I.
General Principles
Case Title: Dominador B. Bustos v. Antonio G. Lucero
G.R. No. L-2068
Date: October 20, 1948
Facts:
Dominador B. Bustos, the petitioner, was an accused in a criminal case. He filed a motion with the Court
of First Instance of Pampanga, requesting that the case record be sent back to the justice of the peace
court of Masantol for the purpose of cross-examining the complainant and her witnesses regarding their
testimony that led to the issuance of a warrant for his arrest. The motion was denied by Judge Antonio G.
Lucero, the respondent.During the preliminary investigation, Bustos, assisted by counsel, appeared before
the justice of the peace. The justice of the peace informed Bustos of the charges and asked for his plea, to
which he entered a plea of not guilty. Bustos's counsel then requested the complainant to present her
evidence so that cross-examination could take place. The prosecutor objected, citing section 11 of rule
108, which was sustained by the justice of the peace. Bustos's counsel then announced the intention to
waive the right to present evidence, and the case was forwarded to the Court of First Instance.
Issue:
Whether the respondent judge acted within his jurisdiction in denying Bustos's motion to return the case
record to the justice of the peace court for cross-examination of the complainant and witnesses.
Ruling:
The Supreme Court held that the respondent judge did not act beyond his jurisdiction or in abuse of
discretion by denying Bustos' motion for the return of the case record. Referring to a previous case,
Dequito and Saling Buhay v. Arellano, the Court reiterated that section 11 of Rule 108 does not limit the
discretion of the justice of the peace in allowing cross-examination during preliminary investigation. The
Court emphasized that while the defendant does not have an absolute right to compel the complainant
and witnesses to repeat their statements in his presence, the justice of the peace or judge holding the
preliminary investigation has the authority, inherent in a court of justice, to pursue actions aimed at
uncovering the truth. The Court also clarified that the constitutional right of an accused to confront
witnesses against him does not apply to preliminary hearings. Moreover, the absence of a preliminary
examination does not infringe on the accused's right to confront witnesses. It further noted that
preliminary investigations can even be dispensed with without violating the accused's right to a fair trial.
The petition was dismissed, with costs against the petitioner.
The Supreme Court dismissed the petition for review on certiorari, affirming the denial of the motion to
return the case record for cross-examination. The Court held that the respondent judge did not exceed his
jurisdiction or abuse his discretion in making this decision. The Court further emphasized that the
constitutional right of an accused to confront witnesses does not extend to preliminary hearings, and the
absence of a preliminary examination does not violate the accused's right to a fair trial.
A. Substantive Law vs. Remedial Law
Case Title: Fabian v. Desierto
G.R. No. 129742
Date: September 16, 1998
Facts:
In the case of Fabian v. Desierto, Agustin, a dispute arose between PROMAT and Agustin, involving a
government construction project and allegations of harassment, intimidation, and threats. Fabian filed an
administrative complaint against Agustin for violation of Section 19 of the Ombudsman Act of 1989 and
Section 36 of the Civil Service Decree, with a request for his preventive suspension. The case went through
various stages, including an appeal to the Ombudsman and Deputy Ombudsman, resulting in a decision
exonerating Agustin from the administrative charges.
Fabian elevated the case to the Supreme Court (SC), arguing that Section 27 of Republic Act No. 6770
(Ombudsman Act of 1989) allowed appeals to the SC from administrative disciplinary cases decided by the
Office of the Ombudsman.
Issue:
Whether administrative disciplinary cases, orders, directives, or decisions of the Office of the Ombudsman
may be appealed to the Supreme Court.
Ruling:
No, administrative disciplinary cases, orders, directives, or decisions of the Office of the Ombudsman
cannot be appealed to the Supreme Court. Section 27 of Republic Act No. 6770, which allows such appeals,
is unconstitutional. This provision violates the constitutional prohibition in Section 30, Article VI of the
Constitution against a law that increases the appellate jurisdiction of the Supreme Court. The Court
highlighted that this constitutional restriction is in place to maintain control over the cases falling under
its appellate jurisdiction. Allowing the indiscriminate enlargement of the Court's appellate jurisdiction
would burden the Court and run counter to the constitutional intent. Thus, Section 27 of Republic Act No.
6770 was declared unconstitutional, and appeals to the Supreme Court from decisions of the Office of the
Ombudsman in administrative disciplinary cases were not permitted.
B. Rule – Making Power of the Supreme Court
Case Title: In Re: Exemption of the National Power Corporation from Payment of Filing/Docket Fees
A.M. No. 05-10-20-SC
Date: March 10, 2010
Supreme Court, En Banc
Facts:
The National Power Corporation (NPC) sought clarification from the Supreme Court regarding its
exemption from the payment of filing fees, appeal bonds, and supersedeas bonds. Initially, on December
6, 2005, the Court issued A.M. No. 05-10-20-SC granting NPC exemption from such payments based on
Section 13 of Republic Act No. 6395 (NPC Charter). Subsequently, on October 27, 2009, the Court issued
A.M. No. 05-10-20-SC, denying NPC's request for exemption, citing its sole power over the rules on
pleading, practice, and procedure. NPC sought clarification on whether it remained exempt from the
payment of these fees.
Issue:
Whether the National Power Corporation is exempt from payment of filing fees, appeal bonds, and
supersedeas bonds.
Ruling:
The National Power Corporation is not exempt from the payment of legal fees. Section 22 of Rule 141
states that government agencies and instrumentalities, including the Republic of the Philippines, are
exempt from legal fees. However, Section 70 of Republic Act No. 9136 confirms that NPC remains a national
government-owned and controlled corporation.
The Court clarified that its power to promulgate rules concerning pleading, practice, and procedure,
including fixing filing fees, is exclusively its domain, as emphasized in the case of Echegaray v. Secretary of
Justice. The 1987 Constitution removed the power of Congress to repeal, alter, or modify such rules,
making the Court's authority over these matters unshared.
Therefore, based on the Court's clear pronouncement, NPC cannot claim exemption from the payment of
legal fees under Republic Act No. 6395 (NPC Charter) or any other basis.
Case Title: Salvador Estipona, Jr. vs. Hon. Judge Frank E. Lobrigo
G.R. No. 226679
Date: August 15, 2017
Facts:
Salvador Estipona, Jr. was charged with violating Section 11, Article II of R.A. No. 9165 for possessing 0.084
grams of shabu. Under Section 23 of R.A. No. 9165, plea bargaining is prohibited in all drug cases. Estipona
sought permission to enter into a plea-bargaining agreement, proposing to plead guilty to the lesser
offense of violating Section 12 of R.A. No. 9165 (Possession of Drug Paraphernalia). The trial court denied
his motion, citing the prohibition in Section 23. Estipona filed a Petition to declare Section 23
unconstitutional.
Issues:
1. Whether Section 23 of R.A. No. 9165, which prohibits plea bargaining in drug cases, violates the
constitutional right to equal protection of the law.
2. Whether Section 23 of R.A. No. 9165 encroaches upon the Supreme Court's rule-making power.
3. Whether the trial court committed grave abuse of discretion in refusing to declare Section 23
unconstitutional.
Ruling:
The Supreme Court ruled on matters of technicality, stating that procedural rules can be disregarded when
substantial and transcendental issues are involved. The Court acknowledged the severe impact of the drug
problem in the Philippines and emphasized the importance of addressing it.
On the Supreme Court's Rule-Making Power, the Court established that the power to promulgate rules of
procedure, pleading, and practice lies solely with the Supreme Court and is no longer shared with the
other branches of government. The Court's authority to define and enforce constitutional rights, and the
rules of procedure for all courts, was recognized. Congress has no authority to alter, supplement, or repeal
procedural rules established by the Court.
Regarding Plea-Bargaining, the Court noted that its rule-making power is limited to preserving substantive
rights. Rules that regulate procedure, rather than alter substantive rights, fall within the Court's
jurisdiction. The Court indicated that it would not make a definitive ruling on whether Section 23 violates
the equal protection clause at that time, to avoid preempting future discussions on the matter. However,
the Court declared the prohibition against plea-bargaining in drug cases invalid until and unless it is
incorporated into the rules of procedure through an administrative circular issued by the Court.
Significance:
The case of Salvador Estipona, Jr. vs. Hon. Judge Frank E. Lobrigo addressed the Supreme Court's rulemaking power and its authority to promulgate rules of procedure, practice, and pleading. The Court
emphasized the exclusivity of its rule-making power, the importance of addressing substantial and
transcendental issues, and the distinction between procedural and substantive rules. The Court declared
the prohibition on plea bargaining in drug cases invalid, pending its incorporation into the rules of
procedure through an administrative circular issued by the Court.
Case Title: Lu vs. Lu YM Sr.
G.R. No. 226679
Date: February 11 2011
Facts:
Three consolidated cases originated from a complaint filed in 2000 in the Cebu City Regional Trial Court
(RTC) by David Lu and others against Paterno Lu Ym, Sr. and his sons, as well as LLDC. The RTC's March 1,
2004 decision favored David et al., nullifying shares issued below par value and ordering LLDC's dissolution.
An appeal of this decision was pending in CA-G.R. CV No. 81163. Subsequent incidents led to three
petitions before the Court. In G.R. No. 153690, David et al. contested the dismissal of their complaint due
to an incomplete signature on a non-forum shopping certificate. The Court's August 26, 2008 decision
found the issue moot due to an amended complaint conforming to procedural rules. In G.R. No. 157381,
Lu Ym father and sons challenged a resolution restraining their motion to lift a receivership order. The
Court's August 26, 2008 decision deemed this moot given the trial court's decision on the main case. G.R.
No. 170889 involved Lu Ym father and sons' denied application for a preliminary injunction. The Court's
August 26, 2008 decision dismissed this, as did its August 4, 2009 resolution, which concluded the trial
court lacked jurisdiction due to improper docket fees. As a result, all pending matters in these cases were
denied.
Issues:
1. Whether the Supreme Court has the power to suspend its rules and exempt a case from their
operation.
2. Whether the doctrine of immutability of decisions applies to decisions rendered in violation of the
constitutional provision regarding the modification or reversal of court-enunciated doctrines.
Ruling:
The Supreme Court, En Banc, held that its Rule-Making Power allowed it to entertain cases, not as an
implication of the incapability of the division of origin but because the nature of the cases called for such
attention. While the Court en banc exercises no appellate jurisdiction over its divisions, it can modify or
reverse decisions laid down by divisions through en banc decisions. The Court clarified that the doctrine
of immutability of decisions applies to final and executory decisions, but not to decisions that may involve
the modification or reversal of court-ordained doctrines or principles. When a decision rendered by a
division violates the constitutional provision, it becomes invalid and can be reopened anytime. The word
"may" in the provision conveys a probability of modification or reversal, not certainty. The Court
acknowledged its power to suspend its rules and exempt cases from their operation if justice requires it.
Rules of procedure are tools designed to facilitate justice, and they should not hinder the dispensation of
justice. The Court stressed that it has the prerogative to re-examine findings of fact and conclusions of law
made earlier if the application of rules frustrates justice.
Significance:
This case highlights the Supreme Court's Rule-Making Power and its ability to entertain cases that involve
the modification or reversal of established doctrines or principles. It emphasizes that the doctrine of
immutability of decisions applies only to final and executory decisions and does not prevent the Court
from reconsidering decisions rendered in violation of constitutional provisions. The ruling underscores the
Court's discretionary authority to suspend its rules and prioritize substantive rights over technicalities to
ensure justice.
C. Principle of Judicial Hierarchy
Case Title: William C. Dagan v. Office of the Ombudsman
G.R. No. 184083
Date: November 19, 2013
Supreme Court of the Philippines, En Banc
Facts:
William C. Dagan filed a complaint against several respondents, including officials of the Philippine Racing
Commission (Philracom), with the Office of the Ombudsman. The complaint alleged various administrative
violations, such as overpayment, improper hiring, oppressive scratching of racehorses, malversation, and
conflict of interest. After a preliminary investigation, the Office of the Ombudsman exonerated the
respondents from the charges. Dagan appealed the decision to the Court of Appeals through a petition for
certiorari under Rule 65 of the Rules of Court. However, the Court of Appeals dismissed the petition,
stating that the proper remedy was a petition for review under Rule 43. Dagan filed a petition before the
Supreme Court, arguing that the decision of the Office of the Ombudsman was final and unappealable
under the Ombudsman Act, thus making a petition for certiorari the appropriate remedy. He cited a
previous case, Barata v. Abalos Jr., to support his position.
Issue:
Whether Dagan correctly filed a petition for certiorari under Rule 65 before the Court of Appeals, or if he
should have filed a petition for review under Rule 43.
Ruling:
The Supreme Court ruled that Dagan should have filed a petition for review under Rule 43 instead of a
petition for certiorari under Rule 65 before the Court of Appeals. The Court abandoned its previous ruling
in Barata and clarified the proper procedure for challenging decisions of the Ombudsman. The Court
explained that decisions of the Office of the Ombudsman absolving respondents from administrative
charges are considered final and unappealable. However, the Court recognized that these decisions may
still be subject to judicial review based on arbitrariness, grave abuse of discretion, fraud, or error of law.
Such review can be pursued through a petition for certiorari under Rule 65. The Court emphasized the
importance of adhering to the hierarchy of courts principle. While the concurrent jurisdiction of the
Supreme Court and the Court of Appeals allows for the filing of a petition for certiorari with the latter, the
direct invocation of the Supreme Court's original jurisdiction through a petition for certiorari should only
be allowed when there are special, important, and compelling reasons. In this case, Dagan's petition failed
to show grave abuse of discretion committed by the Office of the Ombudsman. Therefore, even though
he followed the correct mode of review (petition for certiorari under Rule 65), his petition was dismissed
for lack of merit.
Significance:
The case reinforces the principle of judicial hierarchy, stating that a petition for certiorari under Rule 65
should generally be filed before the Court of Appeals, with the Supreme Court's original jurisdiction being
invoked only in exceptional cases. This principle aims to promote an orderly and efficient administration
of justice by ensuring that cases are heard and decided by the appropriate court level.
D. Doctrine of Non-Interference/Judicial Stability
Case Title: Pacific Ace Finance Ltd. (PAFIN) v. Eiji Yanagisawa
G.R. No. 175303
Date: April 11, 2012
Facts:
Eiji Yanagisawa (Eiji) and Evelyn Castañeda (Evelyn) contracted marriage but later filed for its nullity. During
the nullity case, Evelyn committed in open court not to dispose of or encumber her properties. The court
issued an order reflecting Evelyn's commitment, and it was annotated on the title of her property.
Eiji later discovered that Evelyn had executed a real estate mortgage (REM) on the property in favor of
Pacific Ace Finance Ltd. (PAFIN), in violation of her commitment. Eiji filed a case to annul the REM, alleging
that Evelyn violated her commitment and PAFIN was a mortgagee in bad faith.
The trial court dismissed Eiji's case, stating that as a foreigner, he had no ownership interest in the
property. The Court of Appeals (CA) ruled that the trial court's dismissal was improper as the matter of
ownership had already been submitted to the jurisdiction of another court.
Issue:
Whether the trial court had the authority to rule on the ownership issue when it was already under the
jurisdiction of another court.
Ruling:
The doctrine of non-interference/judicial stability dictates that a court should not interfere with matters
already under the jurisdiction of another court of equal authority. Once a court has jurisdiction over a
particular matter, its authority continues until the matter is finally disposed of, and no court of equal
authority should interfere. Interference can lead to confusion and conflicting decisions. In this case, the
Makati RTC had jurisdiction over the ownership issue, and the Parañaque RTC's interference was improper.
The appellate court correctly annulled the Parañaque RTC's decision and affirmed the principle of judicial
stability.
Significance:
The doctrine of non-interference or judicial stability is a legal principle that emphasizes the importance of
allowing a court that has acquired jurisdiction over a particular matter to exercise its authority without
interference from other courts of equal jurisdiction. This doctrine aims to prevent conflicts, confusion, and
inconsistent decisions arising from different court’s ruling on the same issue. The doctrine highlights the
hierarchy and coordination among courts, ensuring the proper and orderly administration of justice.