G.R. No.

104768 July 21, 2003

REPUBLIC OF THE PHILIPPINES, Petitioner,

vs.
SANDIGANBAYAN, MAJOR GENERAL JOSEPHUS Q. RAMAS and ELIZABETH DIMAANO

President Corazon C. Aquino issued EO No. 1, creating the PCGG to recover ill-gotten wealth of
former President Ferdinand E. Marcos and associates.

PCGG established the AFP Board to investigate unexplained wealth and corrupt practices by AFP
personnel.

Major General Josephus Q. Ramas and Elizabeth Dimaano were investigated for alleged
unexplained wealth.

The Sandiganbayan dismissed the Amended Complaint against Ramas and Dimaano citing various
grounds, including legality issues and insufficiency of evidence.

The main issue was whether PCGG had jurisdiction to investigate and file a forfeiture petition under
RA No. 1379, which the court ruled it did not have.

During the interregnum, the court held that the Bill of Rights under the 1973 Constitution was not
operative, but protections under international covenants remained in effect.

The court concluded that there was an illegal search and seizure of items from Dimaano's house,
and unless the items were contraband per se, they should be returned to her.
MIJARES V. RANADA, GR 139325, APRIL 12, 2005

In the Mijares v. Ranada case, Filipino citizens who were victims of human rights abuses during the
Marcos regime filed a complaint in the United States against Ferdinand Marcos' estate. They later
sought to enforce the US court's judgment in a Philippine court.

However, the court in the Philippines dismissed their case, citing issues with the filing fees they had
to pay. The victims argued that their case involved enforcing a foreign judgment and shouldn't be
subject to high filing fees.

The victims also pointed out that these fees went against the idea of fair access to courts for
everyone, especially considering their difficult financial situations.

The court agreed, stating that requiring high fees based on the amount awarded in a foreign
judgment might not be practical, especially when dealing with foreign currencies and varying property
values. The court emphasized the importance of ensuring access to justice, particularly for those who
can't afford hefty fees.

The decision clarified that it focused on the filing fees issue and didn't make a final decision on other
aspects of the case. It encouraged a prompt resolution of the remaining issues in the trial court.

In the end, the court granted the victims' petition, nullified the previous orders, and reinstated their
case, emphasizing the importance of fair access to justice for all.
MMDA V BEL AIR VILLAGE

MMDA issues notice to open Neptune Street based on Republic Act No. 7924.

BAVA opposes, files a case, seeking an injunction against road opening and wall demolition.

Legal proceedings include a temporary restraining order, denied preliminary injunction, and an
appeal to the Court of Appeals.

Court of Appeals rules on January 28, 1997, stating MMDA lacks authority, emphasizes need for a
Makati City ordinance.

Outcome: MMDA's plan halted; court underscores the importance of following the rule of law.

Neptune Street is a private road owned by BAVA in Bel-Air Village, Makati, within a private
residential subdivision.

MMDA claims authority under police power for public safety, welfare, and convenience.

MMDA cites Sangalang v. Intermediate Appellate Court, argues no need for Makati City ordinance.

Police power is an inherent sovereign power covering public health, safety, morals, and general
welfare, primarily vested in the National Legislature.

Local government units exercise police power through legislative bodies like Sangguniang
panlalawigan, panlungsod, bayan, and barangay.

MMDA administers "metro-wide" basic services in Metro Manila under Republic Act No. 7924.

Transport and traffic management service aims to rationalize operations, infrastructure use, and
ensure safe movement.

Court rejects MMDA's claim, emphasizing Neptune Street as a private road within a subdivision,
asserts local government authority.

Neptune Street owned by BAVA, representing homeowners in Bel-Air Village, separated from
Kalayaan Avenue by a perimeter wall.

Local Government Code of 1991 delegates powers to local government units, authorizing legislative
bodies like Sangguniang panlalawigan, panlungsod, bayan, and barangay.

MMDA's claim challenged; court insists local government, not MMDA, has the power to regulate
private subdivision roads.

MMDA, created in 1995, administers metro-wide services, but lacks legislative powers like the MMC
(Metropolitan Manila Commission).

Court emphasizes the importance of a legal basis for government actions, proper delegation of
powers, and adherence to legal procedures.

Decision sets limits on MMDA's authority, preventing overreach, and reinforces the role of local
government in addressing local issues.
PBM Employees vs. PBM

The case of G.R. No. L-31195 in 1973 involves the Philippine Blooming Mills Employees
Organization (PBMEO) as petitioners against the Philippine Blooming Mills Co., Inc. and the Court of
Industrial Relations as respondents. The key events include PBMEO planning a mass demonstration,
the company warning against potential disruptions, and charges filed against petitioners for unfair
labor practices.

The court held that the petitioners' constitutional rights to freedom of speech and peaceful assembly
were violated. It emphasized the primacy of human rights over property rights and set a stringent
criterion for constitutional infringement. The court found no grave and immediate danger justifying
restrictions on the employees' rights and criticized the employer's focus on property rights over
human rights.

The court underscored that the employees were fighting for their survival against alleged abuses by
the local police and that the employer's plea for property preservation did not outweigh the
employees' constitutional rights. The ruling emphasized the importance of human rights in a
democratic society, stating that if human rights were subject to extinguishment over time, the Bill of
Rights would be rendered useless in limiting government power and preventing tyranny.

Overall, the case highlights the court's defense of constitutional rights, particularly freedom of
expression and peaceful assembly, against perceived abuses and demonstrates the enduring nature
of human rights in the face of property considerations.
DUNCAN ASSOCIATION VS. GLAXO, G.R. NO. 162994. SEPTEMBER 19, 2005

Challenge to Policy: Pedro A. Tecson contested Glaxo Wellcome Philippines, Inc.'s policy prohibiting
employees from marrying individuals employed by competitor companies.

Policy Details: Glaxo's policy mandated disclosure of such relationships, and employees facing a
conflict of interest were expected to resign voluntarily.

Tecson's Situation: Tecson, a medical representative, engaged in a relationship and later married an
employee of Astra Pharmaceuticals, a competitor of Glaxo.

Conflict Notification: Glaxo informed Tecson of the conflict and presented solutions, including a
transfer or preparation for employment outside the company.

Legal Dispute: Tecson resisted the proposed transfer, leading to a legal dispute between him and
Glaxo.

NCMB Decision: The National Conciliation and Mediation Board (NCMB) upheld Glaxo's policy and
Tecson's reassignment.

Court of Appeals Ruling: The Court of Appeals affirmed the NCMB decision, recognizing Glaxo's
right to protect trade secrets and prevent conflicts of interest.

Supreme Court Verdict: The Supreme Court upheld the legality of Glaxo's policy, rejecting Tecson's
claim of constructive dismissal.

Court Emphasis: The Court emphasized Glaxo's efforts to resolve the conflict and the impartial
application of its policy.

Reassignment Affirmed: The Court affirmed Tecson's reassignment, recognizing Glaxo's right to
protect its economic interests and the enforceability of employment contracts.

Equal Protection Clause: The court clarified that Glaxo's policy did not violate the equal protection
clause of the Constitution. It explained that equal protection commands are addressed only to the
state, and private conduct, even if discriminatory, does not violate the equal protection clause.
STAR PAPER CORPORATION V. SIMBOL

 Petitioner: Star Paper Corporation (Company)

 Respondents: Ronaldo D. Simbol, Wilfreda N. Comia, and Lorna E. Estrella (Employees)
 Issue: Whether the company policy prohibiting spouses from working in the same company is
valid or violates the rights of employees under the Constitution and the Labor Code.
 Key Facts:
 Star Paper Corporation is engaged in trading, mainly paper products.
 Employees Ronaldo D. Simbol, Wilfreda N. Comia, and Lorna E. Estrella were regular employees
of the company.
 Company policy, implemented in 1995, prohibits the hiring of relatives up to the 3rd degree and
requires one of the employees to resign if they marry each other.
 Simbol and Comia resigned after getting married to co-employees in compliance with the policy.
 Estrella resigned allegedly due to pressure and financial need after being accused of immoral
conduct.
 Legal Proceedings:
 Labor Arbiter Decision (May 31, 2001): Dismissed the complaint, upholding the company policy
as part of management prerogative.
 NLRC Decision (January 11, 2002): Affirmed the Labor Arbiter's decision.
 Court of Appeals Decision (August 3, 2004): Reversed NLRC decision, declared the policy illegal,
and ordered reinstatement with backwages.
 Supreme Court Decision: Affirmed the Court of Appeals, stating that the policy lacked a
reasonable business necessity and was an invalid exercise of management prerogative.
 Legal Interpretation:
 The company policy prohibiting spouses from working together is akin to an anti-nepotism
employment policy.
 The Court analyzed the policy's validity under Article 136 of the Labor Code, which prohibits
requiring a woman employee to resign upon marriage.
 Different interpretations of marital status discrimination were discussed, including the bona fide
occupational qualification exception.
 The Court emphasized the need for a reasonable business necessity to justify discriminatory
policies.
 The Court ruled that the company failed to establish a valid reason for the policy, rendering it an
invalid exercise of management prerogative.
 Outcome:
 The Court affirmed the invalidity of the company policy.
 Reinstatement with full backwages was ordered for Simbol, Comia, and Estrella.
 The Court considered Estrella's resignation as involuntary due to lack of evidence and ordered
her reinstatement.
upas v. CA- 193 SCRA 597, 1991 (late petition)

Resolution and Road Closure (1969):

In 1969, the Provincial Board of Catanduanes passed Resolution No. 158, closing an old road
leading to the new Capitol Building.

The closure involved exchanging parts of the road with private properties, with new concrete roads
laid on the exchanged properties.

Legal Challenge (1978):

In 1978, the petitioner filed a complaint challenging the closure, arguing that the land was a public
road owned by the province.

Allegations included the invalidity of Resolution No. 158 and deeds of exchange, claiming the
closure caused inconvenience.

Court Decisions:

Trial Court (1980): The trial court acknowledged the land as a "passageway" but upheld the authority
of the provincial board to close the road.

Court of Appeals: Affirmed the trial court's decision, stating the closure was valid under Republic Act
No. 5185 and Section 2246 of the Revised Administrative Code.

Petitioner's Claims (Before the Supreme Court):

The petitioner argued that Resolution No. 158 was not a closure order but an authority for barter or
exchange.

Contended that public roads' control belongs to Congress, not the provincial board.

The Supreme Court cited Republic Act No. 5185, particularly Section 11 (II) (a), which grants
municipal authorities the authority to close thoroughfares with the approval or direction of the
Provincial Board. Section 2246 of the Revised Administrative Code was also referenced,
emphasizing the need for indemnification when closing thoroughfares.

City Council Precedents:

The Supreme Court referred to precedents involving city councils' power to close streets. It cited
cases such as Cebu Oxygen and Acetylene Co., Inc. v. Bercilles and Favis vs. City of Baguio, where
city councils were recognized to have the authority to close streets and withdraw them from public
use.

Doctrine of Discretion:

The Supreme Court highlighted the discretionary power of the provincial board to close roads,
similar to the discretion granted to city councils. It noted that the closure of streets or roads is a
discretionary power, and courts typically refrain from interfering unless there is a clear case of
abuse, fraud, or collusion.

General Welfare Clause:

The construction of the new road was framed as being undertaken under the general welfare clause.
The court emphasized the benefits of the new road to the community, stating that the inconvenience
suffered by the petitioner was outweighed by the greater convenience and improvements brought
about by the new road.

Absence of Right to Compensation:

The Court applied the principle that one whose property does not directly abut the closed section of
a street generally has no right to compensation if reasonable access to the general system of streets
is still available. The inconvenience suffered was considered as a consequence that individuals must
endure for the greater welfare of the community.

The decision underscores the legal authority of the provincial board to close roads for the general
welfare, provided that affected individuals are indemnified. It also reinforces the discretionary power
of local authorities in making such decisions, guided by considerations of public benefit.
BANCO ESPAÑOL FILIPINO V. PALANCA

Engracio Palanca Tanquinyeng y Limquingco mortgaged properties to El Banco Espanol-Filipino but

passed away in China without returning to the Philippines.

Foreclosure proceedings were initiated, and notice by publication was required due to the defendant
being a non-resident.

It's unclear if the Clerk of Court complied with the requirement to send a copy of the summons to the
defendant's last known address in China.

Judgment by default was rendered after publication, and a public auction confirmed by the court
resulted in the bank as the highest bidder on August 7, 1908.

Seven years later, Vicente Palanca, administrator of the defendant's estate, filed a motion to set
aside the default judgment, alleging the court never acquired jurisdiction over the defendant or the
subject matter.

Issues:

Whether the lower court acquired jurisdiction over the defendant and the subject matter.

Whether due process of law was observed.

Ruling on Jurisdiction:

Jurisdiction may refer to the authority of the court over a type of action, the power over the parties, or
the power over the property in question.

The sovereign authority organizing a court determines its competency or jurisdiction.

Jurisdiction over the person is acquired by voluntary appearance or coercive legal process.

Jurisdiction over property may result from seizure under legal process or from legal proceedings
where the court's power is recognized.

How Jurisdiction is Acquired:

Actions to foreclose a mortgage are termed quasi in rem, sharing characteristics with actions in rem.

Quasi in rem proceedings involve naming an individual as the defendant, aiming to subject their
interest to the obligation or lien burdening the property.

The judgment in such proceedings is conclusive only between the parties.

Proceedings become personal if the defendant appears after publication but remain quasi in rem if
the defendant fails to appear.

Conclusion:
The court emphasized that foreclosure actions, being quasi in rem, should be considered with
reference to the principles governing actions in rem.

The distinction clarified the court's jurisdiction, particularly when the defendant failed to appear.

RE:PETITION FOR RADIO & TV COVERAGE (AMPATUAN CASE), A.M. NOS.10-11-5-SC

(GUIDELINES FOR PUBLICITY-JUDICIAL PROCEEDINGS)

Petitioners: National Union of Journalists of the Philippines (NUJP), ABS-CBN Broadcasting

Corporation, GMA Network, Inc., relatives of the victims, individual journalists, and members of the
academe.

Date of Filing: November 19, 2010

Facts: On November 23, 2009, the Maguindanao Massacre occurred, resulting in the death of 57
individuals, including 32 journalists. The accused, including Datu Andal Ampatuan, Jr., faced
charges for 57 counts of murder and rebellion. Almost a year later, various petitioners, including
media entities, filed a petition urging the Supreme Court to allow live television and radio coverage of
the trial, permit recording devices in the courtroom, and formulate reasonable guidelines.

Related Petition: A.M. No. 10-11-6-SC - National Press Club of the Philippines and Alyansa ng
Filipinong Mamamahayag filed a petition on November 22, 2010, seeking the designation of Branch
221 of RTC-Quezon City as a special court exclusively for the Maguindanao Massacre trial, with the
installation of video cameras in the courtroom for broadcasting.

A.M. No. 10-11-7-SC - President Benigno S. Aquino III expressed support for the petition to permit
television and radio broadcast of the trial through a letter dated November 22, 2010.

Contentions: Petitioners argued that the trial's intense media coverage necessitated a revisit of the
1991 and 2001 rulings prohibiting live television and radio coverage of court proceedings. They
emphasized the importance of transparency, freedom of the press, and the public's right to
information.

Principal Accused's Position: Datu Andal Ampatuan, Jr. filed a Consolidated Comment, expressing
concerns about the potential risks to due process resulting from live media coverage. He contended
that existing regulations were sufficient and an outright prohibition was necessary to protect the
accused's right to a fair trial.

Resolution: The Court partially granted the petition for live broadcast subject to specific guidelines. It
emphasized the need to balance constitutional guarantees with the fundamental rights of the
accused and the court's duty to control proceedings. The guidelines included restrictions on
coverage to avoid prejudicing the accused's right to due process.

Key Guidelines:

Media entities must apply to broadcast, ensuring technological readiness.

A single fixed compact camera shall be installed inconspicuously.

Broadcasting should be continuous, without commercial breaks, and in its entirety.

No voice-overs except brief annotations at the start or end of scenes.

Original audio-recording deposited in the National Museum and Records Management and Archives
Office.

A special committee created to study and recommend arrangements and regulations for live
broadcasts.

The ruling of the court in A.M. No. 10-11-5-SC, concerning the live television and radio coverage of
the Maguindanao Massacre trial, was a partial grant of the petition. The court allowed the live
broadcast of the trial proceedings with specific guidelines and restrictions. The court acknowledged
the importance of balancing constitutional guarantees, such as freedom of the press and the public's
right to information, with the fundamental rights of the accused and the court's duty to ensure a fair
trial.
FABELLA V. COURT OF APPEALS

G.R. No. 116695, October 23, 1995

Facts: On September 17, 1990, the Department of Education, Culture and Sports (DECS) Secretary
Isidro Cariño issued a return-to-work order to public school teachers who participated in mass
actions demanding various benefits. Administrative cases were filed against the teachers, including
charges of grave misconduct, gross neglect of duty, and violation of civil service laws.

The administrative hearings began on December 20, 1990, with the teachers' counsel objecting to
the committee's procedure. A subsequent lawsuit was filed, questioning the committee's guidelines
and alleging fraud and deceit. The DECS investigating committee rendered a decision on August 6,
1991, finding the teachers guilty and ordering their immediate dismissal.

Procedural History: The trial court dismissed the teachers' petition for certiorari and mandamus,
prompting an appeal. The Court of Appeals affirmed the trial court's decision. The teachers then
raised issues to the Supreme Court.

Issues:

Whether the Court of Appeals committed grave abuse of discretion in holding that the teachers were
denied due process.

Whether the Court of Appeals erred in strictly applying the provisions of R.A. No. 4670 (Magna Carta
for Public School Teachers) in the composition of the investigating committee.

Whether the Court of Appeals committed grave abuse of discretion in dismissing the appeal and
affirming the trial court's decision.

Ruling: The Supreme Court affirmed the decision of the Court of Appeals, holding that the teachers
were denied due process. The Court emphasized that in administrative proceedings, due process
includes notice, a real opportunity to be heard, a tribunal with competent jurisdiction, and a decision
supported by substantial evidence. The Court noted a serious flaw in the composition of the DECS
investigating committee – the absence of a representative of a teachers' organization, as required by
R.A. No. 4670.

The Court rejected the argument that R.A. No. 4670 was superseded by the Civil Service Decree,
stating that there was no inconsistency between the two laws. The Court concluded that the absence
of a representative of a teachers' organization deprived the teachers of their right to a fair hearing.
Consequently, the administrative proceedings were deemed void, and the teachers were ordered
reinstated with full benefits.

Significance: The case underscores the importance of due process in administrative proceedings,
particularly in cases involving public school teachers. It affirms the need for compliance with specific
procedural requirements, such as the representation of a teachers' organization in the investigating
committee, as mandated by R.A. No. 4670

. NON V. JUDGE DAMES

In the case of Ariel Non vs. Dames (185 SCRA 523), the petitioners, students at Mabini Colleges,
were denied re-enrollment for the academic year 1988-1989 due to their involvement in student
mass actions against the school. The court addressed several key points:

Constitutionally Protected Rights:

Petitioners invoked their rights to peaceable assembly and free speech, asserting that these rights
are not left behind at the school gate.

Academic freedom does not give schools the right to discriminate against students exercising their
constitutional rights.

Limitations on Student Rights:

While students have the right to free speech and assembly, conduct that materially disrupts
classwork or involves substantial disorder is not protected.

The court emphasized that students' exercise of rights does not make school authorities powerless
to discipline.

Circumventing Established Doctrine:

Despite the court's previous rulings, school authorities found new ways to deny re-enrollment, such
as refusing students readmission based on unrelated grounds like "academic deficiency."

Nature of the School-Student Contract:

The court emphasized that the contract between a school and its student is not an ordinary contract
but is imbued with public interest.

Students have the right to be enrolled for the entire duration of their expected course, except in
cases of academic deficiency or disciplinary violations.

Academic Freedom Not a Ground for Denying Rights:

The court rejected the notion that academic freedom allows schools to freely admit or deny students
for re-enrollment without proper justification.

Disciplinary Proceedings and Due Process:

The court noted that the petitioners were not afforded due process in the refusal of re-enrollment
based on failing grades.

Disciplinary proceedings must be commensurate with the offense and follow procedural due
process.

Moot and Academic Penalty:

The court considered the refusal of re-enrollment and the exclusion from the school for several
semesters as sufficient penalty for any breach of discipline related to the mass actions.

Principles and Contract Termination:

Students are considered enrolled for one semester, as stated in the Manual of Regulations for
Private Schools.

After the close of the semester, the school is no longer under contract with the students or teachers,
and compelling the school to enter into another contract is not warranted.

In summary, the court affirmed the importance of protecting students' constitutional rights,
emphasized the special nature of the school-student contract, and rejected attempts to circumvent
established legal principles in denying re-enrollment.
LAO GI ALIAS CHIA, JR. V. COURT OF APPEALS

In this case, the petitioners were facing deportation charges filed with the Commission on
Immigration and Deportation (CID). The charges were based on the cancellation of a previous
opinion by the Minister of Justice, which had affirmed the Filipino citizenship of Filomeno Chia, Sr.,
the father of the petitioners. Despite an earlier court decision dismissing a petition related to the
same issue, the CID proceeded with deportation proceedings.

The key points and rulings in this case include:

Background:

Opinion No. 191 in 1958 affirmed Filomeno Chia, Sr.'s Filipino citizenship.

Opinion No. 147 in 1980 canceled Opinion No. 191, alleging fraud.

CID filed deportation charges against the Chia family for refusing to register as aliens.

Court Decision on Prior Case:

The Supreme Court had dismissed a previous petition (G.R. No. 59619) related to the same issue.

The petitioners argued that the issues in the previous case were different from those in the
subsequent civil case.

Deportation Proceedings:

The CID had the authority to hear the deportation case and determine citizenship.

A hearing was required before an alien could be ordered deported.

Requirement to Register as Aliens:

The power to require an alien to register must be based on a positive finding that the person is an
alien.

The CID needed to determine citizenship before directing registration as aliens.

Due Process in Deportation Proceedings:

Deportation proceedings should adhere to constitutional principles of due process.

Rules of criminal procedure, particularly those on warrants, arrests, and bail, were applicable to
deportation cases.

Role of Private Prosecutors:

Private prosecutors should not be allowed to intervene in deportation cases.

Deportation is a matter solely within the concern of the state, and private parties have no right to
intervene.

Court's Ruling:

The Court granted the petition, setting aside the CID's order and directing the CID to continue the
deportation case.

The CID was instructed to determine the petitioners' citizenship and, if found to be aliens, decide
whether deportation or registration as aliens was warranted.

This case emphasizes the importance of due process in deportation proceedings, the need for a
positive finding of alien status before registration requirements, and the limited role of private
prosecutors in deportation cases.
Case Digest: Nazario v. Municipality of Pagbilao

Title: Eusebio Nazario v. Municipality of Pagbilao

G.R. No.: [Insert Appropriate G.R. Number]

Date: [Insert Date]

Ponente: [Name of the Judge or Justice]

Facts: Eusebio Nazario is charged with violating Municipal Ordinance Nos. 4, 15, and 12 of the
Municipality of Pagbilao, Quezon, for allegedly failing to pay municipal taxes on a fishpond he owns.
The charges pertain to the years 1964, 1965, and 1966. The prosecution argues that Nazario, as the
fishpond operator, refused to pay the required taxes despite repeated demands. The defense
contends that Nazario is a lessee of a government-owned fishpond and disputes the validity of the
municipal ordinances.

Issues:

Whether the municipal ordinances are ambiguous and uncertain.

Whether the municipal ordinances are unconstitutional for being ex post facto.

Whether the municipal ordinances cover only owners or overseers of fishponds of private ownership.

Whether the municipal ordinances can be enforced beyond the territorial limits of Pagbilao and cover
non-residents.

Ruling:

The court rejects the argument that the ordinances are vague, emphasizing that Nazario, as the
actual operator of the fishpond, falls within the scope of "owner or manager." The court finds that the
ordinances provide clear standards for tax payment and dates thereof.
The court dismisses the claim of ex post facto application, stating that the amendments to the
ordinances are curative measures, granting amnesty to delinquent operators, and not imposing
retroactive penalties.

The court clarifies that the ordinances are applicable to fishpond lessees like Nazario, considering
his role as the operator and beneficiary of profits.

The court affirms the power of the municipal council to impose privilege taxes on fishpond
maintenance, distinguishing them from taxes on property. The ordinances are upheld as valid
revenue measures.

Disposition: The appeal is dismissed, and the trial court's decision is affirmed. Eusebio Nazario is
found guilty of violating Municipal Ordinance Nos. 4, 15, and 12, and is sentenced to pay a fine and
costs.

Title: United Harbor Pilots Association v. Philippine Ports Authority

G.R. No.: [Insert Appropriate G.R. Number]

Date: [Insert Date]

Ponente: [Name of the Judge or Justice]

Facts: The case involves a challenge to Administrative Order No. 04-92 (PPA-AO No. 04-92) issued
by the Philippine Ports Authority (PPA). PPA-AO No. 04-92 limited the term of appointment of harbor
pilots to one year, subject to yearly renewal or cancellation, aiming to improve pilotage services and
instill effective discipline. Respondent harbor pilots, through associations, questioned the validity of
the administrative order, arguing that it violated their right to exercise their profession and their right
to due process. The PPA, created in 1974, had previously issued PPA-AO-03-85 in 1985, which
outlined rules and regulations governing pilotage services.

Issues:

Whether PPA-AO No. 04-92 violates the harbor pilots' right to exercise their profession.

Whether PPA-AO No. 04-92 infringes on the harbor pilots' right to due process of law.

Whether the issuance of PPA-AO No. 04-92 lacked ample prior consultation.

Ruling:

The court finds that PPA-AO No. 04-92 unduly restricts the harbor pilots' right to enjoy their
profession, particularly by introducing annual cancellations and evaluations, which was not present
in the prior regulations. The order is deemed an unreasonable deprivation of property without due
process of law.

The court holds that the adoption of PPA-AO No. 04-92 failed to observe due process in terms of
both procedural and substantive aspects. Procedurally, the court emphasizes that notice and
hearing are essential only in quasi-judicial functions, not in the issuance of rules and regulations.
Substantively, the order unreasonably curtails the harbor pilots' vested right to practice their
profession until retirement.

The court agrees with the respondents that PPA-AO No. 04-92 is unnecessary and duplicative, as it
essentially covers matters already addressed by PPA-AO-03-85. The lack of substantial additions
renders PPA-AO No. 04-92 unreasonable and constitutionally infirm.

Disposition: The court dismisses the petition, affirming the trial court's decision declaring PPA-AO
No. 04-92 null and void. No pronouncement as to costs.

Case Digest: City of Manila v. Court of Appeals

G.R. No.: Insert Appropriate G.R. Number

Date: Insert Date
Ponente: Name of the Judge or Justice

Facts: The City of Manila filed a complaint for unlawful detainer against the Army and Navy Club
(ANC) over a land lease dispute on Roxas Boulevard. The Metropolitan Trial Court ruled in favor of
Manila, and the decision was upheld by the Regional Trial Court. ANC filed a supersedeas bond to
stay execution and appealed. The City of Manila sought ex parte execution, claiming finality under
RA 6031. Judge Wilfredo Reyes granted the motion, and ANC was served with a writ of execution.

Issues:

Whether the Regional Trial Court's decision had become final and executory.

Whether execution pending appeal was justified.

Whether the Court of Appeals erred in annulling the writ of execution issued by the Regional Trial
Court.

Ruling:

The Court held that the decision had not become final and executory as ANC still had time to appeal.

Execution pending appeal was not justified as there was no urgency outweighing the potential injury
to ANC during the appeal.

The Court of Appeals did not err in annulling the writ of execution, considering the premature
execution and lack of justification.
Outcome: The petition was dismissed, and the decision of the Court of Appeals annulling the writ of
execution was affirmed. No costs were imposed.

Multiple administrative complaints were filed against C/Insp. Lazaro Torcita, a police officer, for
various offenses, including conduct unbecoming of a police officer, grave threats, abuse of authority,
and violation of COMELEC gun ban. The incidents stemmed from a confrontation between Torcita
and complainants during a pursuit that ended at Hacienda Aimee. The Summary Dismissal Board
consolidated the cases into one major complaint. The Board found Torcita guilty of simple irregularity
in the performance of duty and imposed a 20-day suspension.

Issues:

Whether the offense of "simple irregularity in the performance of duty" is necessarily included in the
charge of "conduct unbecoming of a police officer."

Whether the decision of the Summary Dismissal Board has become final and executory.

Ruling:

The Court held that the offense of "simple irregularity in the performance of duty" is not necessarily
included in the charge of "conduct unbecoming of a police officer." The charges must be specifically
indicated to comply with due process.

The Court affirmed the decision of the Court of Appeals, stating that the decision of the Summary
Dismissal Board did not become final and executory because Torcita was found guilty of an offense
for which he was not properly charged.

Outcome: The decision of the Court of Appeals affirming the annulment of the Summary Dismissal
Board's decision was upheld. Torcita's petition was dismissed, and the ruling stated that the decision
did not become final and executory due to the lack of proper charges and violation of due process.

Lack of Specific Charges: The court highlighted that Torcita was not properly informed of the specific
charges against him. The original twelve administrative cases filed against him did not include the
specific charge of being drunk while on duty. The absence of notification on this particular offense
during the summary dismissal proceedings was considered a violation of due process.

Absence of Opportunity to Defend: Due to the failure to specify the charge related to being drunk
while on duty, Torcita was denied the opportunity to adequately defend himself against this particular
accusation. He was entitled to know the charges he was facing so that he could present a defense
and provide evidence in his favor.

Void Judgment: The court declared that the decision of the Summary Dismissal Board, finding
Torcita guilty of an offense for which he was not properly charged, rendered the decision void. It
emphasized that a void judgment, resulting from a lack of due process, never acquires finality.

Importance of Factual Findings: The court criticized the cursory conclusion of the Dismissal Board
regarding Torcita's alleged breach of internal discipline by consuming alcoholic drinks while on duty.
It stressed the importance of substantiated factual findings to support any charges, emphasizing that
the decision should contain a brief statement of material facts and findings.

In summary, the accused was deprived of due process primarily because he was not properly
notified of the specific charge of being drunk while on duty, leading to a lack of opportunity to defend
himself against this accusation. This failure violated the fundamental principles of due process in
administrative proceedings.

n the case of G.R. No. 148560, dated November 19, 2001, involving Joseph Ejercito Estrada, the
key facts and ruling are as follows:

Facts:

Joseph Ejercito Estrada, a former President and the highest-ranking official prosecuted under RA
7080, challenged the constitutionality of the Plunder Law.

Estrada raised concerns about the law's vagueness, the absence of the reasonable doubt standard,
and the elimination of mens rea in crimes already punishable under the Revised Penal Code.

He argued that these aspects violated his fundamental rights to due process and to be informed of
the nature and cause of the accusation against him.

Issue:

The main issue revolved around whether the Plunder Law was unconstitutional due to vagueness.

Ruling:

The court ruled that the Plunder Law was not unconstitutional for being vague.

It emphasized that the law contained ascertainable standards and well-defined parameters, allowing
the accused to understand the nature of the violation.

The court clarified that a statute is only considered vague if it lacks comprehensive standards,
making it difficult for individuals to determine its meaning and application.

The "void-for-vagueness" doctrine, which challenges laws that are utterly unclear on their face, was
deemed inappropriate in this case.
The court highlighted that the Plunder Law provided a comprehensive guide, and as one of the
senators who voted for its passage, Estrada was aware of the extensive deliberations and legal
implications involved.

In summary, the court rejected the argument that the Plunder Law was unconstitutional due to
vagueness, asserting that the law had clear standards and had undergone thorough legislative
scrutiny

Case Digest: Gonzales v. Ateneo de Davao University

G.R. No. 148560, November 19, 2001

Facts: Lorlene Gonzales, an elementary schoolteacher at Ateneo de Davao University, faced

dismissal based on allegations of corporal punishment. The Investigative Committee, organized by
the school, did not revise its rules despite Gonzales' demand, leading her to refuse participation. The
committee proceeded with the investigation, resulting in her termination.

Gonzales filed a complaint for illegal dismissal, and the Executive Labor Arbiter deemed the
dismissal illegal due to lack of factual basis. The National Labor Relations Commission (NLRC)
reversed this decision, declaring the dismissal valid but recommending the extension of retirement
benefits.

Issues:

Whether there was a violation of due process in the termination proceedings.

Whether substantial evidence supports the validity of Gonzales' dismissal.

Ruling: The Supreme Court ruled in favor of Gonzales on both issues.

Reasoning:

The Court emphasized the importance of due process, noting that Gonzales had the right to demand
compliance with procedural and substantial due process. The refusal to revise investigation rules
violated her right to confront and cross-examine accusers, rendering the investigation flawed.
The Court questioned the probative value of evidence presented by Ateneo, emphasizing that
hearsay evidence and the failure to refute claims of "pre-prepared" affidavits raised doubts about the
evidence's credibility. The Court ruled that Ateneo failed to prove, by substantial evidence, that
Gonzales had committed the alleged offense.

Conclusion: The Supreme Court reversed the NLRC decision, reinstating the Executive Labor
Arbiter's ruling that Gonzales' dismissal was illegal. It affirmed her entitlement to separation pay,
back wages, and 13th-month pay. The Court highlighted the significance of protecting employees
from unjustified dismissals and upheld the constitutional right to security of tenure.

Case Digest: Gravides v. COMELEC

G.R. No. 203055, March 10, 2014

Facts:

Background: The case involves an election protest filed by Pedro C. Borjal against Isabelita P.
Gravides for the position of Punong Barangay in Barangay U.P. Campus, Diliman, Quezon City
during the October 25, 2010 Barangay and Sangguniang Kabataan (SK) Elections.

Election Results: Gravides was initially declared the winner with 2,322 votes against Borjal's 2,320
votes.

Election Protest: Borjal filed an election protest citing irregularities, fraud, and misreading of votes,
among other allegations.

Dismissal by MeTC: The Metropolitan Trial Court (MeTC) dismissed the election protest on
December 7, 2010, for non-compliance with Section 4, Rule 9 of A.M. No. 07-4-15-SC, pertaining to
the contents of the preliminary conference brief.

Appeal to COMELEC: Borjal appealed to the Commission on Elections (COMELEC), arguing that
the MeTC erred in applying the Rules of Civil Procedure and in dismissing the case prematurely.
COMELEC Resolution: The COMELEC's First Division, in its Resolution dated August 25, 2011,
granted Borjal's appeal, annulling the MeTC's order and remanding the case for further proceedings.
It emphasized that Borjal's preliminary conference brief substantially complied with the rules.

Motion for Reconsideration: Gravides filed a motion for reconsideration, but it was denied by the
COMELEC En Banc on November 23, 2011, citing non-payment of motion fees.

Finality of Decision: The Entry of Judgment dated November 24, 2011, declared that the Resolution
dated August 25, 2011, had become final and executory as of September 17, 2011.

Issues:

Whether the COMELEC committed grave abuse of discretion in reversing the MeTC's dismissal
order.

Whether the COMELEC committed grave abuse of discretion in considering the narrow lead of the
petitioner in reversing the MeTC's order.

Whether the COMELEC committed grave abuse of discretion in giving a liberal construction to the
rules governing the filing of preliminary conference briefs.

Whether the COMELEC committed grave abuse of discretion in blaming the MeTC for the failure to
comply with the mandatory requisites under the rules.

Whether the COMELEC committed grave abuse of discretion in denying the motion for
reconsideration despite the alleged influence of counsel for the private respondent.

Ruling: The Supreme Court, in dismissing the petition, held that the COMELEC did not commit grave
abuse of discretion. It considered the circumstances justifying a more reasonable and liberal
application of the rules, including the MeTC's misleading Notice of Preliminary Conference. The
Court emphasized the importance of determining the true will of the electorate and the need to dispel
uncertainties in election cases.

Conclusion: The decision affirms the COMELEC's Resolution, upholding the nullification of the
MeTC's dismissal order and remanding the case for further proceedings. The Court underscores the
significance of adhering to rules while recognizing the need for a reasonable and liberal application
to serve the interest of justice, particularly in election cases.
Title: Ang Tibay, et al. v. Court of Industrial Relations, et al.

G.R. No. L-46496, February 27, 1940

Facts:

The case involves a motion for reconsideration filed by the Solicitor-General on behalf of the
respondent Court of Industrial Relations, disputing certain legal conclusions.

The respondent National Labor Union, Inc. files a motion to vacate the judgment, alleging various
issues against Ang Tibay, a company.

Issues:

Whether the Court of Industrial Relations lacked substantial evidence and failed to observe due
process in its original decision.

Whether the Court of Industrial Relations properly exercised its functions as an administrative body
with both executive and judicial powers.

Whether the evidence presented supported the exclusion of 89 laborers based on their union
affiliation.
Whether the Supreme Court should grant the motion for a new trial filed by the respondent National
Labor Union, Inc.

Ruling:

The Supreme Court emphasizes the dual role of the Court of Industrial Relations as an
administrative body with both executive and judicial functions.

The Court criticizes the lack of substantial evidence and due process in the original decision,
emphasizing the importance of respecting the parties' rights, particularly the right to a fair hearing.

The Supreme Court grants the motion for a new trial filed by the respondent National Labor Union,
Inc., directing the Court of Industrial Relations to reopen the case, receive relevant evidence, and
proceed in accordance with due process.

The decision underscores the need for the Court of Industrial Relations to actively enforce the law
while adhering to fundamental principles, including the right to a fair hearing and the requirement of
substantial evidence.

Conclusion: The Supreme Court's decision in Ang Tibay v. Court of Industrial Relations highlights
the importance of due process and substantial evidence in administrative proceedings. It
emphasizes the unique role of the Court of Industrial Relations and underscores the need for a fair
hearing, ultimately granting a new trial to ensure justice

The petitioner is the President of the 3A Apparel Corporation. He filed a complaint before the
National Bureau of Investigation (NB!) charging the respondents of falsification of two deeds of real
estate mortgage submitted to the Metropolitan Bank and Trust Company (A4etrobank). Both deeds
of real estate mortgage were allegedly signed by the petitioner, one in his own name while the other
was on behalf of 3A Apparel Corporation.

According to the petitioner, the respondents were employees of Metrobank. Respondents Jaime T.
Dee and Edwin So signed the two deeds of real estate mortgage as witnesses; respondents Ramon
S. Miranda and Enriqueto I. Magpantay notarized the deeds of real estate mortgage signed by the
petitioner in his own behalf and for the corporation, respectively. The signature of respondent Larry
Macillan, on the other hand, appeared in the deeds of real estate mortgage which he submitted to the
Office of the Registrar of Deeds for San Juan, Metro Manila. Based on these deeds, Metrobank
2

foreclosed the two properties securing the 3A Apparel Corporation’s loan. 3

After investigation, the NBI filed a complaint with the City Prosecutor of Makati (city prosecutor)
charging the respondents of the crime of forgery and falsification of public documents. The NBI
supported the complaint with the Questioned Documents Report No. 746-1098 (questioned
documents report) issued by its Questioned Documents Division. The questioned documents report
states that the signatures of the petitioner which appear on the questioned deeds are not the same
as the standard sample signatures he submitted to the NBI. 4
The respondents argued in their counter-affidavits that they were denied their right to due process
during the NBI investigation because the agency never required them and Metrobank to submit the
standard sample signatures of the petitioner for comparison. The findings contained in the
5

questioned documents report only covered the sample signatures unilaterally submitted by the
petitioner as compared with the signatures appearing on the two deeds of real estate mortgage. An
examination of the signatures of the petitioner which appear in several documents in Metrobank’s
possession revealed that his signatures in the questioned deeds are genuine. The respondents also
6

argued that the examination of the documents was conducted without the original copies of the
questioned deeds of real estate mortgage.

We find no merit in the respondent’s claim that they were denied due process when they were not
informed by the Secretary of Justice of the pendency of the petitioner’s appeal. The essence of due
process is simply the opportunity to be heard. What the law prohibits is not the absence of previous
notice but its absolute absence and lack of opportunity to be heard. Sufficient compliance with the
requirements of due process exists when a party is given a chance to be heard through his motion
for reconsideration.28