[G.R. No. 138855.

October 29, 2002]

1. LAMBERTO CASALLA, petitioner, vs. PEOPLE OF THE PHILIPPINES, and MILAGROS S.
ESTEVANES, respondents.

Facts: This petition for review on certiorari assails the decision and the resolution of the Court of
Appeals in denying petitioners appeal as well as motion for reconsideration for lack of merit. The facts
show that petitioner Lamberto Casalla issued two (2) Bank of Commerce checks in payment of the
obligation of his wife, TERESITA CASALLA, to private respondent MILAGROS SANTOS-ESTEVANES, in
order to avert a court litigation. The two (2) checks, however, were dishonored by the drawee bank
for reason of insufficiency of funds. Subsequently, private respondent filed two (2) criminal
complaints against petitioner for violation of the Bouncing Checks Law (BP 22).
MTC: On September 22, 1994, the MTC of Pasig City rendered a decision convicting the accused of the
crime charged on two (2) counts.
RTC: Petitioner interposed an appeal to the RTC of Pasig City, which was raffled to Branch 261 thereof
presided upon by public respondent judge, which rendered its decision dated January 18, 1995
affirming the judgment of the lower court with the modification that appropriate subsidiary
imprisonment be imposed on the accused in case of insolvency. On February 8, 1995, petitioner filed a
motion for reconsideration which the RTC denied the motion for reconsideration on account of the
absence of a notice of hearing and because the issues raised therein have already been passed upon in
its decision. On February 22, 1995, petitioner filed a second motion for reconsideration. On February
24, 1995, private respondent filed with the RTC a motion for the issuance of a writ of execution.
Opposition thereto was filed by petitioner. The RTC denied petitioners second motion for
reconsideration and granted the motion for the issuance of a writ of execution. A writ of execution
was issued by the court directing public respondent Deputy Sheriff Jose R. Santos to cause the
execution of the judgment.
CA: Petitioner interposed an appeal via a petition for review with prayer for preliminary injunction
and/or temporary restraining order. The appellate court promulgated its decision denying the appeal
for lack of merit. The CA held that the petition before it did not contain a statement of material dates
showing the timeliness of the petition. It also maintained that the petition was filed out of time,
because the motion to reconsider the decision of the trial court did not contain a notice of hearing.
Hence, being a mere scrap of paper, it did not interrupt the period for filing the petition before the
appellate court, and the period had lapsed before the petition was filed. It also ruled that petitioners
second motion was not only a prohibited pleading but it was also filed out of time.

Issue: Whether the requirement of a notice of hearing applies to the motion for reconsideration filed
before the Regional Trial Court, as said court was acting only in its appellate jurisdiction.

Ruling: Yes. Petitioner received a copy of the decision of the Regional Trial Court on February 1, 1995. From
that date, he had 15 days, or until February 16, 1995, to file a motion for reconsideration. On February 8, 1995,
petitioner did file a motion for reconsideration of the trial courts decision. The motion, however, lacked a notice
of hearing. The Court ruled that the requirements laid down in the Rules of Court, that the notice of hearing
shall be directed to the parties concerned and shall state the time and place for the hearing of the motion, are
mandatory. If not religiously complied with, they render the motion pro forma. As such the motion is a useless
piece of paper that will not toll the running of the prescriptive period. Under the present rules, the notice of
hearing is expressly made a requirement. In the instant case, it is undisputed that the motion for
reconsideration filed by petitioner with the Regional Trial Court did not contain any notice of hearing. This
defect was not cured by the filing of a second motion for reconsideration, which is prohibited under the rules.
The Rules of Court apply to all courts, except as otherwise provided by the Supreme Court. Regional Trial
Courts are not precluded from conducting hearings on matters on which the parties need to be heard, even in
the exercise of their appellate jurisdiction. Additionally, to assail the RTCs issuance of a writ of execution,
petitioner filed a petition for review under Rule 45 with the Court of Appeals. This was improper. What it
should have filed was a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure. Under the
Rules, no appeal may be taken from an order denying a motion for new trial or reconsideration and an order of
execution. Instead, where the judgment or final order may not be appealed, the appropriate recourse is a
special civil action under Rule 65.
………………………………………………………………………………………………………………………………………………………

1
AI version

Facts: Lamberto Casalla issued two Bank of Commerce checks to Milagros S. Estevanes in payment of
his wife’s obligation to her. However, the two checks were dishonored by the drawee bank for
insufficient funds. Subsequently, Estevanes filed two criminal complaints against Casalla for violation
of the Bouncing Checks Law (BP 22). The cases were docketed as Criminal Case Nos. 11844 and 11845
and raffled to Branch 68 of the Metropolitan Trial Court (MTC) of Pasig City. On September 22, 1994,
the MTC of Pasig City rendered a decision convicting Casalla of the crime charged on two counts.

Issue: Whether or not the petitioner is guilty of violating the Bouncing Checks Law (BP 22).

Ruling: The Regional Trial Court (RTC) of Pasig City affirmed the judgment of the lower court with the
modification that appropriate subsidiary imprisonment be imposed on the accused in case of
insolvency. The Court of Appeals denied Casalla’s appeal as well as motion for reconsideration for lack
of merit. The Supreme Court upheld the decision of the Court of Appeals and denied the petition for
review on certiorari.

Relation to (Sec. 2, Rule 1): Section 2, Rule 1 of the Rules of Court provides that “these Rules shall be
liberally construed in order to promote their objective of securing a just, speedy and inexpensive
disposition of every action and proceeding.” In this case, the court applied the provisions of the
Bouncing Checks Law (BP 22) to secure a just and speedy disposition of the criminal complaints filed
against Casalla. The court also imposed appropriate subsidiary imprisonment on the accused in case
of insolvency, in accordance with the provisions of the law.

This case is involving bounced checks. The main points of the selected text are:

- **Petition for review**: The petitioner, Lamberto Casalla, is challenging the decision and resolution
of the Court of Appeals that denied his appeal and motion for reconsideration.
- **Bounced checks**: The petitioner issued two checks to pay his wife's debt to the private
respondent, but the checks were dishonored by the bank due to insufficient funds. The private
respondent filed two criminal complaints against the petitioner for violating the Bouncing Checks Law.
- **Conviction and appeal**: The petitioner was convicted by the Metropolitan Trial Court of Pasig
City on two counts. He appealed to the Regional Trial Court of Pasig City, which affirmed the conviction
with a modification of subsidiary imprisonment. The petitioner filed a motion for reconsideration,
which was denied by the Regional Trial Court.

Cute summary for ambushed recits

Lamberto Casalla (petitioner) against the People of the Philippines and Milagros S. Estevanes
(respondents).
The case revolves around Casalla issuing two Bank of Commerce checks in payment of the obligation of
his wife, Teresita Casalla, to private respondent Milagros Santos-Estevanes, to avert a court litigation.
However, the checks were dishonored due to insufficient funds. Consequently, Estevanes filed two
criminal complaints against Casalla for violation of the Bouncing Checks Law (BP 22). The Metropolitan
Trial Court (MTC) of Pasig City convicted Casalla on two counts of the crime. Casalla appealed to the
Regional Trial Court (RTC) of Pasig City, which affirmed the judgment of the lower court.
A cause of action is defined as the act or omission by which a party violates a right of another. In this
case, the cause of action was the issuance of two checks by Casalla that were dishonored due to
insufficient funds, violating the rights of Estevanes.

2. Surigao Mine Exploration Co.Inc. vs. C. Harris, Surigao-Mainit Mining Syndicate, et.al., G.R. No.
L-45543, May 17, 1939
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FACTS:

On October 24, 1935, Surigao Mine Exploration (Surigao Mines), petitioner, filed a complaint
against C.Harris, et. al., defendants, alleging that it is the owner by purchase of the placer mining
claims and that the lode claims complained of were staked and located by the defendants on
petitioner’s placer claims after the latter had been validly and duly staked and located.
On November 23, 1935, Harris, et. al demurred to the complaint of Surigao Mines on which the
CFI finds merit, hence, required Surigao Mines to amend its complaint.
In the course of adduction of evidence, it was revealed that the placer claims here in question
bear dates posterior to the date of filing of the original complaint. Hence, the defendants moved for the
dismissal of the complaint on the ground that, when the action was commenced, plaintiff’s right of
action had not yet accrued, since, under its own Exhibits, the plaintiff did not become the owner of the
claims in dispute until after the original complaint was filed in the Court of First Instance (CFI) on
October 24, 1935. The CFI dismissed the complaint.

ISSUE:
Whether or not the CFI erred in dismissing the complaint on the basis that it was prematurely
brought to the court.

RULING: No.
The Supreme Court held that subject to certain qualifications, and except as otherwise
provided by law, an action commenced before the cause of action has accrued is prematurely brought
and should be dismissed, provided an objection on this ground is properly and seasonably interposed.
The fact that the cause of action accrues after the action is commenced and while it is pending is of no
moment. Under section 389, which was taken from section 405 of the Code of Civil Procedure of
California, the action is deemed commenced upon the "filing of a complaint in the office of the clerk of
the court in which the action is to be instituted".
In the present case, the original complaint was filed on October 24, 1935. Timely objection was
made by counsel for the defendants upon discovery of the immaturity of the action as result of the
presentation by plaintiff-appellant of certain exhibits hereinabove mentioned.
Hence, having no valid and subsisting cause of action at the time Surigao Mines action is
commenced, the order appealed from is affirmed.

………………………………………………………………………………………………………………………………………………………
AI version
Case Digest: G.R. No. L-45543, Surigao Mine Exploration Co., Inc. vs. C. Harris, Surigao-Mainit
Mining Syndicate, et al.
Facts: The plaintiff, Surigao Mine Exploration Co., Inc., a domestic private corporation domiciled in
Cebu, filed a complaint in the Court of First Instance of Surigao on October 24, 1935 1. The plaintiff
sought a judicial pronouncement1:
 Adjudging the plaintiff to be the owner and possessor of the fourteen placer mining claims
located in the barrio of Tubod, municipality of Mainit, Province of Surigao 1.
 Annulling the forty-three lode mining claims of the defendants, C. Harris, Surigao-Mainit Mining
Syndicate, Surigao Consolidated Mining Co., Inc., and Otto Weber, and cancelling the
registration of said lode claims in the records of the mining recorder of Surigao and in all other
official records1.
 Prohibiting the defendants and their agents, employees, and laborers from interfering with
plaintiff’s ownership and possession of its placer claims1.
 Sentencing the defendants to pay jointly and severally to the plaintiff the sum of P47,000 by
way of damages1.

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Issue: whether the action was prematurely brought, as the plaintiff’s right of action had not yet
accrued when the action was commenced2.

Ruling: The court held that an action commenced before the cause of action has accrued is
prematurely brought and should be dismissed, provided an objection on this ground is properly and
reasonably interposed2. The fact that the cause of action accrues after the action is commenced and
while it is pending is of no moment2.

Relation to Sec. 5, Rule 1: The case is related to Sec. 5, Rule 1 as it discusses the concept of when a
civil action is deemed commenced. The court determined that the date when a civil action is deemed
commenced is determined by section 389 of the Code of Civil Procedure 2. The action is deemed
commenced upon the "filing of a complaint in the office of the clerk of the court in which the action is
to be instituted". This principle is in line with Sec. 5, Rule 1 which discusses the commencement of
actions.

Cute summary for ambushed recits

The case of Surigao Mine Exploration Co., Inc. vs. C. Harris, Surigao-Mainit Mining Syndicate,
et.al., G.R. No. L-45543, May 17, 1939, revolves around the issue of prematurely filed actions12.

The Surigao Mine Exploration Co., Inc., a domestic private corporation domiciled in Cebu, filed
a complaint in the Court of First Instance of Surigao on October 24, 193512. The plaintiff sought
a judicial pronouncement adjudging it as the owner and possessor of fourteen placer mining
claims located in the barrio of Tubod, municipality of Mainit, Province of Surigao12. It also
sought to annul the forty-three lode mining claims of the defendants12.

However, the defendants objected that the action was prematurely brought as the plaintiff’s right
of action had not yet accrued when the original complaint was filed1. The court agreed with the
defendants, stating that an action commenced before the cause of action has accrued should be
dismissed, provided an objection on this ground is properly and reasonably interposed1.

Relating this to Section 5, Rule 1 of the Rules of Court, it emphasizes the importance of the proper timing in
filing a case. An action must be commenced only after the cause of action has accrued. Filing a case
prematurely, as in the Surigao Mine Exploration Co., Inc. vs. C. Harris case, can lead to the dismissal of the
case. This rule ensures that cases are filed and heard at the appropriate time, contributing to the efficient
administration of justice.
 Case Background: The plaintiff, Surigao Mine Exploration Co., Inc., filed a complaint against the
defendants, C. Harris and others, claiming ownership and possession of eleven placer mining claims in
Surigao and seeking to annul the defendants’ lode mining claims on the same area.
 Defendants’ Demurrer: The defendants demurred to the complaint on various grounds, such as misjoinder of
parties, insufficiency of facts, and ambiguity of the complaint. The trial court ordered the plaintiff to amend its
complaint several times.
 Plaintiff’s Exhibits: The plaintiff presented Exhibits O and O-1 to O-9, which are deeds of sale in favor of
the plaintiff covering the placer claims in dispute. However, these exhibits show that the plaintiff acquired the
claims after the filing of the original complaint.
 Trial Court’s Ruling: The trial court dismissed the complaint on the ground that the plaintiff had no cause of
action at the time the action was commenced, and that this defect could not be cured by subsequent
acquisition of the claims1. The plaintiff appealed to the Supreme Court.

3. G.R. No. 198680, Heirs of Magdaleno Ypon vs. Gaudioso Ponteras Ricaforte:

4
Facts: The petitioners, who are the collateral relatives and successors-in-interest of Magdaleno Ypon,
filed a complaint for Cancellation of Title and Reconveyance with Damages against respondent
Gaudioso Ponteras Ricaforte. They alleged that Magdaleno Ypon died intestate and childless, leaving
behind Lot Nos. 2-AA, 2-C, 2-F, and 2-J which were then covered by Transfer Certificates of Title.
Gaudioso, claiming to be the sole heir of Magdaleno, executed an Affidavit of Self-Adjudication and
caused the cancellation of the aforementioned certificates of title, leading to their subsequent transfer
in his name.
Issue: The issue is whether or not the RTC’s dismissal of the case on the ground that the subject
complaint failed to state a cause of action was proper.

Ruling of the Court: The Supreme Court ruled that the petition has no merit. The court found that
while the plaintiffs had established their relationship with Magdaleno in a previous special
proceeding, this did not mean that they could already be considered as the decedent’s compulsory
heirs. The court also observed that Gaudioso satisfactorily established the fact that he is Magdaleno’s
son – and hence, his compulsory heir – through the documentary evidence he submitted 1.

Relation to Section 1, Rule 2 of the Rules of Court: Section 1, Rule 2 of the Rules of Court defines an
action as an ordinary suit in a court of justice, by which one party prosecutes another for the
enforcement or protection of a right, or the prevention or redress of a wrong. In this case, the
petitioners filed an ordinary suit for the enforcement of their alleged right as the collateral relatives
and successors-in-interest of Magdaleno Ypon. However, the court found that they failed to state a
cause of action against Gaudioso, leading to the dismissal of the case.
____________________________________________________________________________________________________________________
AI version
Facts: The petitioners, who are relatives of Magdaleno Ypon, filed a complaint for Cancellation of Title and
Reconveyance with Damages against Gaudioso Ponteras Ricaforte, also known as “Gaudioso E. Ypon”.
They alleged that Magdaleno Ypon died intestate and childless, leaving behind certain lots. Gaudioso,
claiming to be the sole heir of Magdaleno, executed an Affidavit of Self-Adjudication and caused the cancellation of
the certificates of title, leading to their subsequent transfer in his name 1.
Issue: The issue was whether the petitioners have a cause of action against Gaudioso. Gaudioso claimed that he is the
lawful son of Magdaleno, evidenced by his certificate of Live Birth, two letters from Polytechnic School, and a
certified true copy of his passport1.
Ruling: The Regional Trial Court (RTC) dismissed the case, finding that the complaint failed to state a cause of action
against Gaudioso. The RTC observed that while the plaintiffs had established their relationship with Magdaleno in a
previous proceeding, this did not mean that they could already be considered as the decedent’s compulsory heirs 1.
Relation to Rules of Court Section 1 Rule 2: Section 1 Rule 2 of the Rules of Court defines a cause of action as the
act or omission by which a party violates a right of another2. In this case, the court found that the plaintiffs failed to
establish a cause of action against Gaudioso, leading to the dismissal of the case 1.

 The nature of the case: The petitioners are challenging the dismissal of their complaint for
cancellation of title and reconveyance with damages against the respondent, who claims to be the
sole heir of the deceased Magdaleno Ypon.
 The facts of the case: The petitioners are the collateral relatives and successors-in-interest of
Magdaleno Ypon, who died intestate and childless in 1968, leaving behind four lots. The respondent
executed an affidavit of self-adjudication and transferred the titles of the lots to his name, alleging
that he is the lawful son of Magdaleno Ypon.
 The RTC ruling: The RTC dismissed the complaint for lack of cause of action, reasoning that the
petitioners have not been judicially declared as the heirs of Magdaleno Ypon, and that the respondent
has presented documentary evidence to prove his filiation.
Summary: The selected text is an introduction to a legal dispute over the inheritance of four lots left by a
deceased person.
4. G.R. No. 174806 August 11, 2010 (sec.2 rule2)
SOLOIL, INC., Petitioner, vs. PHILIPPINE COCONUT AUTHORITY, Respondent.

5
Nature of the Case: Petition for review on certiorari of the decision and resolution of the Court of
Appeals

Legal Doctrine: A cause of action is the act or omission by which a party violates a right of another.
The essential elements of a cause of action are(1)a right in favor of the plaintiff by whatever means
and under whatever law it arises or is created; (2) an obligation on the part of the named defendant to
respect or not to violate such right; and (3) an act or omission on the part of such defendant in
violation of the right of the plaintiff or constituting a breach of the obligation of the defendant to the
plaintiff for which the latter may maintain an action for recovery of damages or other appropriate
relief.

SC Decision: Petition denied, judgment and resolution affirmed

Facts:

This is a petition for review of the Decision and Resolution of the Court of Appeals. The
Decision vacated the Decision of the Regional Trial Court (Branch 84) of Quezon City. The Resolution
denied petitioner’s motion for reconsideration.

Petitioner Soloil, Inc. (Soloil) is a domestic corporation engaged in the exportation of copra,
crude coconut oil, and other coconut products. Respondent Philippine Coconut Authority (PCA) is a
government owned and controlled corporation created under Presidential Decree No. 232, otherwise
known as the Law Creating A Philippine Coconut Authority, mandated to promote the rapid
development of the coconut and palm oil industry in the country.

In January 1995, the Office of the Government Corporate Counsel sent by registered mail a final
demand letter addressed to Soloil for the payment of the latter’s overdue fees to PCA for the domestic
sale of coconut products. Soloil still did not pay the fees.

On 6 December 1995, PCA filed in the Regional Trial Court (Branch 84) of Quezon City a
complaint alleging that Soloil refused to pay the PCA fees. PCA further claimed that as of 31 December
1994, Soloil’s overdue account had reached ₱403,543.29.

In its answer, Soloil raised the defense that PCA’s demand for the payment of PCA fees based
on domestic sales had no factual basis as Soloil never engaged in the domestic sale of coconut
products.

The case was set for pre-trial. However, for failure of the parties to settle the case amicably,
pre-trial was terminated. Trial on the merits ensued.

PCA presented its lone witness, Trade Control Examiner Victoria Evangelista. Evangelista
testified that she was in charge of monitoring Soloil’s export sales transactions and that she was the
one who prepared Soloil’s Summary of Outstanding PCA Fee Obligations attached as Annex "A" of the
complaint. PCA then presented itemized schedules of Soloil’s outstanding PCA fee obligations as well
as certified reports of the marine cargo surveyor showing that Soloil made export shipments without
paying the requisite PCA fees.

On the other hand, Soloil presented its sole witness, Assistant Vice-President for Trading and
Administration Fernando Uy. Uy testified that Soloil had no record of any domestic sale of coconut
products. On cross-examination, Uy admitted Soloil purchased copra in the course of its business of
exporting coconut products.
In their respective memoranda, the parties raised the following issues: (1) whether the
complaint stated a cause of action; and (2) if so, whether Soloil was liable to pay PCA fees in the
amount of ₱403,543.29.

6
 In its 29 September 2000 Decision, the RTC ruled PCA failed to prove that the claimed amount
of unpaid PCA fees was from Soloil’s domestic sale of coconut products. The RTC held that only the
amount of ₱509.66 with interest of ₱147.23 was duly proven to be from Soloil’s domestic sale of
coconut products.
PCA appealed to the Court of Appeals insisting that Soloil was liable to pay PCA fees on its
purchases of copra for both domestic and export sale of coconut products.
The appellate court held that PCA fees attached upon purchase of copra by copra exporters.
The Court of Appeals pointed out that there was no distinction whether the purchase was for
domestic or for export sale of coconut products. In its 12 May 2006 Decision, the Court of Appeals
granted PCA’s appeal.
Soloil filed a motion for reconsideration, which the Court of Appeals denied for lack of merit in
its 10 October 2006 Resolution. Hence, the instant petition for review.

Issue: Whether or not the complaint, alleging non-payment of PCA fees due on Soloil’s domestic sale
of coconut products, sufficiently stated a cause of action when evidence adduced during trial consisted
of Soloil’s export sale of coconut products.

Ruling: No, the petition has no merit. Petitioner Soloil belabors the fact that the complaint
alleged non-payment of PCA fees on Soloil's domestic sale of coconut products while the attached
annexes showing Soloil's unpaid PCA fees did not indicate whether the amounts due were from
domestic or from export sale of coconut products. Soloil maintains it never had any domestic sale of
coconut products as its sales were all for export. Soloil argues that the complaint should have been
dismissed for lack of cause of action and the RTC should not have allowed PCA, despite Soloil's
vehement objection, to adduce evidence pertaining to export sales.
Respondent PCA counters that the complaint sufficiently established that PCA was mandated
by law to impose and collect PCA fees for every kilo of copra purchased by copra exporters such as
Soloil. PCA insists that PCA fees attached upon Soloil's purchase of copra whether such purchase was
for domestic or for export sale of coconut products.
Rule 2 of the Rules of Court defines a cause of action as: Sec. 2. Cause of action, defined. - A
cause of action is the act or omission by which a party violates a right of another. The essential
elements of a cause of action are(1)a right in favor of the plaintiff by whatever means and under
whatever law it arises or is created; (2) an obligation on the part of the named defendant to respect or
not to violate such right; and (3) an act or omission on the part of such defendant in violation of the
right of the plaintiff or constituting a breach of the obligation of the defendant to the plaintiff for
which the latter may maintain an action for recovery of damages or other appropriate relief.
The complaint in this case, paragraph 4 in particular, contained the following averments: 4. To
defray its operating expenses plaintiff is authorized under P.D. 1854 entitled Authorizing An
Adjustment of the Funding Support of the Philippine Coconut Authority and Instituting a Procedure
for the Management of Such Fund to impose and collect a fee of three centavos for every kilo of copra
or its equivalent in copra terms of other coconut products delivered to and/or purchased by copra
exporters, oil millers, desiccators, and other endusers of coconut products. This fee is otherwise
known as PCA fee;[24] (Emphasis supplied)

This portion of the complaint together with the attached annexes showing Soloil's unpaid PCA
fees sufficiently constituted a cause of action in this case, namely (1) under P.D. 1854, PCA has a right
to collect PCA fees in the amount of three centavos for every kilo of copra purchased by copra
exporters; (2) Soloil, as a copra exporter, is legally bound to pay PCA fees; and (3) Soloil's non-
payment of PCA fees is in violation of PCA's right to collect the same.

In determining whether a complaint states a cause of action, the trial court can consider all the
pleadings filed, including annexes, motions, and the evidence on record. The focus is on the
sufficiency, not the veracity, of the material allegations. Moreover, the complaint does not have to
establish facts proving the existence of a cause of action at the outset; this will have to be done at the
trial on the merits of the case. The fact that the complaint specifically mentioned assessed PCA fees
due on Soloil's domestic sale of coconut products did not preclude a cause of action for PCA fees due

7
on Soloil's export sale of coconut products. PCA sufficiently alleged on paragraph 4 of the complaint
that PCA fees attached upon purchase of copra by copra exporters, such as Soloil, whether for
domestic or for export sale of coconut products.

Presidential Decree No. 1468, otherwise known as the Revised Coconut Industry Code, granted
PCA the power to impose and collect PCA fees to defray its operating expenses, thus: Sec. 3. Power. - In
the implementation of the declared national policy, the Authority [PCA] shall have the following
powers and functions: xxxx k) To impose and collect, under such rules that it may promulgate, a fee of
ten centavos for every one hundred kilos of desiccated coconut, to be paid by the desiccating factory,
coconut oil to be paid by the oil mills, and copra to be paid by the exporters, which shall be used
exclusively to defray its operating expenses.

Presidential Decree No. 1854, otherwise known as the Law Authorizing an Adjustment of the
Funding Support of the Philippine Coconut Authority and Instituting a Procedure for the Management
of such Fund, increased such PCA fees to three centavos per kilo of copra or husked nuts or their
equivalent in other coconut products delivered to and/or purchased by copra exporters, oil millers,
desiccators, and other end-users of coconut products.

Under P.D. 1854, PCA fees automatically attach upon purchase of copra by copra exporters,
such as Soloil in this case. The law does not distinguish whether the purchase of copra is for domestic
or for export sale of coconut products. When the law does not distinguish, neither should we.
However, the law expressly requires that the PCA fees "shall be paid by said copra exporters" for
copra "purchased by copra exporters."

Soloil, as a copra exporter, cannot evade its legal obligation to pay PCA fees on the lame pretext
that it never engaged in domestic sale of coconut products or worse that the complaint for collection
of PCA fees failed to state a cause of action.
………………………………………………………………………………………………………………………………………………………..
AI version
Facts:
 Petitioner Soloil, Inc. is a domestic corporation exporting coconut products.
 Respondent Philippine Coconut Authority (PCA) is a government-owned
corporation promoting the coconut and palm oil industry.
 PCA demanded overdue fees from Soloil for domestic sale of coconut products.
 Soloil contested the demand, claiming it never engaged in domestic sales.
Issue:
 Whether PCA’s complaint sufficiently stated a cause of action based on Soloil’s
export sales of coconut products.
Ruling:
 The Regional Trial Court (RTC) ruled in favor of Soloil, stating PCA failed to prove
Soloil’s domestic sale of coconut products.
 PCA fees automatically attach upon purchase of copra by copra exporters like
Soloil 123.

5. GR No. 201892, Marilag v. Martinez ( Sec 4 Rule 2)

FACTS:

8
Rafael Martinez (Rafael), the respondent's father, obtained- from the petitioner a loan for PHP 160,000.00, with
a stipulated monthly interest of five percent (5%), payable within a period of six (6) months. The loan was
secured by a real estate mortgage over a parcel of land covered by Transfer Certificate of Title (TCT) No. T-
208400. Rafael failed' to settle his obligation upon maturity and despite repeated demands, prompted the
petitioner to file a Complaint about Judicial Foreclosure of Real Estate Mortgage before the RTC of Imus, Cavite.
Rafael failed to file his answer and upon the petitioner's motion, it was declared in default. RTC Imus declared a
decision in the foreclose case, but the record does not show that this Decision had already attained finality.
Meanwhile, prior to Rafael's notice of the above decision, respondent agreed to pay Rafael's obligation to the
petitioner, which was pegged at PHP 689,000.00. After making a total payment of PHP 400,000.00, he executed
a promissory note dated February 20, 1998 (subject PN), binding himself to pay on or before March 31, 1998,
the amount of PHP 289,000.00, "representing the balance of the agreed financial obligation of his father to
petitioner." After learning the decision, the respondent refuse to pay the amount stated in PN. The petitioner
filed a case for the sum of money and damages and the respondent contends that the petitioner has no cause of
action against him.
ISSUE:
Whether litis pendentia applies in the present case.
RULING:
YES. Litis pendentia applies in the present case. Litis pendentia, as a ground for the dismissal of a civil
action, refers to that situation wherein another action is pending between the same parties for the
same cause of action, such that the second act becomes unnecessary and vexatious. For the bar of litis
pendentia to be invoked, the following requisites must concur: (a) identity of parties or at least such
parties as representing the same interests in both actions; (b) identity of rights asserted and relief
prayed for, the relief being founded on the same facts; and (c) the identity of the two preceding
particulars is such that any judgment rendered in the pending case, regardless of which party is
successful would amount to res judicata in the other. Splitting a cause of action is a mode of forum
shopping by filing multiple cases based on the same cause of action, but with different prayers, where
the ground of dismissal is litis pendentia or res judicata, as the case may be. In loan contracts secured
by a real estate mortgage, the rule is that the creditor-mortgagee has a single cause of action against
the debtor mortgagor, i.e., to recover the debt, through the filing of a personal action for collection of
sum of money or the institution of a real action to foreclose on the mortgage security.

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the Supreme Court addressed the issue of whether the creditor’s acceptance of payments from a third person who
assumed the debtor’s obligation results in novation or merely adds debtors1. Let’s break down the case:
Facts:
Rafael Martinez, the respondent’s father, borrowed ₱160,000 from petitioner Norlinda S. Marilag, with a stipulated
monthly interest of 5% and a 6-month repayment period. The loan was secured by a real estate mortgage over a parcel
of land. Rafael defaulted on the loan, leading to a judicial foreclosure case where the court reduced the interest rate to
12% per annum. Respondent Marcelino B. Martinez agreed to pay Rafael’s obligation, which was pegged at ₱689,000.
He executed a promissory note for the balance of ₱289,000.
After learning of the reduced interest rate in the foreclosure case, Marcelino refused to pay the amount covered by the promissory
note1.
Issue:
Whether Marcelino is liable to pay the excess amount based on the judicial foreclosure case’s reduced interest rate1.
Ruling:The Supreme Court held that Marcelino’s claim for the return of the excess payment is a compulsory counterclaim and
survives the dismissal of Norlinda’s collection suit. Thus, it should be resolved based on its own merits and evidentiary support2.
Relevance to Rule 2, Rules of Court: In loan contracts secured by a real estate mortgage, the creditor-mortgagee has a single
cause of action against the debtor mortgagor. This cause of action can be pursued through a personal action for collection of a
sum of money or by instituting a real action to foreclose on the mortgage security3.
In summary, the court ruled in favor of Marcelino’s claim for the return of the excess payment, emphasizing that it is a separate
issue from Norlinda’s collection suit.
6. GR No. 140746, PNE, Inc and Buncan v. Standard Insurance Co. (Sec 5, Rule 2)

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FACTS: In the afternoon of October 28, 1984, Crispin Gicale was driving the passenger jeepney owned
by his mother Martina Gicale. It was then raining. While driving north bound along the National
Highway in Talavera, Nueva Ecija, a passenger bus, owned by Pantranco North Express, Inc., , driven
by Alexander Buncan, was trailing behind. When the two vehicles were negotiating a curve along the
highway, the passenger bus overtook the jeepney. In so doing, the passenger bus hit the left rear side
of the jeepney and sped away. Crispin reported the incident to the Talavera Police Station and
respondent Standard Insurance Co., Inc. (Standard), insurer of the jeepney. The total cost of the repair
was P21,415.00, but respondent Standard paid only P8,000.00. Martina Gicale shouldered the balance
of P13,415.00. Thereafter, Standard and Martina, respondents, demanded reimbursement from
petitioners Pantranco and its driver Alexander Buncan, but they refused. This prompted respondents
to file with the Regional Trial Court (RTC), Branch 94, Manila, a complaint for sum of money. In their
answer, Pantranco and Buncan specifically denied the allegations in the complaint and averred that it
is the Metropolitan Trial Court, not the RTC, which has jurisdiction over the case.
ISSUE: Whether or not the RTC has jurisdiction over the case?
HELD: Yes. In this case, there is a single transaction common to all, that is, Pantranco's bus hitting the
rear side of the jeepney. There is also a common question of fact, that is, whether petitioners are
negligent. There being a single transaction common to both respondents, consequently, they have the
same cause of action against petitioners. As previously stated, respondents' cause of action against
petitioners arose out of the same transaction. Thus, the amount of the demand shall be the totality of
the claims. Respondent Standard's claim is P8,000.00, while that of respondent Martina Gicale is
P13,415.00, or a total of P21,415.00. Section 19 of B.P. Blg. 129 provides that the RTC has "exclusive
original jurisdiction over all other cases, in which the demand, exclusive of interest and cost or the value of the
property in controversy, amounts to more than twenty thousand pesos (P20,000.00)." Clearly, it is the RTC that
has jurisdiction over the instant case. It bears emphasis that when the complaint was filed, R.A. 7691 expanding
the jurisdiction of the Metropolitan, Municipal and Municipal Circuit Trial Courts had not yet taken effect. It
became effective on April 15, 1994.

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Facts:

 On October 28, 1984, Crispin Gicale was driving a passenger jeepney owned by his mother, Martina Gicale.
 While driving along the National Highway in Talavera, Nueva Ecija, a passenger bus owned by Pantranco
North Express, Inc., driven by Alexander Buncan, overtook the jeepney.
 The passenger bus hit the left rear side of the jeepney and then sped away.
 Crispin reported the incident to the Talavera Police Station and respondent Standard Insurance Co., Inc.
(Standard), the insurer of the jeepney.
 The total repair cost was P21,415.00, but Standard paid only P8,000.00, leaving Martina Gicale to shoulder
the balance of P13,415.00.
 Standard and Martina demanded reimbursement from Pantranco and Alexander Buncan, but they refused.
 Respondents filed a complaint for sum of money in the Regional Trial Court (RTC), Branch 94, Manila.

Issue: Whether or not the RTC has jurisdiction over the case.

Ruling: The RTC ruled in favor of respondents Standard and Martina. The Court of Appeals affirmed the trial court’s
ruling. The Court held that under Section 5 (d), Rule 2 of the Revised Rules of Court, in cases where the claims in all
the causes of action are principally for the recovery of money, the aggregate amount claimed shall be the test of
jurisdiction123.
This case highlights the importance of considering the total amount claimed when determining jurisdiction in cases
involving multiple claims arising from the same transaction or series of transactions.

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