DOCTRINES/PRINCPLES: LTL Cases
Philippine British Assurance vs. Intermediate Appelate Court
The rule, founded on logic, is a colorally principle that general words and
phrases in a statute should ordinarly be accorded their natural and
general significance.
People vs. Cabral
In reiterating the rules outlining the duties of a judge in determining the
merit of an application for bail, it is observed that respondent judge did
disregard certain pieces of evidence for the prosecution which should
have been considered. This is a clear case of non sequitur where the
order of the respondent judge was not arrived at as a product of a logical
process as prescribed by the Rules.
People vs. Escobar
The Supreme Court said, “Every decision of a court of record shall clearly
and distinctly state the facts and the law on which it is based” and that the
decision of the lower court failed on this standard. “The inadequacy
stems primarily from the respondent’s judge tendency to generalize and
to form conclusions without detailing the facts from which conclusion are
deduced. Thus, he concluded that the mataerial allegations of the
Amendend Information were the facts without specifying which of the
testimonies or exhibits supported this conclusion. He rejected the
testimony of accused appelant Escober because it awas allegedly replete
with contradictions without pointing out what there contradictions consist
of or what “vital details” Escober shoud have recalled as a credible
witness.
Gamido vs. CA
The High Court noted that the witness, owing to his long position as
custodian of the records of Malacanang Palace, is very well familiar not
only of the signature of the sitting president but the signatures of previous
presidents he had the privilege of serving under.
It is also declared that under the Rules of Court, it is not required that the
person identifying the handwriting of another must have seen the latter
write the document or sign it, but it is enough, if the witness has seen
purporting to be the subject’s upon which it has acted or been charged.
Penalber vs. Ramos
Burden oif proof is the duty of any party to present evidence to establish
his claim or defense by the amount of evidence required by the law,
which is preponderance of evidence in civil case.
MOF Company vs. Shin Yang Brokerage
Basic is the rule in evidence the burden of proof lies upon him who
asserts it, not upon who denies, since by the nature of thinfs, he who
denies a fact cannot produce any proof of it.
VSD Realty vs. Uniwide Sales
In civil cases, the specific rule as to the burden of proof is that the plaintiff
has the burden of proving the material allegations of the complainant
which are denied by the answer; and the defendant has the burden of
proving the material allegations in his answer, which sets up the new
matter as a defense.
Monticalbo vs. Maraya
In administrative proceedings, the burden of proof that respondent
committed the acts complained of rests on the complainant.
Cereno vs. CA
In medical negligences, it is settled that the complainant has the burden
of establishing breach of duty on the part of the doctors or surgeons. It
must be proven the such breach of duty has a causal connection to the
resulting death of the patient.
Claravall vs. Lim
It is settled that the party alleging a fact has the burden of proving it and
mere allegation is not evidence.
Aba vs. De Guzman
According to the equipoise doctrine, when the evidence of the parties are
evenly balanced or there is doubt on which side the evidence
preponderates, the decision should be against the party with the burden
of proof.
OCA vs. Gutierrez
The burden of proof is upon the party who alleges the truth of his claim or
defense or any fact in issue.
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Country Bnakers Insurance Corporation vs. Lagman
The best evidence rule as encapsulated in Rule 130, Sec 3, of the
Revised Rules of Civil Procedure applies only when the content of such
document is the subject of the inquiry.
When the issues is only as to whether such documenta was actually
executed, or exists, or on the circumstances relevant to or surrounding its
execution, the best evidence rule does not apply and testimonial
evidence is admissible. Moreover, under the best evidence rule, the
original document must be produced whenever its contents are the
subject of inquiry; A photocopy, being a mere secondary evidence, is not
admissible unless it is shown that the original is unavailable.
Gaw vs. Chua
Any other substitutionary evidence is likewise admissible without need to
acount for the original. Moreover, production of the original may be
dispensed with, in the trial court’s discretion, whenever the opponent
does not bona fide dispute the contents of the document and no other
useful purpose will be served by requiring production.
Ramos vs. Obispo
Note, however, that preponderance of evidence is the weight, credit, and
value of the aggregate evidence on either side and is usually considered
to be synonymous with the term “greater weight of the evidence” or
“greater weight of the credible evidence”
People vs. De Guzman
Evidence is deemed admissible if it is relevant to the issue and more
importantly, if it is not excluded by provision of law or by the Rules of
Court. As to relevance, such evidence must have such a relation to the
fact in issue as to induce belief in its existence and non-existence.
Evidence to be believed must proceed not only from the mouth of a
credible witness but must be credible in itself as to hurdle the test of
conformity with the knowledge and common experience of mankind.
People vs. Taguibaya
Testimony is generally confined to a personal knowledge, and therefore
excludes hearsay. Thus, a witness can testify only to those facts which
he knows of his personal knowledge which are derived from his own
perception, except as otherwise provided under the Rules of Court.
The direct appreciation of testimonial demeanor during examination,
veracity, sincerity, and candor was foremost the trial court’s domain, not
that of a reviewing court that had no similar access to the witness at the
time they testified.
People vs. Ochoa
This is known as the hearsay rule. The law, however, provides for
specific exceptions to the hearsay rule. One of the exceptions is the
entries in official records made in the performance of duty by a public
officer. In other words, official entries are admissible in evidence
regardless whether the officer or person who made them was presented
and testified in court, since these entries are considered prima facie
evidence of the facts stated therein. Other recognized reason for this
exception are necessity and trustworthiness. The necesity consists in the
inconvenience and difficulty of requiring the official’s attendnace as a
witness to testify the innumerable transactions in the course of his duty.
This will also unduly hamper public business. The trustworthiness
consists in the presumption of regularity of performance of official duty by
a public officer.
People vs. Malngan
The credibility given by trial courts to prosecution witness is an important
aspect of evidence which appelate courts can rely on because of its
unique opportunity to observe them, particularly their demeanor, conduct,
and attitude, during the direct and cross-examination by counsels.
People vs. Astudillo
This is because the trial judge has unique opportunity, denied to the
appelate court, to observe the witnesses and to note their demeanor,
conduct and attitude under direct and cross-examination.
Santiago vs. Valenzuela
Stare decisis et non quieta movere. Srand by the decisions and disturb
not what is settled.
Lambino vs. Comelec
The maxim stare decisis et non quieta movere translates “stand by the
decisions and disturb not what is settled.” As used in our jurisprudence, it
means that once this court has laid down a principle of law as applicable
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to a certain state of facts, it would adhere to that principle and apply it to
future cases in which the facts are substantially the same as in the earlier
controversy. There is considerable literature about whether this doctrine
of stare decisis is a good or bad one, whether this doctrine is usually
justified by arguments which focus on the desirability of stability and
certainty in the law and also by notions of justice and fairness. It would be
a gross injustice to decide alternate cases on opposite princoples.
Fermin vs. People
It is based on the principle that once a question of law has been
examined and decided, it should be deemed settled and closed to further
argument.
Ting vs. Velez-Ting
The doctrine of adherence to precedents or stare decisis was applied by
the English courts and was later adopted by the United States.
Chong vs. Secretary of Labor
This is the doctrine that, when a court has once laid down a principle, and
apply it to all future cases, where facts are substantially the same,
regardless of whether the parties and properties are the same. Follow
past precedents and do not distrub what has been settled. Matters alread
decided on the merits cannot be subject of litigation again. But note that
this rule does nor elicit blind adherence to the precedents.
Nielson and Co. vs. Lepanto Consolidated Mining
The rule of stare decisis cannot be invoked when there is no analogy
between the material facts of the decision relied upon and those of the
instant case.
Republic vs. Nillas
The doctrine of stare decisis compels respect for settled jurisprudence,
especially absent any compelling argument to do otherwise.
Pesca vs. Pesca
The high court found no merit in the petition. Stated Art 8, NCC. Legis
interpretado legis vim obtinet – that the interpretation placed upon the
written law by a competent court has the force of law. It is only when a
prior ruling of this Court finds itself later overruled, and a different view is
adopted, that the new doctrine may have to be applied prospectively in
favor of the parties who have reliaed on the old doctrine and have acted
in good faith in accordance therewith under the familiar rule of “lex
prospicit, non respicit”.
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