Case Digest

Submitted by: Matthew Gary Deleverio Hinoguin

Block: B

1. 94 Phil 534
Albino Cunanan Et al.
March 18,1954

Facts:
The "Bar Flunkers' Act of 1953," officially known as Republic Act Number
972, was passed by Congress. According to this law, the Supreme Court
proceeded to admit candidates to the bar who had achieved an average score of
72 percent, but this requirement was raised to 75 percent. Following the law's
enactment, numerous postwar candidates who had previously failed filed
petitions for bar admission, citing its provisions. Some also submitted requests
for the reevaluation of their examination papers, using the same law as an
additional basis for admission. There were also individuals who simply sought a
reconsideration of their grades without explicitly referencing the law. In order to
ensure fairness to all petitioners, the court initially reviewed reconsideration
requests, regardless of whether Republic Act No. 972 had been invoked.

Issues:
Whether or not the R.A No. 972 is constitutional.

Ruling:
It is not constitutional. Section 2 was ruled unconstitutional because it had
a fundamental flaw, it was not covered by the Act's title. According to the title, the
Act should only apply to individuals who failed the bar exams from 1946 to 1955.
However, Section 2 attempted to establish a permanent system without a
specified duration. Additionally, it was invalidated because it permitted partial
passing, failing to recognize that laws and legal principles evolve over time.

2. G.R No. L-52245

95 SCRA 392
Dumlao vs COMELEC
January 22, 1980

Facts:
Patricio Dumlao, the former Governor of Nueva Vizcaya, had already
concluded his term and was receiving retirement benefits. In 1980, he submitted
his candidacy for reelection to the same position. During this time, Batas
Pambansa Blg. 52 was passed. This law stipulated, among other things, that
individuals who had retired from public office, such as Dumlao, were not qualified
to run for office again. Dumlao challenged the constitutionality of this law, arguing
that it constituted discriminatory legislation and thus violated the principle of
equal protection.

Issues:
Whether or not BP Blg. 52 is constitutional.

Ruling:
BP Blg. 52 is not constitutional. The argument challenging the
compatibility of BP. Blg. 52 with the principle of equal protection lacks merit. The
constitutional assurance of equal protection under the law allows for reasonable
classification. If these groupings are grounded in rational and actual distinctions,
 it is permissible to treat and regulate one group differently from another. In the
context of public service, employees who are 65 years old have been
appropriately classified differently from their younger counterparts. Those
reaching this age are subject to mandatory retirement, whereas younger
employees do not face compulsory retirement.

3. G.R. No. L-33517

56 SCRA 477
PHILCONSA vs. Villareal
March 29, 1974

Facts:
The petitioner, the Philippine Constitution Association, along with other
delegates to the 1971 Constitutional Convention, filed a mandamus proceeding
on May 15, 1971. They requested a writ ordering certain officials, including
Cornelio T. Villareal, the Speaker of the House of Representatives, to inspect and
examine relevant books, records, vouchers, and papers of the House of
Representatives. These documents were related to the alleged transfer of P26.2
million from various executive offices to the House of Representatives and the
original allocation of P39 million for the 1969-1970 fiscal year.

The Supreme Court issued a resolution on May 19, 1971, requiring the
respondents to file an answer to the mandamus petition within 10 days and not to
move for its dismissal.

On June 16, 1971, respondents filed an answer and a motion to dismiss

the suit, citing several grounds, including lack of jurisdiction due to the separation
of powers, absence of a cause of action, lack of legal standing to sue, nonjoinder
of indispensable parties, and the potential negative consequences of the lawsuit.

Subsequent legal actions included a reply by petitioners on June 26, 1971,

a rejoinder by respondents on June 28, 1971, a surrejoinder by respondents on
July 6, 1971, and a reply to the surrejoinder on the same day. The case
proceeded to a hearing on August 4, 1971.

Issues:
Whether or not the petitioners, including the Philippine Constitution
Association and delegates to the 1971 Constitutional Convention, have the legal
standing and cause of action to file a mandamus proceeding

Ruling:
The legal issues raised in this case need not be addressed because as
per the ruling in the case of Philippine Constitution Association, Inc. v. Gimenez,
decided on February 28, 1974, this type of lawsuit has become moot and
academic due to the enactment of the current Constitution and the subsequent
dissolution of the House of Representatives. It's worth noting that the current
Constitution explicitly provides for public access to the records and books of
accounts of the National Assembly in accordance with the law. Additionally, these
books are subject to auditing by the Commission on Audit, which must annually
publish itemized expenditures for each member of the house.

4. G.R No. L-21450

23 SCRA 29
Tijam vs. Sibonghanoy
April 15, 1968

Facts:
 Spouses Tijam sued spouses Sibonghanoy to recover P1,908.00 with
legal interest and costs. Initially, a writ of attachment was issued but later
dissolved when the defendants and Manila Surety and Fidelity Co., Inc. filed a
counter-bond.

The court ruled in favor of the plaintiffs, and after the decision became
final and executory, a writ of execution was issued against the defendants. Since
the writ couldn't collect the judgment amount, the plaintiffs tried to execute the
Surety's bond.

Surety objected, citing reasons such as failure to prosecute and no

demand for payment under the judgment. After a proper demand, the plaintiffs
filed a second motion for execution against the counterbond, which was granted.

Surety tried to quash the writ, arguing it lacked the required summary
hearing per Section 17 of Rule 59 of the Rules of Court. The court denied this,
and Surety appealed to the CA, which upheld the decision.

Later, Surety asked for more time to file a motion for reconsideration,
which was granted. Two days afterward, Surety filed a motion to dismiss,
claiming the court (CFI) had no jurisdiction due to Republic Act No. 296, which
put cases with a subject matter value under P2,000.00 under the exclusive
jurisdiction of inferior courts.

The CA requested the plaintiffs to respond to the motion to dismiss, but

they didn't.

Issues:
Whether or not Surety is barred from raising the jurisdictional issue by laches.

Ruling:
Yes, a party can be estopped or prevented from raising a legal issue in
various ways and for different reasons. These include estoppel in pais, estoppel
by deed or record, and estoppel by laches. Laches, in a broad sense, refers to
the failure or neglect to take action within a reasonable time, implying either
abandonment or refusal to assert a right due to negligence or omission.

In this case, it is evident that the Surety had the opportunity to question
the jurisdiction of the CFI of Cebu, given the amount involved, which was under
the jurisdiction of inferior courts as per the prevailing law. However, the Surety
did not raise this issue. Instead, at various stages of the proceedings in both the
trial court and the Court of Appeals, the Surety actively sought relief from these
courts and presented its case for a final decision on its merits.

It was only after an adverse decision by the Court of Appeals that the
Surety raised the jurisdictional question. If such behavior were accepted, it would
render all the proceedings in this case, which began on July 19, 1948, pointless,
forcing the judgment creditors to go through the legal process once again.

5. G.R No. L-9396

99 Phil 738
Manila Motor Company Inc. vs Manuel T. Flores
August 16, 1956

Facts:
In May 1954, Manila Motor Company initiated legal proceedings in the
Municipal Court of Manila to recover the sum of P1,047.98 from Manuel T. Flores.
 This amount represented outstanding chattel mortgage installments due in
September 1941. The defendant raised the defense of prescription, arguing that
the time elapsed from 1941 to 1954 had rendered the claim invalid.
Consequently, the complaint was dismissed at the municipal court level.

However, upon appeal, the Court of First Instance took a different view,
supporting the plaintiff's argument that the moratorium laws had halted the ticking
of the prescriptive period. By deducting the time during which these laws were in
effect, which amounted to three years and eight months, the court determined
that the ten-year limitation had not expired when the plaintiff filed the collection
suit in May 1954. Therefore, the Court of First Instance ordered the case to be
sent back to the municipal judge for a trial on the merits. The defendant
subsequently filed an appeal against this decision.

Issues:
Whether or not the moratorium laws did not have the effect of suspending the
period of limitations because they were unconstitutional. (based on Ruther vs
Esteban case)

Ruling:
The court ruled in favor of the petitioners. Despite the previous ruling in
the Ruther vs. Esteban case, declaring the unconstitutionality of the moratorium
law, there have been numerous cases in which courts, driven by fairness, have
made exceptions or tempered its impact. This is because the existence of a
statute before such a declaration carries practical consequences that cannot be
simply disregarded.

6. G.R No. 47800

70 Phil 726
Calalang vs Williams Et al.
December 2, 1940

Facts:
Maximo Calalang, a private citizen, filed a writ of prohibition against the
following respondents: A. D. Williams (Chairman of the National Traffic
Commission), Vicente Fragante (Director of Public Works), Sergio Bayan (Acting
Secretary of Public Works and Communications), Eulogio Rodriguez (Mayor of
the City of Manila), and Juan Dominguez (Acting Chief of Police of Manila).

The petition arises from the restriction on animal-drawn vehicles traveling along
Rosario Street (from Plaza Calderon de la Barca to Dasmarinas Street) between
7:30 AM to 12:30 PM and from 1:30 PM to 5:30 PM, as well as Rizal Avenue
(from the railroad crossing at Antipolo Street to Azcarraga Street) from 7 AM to 11
PM. This restriction is in effect for one year from the opening of the Colgante
Bridge to traffic. Consequently, all animal-drawn vehicles are unable to operate
and serve passengers in these specified areas, negatively impacting both their
owners and the commuting public.
Petitioner claims that such infringes upon the constitutional precept regarding the
promotion of social justice to insure the well-being and economic security of all
the people.

Issues:
Whether or not the petitioner’s claims on infringement of social justice are
correct.

Ruling:
No, the promotion of social justice does not involve misguided sympathy
toward any specific group. Social justice does not align with communism,
 despotism, atomism, or anarchy. Instead, it entails making laws more humane
and equalizing social and economic forces through government actions. These
actions aim to ensure the welfare of all citizens by maintaining economic stability
and a fair balance in social relationships. This can be achieved through
constitutional measures or, when necessary, by using the government's inherent
powers, always with the principle that the well-being of the people is the highest
law. Social justice recognizes the interdependence of diverse segments of
society and the need to protect all groups equally. Ultimately, it seeks to promote
the health, comfort, and well-being of all individuals, striving for the greatest good
for the greatest number.

7. G.R No. L-5060

45 Phil 85
U.S vs Toribio
January 26, 1910

Facts:
In the early 1900s, Toribio sought permission to have his carabao
slaughtered for human consumption. However, his request was rejected on the
grounds that his carabao was still fit for work. In spite of this refusal, he
proceeded to slaughter the carabao without obtaining the required license.
Subsequently, he faced legal action and was ultimately convicted by the trial
court. His legal representative contended that the law mandating the acquisition
of a permit before carabao slaughter does not constitute a legitimate exercise of
police power.

Issues:
Whether or not the said law is valid or constitutional

Ruling:
Yes, the law is valid and constitutional. The Supreme Court ruled against
Toribio and explained that the law requiring a permit for carabao slaughter is not
a seizure of property for public use under the constitution. Instead, it is a
legitimate exercise of legislative power to regulate and prevent property use that
could harm public rights. Property ownership includes the condition that it should
not be used in a way that injures others' rights or significantly impairs public
interests.

The rationale behind this law is to prohibit the slaughter of carabaos for
human consumption as long as these animals are still fit for agricultural work or
draft purposes. This limitation on private ownership was considered reasonably
necessary to protect the community from losing the services of such animals
due to their slaughter by owners driven by greed or a desire for luxury food, even
if it could harm the community's productivity.

8. G.R No. L-49112

88 SCRA 195
Agustin vs Edu
February 2, 1979

Facts:
Petitioner was an owner of a volkswagen beetle car, model 13035 already
properly equipped when it came out from the assembly lines with blinking lights
which could serve as an early warning device in case of the emergencies
mentioned in Letter of Instructions no. 229, as amended, as well as the
implementing rules and regulations in A.O no. 1 issued by Land transportation
Commission. Respondent Land Transportation Commissioner Romeo Edu
issued memorandum circular no. 32 pursuant to Letter of Instructions no.229, as
 amended. It required the use of early Warning Devices (EWD) on motor vehicles.
Petitioner alleged that the letter of instructions, as well as the implementing rules
and regulations were unlawful and unconstitutional.

Issues:
Whether the Letter of Instruction imposes valid measure of police power

Ruling:
Yes, the court ruled that Letter of Instruction No. 229 and its implementing
rules were constitutionally valid as an exercise of police power. These regulations
align with the Vienna Convention on Road signs and signals, which the
Philippines ratified through local legislation for road safety. Therefore, it's clear
that the Constitutional Principle favoring municipal law prevails over international
law when they come into conflict

9. G.R No. 10278

32 Phil 286
The Manila Railroad Company vs. Velazquez
November 23, 1915

Facts:
Manila Railroad Company filed expropriation proceedings for 12 small
parcels of land for a railroad station site at Lucena, Province of Tayabas. The
commissioners fixed the value of the twelve parcels at P81,412.75, and awarded
P600 to Simeon Perez (one of the respondents) as damages for the removal of
an uncompleted camarin. Upon hearing, the commissioners’ report was approved
and the plaintiff directed to pay to the Tayabas Land Company the total amount
awarded, with interest and costs. Basis for appraisement: 1) the construction of
the provincial building and the high school had increased the price of land in their
vicinity. 2) the neighborhood of these buildings had become a choice residential
district. 3) the population in the vicinity had increased. The petitioner company
alleges that that amount is grossly excessive, pointing out that the land has never
been used except for rice culture. Lower court affirmed the commissioners’
report. Hence, an appeal by the petitioner was filed asking the Court to review
the evidence and reduce the appraised value of the condemned land in
accordance with its findings.

Issues:
Whether or not the CFI has power over the reports of commissioners

Ruling:
Yes, in cases involving condemnation of land, the statute provides courts
with the authority to modify the commissioners' report on the land's value, either
increasing or decreasing the award, if the facts warrant such changes. The
commissioners' report is not final, and it requires a court judgment to determine
the final valuation. This judgment is based on a consideration of the evidence
submitted to the commissioners, their report, and any exceptions raised during
the report's hearing. Section 246 empowers the court to correct the
commissioners' report as needed to reach a final judgment and conclude the
legal proceedings. This final order and judgment can be reviewed by the higher
court through a bill of exceptions, just like any other legal action. Sections 496
and 497 provide that in cases where eminent domain is exercised and procedural
requirements are met, the higher court can examine the evidence and decide the
case based on a preponderance of evidence, essentially allowing for a retrial on
the merits to render a judgment in line with justice and equity.

10. G.R No. L-35861

93 SCRA 503
 Municipality of Daet vs. CA
October 18, 1979

Facts:
The Court of Appeals' judgment, which set the fair market value of the
expropriated property at P200.00 per square meter (a total of P543,400.00) and
the value of improvements at P36,500.00, with legal interest accruing from the
date of possession by the Municipality of Daet until full payment, should be
upheld. This decision is justified by the extraordinary and protracted
circumstances in this case, where the condemnation lawsuit was initiated 17
years ago, and yet the Municipality of Daet has not deposited the required funds
to take possession of the property in question.

Issues:
Whether or not the valuation is just, fair, and reasonable.

Ruling:
In cases where the government acquires private property for public use
and needs to determine just compensation, the basis for valuation is either the
current fair market value declared by the owner/administrator or the market value
determined by the assessor, whichever is lower. It's important to note that laws
are typically applied prospectively. In the specific case being discussed, a
provisional value for the property had already been established. However, the
deposits made on February 9, 1973 (P54,370.00 for land) and October 21, 1977
(P25,830.00 for improvements) were found to be insufficient, although these
amounts should still be subtracted from the total amount owed to the property
owner. The actual taking of possession of the property by the Municipality of Daet
occurred on February 14, 1978, when the building was demolished by the
Municipal Mayor, Engr. Jose P. Timoner. From that date onward, interest at the
legal rate should be paid by the municipality until the full compensation amount is
settled. This decision affirms the Court's previous ruling.

11. G.R No. 78742

175 SCRA 343
Association of Small Land Owners in the Philippines vs Secretary of Agrarian
Reform
July 14, 1989

Facts:
On September 3, 1986, the petitioner protested the erroneous inclusion of
his small landholding under Operation Land transfer and asked for the recall and
cancellation of the Certificates of Land Transfer in the name of the private
respondents. The petitioner contends that the issuance of E.0. Nos. 228 and 229
shortly before Congress convened is anomalous and arbitrary, besides violating
the doctrine of separation of powers. The petitioner also invokes his rights not to
be deprived of his property without due process of law and to the retention of his
small parcels of rice holding as guaranteed under Article 13, Section 4 of the
Constitution.

Issues:
Whether or not CARL violates due process because landowner is divested of his
property even before actual payment to him in full of just compensation, in
contravention of a well- accepted principle of eminent domain.

Ruling:
No, the established rule is that ownership of expropriated property
transfers to the expropriator only upon full payment of just compensation. This
principle is consistent not only in our legal system but also in democratic
 jurisdictions globally. While Presidential Decree No. 27 stipulated the
emancipation of tenant-farmers starting on October 21, 1972, and deemed them
as owners of family-sized farms, it was understood that actual title to the land
would only be issued upon full payment of just compensation, in line with
constitutional requirements.

12. G.R No. L-4817

95 Phil 46
Punzalan vs. The Municipal Board of Manila
May 26, 1954

Facts:
Petitioners, who are professionals in the city, assail Ordinance No. 3398
together with the law authorizing it (Section 18 of the Revised Charter of the City
of Manila). The ordinance imposes a municipal occupation tax on persons
exercising various professions in the city and penalizes non-payment of the
same. The law authorizing said ordinance empowers the Municipal Board of the
city to impose a municipal occupation tax on persons engaged in various
professions. Petitioners, having already paid their occupation tax under section
201 of the National Internal Revenue Code, paid the tax under protest as
imposed by Ordinance No. 3398. The lower court declared the ordinance invalid
and affirmed the validity of the law authorizing it.

Issues:
Whether or not the ordinance and law authorizing it constitute class legislation,
and authorize what amounts to double taxation.

Ruling:
Judgment of the lower court is reversed with regard to the ordinance and
affirmed as to the law authorizing it. The Legislature may, in its discretion, select
what occupations shall be taxed, and in its discretion may tax all, or select
classes of occupation for taxation, and leave others untaxed. It is not for the
courts to judge which cities or municipalities should be empowered to impose
occupation taxes aside from that imposed by the National Government. That
matter is within the domain of political departments. The argument against
double taxation may not be invoked if one tax is imposed by the state and the
other is imposed by the city. It is widely recognized that there is nothing
inherently terrible in the requirement that taxes be exacted with respect to the
same occupation by both the state and the political subdivisions thereof.

13. G.R No. L-19201

40 SCRA 292
Lladoc vs. Commissioner of Internal Revenue
June 16,1965

Facts:
Sometime in 1957, M.B. Estate Inc., of Bacolod City, donated 10,000.00
pesos in cash to Fr. Crispin Ruiz, the parish priest of Victorias, Negros
Occidental, and predecessor of Fr. Lladoc, for the construction of a new Catholic
church in the locality. The donated amount was spent for such purpose. On
March 3, 1958, the donor M.B. Estate filed the donor's gift tax return. Under date
of April 29, 1960. Commissioner of Internal Revenue issued an assessment for
the donee's gift tax against the Catholic Parish of Victorias of which petitioner
was the parish priest.

Issues:
Whether or not the imposition of gift tax despite the fact the Fr. Lladoc was not
the Parish priest at the time of donation, Catholic Parish priest of Victorias did not
have juridical personality as the constitutional exemption for religious purpose is
valid.

Ruling:
Yes, the imposition of the gift tax is deemed valid. This is because Section
22(3) Article 6 of the Constitution pertains to an exemption solely from property
taxes, as distinct from excise taxes. Therefore, imposing a gift tax on property
used for religious purposes does not contravene the Constitution. It's essential to
note that a gift tax does not classify as a property given through a gift inter vivos
(between living persons). In cases involving the imposition of the donee's tax on
property donated to the church for religious purposes, the true party with a
vested interest is the head of the Diocese, not the parish priest.