2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
/ ACKNOWLEDGMENTS /
Dyannah Alexa Marie Ramacho
Project Jurisprudence – Philippines
Supreme Court E-Library
The LAWPHiL Project
/ Civil Law /
1
2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
/ ACKNOWLEDGMENTS /
Dyannah Alexa Marie Ramacho
Project Jurisprudence – Philippines
Supreme Court E-Library
The LAWPHiL Project
/ Civil Law /
2
2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
/ READ ME FIRST! /
There is no penned case recorded in the following months and year April 2020 and May 2020.
The author is not in any way connected or related to the Supreme Court or
to Justice Marvic Leonen.
/ Civil Law /
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
CASE DOCTRINES
ALEJANDRO V. TANKEH vs. DEVELOPMENT BANK OF THE PHILIPPINES
G.R. No. 171428 / November 11, 2013
To justify an award for exemplary damages, the wrongful act must be accompanied
by bad faith, and an award of damages would be allowed only if the guilty party acted
in a wanton, fraudulent, reckless or malevolent manner. In this case, this Court finds
that respondent x x x acted in a fraudulent manner through the finding of dolo
incidente due to his failure to act in a manner consistent with propriety, good morals,
and prudence.
REX M. TUPAL vs. JUDGE REMEGIO V. ROJO
A.M. No. MTJ-14-1842 / February 24, 2014
Municipal trial court judges cannot notarize affidavits of cohabitation of parties whose
marriage they will solemnize.
ARCO PULP AND PAPER CO., INC. vs. QUALITY PAPERS & PLASTIC
PRODUCTS ENTERPRISES
G.R. No. 206806 / June 25, 2014
Novation must be stated in clear and unequivocal terms to extinguish an obligation.
It cannot be presumed and may be implied only if the old and new contracts are
incompatible on every point.
AFP RETIREMENT AND SEPARATION BENEFITS SYSTEM [AFP-RSBS] vs.
REPUBLIC OF THE PHILIPPINES
G.R. No. 180086 / July 2, 2014
The period of possession prior to the declaration that land is alienable and disposable
agricultural land is included in the computation of possession for purposes of
acquiring registration rights over a property if the land has already been declared as
such at the time of the application for registration.
CELERINA J. SANTOS vs. RICARDO T. SANTOS
G.R. No. 187061 / October 08, 2014
The proper remedy for a judicial declaration of presumptive death obtained by
extrinsic fraud is an action to annul the judgment. An affidavit of reappearance is not
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
the proper remedy when the person declared presumptively dead has never been
absent.
CARLOS A. LORIA vs. LUDOLFO P. MUÑOZ, JR.
G.R. No. 187240 / October 15, 2014
No person should unjustly enrich himself or herself at the expense of another.
Unjust enrichment exists, according to Hulst v. PR Builders, Inc., "when a person
unjustly retains a benefit at the loss of another, or when a person retains money or
property of another against the fundamental principles of justice, equity and good
conscience." The prevention of unjust enrichment is a recognized public policy of the
State, for Article 22 of the Civil Code explicitly provides that "[e]veryperson who
through an act of performance by another, or any other means, acquires or comes
into possession of something at the expense of the latter without just or legal ground,
shall return the same to him." It is well to note that Article 22 "is part of the chapter
of the Civil Code on Human Relations, the provisions of which were formulated as
basic principles to be observed for the rightful relationship between human beings
and for the stability of the social order; designed to indicate certain norms that spring
from the fountain of good conscience; guides for human conduct that should run as
golden threads through society to the end that law may approach its supreme ideal
which is the sway and dominance of justice."
REMIGIO D. ESPIRITU vs. LUTGARDA TORRES DEL ROSARIO
G.R. No. 204964 / October 15, 2014
Lands classified as non-agricultural in zoning ordinances approved by the Housing
and Land Use Regulatory Board or its predecessors prior to June 15, 1998 are outside
the coverage of the compulsory acquisition program of the Comprehensive Agrarian
Reform Law. However, there has to be substantial evidence to prove that lands
sought to be exempted fall within the non-agricultural classification.
ROSARIO MATA CASTRO vs. JOSE MARIA JED LEMUEL GREGORIO
G.R. No. 188801 / October 15, 2014
The policy of the law is clear. In order to maintain harmony, there must be a showing
of notice and consent. This cannot be defeated by mere procedural devices. In all
instances where it appears that a spouse attempts to adopt a child out of wedlock,
the other spouse and other legitimate children must be personally notified through
personal service of summons. It is not enough that they be deemed notified through
constructive service.
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ONOFRE ANDRES vs. PHILIPPINE NATIONAL BANK
G.R. No. 173548 / October 15, 2014
A bank that accepts a mortgage based upon a title which appears valid on its face
and after exercising the requisite care, prudence, and diligence appropriate to the
public interest character of its business can be deemed a mortgagee in good faith.
The subsequent consolidation of title in its name after a valid foreclosure shall be
respected notwithstanding later proof showing that the title was based upon a void
transaction.
AMADA COTONER-ZACARIAS vs. SPOUSES ALFREDO AND THE HEIRS
REVILLA OF PAZ REVILLA
G.R. No. 190901 / November 12, 2014
Well-settled is the rule that "conveyances by virtue of a forged signature ... are void
ab initio [as] [t]he absence of the essential [requisites] of consent and cause or
consideration in these cases rendered the contract inexistent[.]"
JUAN P. CABRERA vs. HENRY YSAAC
G.R. No. 166790 / November 19, 2014
Unless all the co-owners have agreed to partition their property, none of them may
sell a definite portion of the land. The co-owner may only sell his or her proportionate
interest in the co-ownership. A contract of sale which purports to sell a specific or
definite portion of unpartitioned land is null and void ab initio.
HEIRS OF GREGORIO LOPEZ vs. DEVELOPMENT BANK OF THE PHILIPPINES
G.R. No. 193551 / November 19, 2014
To reiterate, the protection accorded to mortgagees in good faith cannot be extended
to mortgagees of properties that are not yet registered or registered but not under
the mortgagor’s name.
FLORENTINO W. LEONG AND ELENA LEONG vs. EDNA C. SEE
G.R. No. 194077 / December 3, 2014
Factual findings of lower courts are generally deemed conclusive and binding upon
this court. In any event, "even if the procurement of title was tainted with fraud and
misrepresentation, such defective title may be the source of a completely legal and
valid title in the hands of an innocent purchaser for value."
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
PHILIPPINE NATIONAL BANK vs. CARMELITA S. SANTOS
G.R. No. 208293 / December 10, 2014
G.R. No. 208295
The standard of diligence required of banks is higher than the degree of diligence of
a good father of a family.
THE WELLEX GROUP, INC. vs. U-LAND AIRLINES, CO., LTD.
G.R. No. 167519 / January 14, 2015
In one case, “The cardinal rule in the interpretation of contracts is embodied in the
first paragraph of Article 1370 of the Civil Code: “[i]f the terms of a contract are clear
and leave no doubt upon the intention of the contracting parties, the literal meaning
of its stipulations shall control.” This provision is akin to the “plain meaning rule”
applied by Pennsylvania courts, which assumes that the intent of the parties to an
instrument is “embodied in the writing itself, and when the words are clear and
unambiguous the intent is to be discovered only from the express language of the
agreement.” It also resembles the “four corners” rule, a principle which allows courts
in some cases to search beneath the semantic surface for clues to meaning. A court's
purpose in examining a contract is to interpret the intent of the contracting parties,
as objectively manifested by them. The process of interpreting a contract requires
the court to make a preliminary inquiry as to whether the contract before it is
ambiguous. A contract provision is ambiguous if it is susceptible of two reasonable
alternative interpretations. Where the written terms of the contract are not
ambiguous and can only be read one way, the court will interpret the contract as a
matter of law. If the contract is determined to be ambiguous, then the interpretation
of the contract is left to the court, to resolve the ambiguity in the light of the intrinsic
evidence.”
STRONGHOLD INSURANCE COMPANY, INC. vs. SPOUSES RUNE and LEA
STROEM
G.R. No. 204689 / January 21, 2015
It is settled that the surety’s solidary obligation for the performance of the principal
debtor’s obligation is indirect and merely secondary. Nevertheless, the surety’s
liability to the “creditor or promisee of the principal is said to be direct, primary and
absolute; in other words, he is directly and equally bound with the principal.”
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HOME GUARANTY CORPORATION
CORPORATION
G.R. No. 168616 / January 28, 2015
vs.
LA
SAVOIE
DEVELOPMENT
On the other hand, implied trusts are those which, without being expressed, are
deducible from the nature of the transaction as matters of intent or which are
superinduced on the transaction by operation of law as matters of equity,
independently of the particular intention of the parties. In turn, implied trusts are
either resulting or constructive trusts. These two are differentiated from each other
as follows:
Resulting trusts are based on the equitable doctrine that valuable consideration and
not legal title determines the equitable title or interest and are presumed always to
have been contemplated by the parties. They arise from the nature or circumstances
of the consideration involved in a transaction whereby one person thereby becomes
invested with legal title but is obligated in equity to hold his legal title for the benefit
of another. On the other hand, constructive trusts are created by the construction of
equity in order to satisfy the demands of justice and prevent unjust enrichment. They
arise contrary to intention against one who, by fraud, duress or abuse of confidence,
obtains or holds the legal right to property which he ought not, in equity and good
conscience, to hold.
ALICIA B. REYES vs. SPOUSES FRANCISCO S. VALENTIN
G.R. No. 194488 / February 11, 2015
An easement of right of way is a real right. When an easement of right of way is
granted to another person, the rights of the property's owner are limited. An owner
may not exercise some of his or her property rights for the benefit of the person who
was granted the easement of right of way. Hence, the burden of proof to show the
existence of the above conditions is imposed on the person who seeks the easement
of right of way.
SPOUSES ABELLA vs. SPOUSES ABELLA
G.R. No. 195166 / July 08, 2015
The legal rate of interest is the presumptive reasonable compensation for borrowed
money. While parties are free to deviate from this, any deviation must be reasonable
and fair. Any deviation that is far-removed is suspect. Thus, in cases where stipulated
interest is more than twice the prevailing legal rate of interest, it is for the creditor
to prove that this rate is required by prevailing market conditions.
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LA TONDEÑA, INC. vs. REPUBLIC OF THE PHILIPPINES
G.R. No. 194617 / August 05, 2015
This court held that "the agricultural land subject of the application needs only to be
classified as alienable and disposable as of the time of the application, provided the
applicant's possession and occupation of the land dated back to June 12, 1945, or
earlier.''
Survey notations are not considered substantive evidence of the land's classification
as alienable and disposable.
THE REGISTER OF DEEDS OF NEGROS OCCIDENTAL vs. OSCAR ANGLO, SR.
G.R. No. 171804 / August 05, 2015
The Assurance Fund is part of our property registration system covered by
Presidential Decree No. 1529. Its purpose is to protect individuals who rely on a
property's certificate of title as evidence of ownership. A claim from the fund must
meet the strict requirements of Presidential Decree No. 1529:
SEC. 95. Action for compensation from funds. — A person who, without
negligence on his part, sustains loss or damage, or is deprived of land
or any estate or interest therein in consequence of the bringing of the
land under the operation of the Torrens system of arising after original
registration of land, through fraud or in consequence of any error,
omission, mistake or misdescription in any certificate of title or in any
entry or memorandum in the registration book, and who by the
provisions of this Decree is barred or otherwise precluded under the
provision of any law from bringing an action for the recovery of such
land or the estate or interest therein, may bring an action in any court
of competent jurisdiction for the recovery of damages to be paid out of
the Assurance Fund.
Claims will not be allowed when the claimant is negligent.
ISMAEL V. CRISOSTOMO vs. MARTIN P. VICTORIA
G.R. No. 175098 / August 26, 2015
As long as the legal possessor of the land constitutes a person as a tenant-farmer by
virtue of an express or implied lease, such an act is binding on the owner of the
property even if he himself may not have given his consent to such an arrangement.
This is settled jurisprudence. The purpose of the law is to protect the tenant-farmer's
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
security of tenure, which could otherwise be arbitrarily terminated by an owner
simply manifesting his non-conformity to the relationship.
PEDRO MENDOZA vs. REYNOSA VALTE
G.R. No. 172961 / September 07, 2015
The existence or non-existence of fraud is a legal conclusion based on a finding that
the evidence presented is sufficient to establish facts constituting its
elements. Questions of fact are generally not entertained in a petition for review
before this court. In any event, petitions for a review or reopening of a decree of
registration based on actual fraud must be filed before the proper court within the
one-year period provided under the relevant laws. The party alleging fraud must
overcome the burden of proving the fraud with clear and convincing evidence. Section
101 of Commonwealth No. 141 allows actions for the reversion of land fraudulently
granted to private individuals filed even after the lapse of the one-year period, but
this must be initiated by the state.
ELISEO MALTOS and ROSITA P. MALTOS vs. HEIRS OF EUSEBIO BORROMEO
G.R. No. 172720 / September 14, 2015
The sale of a parcel of agricultural land covered by a free patent during the five-year
prohibitory period under the Public Land Act is void. Reversion of the parcel of land
is proper. However, reversion under Section 101 of the Public Land Act is not
automatic. The Office of the Solicitor General must first file an action for reversion.
LORENZO SHIPPING CORPORATION vs. NATIONAL POWER CORPORATION
G.R. No. 181683 / October 07, 2015
G.R. No. 184568
In resolving this case, we have had to sift through the parties' competing claims as
to who exactly is liable and to what extent. Reduced to its fundamentals, however,
this case remains to be about damage sustained by property owned by National
Power Corporation when the MV Lorcon Luzon rammed into it. This damage is
susceptible to financial reckoning. Unfortunately for National Power Corporation, it
failed to establish the precise amount of its pecuniary loss. This vice of precision
notwithstanding, it would be improper to completely turn a blind eye to the loss
suffered by National Power Corporation and to deny it, as Lorenzo Shipping suggests,
of any form of recompense. Under these circumstances, we sustain the Court of
Appeals' award of temperate damages.
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REPUBLIC OF THE PHILIPPINES vs. VIRGILIO M. TATLONGHARI
G.R. No. 170458 / November 23, 2015
The notation "in trust for" or "for escrow" that comes with deposited funds indicates
that the deposit is for the benefit of a third party. In this case, Asset Privatization
Trust deposited funds "in trust for" Pantranco North Express, Inc., (Pantranco) a
corporation under the management of Asset Privatization Trust. These funds belong
to Pantranco. Further, in the absence of evidence that Asset Privatization Trust is
authorized to collect Pantranco's indebtedness to Philippine National Bank, the
subject funds can be garnished to satisfy the claims of Pantranco's creditors.
When Pantranco was under sequestration, it remained to be a private corporation,
and its funds also remained to be private. Although the Presidential Commission on
Good Government is a government agency, it does not follow that Pantranco's funds
were converted into public funds by the mere fact that its conservator was a
government agency.
METROPOLITAN BANK & TRUST
INCORPORATED
G.R. No. 189509 / November 23, 2015
COMPANY
vs.
G&P
BUILDERS,
[W]hen an agreement has been reduced to writing, the parties cannot be permitted
to adduce evidence to prove alleged practices [that], to all purposes, would alter the
terms of the written agreement. Whatever is not found in the writing is understood
to have been waived and abandoned.
SPOUSES ALEXANDER AND JULIE LAM vs. KODAK PHILIPPINES, LTD.
G.R. No. 167615 / January 11, 2016
The award for moral and exemplary damages also appears to be sufficient. Moral
damages are granted to alleviate the moral suffering suffered by a party due to an
act of another, but it is not intended to enrich the victim at the defendant’s
expense. It is not meant to punish the culpable party and, therefore, must always be
reasonable vis-a-vis the injury caused. Exemplary damages, on the other hand, are
awarded when the injurious act is attended by bad faith.
ERWIN LIBO-ON DELA CRUZ vs. PEOPLE OF THE PHILIPPINES
G.R. No. 209387 / January 11, 2016
Routine baggage inspections conducted by port authorities, although done without
search warrants, are not unreasonable searches per se. Constitutional provisions
protecting privacy should not be so literally understood so as to deny reasonable
safeguards to ensure the safety of the traveling public.
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PEOPLE OF THE PHILIPPINES vs. RUBEN BARON
G.R. No. 213215 / January 11, 2016
The saddest thing about court decisions is that they cannot prevent moral depravity
when it has already happened. We can only do justice by imposing the proper penalty
upon the finding of guilt beyond reasonable doubt.
In one case, the Court took occasion to require an increase in the minimum award of
damages where the death penalty would have been imposed, were it not for a law
[RA No. 9346] preventing it: P100,000.00 as civil indemnity; P100,000.00 as moral
damages which the victim is assumed to have suffered and thus needs no proof; and
P100,000.00 as exemplary damages to set an example for the public good.
No amount of remorse can change the fact that a seven-year-old girl is dead. There
is no penalty commensurate with the indignity and the suffering that this child
endured in the fading moments of her brief life. Nor is there any pecuniary equivalent
to the loss of potential and the lifelong grief of her family.
FLORANTE VITUG vs. EVANGELINE A. ABUDA
G.R. No. 201264 / January 11, 2016
Parties who have validly executed a contract and have availed themselves of its
benefits may not, to escape their contractual obligations, invoke irregularities in its
execution to seek its invalidation.
NORBERTO A. VITANGCOL vs. PEOPLE OF THE PHILIPPINES
G.R. No. 207406 / January 13, 2016
Persons intending to contract a second marriage must first secure a judicial
declaration of nullity of their first marriage. If they proceed with the second marriage
without the judicial declaration, they are guilty of bigamy regardless of evidence of
the nullity of the first marriage.
SPOUSES ROBERT ALAN L. and NANCY LEE LIMSO vs. PHILIPPINE NATIONAL
BANK
G.R. No. 158622 / January 27, 2016
G.R. No. 169441
G.R. No. 172958
G.R. No. 173194
G.R. No. 196958
G.R. No. 197120
G.R. No. 205463
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There is no mutuality of contract when the interest rate in a loan agreement is set at
the sole discretion of one party. Nor is there any mutuality when there is no
reasonable means by which the other party can determine the applicable interest
rate. These types of interest rates stipulated in the loan agreement are null and void.
However, the nullity of the stipulated interest rate does not automatically nullify the
provision requiring payment of interest. Certainly, it does not nullify the obligation to
pay the principal loan obligation.
REPUBLIC OF THE PHILIPPINES vs. MOLDEX REALTY, INC.
G.R. No. 171041 / February 10, 2016
A case becomes moot and academic when, by virtue of supervening events, the
conflicting issue that may be resolved by the court ceases to exist. There is no longer
any justiciable controversy that may be resolved by the court. This court refuses to
render advisory opinions and resolve issues that would provide no practical use or
value. Thus, courts generally "decline jurisdiction over such case or dismiss it on
ground of mootness."
CARAVAN TRAVEL AND TOURS INTERNATIONAL, INC. vs. ERMILINDA R.
ABEJAR
G.R. No. 170631 / February 10, 2016
The plaintiff may first prove the employer's ownership of the vehicle involved in a
mishap by presenting the vehicle's registration in evidence. Thereafter, a disputable
presumption that the requirements for an employer's liability under Article 2180 of
the Civil Code have been satisfied will arise. The burden of evidence then shifts to
the defendant to show that no liability under Article 2180 has ensued. This case, thus,
harmonizes the requirements of Article 2180, in relation to Article 2176 of the Civil
Code, and the so-called registered-owner rule.
REPUBLIC OF THE PHILIPPINES vs. SOGOD DEVELOPMENT CORPORATION
G.R. No. 175760 / February 17, 2016
For a judicial confirmation of title under Section 48(b) of the Public Land Act, the land
subject of the application needs only to be alienable and disposable as of the time of
the application, provided the applicant's possession and occupation of the land dates
back to June 12, 1945, or earlier.
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VICTOR S. LIMLINGAN vs. ASIAN INSTITUTE OF MANAGEMENT, INC.
G.R. No. 220481 / February 17, 2016
When the obligation is breached, and it consists in the payment of a sum of
money, i.e., a loan or forbearance of money, the interest due should be that which
may have been stipulated in writing. Furthermore, the interest due shall itself earn
legal interest from the time it is judicially demanded. In the absence of stipulation,
the rate of interest shall be 6% per annum to be computed from default, i.e., from
judicial or extrajudicial demand under and subject to the provisions of Article 1169
of the Civil Code.
When an obligation, not constituting a loan or forbearance of money, is breached, an
interest on the amount of damages awarded may be imposed at the discretion of the
court at the rate of 6% per annum. No interest, however, shall be adjudged on
unliquidated claims or damages, except when or until the demand can be established
with reasonable certainty. Accordingly, where the demand is established with
reasonable certainty, the interest shall begin to run from the time the claim is made
judicially or extrajudicially (Art. 1169, Civil Code), but when such certainty cannot be
so reasonably established at the time the demand is made, the interest shall begin
to run only from the date the judgment of the court is made (at which time the
quantification of damages may be deemed to have been reasonably ascertained).
The actual base for the computation of legal interest shall, in any case, be on the
amount finally adjudged.
When the judgment of the court awarding a sum of money becomes final and
executory, the rate of legal interest, whether the case falls under paragraph 1 or
paragraph 2, above, shall be 6% per annum from such finality until its satisfaction,
this interim period being deemed to be by then an equivalent to a forbearance of
credit.
EDNA MABUGAY-OTAMIAS vs. REPUBLIC OF THE PHILIPPINES
G.R. No. 189516 / June 08, 2016
A writ of execution lies against the pension benefits of a retired officer of the Armed
Forces of the Philippines, which is the subject of a deed of assignment drawn by him
granting support to his wife and five (5) children. The benefit of exemption from
execution of pension benefits is a statutory right that may be waived, especially in
order to comply with a husband's duty to provide support under Article XV of the
1987 Constitution and the Family Code.
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NATIONAL POWER CORPORATION vs. SOUTHERN PHILIPPINES POWER
CORPORATION
G.R. No. 219627 / July 04, 2016
We resort to the fundamental principle that a contract is the law between parties.
Absent any showing that its provisions are contrary to law, morals, good customs,
public order, or public policy, it should be enforced to the letter. Contracts cannot
be altered for the benefit of one party and to the detriment of another. Neither can
this Court, by construction, "relieve [a] party from the terms to which [it] voluntarily
consented, or impose on [it] those which [it] did not."
PABLO M. PADILLA, JR. vs. LEOPOLDO MALICSI
G.R. No. 201354 / September 21, 2016
The owner of the land (in good faith) has three alternative rights: (1) to appropriate
what has been built without any obligation to pay indemnity therefor, or (2) to
demand that the builder remove what he had built, or (3) to compel the-builder to
pay the value of the land. In any case, the landowner is entitled to damages x x x.
PHILIPPINE
ECONOMIC
ZONE
AUTHORITY
CORPORATION
G.R. No. 185765 / September 28, 2016
vs.
PILHINO
SALES
Although the provisions of a contract are legally null and void, the stipulated method
of computing liquidated damages may be accepted as evidence of the intent of the
parties. The provisions, therefore, can be basis for finding a factual anchor for
liquidated damages. The liable party may nevertheless present better evidence to
establish a more accurate basis for awarding damages.
PHILIPPINE NATIONAL BANK vs. VENANCIO C. REYES, JR.
G.R. No. 212483 / October 05, 2016
A spouse's consent is indispensable for the disposition or encumbrance of conjugal
properties.
HEIRS OF LEOPOLDO DELFIN vs. NATIONAL HOUSING AUTHORITY
G.R. No. 193618 / November 28, 2016
Under Commonwealth Act No. 141, a claimant may acquire alienable and disposable
public land upon evidence of exclusive and notorious possession of the land since
June 12, 1945. The period to acquire public land by acquisitive prescription under
Presidential Decree No. 1529 begins to run only after the promulgation of a law or a
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proclamation by the President stating that the land is no longer intended for public
use or the development of national wealth.
THE SECRETARY OF JUSTICE vs. GLORIA RODRIGUEZ DE GUZMAN
G.R. No. 187291 / December 05, 2016
Land registration cases that only resolve the propriety of the results of a resurvey of
Baguio City properties do not bar a subsequent declaration of the nullity of the titles.
Our courts should be more aware of the machinations used by unscrupulous parties
to acquire and title lands in Baguio City. As in this case, parties obtained more land
through a resuryey of property. They filed an action or proceeding to "correct" the
technical descriptions or the supporting survey plans. Trial courts become
participants in this scheme by denying the intervention or opposition of the Solicitor
General and x x x make very loose observations regarding the presumptions of
validity of obviously defective titles already declared null and void by Marcos and
confirmed as such by Presidential Decree No. 1271. Thereafter, in subsequent cases,
as in these cases, the party who gains through a simple resurvey of its property
erroneously raises res judicata as a defense; thus the party secures its spurious titles
against any further legal questions.
These machinations brought about by the clearly erroneous application of doctrine
should stop. Otherwise, genuine property owners in Baguio City will forever be unsure
of possible land grabbing.
HEIRS OF TEODORA LOYOLA vs. COURT OF APPEALS
G.R. No. 188658 / January 11, 2017
Fraud and irregularity are presupposed in an action for reconveyance of property. The
party seeking to recover the property must prove, by clear and convincing evidence,
that he or she is entitled to the property, and that the adverse party has committed
fraud in obtaining his or her title. Allegations of fraud are not enough. "Intentional
acts to deceive and deprive another of his right, or in some manner injure him, must
be specifically alleged and proved." In the absence of any proof, the complaint for
reconveyance cannot be granted.
REPUBLIC OF THE PHILIPPINES vs. SPOUSES FRANCISCO R. LLAMAS
G.R. No. 194190 / January 25, 2017
To be considered a donation, an act of conveyance must necessarily proceed freely
from the donor's own, unrestrained volition. A donation cannot be forced: it cannot
arise from compulsion, be borne by a requirement, or otherwise be impelled by a
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mandate imposed upon the donor by forces that are external to him or her. Article
726 of the Civil Code reflects this commonsensical wisdom when it specifically states
that conveyances made in view of a "demandable debt" cannot be considered true or
valid donations.
DEVELOPMENT BANK OF THE PHILIPPINES vs. STA. INES MELALE FOREST
PRODUCTS CORPORATION
G.R. No. 193068 / February 01, 2017
G.R. No. 193099 / February 01, 2017
A condition shall be deemed fulfilled when the obligor voluntarily prevents its
fulfilment and a debtor loses the right to make use of the period when a condition is
violated, making the obligation immediately demandable.
ROMEO F. ARA vs. DRA. FELY S. PIZARRO
G.R. No. 187273 / February 15, 2017
For a claim of filiation to succeed, it must be made within the period allowed, and
supported by the evidence required under the Family Code.
LAND BANK OF THE PHILIPPINES vs. LORENZO MUSNI
G.R. No. 206343 / February 22, 2017
Banks must show that they exercised the required due diligence before claiming to
be mortgagees in good faith or innocent purchasers for value.
MARIA TERESA B. TANI-DE LA FUENTE vs. RODOLFO DE LA FUENTE, JR.
G.R. No. 188400 / March 8, 2017
Psychological incapacity is a mental illness that leads to an inability to comply with
or comprehend essential marital obligations.
UNION BANK OF THE PHILIPPINES vs. SPOUSES JEROME
G.R. No. 205657 / March 29, 2017
Upon accepting an agency, the agent becomes bound to carry out the agency and
shall be held liable for the damages, which the principal may incur due to the agent's
non-performance.
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HEIRS OF AUGUSTO SALAS, JR. vs. MARCIANO CABUNGCAL
G.R. No. 191545 / March 29, 2017
Republic Act No. 6657 (Comprehensive Agrarian Reform Law of 1988) or the
Comprehensive Agrarian Reform Law generally covers all public and private
agricultural lands.
The law defines agricultural land as "land devoted to agricultural activity and not
classified as mineral, forest, residential, commercial or industrial land." For
agricultural land to be considered devoted to an agricultural activity, there must be
"cultivation of the soil, planting of crops, growing of fruit trees, raising of livestock,
poultry or fish, including the harvesting of such farm products, and other farm
activities and practices performed by a farmer in conjunction with such farming
operations done by persons whether natural or juridical."
HEIRS OF LEONILO P. NUÑEZ, SR. vs. HEIRS OF GABINO T. VILLANOZA
G.R. No. 218666 / April 26, 2017
Under the Comprehensive Agrarian Reform Law, the landowner may retain a
maximum of five (3) hectares of land, but this land must be compact or contiguous.
If the area selected for retention is tenanted, the tenant-farmer may choose to
remain in the area or be a beneficiary in a comparable area.
SPS. ROBERTO ABOITIZ vs. SPS. PETER L. PO
G.R. No. 208450 / June 05, 2017
G.R. No. 208497
The rationale for allowing reconveyance despite the finality of the registration is that
the issuance of a certificate of title does not create or vest ownership to a person
over the property. Registration under the Torrens system "is not a mode of acquiring
ownership." A certificate is only a proof of ownership. Thus, its issuance does not
foreclose the possibility of having a different owner, and it cannot be used against
the true owner as a shield for fraud.
LOLITA BAS CAPABLANCA vs. HEIRS OF PEDRO BAS
G.R. No. 224144 / June 28, 2017
In one case, the right to assert a cause of action as an heir, although he has not been
judicially declared to be so, if duly proven, is well settled in this jurisdiction. This is
upon the theory that the property of a deceased person, both real and personal,
becomes the property of the heir by the mere fact of death of his predecessor in
interest, and as such he can deal with it in precisely the same way in which the
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deceased could have dealt, subject only to the limitations which by law or by contract
may be imposed upon the deceased himself. Thus, it has been held that "[t]here is
no legal precept or established rule which imposes the necessity of a previous legal
declaration regarding their status as heirs to an intestate on those who, being of age
and with legal capacity, consider themselves the legal heirs of a person, in order that
they may maintain an action arising out of a right which belonged to their ancestor."
HEIRS OF CAYETANO CASCAYAN vs. SPOUSES OLIVER AND EVELYN
GUMALLAOI
G.R. No. 211947 / July 03, 2017
In one case, the Court held that a counterclaim, specifically one for annulment of title
and reconveyance based on fraud, is a direct attack on the Torrens title upon which
the complaint for quieting of title is premised.
REPUBLIC OF THE PHILIPPINES vs. SPOUSES DANILO GO
G.R. No. 197297 / August 02, 2017
Public land remains inalienable unless it is shown to have been reclassified and
alienated to a private person.
CE CONSTRUCTION CORPORATION vs. ARANETA CENTER INC.
G.R. No. 192725 / August 09, 2017
A tribunal confronted not only with ambiguous contractual terms but also with the
total absence of an instrument which definitively articulates the contracting parties'
agreement does not act in excess of jurisdiction when it employs aids in
interpretation, such as those articulated in Articles 1370 to 1379 of the Civil Code. In
so doing, a tribunal does not conjure its own contractual terms and force them upon
the parties.
ORIENT FREIGHT INTERNATIONAL, INC. vs. KEIHIN-EVERETT FORWARDING
COMPANY, INC.
G.R. No. 191937 / August 09, 2017
Article 2176 of the Civil Code does not apply when the party's negligence occurs in
the performance of an obligation. The negligent act would give rise to a quasi-delict
only when it may be the basis for an independent action were the parties not
otherwise bound by a contract.
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RICHELLE P. ABELLA vs. POLICARPIO CABAÑERO
G.R. No. 206647 / August 09, 2017
Filiation must be established for a child to claim support from a putative father. When
"filiation is beyond question, support follows as [a] matter of obligation." To establish
filiation, an action for compulsory recognition may be filed against the putative father
ahead of an action for support. In the alternative, an action for support may be
directly filed, where the matter of filiation shall be integrated and resolved.
FGU INSURANCE CORPORATION vs. SPOUSES FLORO ROXAS AND EUFEMIA
ROXAS
G.R. No. 189526 / August 09, 2017
G.R. No. 189656 / August 9, 2017
The liability of a surety is determined strictly in accordance with the actual terms of
the performance bond it issued. It may, however, set up compensation against the
amount owed by the creditor to the principal.
DEE HWA LIONG FOUNDATION MEDICAL CENTER vs. ASIAMED SUPPLIES
G.R. No. 205638 / August 23, 2017
A contract need not be contained in a single writing. It may be collected from several
different writings which do not conflict with each other and which, when connected,
show the parties, subject matter, terms and consideration, as in contracts entered
into by correspondence. A contract may be encompassed in several instruments even
though every instrument is not signed by the parties, since it is sufficient if the
unsigned instruments are clearly identified or referred to and made part of the signed
instrument or instruments. Similarly, a written agreement of which there are two
copies, one signed by each of the parties, is binding on both to the same extent as
though there had been only one copy of the agreement and both had signed it.
PRISCILLA ZAFRA ORBE vs. FILINVEST LAND, INC.
G.R. No. 208185 / September 06, 2017
When Republic Act No. 6552 or the Maceda Law speaks of paying "at least two years
of installments" in order for the benefits under its Section 3 to become available, it
refers to the buyer's payment of two (2) years' worth of the stipulated fractional,
periodic payments due to the seller. When the buyer's payments fall short of the
equivalent of two (2) years' worth of installments, the benefits that the buyer may
avail of are limited to those under Section 4. Should the buyer still fail to make
payments within Section 4's grace period, the seller may cancel the contract. Any
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
such cancellation is ineffectual, however, unless it is made through a valid notarial
act.
TEAM IMAGE ENTERTAINMENT, INC. vs. SOLAR TEAM ENTERTAINMENT, INC.
G.R. No. 191652 / September 13, 2017
G.R. No. 191658 / September 13, 2017
A judgment upon a compromise is rendered based on the parties' reciprocal
concessions. With all the more reason should a judgment upon a compromise be
complied with in good faith considering that the parties themselves crafted its terms.
REPUBLIC OF THE PHILIPPINES vs. SPOUSES JOEL
G.R. No. 170316 / September 18, 2017
When an applicant in the registration of property proves his or her open, continuous,
exclusive, and notorious possession of a land for the period required by law, he or
she has acquired an imperfect title that may be confirmed by the State. The State
may not, in the absence of controverting evidence and in a pro forma opposition,
indiscriminately take a property without violating due process.
VICENTE L. LUNTAO vs. BAP CREDIT GUARANTY CORPORATION
G.R. No. 204412 / September 20, 2017
The validity of accessory contracts mainly flows from the validity of the principal
contracts. A real estate mortgage is in the nature of an accessory contract. Thus, the
validity of a mortgage contract that was constituted to secure a loan obligation is
affected by the validity of the loan contract.
VELIA J. CRUZ vs. SPOUSES MAXIMO
G.R. No. 205539 / October 4, 2017
The prior service and receipt of a demand letter is unnecessary in a case for unlawful
detainer if the demand to vacate is premised on the expiration of the lease, not on
the non-payment of rentals or non-compliance of the terms and conditions of the
lease.
ORIENTAL ASSURANCE CORPORATION vs. MANUEL ONG
G.R. No. 189524 / October 11, 2017
The consignee's claim letter that was received by the arrastre operator two (2) days
after complete delivery of the cargo constitutes substantial compliance with the time
limitation for filing claims under the Gate Pass and the Management Contract.
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However, the arrastre operator's liability for damage to the cargo is limited to
P5,000.00 per package in accordance with the Management Contract.
FRANCISCA TAAR vs. CLAUDIO LAWAN
G.R. No. 190922 / October 11, 2017
A judgment approving the subdivision of a parcel of land does not preclude other
parties with a better right from instituting free patent applications over it. Entitlement
to agricultural lands of the public domain requires a clear showing of compliance with
the provisions of Commonwealth Act No. 141, as amended, otherwise known as the
Public Land Act.
SIMEON TRINIDAD PIEDAD vs. CANDELARIA LINEHAN BOBILLES
G.R. No. 208614 / November 27, 2017
Courts should take to heart the principle of equity if the strict application of the
statute of limitations or laches would result in manifest wrong or injustice.
JOSEPH HARRY WALTER POOLE-BLUNDEN vs. UNION BANK OF THE
PHILIPPINES
G.R. No. 205838 / November 29, 2017
Banks are required to observe a high degree of diligence in their affairs. This
encompasses their dealings concerning properties offered as security for loans. A
bank that wrongly advertises the area of a property acquired through foreclosure
because it failed to dutifully ascertain the property's specifications is grossly negligent
as to practically be in bad faith in offering that property to prospective buyers. Any
sale made on this account is voidable for causal fraud. In actions to void such sales,
banks cannot hide under the defense that a sale was made on an as-is-where-is
basis. As-is-where-is stipulations can only encompass physical features that are
readily perceptible by an ordinary person possessing no specialized skills.
VISAYAN ELECTRIC COMPANY, INC. vs. EMILIO G. ALFECHE
G.R. No. 209910 / November 29, 2017
An electric distribution company is a public utility presumed to have the necessary
expertise and resources to enable a safe and effective installation of its facilities.
Absent an indication of fault or negligence by other actors, it is exclusively liable for
fires and other damages caused by its haphazardly installed posts and wires.
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ERMA INDUSTRIES, INC vs. SECURITY BANK CORPORATION
G.R. No. 191274 / December 06, 2017
The law has authorized the formation of corporations for the purpose of conducting
surety business, and the corporate surety differs significantly from the individual
private surety. First, unlike the private surety, the corporate surety signs for cash
and not for friendship. The private surety is regarded as someone doing a rather
foolish act for praiseworthy motives; the corporate surety, to the contrary, is in
business to make a profit and charges a premium depending upon the amount of
guaranty and the risk involved. Second, the corporate surety, like an insurance
company, prepares the instrument, which is a type of contract of adhesion whereas
the private surety usually does not prepare the note or bond which he signs. Third,
the obligation of the private surety often is assumed simply on the basis of the
debtor's representations and without legal advice, while the corporate surety does
not bind itself until a full investigation has been made. For these reasons, the courts
distinguish between the individual gratuitous surety and the vocational corporate
surety. In the case of the corporate surety, the rule of strictissimi juris is not
applicable, and courts apply the rules of interpretation of appertaining to contracts of
insurance.
VIVIAN B. TORREON vs. GENEROSO APARRA
G.R. No. 188493 / December 13, 2017
Lack of documentary evidence is not fatal to a claim for the deceased's lost earning
capacity. Testimony from a competent witness familiar with his salary is a sufficient
basis to determine the deceased's income before his death.
TEODORO C. TORTONA vs. JULIAN C. GREGORIO
G.R. No. 202612 / January 17, 2018
Documents acknowledged before a notary public are presumed to have been duly
executed. This presumption may be contradicted by clear and convincing evidence.
A notarized Deed of Absolute Sale where the thumbmark of a party is shown to be a
forgery is void.
REPUBLIC OF THE PHILIPPINES vs. MICHELLE SORIANO GALLO
G.R. No. 207074 / January 17, 2018
Names are labels for one's identity. They facilitate social interaction, including the
allocation of rights and determination of liabilities. It is for this reason that the State
has an interest in one's name.
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The name through which one is known is generally, however, not chosen by the
individual who bears it. Rather, it is chosen by one's parents. In this sense, the choice
of one's name is not a product of the exercise of autonomy of the individual to whom
it refers.
In view of the State's interest in names as markers of one's identity, the law requires
that these labels be registered. Understandably, in some cases, the names so
registered or other aspects of one's identity that pertain to one's name are not
reflected with accuracy in the Certificate of Live Birth filed with the civil registrar.
Changes to one's name, therefore, can be the result of either one of two (2) motives.
The first, as an exercise of one's autonomy, is to change the appellation that one was
given for various reasons. The other is not an exercise to change the label that was
given to a person; it is simply to correct the data as it was recorded in the Civil
Registry.
VICTORIA N. RACELIS vs. SPOUSES GERMIL JAVIER AND REBECCA JAVIER
G.R. No. 189609 / January 29, 2018
Lessees are entitled to suspend the payment of rent under Article 1658 of the Civil
Code if their legal possession is disturbed. Acts of physical disturbance that do not
affect legal possession is beyond the scope of this rule.
In a contract to sell, the payment of earnest money represents the seller's
opportunity cost of holding in abeyance the search for other buyers or better deals.
Absent proof of a clear agreement to the contrary, it should be forfeited if the sale
does not happen without the seller's fault. The potential buyer bears the burden of
proving that the earnest money was intended other than as part of the purchase price
and to be forfeited if the sale does not occur without the seller's fault.
INTRAMUROS
ADMINISTRATION
DEVELOPMENT COMPANY
G.R. No. 196795 / March 07, 2018
vs.
OFFSHORE
CONSTRUCTION
The sole issue in ejectment proceedings is determining which of the parties has the
better right to physical possession of a piece of property. The defendant's claims and
allegations in its answer or motion to dismiss do not oust a trial court's jurisdiction
to resolve this issue.
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EVERSLEY
CHILDS
SANITARIUM
PERLABARBARONA
G.R. No. 195814 / April 4, 2018
vs.
SPOUSES
ANASTACIO
A case for unlawful detainer must state the period from when the occupation by
tolerance started and the acts of tolerance exercised by the party with the right to
possession. If it is argued that the possession was illegal from the start, the proper
remedy is to file an accion publiciana, or a plenary action to recover the right of
possession. Moreover, while an ejectment case merely settles the issue of the right
of actual possession, the issue of ownership may be provisionally passed upon if the
issue of possession cannot be resolved without it. Any final disposition on the issue
of ownership, however, must be resolved in the proper forum.
REPUBLIC OF THE PHILIPPINES vs. LAUREANA MALIJAN-JAVIER
G.R. No. 214367 / Aril 4, 2018
To establish that the land sought to be registered is alienable and disposable,
applicants must "present a copy of the original classification approved by the
[Department of Environment and Natural Resources] Secretary and certified as a true
copy by the legal custodian of the official records."
MAKATI TUSCANY CONDOMINIUM
DEVELOPMENT CORPORATION
G.R. No. 185530 / April 18, 2018
CORPORATION
vs.
MULTI-REALTY
Reformation of an instrument may be allowed if subsequent and contemporaneous
acts of the parties show that their true intention was not accurately reflected in the
written instrument.
ALICIA C. GALINDEZ vs. SALVACION FIRMALAN
G.R. No. 187186 / June 06, 2018
Findings of fact by the Director of Lands shall be conclusive when approved by the
Department of Environment and Natural Resources Secretary and supported by
substantial evidence.
RHODORA ILUMIN RACHO vs. SEIICHI TANAKA
G.R. No. 199515 / June 25, 2018
Judicial recognition of a foreign divorce requires that the national law of the foreign
spouse and the divorce decree be pleaded and proved as a fact before the Regional
Trial Court. The Filipino spouse may be granted the capacity to remarry once our
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
courts find that the foreign divorce was validly obtained by the foreign spouse
according to his or her national law, and that the foreign spouse's national law
considers the dissolution of the marital relationship to be absolute.
FEDERAL EXPRESS CORPORATION vs. LUWALHATI R. ANTONINO
G.R. No. 199455 / June 27, 2018
The duty of common carriers to observe extraordinary diligence in shipping goods
does not terminate until delivery to the consignee or to the specific person authorized
to receive the shipped goods. Failure to deliver to the person authorized to receive
the goods is tantamount to loss of the goods, thereby engendering the common
carrier's liability for loss. Ambiguities in contracts of carriage, which are contracts of
adhesion, must be interpreted against the common carrier that prepared these
contracts.
SINDOPHIL, INC. vs. REPUBLIC OF THE PHILIPPINES
G.R. No. 204594 / November 07, 2018
The presumption that a holder of a Torrens title is an innocent purchaser for value is
disputable and may be overcome by contrary evidence. Once a prima facie case
disputing this presumption is established, the adverse party cannot simply rely on
the presumption of good faith and must put forward evidence that the property was
acquired without notice of any defect in its title.
CEZAR YATCO REAL ESTATE SERVICES,
ASSOCIATION, INC.
G.R. No. 211780 / November 21, 2018
INC.
vs.
BEL-AIR
VILLAGE
In contract interpretation, courts must first determine whether a stipulation is
ambiguous or susceptible of multiple interpretations. If no ambiguity is found and the
terms of the contract clearly reflect the intentions of the contracting parties, the
stipulation will be interpreted as it is written.
SPOUSES RAINIER JOSE M. YULO vs. BANK OF THE PHILIPPINE ISLANDS
G.R. No. 217044 / January 16, 2019
When issuing a pre-screened or pre-approved credit card, the credit card provider
must prove that its client read and consented to the terms and conditions governing
the credit card's use. Failure to prove consent means that the client cannot be bound
by the provisions of the terms and conditions, despite admitted use of the credit card.
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BANGKO SENTRAL NG PILIPINAS vs. SPOUSES JUANITO AND VICTORIA
LEDESMA
G.R. No. 211176 / February 06, 2019
G.R. No. 211583 / February 06, 2019
In cases where the loan records which will serve as the basis for computing the excess
payments of the sugar producer are no longer available, the lending bank shall
immediately notify the BSP. The BSP shall then direct the claimant sugar producer to
submit documents in his possession which are acceptable to COA to substantiate his
claim. Such documents shall be submitted by the sugar producer to the lending bank
within sixty (60) calendar days from receipt of notification from the BSP.
MELINDA M. MALABANAN vs. FRANCISCO MALABANAN, JR.
G. R. No. 187225 / March 06, 2019
The plain meaning attached to the plain language of the law is that the contract, in
its entirety, executed by the husband without the wife's consent, may be annulled by
the wife. Had Congress intended to limit such annulment in so far as the contract
shall "prejudice" the wife, such limitation should have been spelled out in the statute.
It is not the legitimate concern of this Court to recast the law. As Mr. Justice Jose B.
L. Reyes of this Court and Judge Ricardo C. Puno of the Court of First Instance
correctly stated, "[t]he rule (in the first sentence of Article 173) revokes Baello vs.
Villanueva, . . . and Coque vs. Navas Sioca, . . ." in which cases annulment was held
to refer only to the extent of the one-half interest of the wife. . . .
ANNIE TAN vs. GREAT HARVEST ENTERPRISES, INC.
G.R. No. 220400 / March 20, 2019
Common carriers are obligated to exercise extraordinary diligence over the goods
entrusted to their care. This is due to the nature of their business, with the public
policy behind it geared toward achieving allocative efficiency and minimizing the
inherently inequitable dynamics between the parties to the transaction.
BNL MANAGEMENT CORPORATION vs. REYNALDO UY
G.R. No. 210297 / April 03, 2019
Under Section 9 of Republic Act No. 4726, or the Condominium Act, a condominium
owner shall register a declaration of restrictions, which shall be annotated to the
certificate of title of land included within the project. The declaration of restrictions
provides for the project management, among others, and is enforceable by the
condominium's management body.
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In a multi-occupancy dwelling such as Apartments, limitations are imposed under
R.A. 4726 in accordance with the common interest and safety of the occupants
therein which at times may curtail the exercise of ownership. To maintain safe,
harmonious and secured living conditions, certain stipulations are embodied in the
duly registered deed of restrictions, in this case the Master Deed, and in house rules
which the condominium corporation, like respondent, is mandated to implement.
Upon acquisition of a unit, the owner not only affixes his conformity to the sale; he
also binds himself to a contract with other unit owners.
WILLIAM G. KWONG MANAGEMENT, INC. vs. DIAMOND HOMEOWNERS &
RESIDENTS ASSOCIATION
G.R. No. 211353 / June 10, 2019
A homeowners' association may regulate passage into a subdivision for the safety
and security of its residents, even if its roads have already been donated to the local
government. It has the right to set goals for the promotion of safety and security,
peace, comfort, and the general welfare of its residents.
GENEVIEVE ROSAL ARREZA vs. TETSUSHI TOYO, LOCAL CIVIL REGISTRAR
OF QUEZON CITY
G.R. No. 213198 / July 01, 2019
Philippine courts do not take judicial notice of foreign judgments and laws. They must
be proven as fact under our rules on evidence. A divorce decree obtained abroad is
deemed a foreign judgment, hence the indispensable need to have it pleaded and
proved before its legal effects may be extended to the Filipino spouse.
GOVERNMENT SERVICE INSURANCE SYSTEM vs. MUNICIPAL AGRARIAN
REFORM OFFICER ROMERICO DATOY
G.R. No. 232863 / July 24, 2019
Lands foreclosed by the Government Service Insurance System, a government
financial institution, are subject to agrarian reform and are not among the
Comprehensive Agrarian Reform Law's exclusive list of exemptions and exclusions.
The exemptions under RA 6657 (Comprehensive Agrarian Reform Law) form an
exclusive list, as follows:
SEC. 10. Exemptions and Exclusions. -
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
(a) Lands actually, directly and exclusively used for parks, wildlife, forest reserves,
reforestation, fish sanctuaries and breeding grounds, watersheds and mangroves
shall be exempt from the coverage of this Act.
(b) Private lands actually, directly and exclusively used for prawn farms and fishponds
shall be exempt from the coverage of this Act: Provided, That said prawn farms and
fishponds have not been distributed and Certificate of Land Ownership Award (CLOA)
issued under the Agrarian Reform Program.
In cases where the fishponds or prawn farms have been subjected to the
Comprehensive Agrarian Reform Law, by voluntary offer to sell, or commercial farms
deferment or notices of compulsory acquisition, a simple and absolute majority of the
actual regular workers or tenants must consent to the exemption within one (1) year
from the effectivity of this Act. When the workers or tenants do not agree to this
exemption, the fishponds or prawn farms shall be distributed collectively to the
worker-beneficiaries or tenants who shall form cooperative or association to manage
the same.
In cases where the fishponds or prawn farms have not been subjected to the
Comprehensive Agrarian Reform Law, the consent of the farmworkers shall no longer
be necessary; however, the provision of Section 32-A hereof on incentives shall
apply.
(c) Lands actually, directly and exclusively used and found to be necessary for
national defense, school sites and campuses, including experimental farm stations
operated by public or private schools for educational purposes, seeds and seedlings
research and pilot production center, church sites and convents appurtenant thereto,
mosque sites and Islamic centers appurtenant thereto, communal burial grounds and
cemeteries, penal colonies and penal farms actually worked by the inmates,
government and private research and quarantine centers and all lands with eighteen
percent (18%) slope and over, except those already developed, shall be exempt from
the coverage of this Act. (As amended by R.A. 7881)
CAMP JOHN HAY DEVELOPMENT CORPORATION vs. CHARTER CHEMICAL
AND COATING CORPORATION
G.R. No. 198849 / August 07, 2019
Rescission under Article 1191 of the Civil Code is the proper remedy when a party
breaches a reciprocal obligation. Because each case has its own distinct
circumstances, this Court's power to fix a period of an obligation under Article 1197
is discretionary and should be exercised only if there is just cause.
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2020.21 JUSTICE MARVIC LEONEN CASE DOCTRINES
PRUDENCIO DE GUZMAN Y JUMAQUIO vs. PEOPLE OF THE PHILIPPINES
G.R. No. 224742 / August 07, 2019
A person cannot unilaterally declare his marriage void. The law provides that a judicial
declaration of nullity is indispensable for the purposes of remarriage.
CLARET
SCHOOL
OF
QUEZON
G.R. No. 226358 / October 09, 2019
CITY
vs.
MADELYN
I.
SINDAY
Brent School, Inc. v. Zamora recognized that the Civil Code and the Labor Code allow
the execution of fixed-term employment contracts. However, in cases where periods
are imposed to prevent an employee from acquiring security of tenure, such contracts
must
be
disregarded
for
being
contrary
to
public
policy
and
morals. Brent's application is limited to cases where the employer and the employee
are more or less on an equal footing when they enter into the contract.
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY vs. CITI APPLIANCE
M.C. CORPORATION
G.R. No. 214546 / October 9, 2019
An action for forcible entry must be filed within one (1) year from the date of actual
entry on the land. However, when the entry was done through stealth, the one-year
time bar is reckoned from the time the entry was discovered. In contrast to unlawful
detainer suits, no previous demand to vacate is required before an action for forcible
entry may be filed.
SPOUSES LAURETO V. FRANCO AND NELLY DELA CRUZ-FRANCO vs. SPOUSES
MACARIO GALERA, JR. AND TERESITA LEGASPINA
G.R. No. 205266 / January 15, 2020
An express agreement is not necessary to establish the existence of agricultural
tenancy. The tenancy relationship can be implied when the conduct of the parties
shows the presence of all the requisites under the law.
For a valid agricultural tenancy arrangement to exist, these elements must concur:
(1) the parties are the landowner and the tenant:(2) the subject matter is agricultural
land; (3) there is consent between the parties: (4) the purpose is agricultural
production; (5) there is personal cultivation by the tenant; and, (6) there is sharing
of the harvests between the parties.
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All these elements must be proven by substantial evidence; "the absence of one or
more requisites is fatal." As with any affirmative allegation, the burden of proof rests
on the party who alleges it. The tenancy relationship cannot be presumed.
SPOUSES DANILO AND CLARITA GERMAN vs. SPOUSES BENJAMIN AND
EDITHA SANTUYO AND HELEN S. MARIANO
G.R. No. 210845 / January 22, 2020
When circumstances are present that should prompt a potential buyer of registered
real property to be on guard, it is expected that they inquire first into the status of
the property and not merely rely on the face of the certificate of title.
To buy real property while having only a general idea of where it is and without
knowing the actual condition and identity of the metes and bounds of the land to be
bought, is negligent and careless. Failure to take such ordinary precautionary steps,
which could not have been difficult to undertake for respondents Santuyo Spouses,
as they were situated near where the property is located, precludes their defense of
good faith in the purchase.
ALLAN MAÑAS vs. ROSALINA ROCA NICOLASORA
G.R. No. 208845 / February 03, 2020
[A] lease contract's implied renewal does not mean that all the terms in the original
contract are deemed revived. Only the terms that affect the lessee's continued use
and enjoyment of the property would be considered part of the implied renewal.
Indeed, the right of first refusal has nothing to do with the use and enjoyment of
property.
SAPHIA MUTILAN vs. CADIDIA MUTILAN
G.R. No. 216109 / February 05, 2020
The probate court can decide the question of title or ownership over properties when
the interested parties are all heirs and the rights of third parties are not impaired.
When, however, a separate civil action is still filed to decide the question of
ownership, it is mandatory that it be instituted by the real parties in interest, and the
indispensable parties be impleaded. These are jurisdictional requirements, which,
when failed to be satisfied, prove fatal to the civil action.
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REPUBLIC OF THE PHILIPPINES vs. WINSTON BRIAN CHIA LAO AND
CHRISTOPHER TROY CHIA LAO
G.R. No. 205218 / February 10, 2020
G.R. No. 207075 / February 10, 2020
The birth certificate, more than a historical record of one's birth, is a vital marker of
identity. Therefore, acts and events, though occurring after birth, may be annotated
on the birth certificate so long as they are consistent with a legal truth and a special
law provides for its effects.
SPOUSES RENE LUIS GODINEZ AND SHEMAYNE GODINEZ vs. SPOUSES
ANDREW T. NORMAN AND JANET A. NORMAN
G.R. No. 225449 / February 26, 2020
Generally, partial payments of the purchase price on a contract to sell should be
returned to the buyer if the sale does not push through, unless forfeiture of such
partial payments was stipulated. However, these partial payments may be retained
and considered as rentals by the seller if the buyer was given possession or was able
to use the property prior to transfer of title.
BAGONG REPORMANG SAMAHAN NG MGA TSUPER AT OPERATOR SA ROTANG
PASIG QUIAPO VIA PALENGKE SAN JOAQUIN IKOT, INC. vs. CITY OF
MANDALUYONG
G.R. No. 218593 / June 15, 2020
A certificate of public convenience does not vest property rights to its holder to
conduct business along the route covered in it. This privilege is subject to compliance
with local traffic regulations, because the Land Transportation Franchising and
Regulatory Board's authority to issue such certificates is only supplemental to the
right of local governments to control and regulate traffic in their localities.
PHILIPPINE SAVINGS BANK vs. MARIA CECILIA SAKATA
G.R. No. 229450 / June 17, 2020
It is settled that "a bank is bound to know the signatures of its customers; and if it
pays a forged check, it must be considered as making the payment out of its own
funds, and cannot ordinarily charge the amount so paid to the account of the
depositor whose name was forged."
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SPOUSES RUTH DIZON DEVISFRUTO AND ALLAN DEVISFRUTO vs. MAXIMA
L. GREENFELL
G.R. No. 227725 / July 1, 2020
As held in one case, a donation must comply with the mandatory formal requirements
set forth by law for its validity. When the subject of donation is purchase money,
Article 748 of the NCC is applicable. Accordingly, the donation of money as well as
its acceptance should be in writing. Otherwise, the donation is invalid for noncompliance with the formal requisites prescribed by law.
Art. 748. The donation of a movable may be made orally or in writing. —
An oral donation requires the simultaneous delivery of the thing or of the
document representing the right donated.
If the value of the personal property donated exceeds five thousand pesos, the
donation and the acceptance shall be made in writing. Otherwise, the donation
shall be void.
CJH DEVELOPMENT CORPORATION vs. CORAZON D. ANICETO
G.R. No. 224006 / July 6, 2020
G.R. No. 224472
A stipulation in a lease contract that authorizes the lessor to take possession of the
leased premises is valid and binding, even when there is no judicial action.
JULIE PARCON-SONG vs. LILIA B. PARCON
G.R. No. 199582 / July 7, 2020
Generally, if the certificate of title indicates nothing that will raise concern, and the
mortgagee is unaware of any defect in the title or any other problematic circumstance
surrounding the property, the mortgagee is not required to further investigate.
However, when the mortgagee is a bank, a higher standard is imposed before it is
considered a mortgagee in good faith. Banks cannot simply rely on the title alone,
but must further investigate the property to ensure the genuineness of the title.
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JULIE PARCON-SONG vs. LILIA B. PARCON
G.R. No. 199582 / July 7, 2020
[A] foreign bank can now participate in foreclosure sales of real property mortgaged
to it, and even possess it. There are limitations, namely: (a) the possession must be
limited to five years; (b) the property title shall not be transferred to it; and (c) within
the five-year period, it must transfer its rights to a qualified Philippine national. In
case a foreign bank fails to transfer the property, it will be liable to pay half of 1 %
per annum of the foreclosure price until it transfers the property.
ALESON SHIPPING LINES vs. CGU INTERNATIONAL INS. PLC. AND CANDANO
SHIPPING LINES, INC.
G.R. No. 217311 / July 15, 2020
The high degree of diligence exacted by the law creates a presumption against
common carriers when goods are lost, destroyed or deteriorated. To overcome this
presumption, common carriers must prove that they exercised extraordinary
diligence in the handling and transportation of the goods.
JEFFREY M. CALMA vs. MARI KRIS SANTOS-CALMA
G.R. No. 242070 / August 24, 2020
When the totality of evidence demonstrates psychological incapacity, a marriage may
be declared null and void pursuant to Article 36 of the Family Code.
GOTESCO PROPERTIES, INC. vs. NTERNATIONAL EXCHANGE BANK (NOW
UNION BANK OF THE PHILIPPINES)
G.R. No. 212262 / August 26, 2020
Acceleration clauses in loans for a fixed term give creditors a choice to: (1) defer
collection of any unpaid amounts until the period ends; or (2) invoke the clause and
collect the entire demandable amount immediately. This right to choose is rendered
meaningless if the loan is made demandable only when the term expires.
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Case Digests for Bar Exams
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