoza did not establish the
illumination in the crime scene which would have enabled Christopher to see the attacker. It was only
described that the room had a door and there was no mention of a window which would have allowed
entry of some kind of light from the outside. The Court said that it is improbable that the boy could identify
the attacker at such condition, as he just been roused from his sleep and his eyes have to adjust to the
unlit room. Thus, the prosecution failed to paint a crystal clear picture of the environ by which Christopher
could have made an accurate and reliable identification of the attacker.

The prosecution also failed to explain why Christopher did not immediately named the attacker
when he was questioned, as he was coherent at that time. The Court also stated that identification of an
accused during a confrontation where the suspect alone is brought face to face to the witness is seriously
flawed as it constitutes a grossly suggestive identification procedure. The Supreme Court reversed the
decision of the trial court and acquitted the appellant for the crime charged.
REPUBLIC OF THE PHILIPPINES vs COURT OF APPEALS and JOSEFA GACOT

Facts:

In a cadastral case, Josefa Gacot, in her answer dated June 7, 1971, claimed a parcel of land
located in Magsaysay, Palawan and were in actual possession of the property for more than thirty years
having bought the same as per a deed of sale dated April 22, 1955. She introduced improvements
thereon as well as declared the lot for tax purposes and paid the corresponding taxes. Before the
scheduled hearing, however, the court received a report from the Land Registration Authority that a
decision was rendered in October 20, 1950 declaring the lot as property of the Republic. The trial court
rendered judgment adjudicating the property to Josefa Gacot and the Republic, represented by the
Solicitor General, appealed the case to the Court of Appeals.

The Solicitor General was able to verify that the subject lot was earlier declared as property of the
Republic thus filed a motion to the appellate court to reopen the case and remand to the court a quo to
allow the Republic to present the decision dated 1950. The Court of Appeals granted the motion.
Thereafter, the hearing of the case was scheduled several times for the government to present their
evidence and respective memorandum. The claimant submitted their memorandum but the government,
as represented by the assistant provincial prosecutor assigned failed to present any witness to support
the claim of the Republic and did not submit any memorandum. The trial court then ruled that Josefa
Gacot’s occupation of the land for 38 years entitles her to the lawful adjudication of the lot in her name
and the government did not protest nor interposed any objection on the claim of the private respondent.

The Solicitor General appealed the said decision and argued that since the subject lot was owned
by the government as decided in the case in 1950, Republic Act 2061 will apply. Under this law, the time
for filing an application for reopening of judicial proceedings on certain lands declared as public land does
shall not extend beyond December 31, 1968. Since Gacot only filed her answer on June 7, 1971, the
court did not acquire jurisdiction over her claim as the answer was filed beyond the term provided by the
aforementioned law. The Court of Appeals ruled affirmed the decision of the trial court, stating that it
cannot consider evidence not formally offered and cannot take as judicial notice the decision rendered in
October 20, 1950.

Issue:

Whether or not the court may take judicial notice of the decision rendered in October 20, 1950
and Republic Act 2061.

Ruling:

The Supreme Court held that while the rules of procedure do not sanction the grant of evidentiary
value of evidence which is not formally offered and remedial law not to be taken lightly, nevertheless, it
can be construed liberally as to meet and advance the cause of substantial justice. It further states that
under the Rules of Court, a court can take judicial notice of the official acts of the legislative, executive
and judicial departments of the Philippines. As Justice Paras opined, A court will take judicial notice of its
own acts and records in the same case, of facts established in prior proceedings in the same case, of the
authenticity of its own records of another case between the same parties, of the files of related cases in
the same court, and of public records on file in the same court. In addition judicial notice will be taken of
the record, pleadings or judgment of a case in another court between the same parties or involving one of
the same parties, as well as of the record of another case between different parties in the same court.
Judicial notice will also be taken of court personnel. The Supreme Court remanded the case to the trial
court for further proceedings to ascertain and resolve the claims.
ENRICO SANTOS vs NATIONAL STATISTICS OFFICE

Facts:

Petitioner filed a complaint for Unlawful Detainer against the respondent National Statistics Office
for failing to pay despite demand the rentals amounting to P297,270, and its refusal to vacate the property
even after the expiration of the lease contract between the parties. Petitioner sent respondent a formal
letter of demand to pay the rentals due and vacate the property. However, the respondent still did not
comply with the demand. Respondent, as represented by the Solicitor General, questioned the ownership
of petitioner of the said property. It alleged that the subject property was sold through a public auction
because of an extrajudicial foreclosure when the petitioner failed to pay his obligation to China Bank. The
said bank was the highest bidder to the auction sale and petitioner failed to redeem the property within
the redemption period thus a TCT was issued in favor of the bank. According to respondent, petitioner
Santos misrepresented himself as still the owner of the property and it was sometime later that
respondent was informed of the extrajudicial foreclosure when it received a letter from China Bank that
the property was titled in it name. Hence, petitioner have no right to demand payment and from
respondent and vacate it from the property.

The MTC decided in favor of petitioner, stating that when respondent admitted that it was a
lessee of the premises owned by the petitioner, it took away its right to question the former’s title and
ownership thereof. The lower court reiterated the rule that a tenant cannot, in cases involving possession
of leased premises, controvert the title of the landlord. As the evidence shows that respondent failed to
pay its obligation, the lower court declared that it is a lessee in default which should be ejected from the
property. The RTC affirmed the decision of the MTC. The Court of Appeals then ruled that the
abovementioned rule cited by the MTC is subject to a qualification that is when the landlord’s title expired
or has been conveyed to another or has been defeated, subsequent to the lessor-lessee relationship.

Issue:

Whether or not the conclusive presumption against tenants will apply.

Ruling:

The Supreme Court held that the rule should not apply. It is clear from the provision of the Rules
of Court that what the tenant is estopped from denying is the title of the landlord from the commencement
of the tenancy relationship. The conclusive presumption will not apply if the title asserted is one that is
alleged to have been acquired subsequent to the commencement of the landlord-tenant relationship.
Hence, the tenant may show that the title of the landlord has expired or was conveyed to another.
ASIAN TERMINALS, INCORPORATED vs MALAYAN INSURANCE, CO., INCORPORATED

Facts:

Petitioner, a corporation engaged in providing arrastre and stevedoring services, unloaded bags
of soda ash dense from the vessel and brought them to an open storage area for temporary storage and
safekeeping, pending the clearance from the Bureau of Customs and delivery to the consignee. Upon
completion of the unloading, it was discovered that 2, 702 of the bags were in bad order condition. The
bags were then loaded to the trucks of MEC Customs Brokerage for delivery to the consignee. After all
the bags were unloaded in the warehouse of the consignee, it was known that 2, 881 bags were in bad
order condition due to spillage, caking and hardening of the contents. Respondent, Malayan insurance, as
insurer paid the value of the damaged goods to the consignee and filed, as subrogee of the consignee, to
the RTC a complaint for damages against the petitioner. The RTC ruled that the petitioner is liable for
damages. It found out that the proximate cause of the damage was the negligence of the petitioner is the
handling of the bags during unloading. They used steel hooks despite the protests of the cargo surveyors
which pierced the bags and caused the spillage.

The Court of Appeals then affirmed the decision of the trial court. The petitioner appealed the
decision to the Supreme Court.

Issue:

Whether or not the rule on judicial notice will apply as to the agreement between the petitioner
and the Philippine Ports Authority.

Ruling:

The Supreme Court answered in the negative. The provision of the Rules of Court with respect to
judicial notice does not include the nature or character of the agreement between the petitioner and the
PPA. It cannot be considered as an official act of the executive. PPA, a government owned and controlled
corporation, was only performing a proprietary function when it entered into a Memorandum Contract with
petitioner. Such act cannot be a subject of a judicial notice.
PEOPLE OF THE PHILIPPINES vs BAIDA SALAK

Facts:

NBI Special Investigators Edgardo Kawada and Raoul Manguerra conducted a buy-bust
operation that resulted to the arrest and conviction of the respondent Baida Salak for the illegal sale of a
regulated drug in violation of the Dangerous Drug Act. However, it is the contention of the respondent that
during the inventory of the confiscated drugs, the investigators failed to comply with the compliance
required by law. The RTC ruled against the respondent and upon appeal, the Court of Appeals affirmed
the decision of the trial court.

Issue:

Whether or not there was a failure on the part of the prosecution to establish the integrity of the
confiscated shabu for non-compliance with the requirement that a physical inventory and photograph of
the confiscated drugs be taken.

Ruling:

The Supreme Court held that the failure of the operation team to comply with the requirements
set by law does not overturn the presumption of regularity in the performance of duty. To defeat the
presumption, it must be shown that the arresting officers must have ill motive or malice against the
accused. Further, the non-compliance does not render the items inadmissible in evidence as what is
important is that the integrity and evidentiary value of the seized drugs are preserved.
PEOPLE OF THE PHILIPPINES vs ARMANDO CHINGH

Facts:

An information for Rape was filed against the respondent for committing sexual abuse and
lascivious act against the victim, VVV, a ten year old girl. He committed the crime by pulling her in a dark
place then mashing her breasts and inserting his fingers in her vagina and afterwards his penis, against
her will and consent. The genital examination shows the existence of a laceration on the vaginal area of
VVV. Armando denied the rape in his version of events wherein he stated that he was with his
granddaughter when they passed by VVV. The latter then approached him asked if she can go with him
to buy some sunkist. He refused and told her to go home. The RTC convicted Chingh of statutory rape
after finding the evidence of the prosecution overwhelming against the defense of alibi interposed by the
respondent. The Court of Appeals affirmed the decision with modification that Chingh was also guilty of
Rape through Sexual Assault.

Issue:

Whether or not the defense of alibi will hold.

Ruling:

No. The Supreme Court stated that Armando tendered nothing but his bare denial and contention
that he was elsewhere when the crime was committed. Aside from this, he presented no more evidence
to substantiate his claims. Jurisprudence dictates that denial and alibi are the common defenses in rape
cases. Sexual abuse is denied on the allegation that the accused was somewhere else and could not
have physically committed the crime. This Court has always held that these two defenses are inherently
weak and must be supported by clear and convincing evidence in order to be believed. As negative
defenses, they cannot prevail over the positive testimony of the complainant. Consequently, Armando's
bare denial and alibi must fail against the testimony of VVV and her positive identification that he was the
perpetrator of the horrid deed.
COUNTRY BANKERS INSURANCE CORPORATION vs ANTONIO LAGMAN

Facts:

Petitioner issued warehouse bonds in favor of Santos, who applied for such as it was a condition
for his application for a license from the NFA to engage in the business of storing sacks of palay in his
warehouse. The transaction was entered upon with Antonio Lagman as the agent, which made him a
surety. Santos thereafter contracted a loan using the warehouse bonds as collateral. However, when the
loan became due, Santos defaulted in his payment. The sacks of palays were also missing from the
warehouse. Due to this fact, Country Bankers was forced to pay the loan. Consequently, it filed a civil
case before the RTC of Manila against Santos, but the latter was nowhere to be found. Thus, the RTC
declared that Lagman is liable to the petitioner as co-signor. In his defense, Lagman contends that the
lifetime of the bonds issued in 1989 is only for 12 months while the bond issued in 1990 superseded the
two prior bonds and it was not pleaded in the complaint. He presented a photocopy of the bond issued in
1990.

Issue:

Whether or not a photocopy is admissible in court, it being a secondary evidence.

Ruling:

The Supreme Court in the negative. Under the best evidence rule, the original document must be
produced whenever its contents are the subject of the inquiry. A photocopy, a secondary evidence, is not
admissible unless it is shown that the original is unavailable. Before a party is allowed to adduce
secondary evidence to prove the contents of the original, the offeror must prove the following: (1) the
existence or due execution of the original; (2) the loss and destruction of the original or the reason for its
non-production in court; and (3) on the part of the offeror, the absence of bad faith to which the
unavailability of the original can be attributed. The correct order of proof is as follows: existence,
execution, loss, and contents. In the present case, duplicate originals of the 1990 bond is in existence: in
the NFA, the loan officer of the NFA in Tarlac, with the Country Banker Insurance and with Lagman
himself. Country Bankers and the fourth was in his possession. A party must first present to the court
proof of loss or other satisfactory explanation for the non-production of the original instrument. When
more than one original copy exists, it must appear that all of them have been lost, destroyed, or cannot be
produced in court before secondary evidence can be given of any one. A photocopy may not be used
without accounting for the other originals.
PEOPLE OF THE PHILIPPINES vs JAIME GATBALAYAN

Facts:

Respondent Gatbalayan was arrested by PO1 Jose Gordon Antonio, PO1 Fortunato Jiro and
PO1 Albarico upon a tip from an informant that he was rampantly selling shabu at Rodriguez, Rizal. The
three officers formed a composite team to conduct a buy bust operation against the respondent. Upon
reaching the area where Gatbalayan was located, the asset pointed him to the police officers and they
started the operation, PO1 Antonio acting as poseur-buyer. The latter handed the marked money to
Gatbalayan in exchange for a small sachet containing shabu. Upon consummation of the sale, PO1
Antonio gave the signal and the other two police officers arrested the respondent. He was charged for
Illegal Sale of Drugs, a violation of the Dangerous Drugs Act. The RTC convicted him and the Court of
Appeals affirmed the said decision. Upon appeal to the Supreme Court, The appellant averred that the
RTC and CA were mistaken in upholding the presumption of regularity in the performance of official
functions. He posits that the prosecution failed to establish the material details of the entrapment
operation and his arrest was invalid. He also contends that the apprehending team failed to comply with
the procedure provided under the law as regards the inventory of the seized drug. The prosecution,
according to him failed to establish the proper chain of custody of the shabu seized from him.

Issue:

Whether or not sufficient evidence exists to support the conviction of the accused.

Ruling:

The Supreme Court ruled in the negative. Jurisprudence has firmly entrenched that in prosecution
of illegal sale of dangerous drugs, the following essential elements must be established: (1) the
transaction or sale took place; (2) the corpus delicti or the illicit drug was presented as evidence; and (3)
the buyer and seller were identified.1 Implicit in all these is the need for proof that the transaction or sale
actually took place, coupled with the presentation in court of the confiscated prohibited or regulated drug
as evidence.

An examination of the case records show that while the identities of the seller and the buyer and
the consummation of the transaction involving the sale of illegal drug on September 10, 2002 have been
proven by the prosecution through the testimony of PO1 Antonio as corroborated by the testimony of PO1
Jiro, the Court, nonetheless, finds the prosecution evidence to be deficient for failure to adequately show
the essential links in the chain of custody. It is likewise noteworthy that the prosecution failed to present
evidence pertaining to the identity of the police investigator to whom the buy-bust team turned over the
seized item. Although the Request for Laboratory Examination was signed by a certain Santiago for and
in behalf of Police Senior Inspector Anastacio Benzon, it was not shown that he was the same official who
received the subject shabu from the buy-bust team or from the police investigator. A perusal of the
Request for Laboratory Examination and the Chemistry Report reveals that the marking on the plastic
sachet containing the subject shabu was changed to EXHIBIT 1 JBG. The prosecution, however, failed to
disclose the name and identity of the police officer who changed the marking of the specimen. Further,
the prosecution evidence is wanting as to the identity of the person who submitted the specimen to the
PNP Crime Laboratory; as to whether the forensic chemist whose name appeared in the chemistry report
was the one who received the subject shabu when it was forwarded to the crime laboratory; and as to
who exercised custody and possession of the specimen after the chemical examination and before it was
offered in court. Neither was there any evidence adduced to show how the seized shabu was handled,
stored and safeguarded pending its offer as evidence in court.
FRANCISCO IMSON vs PEOPLE OF THE PHILIPPINES

Facts:

On 24 January 2003, a confidential informant arrived at the District Drug Enforcement Unit office
in Langaray, Caloocan City. The confidential informant advised PO1 Gerry Pajares, PO1 Noli Pineda and
other policemen that Imson was selling shabu at Raja Matanda Street, San Roque, Navotas. District Drug
Enforcement Unit Chief P/Supt. Reynaldo Orante formed a team to conduct a buy bust operation,
with Pajares acting as poseur buyer. Pajares, Pineda, the confidential informant, and other policemen
arrived at Raja Matanda Street at around 10:30 p.m. There, they saw Imson talking with Dayao.
Thereafter, they saw Imson giving Dayao a transparent plastic sachet containing white crystalline
substance. Pajares approached the two men and introduced himself. He immediately
apprehended Imson while Pineda ran after Dayao who tried to escape. The policemen confiscated two
plastic sachets containing the suspected shabu. The policemen brought Imson and Dayao to
the Langaray Police Station where Imson and Dayao executed their joint sworn statements and where
PO1 Ariosto B. Rana marked the two plastic sachets with RDS and FIA. The two plastic sachets were
sent to the Philippine National Police - Northern Police Crime Laboratory Office for examination. Both
tested positive for shabu.Third Assistant State Prosecutor Marcos filed two informations dated 27 January
2003 for illegal possession of dangerous drugs against Imson and Dayao.

The RTC convicted Imson and Dayao as their defense of denial, sort of alibi and insinuated claim
of evidence planting was not sustained. The Court of Appeals, upon appeal, did not find merit in their
claim that the policemen failed to conduct a physical inventory of the subject specimen and to photograph
the same which resulted to procedural lapses.

Issue:

Whether or not the two plastic sachets containing shabu were inadmissible in evidence because
the integrity of the chain of custody was impaired.

Ruling:

The Supreme Court answered in the negative. The failure of the policemen to make a physical
inventory and to photograph the sachets containing the shabu does not render the confiscated items as
inadmissible in evidence. This is likewise true as to their failure to mark the sachets at the place of the
arrest. The reason is that even if the procedure expressly stated under RA 9165 is not complied with, the
important thing is that the evidentiary value and integrity of the seized items are preserved, as it will be
utilized in the determination of the guilt of the accused.
HENRY CHING TIU vs PHILIPPINE BANK OF COMMERCE

Facts:

Asian Water Resources Inc applied for a real estate loan with PBCOM to fund its purified water
distribution business. The petitioners, who represented AWRI, submitted a Board Resolution and the loan
was guaranteed by collateral over the property. The loan was approved. Subsequently, AWRI applied for
an additional loan using the same board resolution but not offering any additional collateral. With the
additional loan unsecured, PBCOM required all members of the board to execute a Surety Agreement
signed by all the directors and acknowledged by a notary public. All copies of the Agreement was kept by
PBCOM except for the copy of the notary public and the copy that was submitted to the Records Office of
the Clerk of Court. Sometime after, AWRI informed PBCOM its decision to assign all its properties to the
latter to satisfy its obligation. However, the bank refused the offer and demanded full payment of the loan.
Unable to collect payment, PBCOM filed an action for collection against petitioners. In their Answer, the
petitioners contends that they were not liable because they signed only in their capacities as officers of
the bank. They alleged that the Surety Agreement attached to the complaint was falsified for the reason
that the contract they signed did not contain the phrase, “in his personal capacity.” The counsel of
PBCOM then discovered that the additional phrase does not appear in the original document and it was
only ordered by the bank auditor in accordance to bank standard operating procedure. The notary public
was not informed of this development. PBCOM admitted the mistake but maintains that the petitioners are
still liable as they admitted in their pleadings that they voluntarily executed and signed the Agreement in
its original form. The respondent then invoked liberal construction of the rules to allow them to amend the
complaint. The RTC allowed the substitution of the altered document with the original Surety Agreement.

Issue:

Whether or not the trial court erred in allowing the substitution of the attached Surety Agreement
in the pleading.

Ruling:

The Supreme Court ruled that there is no error to the allowance of the substitution. The Rules of
Court provides that upon the answer of the petitioners of the complaint, the respondent have the right to
amend the complaint, with leave of court. The courts should be liberal in allowing amendments to
pleadings to avoid a multiplicity of suits and in order that the real controversies between the parties are
presented, their rights determined, and the case decided on the merits without unnecessary delay. This
liberality is greatest in the early stages of a lawsuit, especially in this case where the amendment was
made before the trial of the case, thereby giving the petitioners all the time allowed by law to answer and
to prepare for trial. Furthermore, amendments to pleadings are generally favored and should be liberally
allowed in furtherance of justice in order that every case, may so far as possible, be determined on its real
facts and in order to speed up the trial of the case or prevent the circuitry of action and unnecessary
expense. That is, unless there are circumstances such as inexcusable delay or the taking of the adverse
party by surprise or the like, which might justify a refusal of permission to amend.
SPOUSES ANTONIO AND LITICIA VEGA vs SOCIAL SECURITY SYSTEM

Facts:

Magdalena Reyes owned a piece of land in Pilar Village, Las Pinas City and she secured a
housing loan from SSS using the said property as a mortgage. Sometime after, spouses Vega assumed
the obligation and acquired her house and lot as Reyes is planning to emigrate. Reyes and spouses Vega
entered into an agreement wherein the former will execute a deed of assignment of the real property with
assumption of the mortgage and she will update the amortizations before leaving the country. However,
she failed to do it when she left the country but she gave her sister a Special Power of Attorney to convey
the ownership to the subject land. The sister then executed the deed and gave two copies to the spouses
and kept the other. Unfortunately, a flood destroyed their copy of the deed. The spouses Vegas, because
of the failure of Reyes, have to update the amortization on the SSS themselves. Here comes Pilar Dev’t
Corporation. It filed an action for collection of sum of money in the RTC against Reyes for the unpaid loan
which she used to acquire the lot and construction of the house. RTC rendered a decision for Pilar and
issued a writ of execution to satisfy the judgment and the sheriff levied the property in Pilar Village.
Spouses Vegas requested SSS to acknowledge their status of subrogees and updated of the account to
be able them to settle it in full. However, SSS did not reply. Thus, RTC directed the sheriff to proceed the
execution. The spouses filed an action against SSS, the PDC and the sheriff before the RTC of Las
Pinas. The court decided in favor of the spouses, stating that SSS cannot deny the final payment of the
Vegas and deny their assumption of the debt, given that it previously accepted the payment from them.
The spouses were subrogated to the rights of Reyes and they proved it by showing receipts that wherein
they were named as payors. The SSS appealed to the CA and it reversed the decision.

Issue:

Whether or not the Vegas presented sufficient proof that Reyes sold to them the subject property.

Ruling:

The Supreme Court held that the rule that original documents must be presented is not absolute
as secondary evidence can be adduced, when the original has been lost without bad faith on the part of
the party offering it. Here, not only did the Vegas prove the loss of the deed of assignment in their favor
and what the same contained, they offered strong corroboration of the fact of Reyes sale of the property
to them. They took possession of the house and lot after they bought it. Indeed, they lived on it and held it
in the concept of an owner for 13 years before PDC came into the picture. They also paid all the
amortizations to the SSS with Antonio Vegas personal check, even those that Reyes promised to settle
but did not. And when the SSS wanted to foreclose the property, the Vegas sent a managers check to it
for the balance of the loan. Neither Reyes nor any of her relatives came forward to claim the property.
The Vegas amply proved the sale to them.
PEOPLE OF THE PHILIPPINES vs MARIO CASTRO

Facts:

Respondent was charged with Rape against her sister-in-law. According to the testimony of the
victim, the appellant fetched her in her aunt’s house as he told her that her sister was confined in a clinic.
However, instead of bringing her to her sister, the accused led her to an abandoned building and
proceeded to rape her. As to the defense, they presented a Margarita Sangalang to testify. She testified
that at the time of the supposed rape, the accused was at her house for her birthday celebration. He did
not leave the party until after midnight. She knew that he went home as she saw him at his house when
she returned some utensils to the appellant’s mother. The house of the witness is at the back of the
accused’s house. The RTC convicted Castro for the crime of rape.

Issue:

Whether or not the court should give full weight and credence to the testimony of the
complainant.

Ruling:

The Supreme Court ruled that accused-appellant’s contentions relate to the credibility of the
testimony of complainant. We have time and again said that the findings of the trial court pertaining to the
credibility of witnesses are entitled to great respect since it has the opportunity to examine their demeanor
on the witness stand. Unless shown that the trial court overlooked or misunderstood some facts or
circumstances of weight and substance that could affect the result of the case, its findings on questions of
facts will not be disturbed on appeal. We have reviewed the record of the instant case and found nothing
which would warrant a reversal of the trial court’s findings.

Accused-appellant maintains that complainant failed to mention any pumping motion and whether
she was standing or lying down when she was allegedly raped. These matters, however, have no bearing
on the principal question of whether accused-appellant had carnal knowledge of the victim. Besides,
contrary to appellant's contention, complainant testified in no uncertain terms during cross-examination
that she did not willingly lie down but was forced to do so by accused-appellant. Courts usually give
greater weight to the testimony of a girl who is a victim of sexual assault, especially a minor, as in this
case, because no woman would be willing to undergo a public trial and put up with the shame, humiliation
and dishonor of exposing her own degradation were it not to condemn an injustice and have the offender
apprehended and punished.

Nor is there any question that accused-appellant in this case committed rape by means of threat
and intimidation. Being 30 years old and the brother-in-law of complainant, accused-appellant exercised
not only physical superiority, but also moral ascendancy over his 14-year old victim such that his threat to
inflict physical harm on her effectively cowed her into submitting to his lustful designs. In fact, complainant
was aware that accused-appellant had killed someone before which all the more engendered fear in her –
fear that if she did not yield to accused-appellant's demands, he would carry out his threat to kill her.
RIVERA vs COURT OF APPEALS

Facts:

Petitioner filed for the ejectment of the private respondents who allegedly constructed a house in
his property. The MTC ruled in his favor and ordered the private respondents to vacate the premises. On
appeal, the appellate court reversed the decision of the MTC taking into consideration the fact that the
house mentioned was not built on the property of the petitioner, hence there was no cause of action.
Respondent court ruled that the lower courts failed to make a definitive ruling as to the issue whether or
not the house constructed are within private land owned by petitioner or a public land.

Issue:

Whether or not petitioner proved his cause of action.

Ruling:

The Supreme Court ruled in the negative. Basic is the rule in civil cases that the party having the
burden of proof must establish his case by a preponderance of evidence. By preponderance of evidence
is meant simply evidence which is of greater weight, or more convincing than that which is offered in
opposition to it. In the present ejectment case, petitioner has the burden of proving that the houses of
private respondents were located within his titled land. To justify a judgment in his favor, petitioner must
therefore establish a preponderance of evidence on this essential fact. The records support the finding of
the CA that the aggregate of evidence submitted by the parties is insufficient to determine whether the
house was built inside the petitioner’s property. The claim that it is public land is unconvincing because of
the title. The private survey commissioned by the petitioner is likewise unconvincing. When the evidence
of the parties is in equipoise, or when there is a doubt as to where the preponderance of evidence lies,
the party with the burden of proof fails and the petition/complaint must thus be denied.
THE MUNICIPALITY OF CANDIJAY, BOHOL vs COURT OF APPEALS

Facts:

The RTC decided that barrio Pagahat is within the territorial jurisdiction of the plaintiff-
municipality. On appeal, however, the Court of Appeals stated that the trial committed an error in such
declaration because in relying on the evidence presented by the petitioner, the effect of which is that the
Barrios Putlongcam and La Hacienda will also be included in the territorial jurisdiction of the plaintiff when
the said barrios are indisputably part of appellant Alicia’s territory under EO 265. After examination of the
survey plans submitted by the plaintiff and the respondent, the Court of Appeals ruled that both plans
were inadequate to determine the boundary lines between the areas and therefore Barrio Pagahat is not
part of the municipality of Alicia, as it is not mentioned on the law created it, and also not part of Candijay
as their evidence failed to show that it should be included in its territorial jurisdiction.

Issue:

Whether or not the respondent erred in applying the doctrine of equiponderance of evidence for
basing its decision on the evidence that is void, according to the petitioner.

Ruling:

The Supreme Court ruled in the negative. The determination of equiponderance of evidence by
the respondent Court involves the appreciation of evidence by the latter tribunal, which will not be
reviewed by this Court unless shown to be whimsical or capricious; here, there has been no such
showing. The fact remains that, as correctly evaluated by the respondent Court, neither party was able to
make out a case; neither side could establish its cause of action and prevail with the evidence it had.
They are thus no better off than before they proceeded to litigate, and, as a consequence thereof, the
courts can only leave them as they are. In such cases, courts have no choice but to dismiss the
complaints/petitions.
PEOPLE OF THE PHILIPPINES vs ALEXANDER NAVAJA

Facts:

Respondent was convicted for the crime of illegal sale of prohibited substance, marijuana, in
violation of RA 6425. The authorities conducted a buy bust operation to arrest him, however he managed
to elude the arrest. About a year later, his mother instituted a habeas corpus case and there he was
arrested. In his defense, he presented witnesses to prove that he is not the Alexander Navaja who is a
notorious drug pusher, but he is merely his namesake. A witness also testified that the respondent is
engaged in buying and selling of fighting cocks and that the respondent was in Dalaguete, one hour from
Cebu City, at the time of the arrest. The RTC convicted him based on the testimony of a police officer who
arrested him, making a positive identification that he is the one who was selling the marijuana. In his
appeal, he contended that the trial court erred in convicting him as only one of the five policemen who
apprehended him were presented as witness by the prosecution.

Issue:

Whether or not the trial court erred in relying on the testimony of one witness.

Ruling:

The Supreme Court did not agree with the contention of the respondent. We are unable to agree.
There is no rule of evidence which requires the presentation of a specific or minimum number of
witnesses to sustain a conviction for any of the offenses described in the Dangerous Drugs Act. It is the
prosecuting fiscal's prerogative to determine who or how many witnesses are to be presented in order to
establish the quantum of proof necessary for conviction. In this case, the prosecution deemed it sufficient
to present Pfc. Espina alone since any other testimony which would have been given by the other
members of the buy-bust team would be merely corroborative in nature. The non-presentation of
corroborative witnesses does not constitute suppression of evidence and would not be fatal to the
prosecution's case. Besides, there is no showing that the other peace officers were not available to the
accused for the latter to present as his own witnesses. The rule is settled that the adverse presumption
from a suppression of evidence is not applicable when (1) the suppression is not willful, (2) the evidence
suppressed or withheld is merely corroborative or cumulative, (3) the evidence is at the disposal of both
parties and (4) the suppression is an exercise of a privilege. The court, for its part, is not precluded from
rendering a judgment of conviction based solely on the testimony of a single witness as long as such
testimony is found to be credible and satisfies the court that the accused is guilty beyond any reasonable
doubt of the crime charged.
ROBERT LASTRILLA vs RAFAEL GRANDA

Facts:
Rafael Granda is the grandson and legal heir of deceased Rafael and Aurora Granda. The
spouses have ten children and the respondent’s father predeceased the spouses. During the lifetime of
Aurora, she owned several parcels of land in Tacloban and three of those lots were the subject of the
present case. After her death, her grandson discovered that the titles of the lots were already cancelled
and were named to the petitioner’s siblings. It was alleged that the properties were sold to the petitioner’s
siblings for P18, 800,000. Rafael verified the report by requesting from the Register of Deeds copies of
the deed of absolute sale. He suspected that the signatures of his grandparents were forged and seek
confirmation from the PNP. After examination, it was concluded by the PNP Crime Laboratory that there
was indeed a forgery of the signatures.

Issue:

Whether or not there is a probable cause for falsification of public documents.

Ruling:

The High Court affirmed the findings of the trial court. It is shown in the record that Robert
Lastrilla signed as an instrumental witness to the deeds of absolute sale. He therefore attested that he
was present when the spouses Granda signed the deeds. The investigating prosecutor found probable
cause as it believed that the signatures are falsified based on the findings of the PNP Crime Laboratory
that the said signatures were forged. Also, one of the servants of Aurora testified that during the time of
the purported sale, Aurora was already very sick and incapable to do anything and have lapses as to her
memory. From this pieces of evidence, it is clear that a prima facie case for falsification exist against the
petitioner.
PHILIPPINE AIRLINES vs COURT OF APPEALS AND PANTEJO

Facts:

Private respondent Pantejo boarded a PAL plane in Manila and landed in Cebu City wherein he
will take a connecting flight to Surigao City. However because of the typhoon, the connecting flight was
cancelled. To accommodate the needs of the stranded passengers, they handed out initially P100, then
another P200 as it was expected that they will stay there for two days. Pantejo requested PAL that
instead of giving him the cash, the latter should just pay his hotel expenses for his stay but this was
refused by PAL. Respondent then shared a room with a co-passenger with a promise that he will pay his
share of the expenses upon reaching Surigao. Thereafter, when the flight was resumed, Pantejo learned
that the Airline reimbursed the hotel expenses of his co-passengers and at this point he informed Jereza,
the Manager for Departure Services, that he will sue the Airlines. Jereza offered to pay Pantejo but the
latter refused due to the ordeal and anguish he suffered. The RTC of Surigao rendered judgment in favor
of Pantejo in the action for damages filed against PAL. On appeal, the Appellate Court affirmed the
decision of the trial court.

Issue:

Whether or not it was proven that petitioner acted in bad faith thus making it liable for damages.

Ruling:

The Supreme Court stated that the bad faith was existing due to the fact that contrary to the claim
of the petitioners that cash was given because of the non-availability of the rooms, evidence shows that
the hotel had plenty of rooms available. It was also shown in the records that the P300 given to the co-
passengers were not refund for the plane ticket but it was a reimbursement for the hotel expenses. It is
likewise not denied that respondent was only informed of the reimbursements by his co-passenger as the
latter obtained reimbursement herself. And petitioner offered to pay Pantoja P300 only after he confronted
the manager about the discrimination committed against him. It must be stressed that these factual
findings, which are supported by substantial evidence, are binding, final and conclusive upon this Court
absent any reason, and we find none, why this settled evidential rule should not apply. What makes
petitioner liable for damages in this particular case and under the facts obtaining herein is its blatant
refusal to accord the so-called amenities equally to all its stranded passengers who were bound for
Surigao City. No compelling or justifying reason was advanced for such discriminatory and prejudicial
conduct.
EDUARDO BUGHAW, JR. vs. TREASURE ISLAND INDUSTRIAL CORPORATION

Facts:

Petitioner was a production worker employed by the respondent. He was implicated by a co-
worker, Loberanes, when the latter was apprehended by the police for committing a crime while in
possession of shabu. Consequently, the respondent served a Memo for Explanation to petitioner requiring
him to explain within 120 hours his position as to the statement made by Loberanes and why he should
not be subjected to a disciplinary action. He was also directed to appear at the respondent’s legal counsel
for a hearing. However, petitioner did not comply with the memo and did not attend with the hearing. The
respondent then sent a second letter directing him to attend an administrative hearing but petitioner again
did not show up. Thus, a third letter was sent informing him that he was terminated from service for using
illegal drugs within company premises during working hours and for refusal to attend the administrative
hearing and for explaining his position on the matter. Petitioner then filed an illegal dismissal case and the
Labor Arbiter rendered a decision in favor of the petitioner stating that respondent failed to present
substantial evidence to establish the charge against Bughaw. Apart from the statements made by
Loberanes, no other corroborating proof was presented to justify the dismissal. The decision was affirmed
by the NLRC. But the Court of Appeals reversed the decision.

Issue:

Whether or not there is substantial evidence to support the dismissal of Bughaw.

Ruling:

Yes, there is substantial evidence therefore the dismissal is not illegal. The Supreme Court ruled
that the statements of Loberanes which was given to the police during the investigation is evidence that
can be considered by the respondent as basis against the petitioner. Likewise, the petitioner failed to
controvert said evidence. Records also show that petitioner ignored the two letters requesting for his
explanation and appearance to the hearings to personally present his side regarding the situation. His
inaction and omission prevented him to present evidence to refute the charge against him. Thus, the
respondent cannot be faulted in relying on the statement of Loberanes as the only evidence and basis for
the illegal dismissal for a just cause.
MANDARIN VILLA, INC., vs COURT OF APPEALS AND CLODUALDO DE JESUS

Facts:

Private respondent hosted a dinner for his friends at the restaurant of the petitioner located in
Greenhills, Mandaluyong City. When the waiter handed him the bill, De Jesus paid using his BANKARD
credit card. However, the waiter returned informing him that his credit card has expired. Private
respondent denied this and told him that the expiration indicated in the card is for more than a year. De
Jesus and two other guests approached the cashier and the latter swiped again the card, but it was again
denied due to supposed expiration. A guest then remarked, “Clody, may problema ba? Baka kailangang
maghugas na kami ng pinggan?" Private respondent then produced his BPI credit card which was
accepted and honored by the cashier. Thereafter, De Jesus filed an action for damages against the
petitioner. The trial court ruled in his favor. Petitioner appealed to the Court of Appeals and the appellate
court affirmed the decision. Hence the appeal to the Supreme Court.

Issue:

Whether or not the proximate cause is the negligence of the private respondent in not bringing
sufficient cash.

Ruling:

No, the Supreme Court found this argument devoid of merit. While the fact that De Jesus was not
carrying sufficient cash at the time, it cannot be considered as the proximate cause of the damage. The
Court took judicial notice of the current practice among major establishments of accepting payments by
means of credit cards in lieu of cash. As such, in cases when the credit card is rejected, the cashier must
check the expiration indicated in the card itself and if it is not yet expired, then the card must be accepted.
This procedure was outlined in the Point of Sale Guidelines. Hence, petitioner did not use the reasonable
care and caution which an ordinary prudent person would have used in the same situation and as such,
petitioner is guilty of negligence.
THE PEOPLE OF THE PHILIPPINES vs ZAIDA KAMAD

Facts:

The Drug Enforcement Unit of the PNP in Fort Bonifacio, Taguig received an information from an
asset that a certain Zaida was engaged in illegal sale of shabu. The Taguig Police then formed a buy bust
team to apprehend the supposed drug dealer. Upon seeing Zaida and her boyfriend, the asset and the
poseur buyer approached them and bought shabu and handed over the marked money. After the signal,
the other arresting officers immediately arrested Zaida and her boyfriend and took them to their office for
investigation. They marked the confiscated sachets of shabu and then sent to PNP Crime Laboratory for
qualitative examination where it was confirmed as shabu. However, the defense of Zaida and her
boyfriend is that they were framed up by the police. The RTC convicted them for the violation of
Dangerous Drug Act. Upon appeal, the Court of Appeals affirmed the decision of the lower court, brushing
aside the minor inconsistencies in the uncertainness of the witness in the buy bust operation.

Issue:

Whether or not the chain of custody in handling the seized drug was strictly complied with.

Ruling:

The Supreme Court held that there is serious lapses in the chain of custody in handling the
seized drug that resulted in the prosecution’s failure to properly identify the shabu offered in evidence
which is the same as that was confiscated from the accused. The prosecution failed to establish the
unbroken link in the chain of custody as there is insufficient evidence to the necessary links from the
seizure of the drug until its presentation in court. As a method of authenticating evidence, the chain of
custody rule requires that the admission of an exhibit be preceded by evidence sufficient to support a
finding that the matter in question is what the proponent claims it to be. It would include testimony about
every link in the chain, from the moment the item was picked up to the time it is offered into evidence, in
such a way that every person who touched the exhibit would describe how and from whom it was
received, where it was and what happened to it while in the witnesses' possession, the condition in which
it was received and the condition in which it was delivered to the next link in the chain. These witnesses
would then describe the precautions taken to ensure that there had been no change in the condition of
the item and no opportunity for someone not in the chain to have possession of the same. It is ruled, too,
that the discrepancy in the prosecution evidence on the identity of the seized and examined shabu and
that formally offered in court cannot but lead to serious doubts regarding the origins of the shabu
presented in court. This discrepancy and the gap in the chain of custody immediately affect proof of the
corpus delicti without which the accused must be acquitted.
PEOPLE OF THE PHILIPPINES vs EDGARDO FERMIN AND JOB MADAYAG, JR.

Facts:

A police asset informed the La Loma Police Station that two men identified as Job Madayag and
Edgardo Fermin are engaged in the illegal sale of drugs. Acting upon the information, Senior Police
Inspector Villanueva created a team to conduct a buy bust operation. The team is composed of police
officers and PO2 Ibasco will act as poseur buyer. The buy bust team together with the informant went to
the target area of operation and approached Madayag to conduct the sale. After paying the marked
money, Madayag called Fermin from inside the house and the latter gave three sachets of shabu. PO2
Ibasco examined one of the sachets and when he was certain that it contains shabu, he did the pre-
arranged signal to arrest the respondents. The trial court found both guilty beyond reasonable doubt of
the crime charged. The Court of Appeals agreed with the decision of the trial court.

Issue:

Whether or not the testimonies of the police officers create doubt as to the validity of the buy bust
operation.

Ruling:

The Supreme Court ruled that they are not in agreement with the ruling of the lower courts and
acquits the respondents. We have repeatedly held that the trial courts evaluation of the credibility of
witnesses and their testimonies is entitled to great respect and will not be disturbed on appeal. However,
this is not a hard and fast rule. We have reviewed such factual findings when there is a showing that the
trial judge overlooked, misunderstood, or misapplied some fact or circumstance of weight and substance
that would have affected the case. Cognate to this, while the entrenched rule is that the assessment of
witnesses and their testimonies is a matter best undertaken by the trial court which had the opportunity to
observe the demeanor, conduct or attitude of the witnesses, the findings of the lower court on this point
will be reversed on appeal, if it overlooked substantial facts and circumstances which, if considered,
would materially affect the result of the case. This Court believes that on application of the rule to the
testimonies of the prosecution witnesses, the exception to the high value of the trial courts findings
surfaces. We find irreconcilable conflicts in the recollections about the principal factum probandum which
is the buy-bust itself. The varying versions about the pre-operation, the illegal sale itself and the
immediately preceding actions put doubts about what really transpired on 9 July 2003. The clear
inconsistencies on important points cannot be disregarded where the issue is ones liberty. The
contradictory statements of the main prosecution witnesses need not even be appreciated together with
the defense position. The proof of the supposed buy-bust operation rests exclusively on the prosecution.
JESSE LUCAS vs JESUS LUCAS

Facts:

Petitioner Jesse Lucas filed a Petition to Establish Filiation with a Motion for the Submission of
Parties to DNA Testing before the RTC. He alleged that he is the son of Jesus Lucas who was acquainted
with his mother in Manila. When respondent Jesus Lucas leaned of the petition, he filed a Special
Appearance and Comment stating that the petition is adversarial in nature and he should be served
summons. Jesse then filed a Motion to Try and Hear the Case which was granted by the RTC but Jesus
filed a Motion for Reconsideration arguing that DNA testing cannot be conducted based only on the
allegations that he is the father of Jesse. The RTC dismissed the case and held that Jesse failed to
establish compliance with the four procedural aspects for a paternity action: a prima facie case,
affirmative defenses, presumption of legitimacy and physical resemblance between the putative father
and child. This prompted Jesse to file a Motion for Reconsideration which the RTC granted. A new
hearing was scheduled where the RTC held that ruling on the grounds relied upon by Jesse for filing the
instant petition is premature considering that a full-blown trial has not yet taken place. Jesus filed a Motion
for Reconsideration which was denied by the RTC. He then filed a petition for certiorari with the Court of
Appeals (CA). The CA ruled in favor of Jesus, it noted that Jesse failed to show that the four significant
aspects of a traditional paternity action had been met and held that DNA testing should not be allowed
when the petitioner has failed to establish a prima facie case.

Issue:

Whether a prima facie  showing is necessary before a court can issue a DNA testing order

Ruling:

Yes, but it is not yet time to discuss the lack of a pima facie case vis-à-vis the motion for DNA
testing since no evidence has, as yet, been presented by petitioner. Misapplication of Herrera v. Alba by
the Regional Trial Court and the Court of Appeals. The statement in Herrera v. Alba that there are four
significant procedural aspects in a traditional paternity case which parties have to face has been widely
misunderstood and misapplied in this case. A party is confronted by these so-called procedural aspects
during trial, when the parties have presented their respective evidence. They are matters of evidence that
cannot be determined at this initial stage of the proceedings, when only the petition to establish filiation
has been filed. The CA’s observation that petitioner failed to establish a prima facie case is herefore
misplaced. A prima facie case is built by a party’s evidence and not by mere allegations in the initiatory
pleading.
ONG CHIA vs REPUBLIC OF THE PHILIPPINES

Facts:

Petitioner Ong Chia filed a verified petition to be admitted as a Filipino citizen under the Revised
Naturalization law. He presented witnesses to corroborate his testimony that he was born in China and
arrived in Manila to engage in a business and eventually married a Filipina where he have four children.
With the said testimony, the Prosecutor asked the trial court to admit the Philippine citizenship of the
petitioner and wished not to present evidence to refute the testimony. The trial court allowed and admitted
the petition. The State, as represented by the Solicitor General, appealed the decision as petitioner failed
to disclose his other name in his petition; he also did not indicate all his former addresses; he failed to
conduct himself in a proper manner as it was discovered that he lived without marriage with his wife for 24
years before marrying her; and, he does not have a lucrative business or trade or profession, as required
by law. The Stated further alleged that petitioner failed to support his petition with the appropriate
documentary evidence. The Court of Appeals reversed the decision of the trial court. Ong Chia appealed
the said decision, contending that the appellate court erred in considering the documents which were
merely attached by the State to its appellant’s brief. Invoking the Rules of Court, he said that such
documents were merely scraps of paper devoid of evidentiary value as it were not formally offered as
evidence.

Issue:

Whether or not the argument of the petitioner is tenable.

Ruling:

The rule on formal offer of evidence is clearly not applicable to a petition for naturalization
proceedings. Petitioner failed to note Rule 143 of the Rules of Court which provides that the rules shall
not apply to land registration, cadastral and election cases, naturalization, and insolvency proceedings,
and other cases not herein provided for, except by analogy or in a suppletory character and whenever
practicable and convenient. The rule on formal offer of evidence (Rule 132, §34) invoked by petitioner is
clearly not applicable to the present case involving a petition for naturalization. The only instance when
said rules may be applied by analogy or suppletorily in such cases is when it is "practicable and
convenient." That is not the case here, since reliance upon the documents presented by the State for the
first time on appeal, in fact, appears to be the more practical and convenient course of action considering
that decisions in naturalization proceedings are not covered by the rule on res judicata. Consequently, a
final favorable judgment does not preclude the State from later on moving for a revocation of the grant of
naturalization on the basis of the same documents.
GOVERNMENT SERVICE INSURANCE SYSTEM vs DINNAH VILLAVIZA, et al.

Facts:

Winston Garcia, the President and General Manager of GSIS, filed charges against the
respondents for Grave Misconduct and/or Conduct Prejudicial to the Best Interest of the Service. The said
violation arose from the actions of the respondents of wearing red shirts and marched outside the office of
the Investigation Unit in a mass rally in support of their union leader. Respondents submitted a letter-
explanation to clarify their position. According to them, the demonstration was not planned and it was a
spontaneous reaction on their part upon learning that their union leader was at the office of the
Investigation Unit as they wanted to support him as well as the fact that the hearing might affect them.
Garcia then issued a decision whereby finding the respondents guilty of the charges and meting out a
penalty of one year suspension plus accessory penalties. Upon appeal, the Civil Service Commission
found the respondents guilty of the lesser offense of violation of Reasonable Office Rules and
Regulations and reduced their penalties. The Commission held that the respondents were not denied of
due process but there was no substantial evidence to hold them guilty of the offense charged. The action
of the respondents of going to the office of the IU, wearing of red shirts and witness a public hearing are
not sufficient to be considered constitutive of the offense charged. It can only be considered as the
exercise of their freedom of expression. Garcia filed a motion for reconsideration but denied. He then filed
a petition for review with the Court of Appeals, which upheld the decision of the CSC. The case was then
appealed to the Supreme Court.

Issue:

Whether or not the provisions of the Rules of Court will apply suppletorily in an administrative
proceeding as to the effect when a party failed to deny the allegations in the complaint and failed to file a
responsive pleading.

Ruling:

The Court finds no merit in the petition. Petitioners primarily question the probative value
accorded to respondents’ letters of explanation in response to the memorandum of the GSIS-IU
Manager.  The respondents never filed their answers to the formal charges. The petitioners argue that
there being no answers, the allegations in the formal charges that they filed should have been deemed
admitted pursuant to the Rules of Court. The Court does not subscribe to the argument of the
petitioners. The Petitioner’s own rules provide that if the respondent failed to file an answer within five
days, he shall be considered to have waived his right to file an answer and judgment may be rendered
against him based on facts and evidence submitted by the prosecution. It is clear from their rules that
respondent’s failure to file his answer will only constitute as a waiver to file an answer and not to consider
the charges deemed admitted. While the Rules provided that it can be applied suppletory, this only means
it will be applied when there is insufficiency in the applicable rules. There is no deficiency as the rules of
the GSIS are explicit in case of failure to file answer.
RICO ROMMEL ATIENZA vs BOARD OF MEDICINE (BOM) and EDITHA SIOSON

Facts:

Private respondent underwent a kidney operation in Rizal Memorial Center after diagnostic
laboratory shows that her left kidney was not functioning. The operation was conducted by four
physicians, one of which is the petitioner Atienza. The operation ended in disaster as it was discovered
that the doctors removed her fully functioning right kidney instead of the left kidney. The husband of the
private respondent filed a complaint against the four doctors before the Board of Medicine due to their
gross negligence and incompetence. Editha presented four certified photocopies as her documentary
evidence to show that her kidneys are in the correct position and location during the time of the operation.
The petitioner filed an objection with respect to the formal offer of evidence, alleging that it is inadmissible
as well as incompetent because the same are mere photocopies. Further, he alleged that the said
evidence were not properly identified and authenticated, which violates the best evidence rule and his
substantive rights and such evidence were hearsay.

Issue:

Whether or not the evidence presented were inadmissible.

Ruling:

No. To begin with, rules of evidence are not strictly applied in proceedings before administrative
bodies such as the BOM. Although trial courts are enjoined to observe strict enforcement of the rules of
evidence, in connection with evidence which may appear to be of doubtful relevancy, incompetency, or
admissibility, the court have held that it is the safest policy to be liberal, not rejecting them on doubtful or
technical grounds, but admitting them unless plainly irrelevant, immaterial or incompetent, for the reason
that their rejection places them beyond the consideration of the court, if they are thereafter found relevant
or competent; on the other hand, their admission, if they turn out later to be irrelevant or incompetent, can
easily be remedied by completely discarding them or ignoring them.

Second, petitioner’s insistence that the admission of Editha’s exhibits violated his substantive
rights leading to the loss of his medical license is misplaced. As pointed out by the appellate court, the
admission of the exhibits did not prejudice the substantive rights of petitioner because, at any rate, the
fact sought to be proved thereby, that the two kidneys of Editha were in their proper anatomical locations
at the time she was operated on, is presumed under Section 3, Rule 131 of the Rules of Court. The fact
sought to be established by the admission of Editha’s exhibits, that her kidneys were both in their proper
anatomical locations at the time of her operation, need not be proved as it is covered by mandatory
judicial notice. Unquestionably, the rules of evidence are merely the means for ascertaining the truth
respecting a matter of fact. Thus, they likewise provide for some facts which are established and need not
be proved, such as those covered by judicial notice, both mandatory and discretionary. Laws of nature
involving the physical sciences, specifically biology, include the structural make-up and composition of
living things such as human beings. In this case, we may take judicial notice that Editha’s kidneys before,
and at the time of, her operation, as with most human beings, were in their proper anatomical locations.
NOVER BRYAN SALVADOR vs PEOPLE OF THE PHILIPPINES

Facts:

Spouses Ernesto and Margarita Zuiga went to a wake with their daughter Marianne while their
two other daughters, Arlene and Mary Ann stayed at home, the latter with her husband Nover Salvadord
and their new born child. Nover Salvador went to a party afterwards and returned home with his friend
Eduardo Palomares to get some karaoke tapes that will be used to the party. They went back to the party
and Nover returned about midnight. Spouses Zuiga with daughter Marianne returned early morning of the
next day and the latter proceeded to her room shared with Arlene and to her horror, she saw Arlene dead
due to stab wounds. After seeing the body the Spouses Zuniga went to the room of Mary Ann and Nover.
Mary Ann went to the room to see Arlene while Nover stayed at the sala and began crying, saying that he
was innocent. The police came and investigated the scene. They concluded that there was no forcible
entry, no valuables were missing and the only blood that was found was Arlene’s. They discovered in the
kitchen petitioner’s underwear, shirt and short pants. They also found hair strands on the bed of Arlene.
These pieces of evidence were then delivered to the Crime Laboratory for examination. It was found that
the shirt and underwear were positive with type O human blood, matching with Arlene’s. NBI Forensics
conducted a DNA Analysis which yielded positive results of the presence of human DNA in petitioner’s
gray shirt, the strand of hair found on Arlene’s bed and the result of the buccal swab of petitioner. A case
was filed against petitioner for homicide. It was established as ill motive when known that petitioner was
peeping through the bathroom and Arlene’s room on two instances when Arlene was taking a bath and
she was inside the room. The trial court bound petitioner guilty and it was later affirmed by the Court of
Appeals.

Issue:

Whether or not the Court of Appeals erred in affirming the decision of the trial basing only the
decision on circumstantial evidence.

Ruling:

No. The Supreme Court held that direct evidence is not the only matrix wherefrom a trial court
may draw its conclusion and finding of guilt, as circumstantial evidence may suffice provided it complied
with the requirements under the law. Circumstantial evidence is that evidence which proves a fact or
series of facts from which the facts in issue may be established by inference. Conviction based on
circumstantial evidence can be upheld, provided that the circumstances proven constitute an unbroken
chain which leads to one fair and reasonable conclusion that points to the accused, to the exclusion of all
others, as the guilty person. In the present case, both the trial and appellate courts considered these
pieces of evidence in finding petitioner’s guilt: 1) the non-employment of force in entering the scene of the
crime; 2) no missing personal belongings; 3) the absence of bloodstains in other parts of the house
except Arlene’s room; 4) petitioner’s ownership of a balisong, the same weapon used in stabbing the
victim; 5) the presence of type "O" human blood on petitioner’s T-shirt and briefs; 6) the positive result of
the DNA analysis using the bloodstains found in petitioner’s shirt and briefs; and 7) petitioner’s unusual
behavior after the discovery of the victim’s lifeless body. Section 4, Rule 133 of the Rules of Court,
provides that circumstantial evidence is sufficient for conviction if the following requisites are complied
with: (1) There is more than one circumstance; (2) The facts from which the inferences are derived are
proven; and (3) The combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt. In view of the foregoing, petition is denied and the petitioner was correctly convicted of
homicide.

PEOPLE OF THE PHILIPPINES vs JESSIE VILLEGAS MURCIA

Facts:

Murcia was having a drinking session with his cousin Herminio and two brothers in law in front of
their house in Bauang, La Union. Sometime after, Murcia and Herminio had an argument with respect
with the manner of caring of Felicidad Quilantes, Murcia’s mother. Murcia went inside the house to get a
bolo and emerged to attack Herminio but the latter managed to escape from him. After they were pacified,
they resumed drinking. A few minutes later, one of the brothers in law named Ricky noticed that smoke
was coming out from the room of Murcia. As he was about to enter the room, he witnessed Murcia
stabbing Felicidad and Alicia. As for Herminio, he also noticed the smoke and peeped through the window
and saw that Murcia was burning some clothes in the sala. Appellant testified that while he admits to the
crime of frustrated homicide against Alicia, he denies setting the house on fire. He questions the
credibility of the witnesses especially Herminio as the latter harbors ill feeling against him for chasing
Herminio with bolo. He further contends that the witnesses failed to prove the identity of the perpetrator.
The Solicitor General, on the other hand, banks on circumstantial evidence as relied by the trial court.

Issue:

Whether or not Murcia can be convicted even in the absence of direct evidence against him.

Ruling:

Yes. The Supreme Court ruled that direct evidence is not the sole means of establishing the guilt
of the accused beyond reasonable doubt. Established facts that form a chain of circumstances can lead
the mind intuitively or impel a conscious process of reasoning towards a conviction. The Rules of Court
and jurisprudence have recognized that the accused may be convicted beyond reasonable doubt with the
use of circumstantial evidence.

Section 4, Rule 133 of the Rules of Court, provides that circumstantial evidence is sufficient for
conviction if the following requisites are complied with: (1) There is more than one circumstance; (2) The
facts from which the inferences are derived are proven; and (3) The combination of all the circumstances
is such as to produce a conviction beyond reasonable doubt. Appellant was last seen inside the house
before the fire started. Eulogio Quilantes, the owner of the house, and Ricky saw smoke emanating from
the room of appellant. Herminio testified that he saw appellant burning clothes in his room. Appellant then
went on a stabbing rampage while the house was on fire. While nobody directly saw appellant burn the
house, these circumstances would yield to a logical conclusion that the fire that gutted eight (8) houses
was authored by appellant.
ROMMEL BRIONES vs PEOPLE OF THE PHILIPPINES

Facts:

S/G Molina and S/G Gual were security guards of BF Homes Northwest, Paranaque City.
On the night of January 6, 1998, they noticed Romulo Bersamina was being mauled by four individuals,
one of whom was petitioner Rommel Briones and another was identified as his brother, Vicente Briones.
Both were also residents of BF Homes. The security guards approached them to intervene in the
altercation and it was at this point that S/G Molina lost his firearm to Rommel Briones. It was unclear
whether the former lost it due to accompanying violence or intimidation exerted by the latter. Briones,
however denied having participation in the incident and claimed that he was in his house during that time.
The RTC rendered a decision convicting Briones of simple theft under the Revised Penal Code. The trial
court relied on the positive testimony of S/G Gual and rejected the defense of denial and alibi of the
petitioner. According to the trial court, no robbery was committed as there was no violence and
intimidation which were important elements to robbery. S/G Gual merely testified that Briones grabbed the
firearm of Molina. Briones appealed the decision to the Court of Appeals. He contends that the trial court
erred in basing its decicion solely on the testimony of S/G Gual who was not present at the scene thus did
not see what really happened. The appellate court, however, ruled that robbery was indeed committed.
Violence and intimidation attended the taking of the firearm when Briones approached S/G Molina.
Briones then filed a petition for review on certiorari to the Supreme Court.

Issue:

Whether or not S/G Gual was a credible witness.

Ruling:

Yes. In this regard, SC gave special significance to the RTCs unique position in assessing the
credibility of witnesses, as the RTC has the unrestricted opportunity to observe firsthand the conduct and
demeanor of witnesses at the trial. Unless the trial judge plainly overlooked certain facts whose substance
and value may affect the result of the case, SC respect his assessment of the credibility of the witnesses.
S/G Gual gave clear and precise answers; no inconsistencies existed materially affecting their veracity.
Neither was it shown that S/G Gual was driven by any improper motive to falsely testify against Briones.
As S/G Gual is a credible eyewitness to the incident, there is no reason to doubt that he was with S/G
Molina when the incident happened, and saw all the incidents of the crime.