Narciso Buenaventura & Maria Buenaventura v. CA &
Manotok Realty, Inc. [GR 50837, Dec. 28, 1992]
Facts:
Julian Caiña was the occupant and tenant of a parcel of land owned by the Republic of
the Philippines.
The Republic of the Philippines acquired the land through expropriation for resale to
qualified and bona fide tenants-occupants.
Julian Caiña had a brother, Justo Caiña, survived by three children.
Before the land could be subdivided, Julian Caiña and Justo Caiña died.
Peoples Homesite and Housing Corporation (PHHC) executed a 'Deed of Absolute
Sale' over the land to Lorenzo Caiña and Francisca Caiña-Rivera, as the heirs and
successors-in-interest of Julian Caiña.
Transfer Certificate of Title No. 21013 was issued to Lorenzo Caiña and Francisca
Caiña-Rivera.
Subsequent transfers of the land occurred, leading to the issuance of Transfer
Certificate of Title No. 2145 in favor of Manotok Realty, Inc.
Private respondents filed a complaint against various parties, seeking annulment of
titles, contracts, reconveyance, and damages.
Issues:
Whether Article 1410 of the Civil Code, on imprescriptibility of actions, applies to the
case.
Whether the doctrine of laches may be applied against the private respondents.
Ruling:
The court mentioned that the principle of prescription of actions is designed to cover
situations where there have been transfers to innocent purchasers for value.
The court pointed out that, independently of prescription, the doctrine of laches may be
applied, especially when there is a series of transfers to innocent purchasers.
The Court of Appeals ordered the dismissal of the complaint, stating that the action for
reconveyance was barred by prescription. The court held that Article 1410 of the Civil
Code was not applicable because fraud was alleged in the transfer of the property. The
court also considered the doctrine of laches, stating that the private respondents
delayed in asserting their rights.
Philippine Carpet Manufacturing Corporation vs. Tagyamon [G.R. No.
191475, December 11, 2013]
Facts:
Petitioners: Philippine Carpet Manufacturing Corporation (PCMC), Pacific Carpet
Manufacturing Corporation, Mr. Patricio Lim, and Mr. David Lim.
Respondents: Ignacio B. Tagyamon, Pablito I. Luna, Fe B. Badayos, Grace B. Marcos,
Rogelio C. Nemis, Roberto B. Ilao, Anicia D. Dela Cruz, and Cynthia L. Comandao.
Background:
PCMC is engaged in manufacturing wool and yarn carpets and rugs.
Respondents were regular employees affected by PCMC's retrenchment and voluntary
retirement programs.
PCMC issued dismissal memoranda to some employees due to a slump in market
demand.
Legal Proceedings:
Respondents filed separate complaints for illegal dismissal.
PCMC defended its decision, citing necessary management prerogative and financial
constraints.
Labor Arbiter (LA) and National Labor Relations Commission (NLRC) ruled in favor of
PCMC.
Court of Appeals (CA) reversed the decisions and ordered reinstatement with
backwages.
Issues:
Laches:
Petitioners argued that respondents' complaint was filed almost three years after
dismissal, invoking the principle of laches.
CA rejected the application of laches as the case was filed within the four-year
prescriptive period.
Stare Decisis:
Petitioners contested the application of stare decisis, urging a re-examination of the
Philcea case relied upon by the CA.
CA applied stare decisis, considering similar factual circumstances in both cases.
Waivers, Releases, and Quitclaims:
Petitioners claimed that the waivers, releases, and quitclaims signed by respondents
bar them from demanding benefits.
CA found the quitclaims illegal due to misrepresentation by PCMC about its financial
condition.
Ruling:
Laches:
The Court rejected the application of laches as the complaint was filed within the fouryear prescriptive period.
Stare Decisis:
The Court upheld the application of stare decisis, reaffirming the conclusions in the
Philcea case.
Waivers, Releases, and Quitclaims:
The Court deemed the quitclaims illegal due to misrepresentation by PCMC, allowing
respondents to demand benefits.
Conclusion:
The CA's decision was affirmed, ordering reinstatement with backwages and
recognizing the illegality of the quitclaims.
Key Legal Principles:
Laches:
Laches is the failure to assert one's rights within a reasonable time, and it cannot be
invoked if the claim is filed within the prescribed period.
Stare Decisis:
Stare decisis dictates that a court should adhere to precedent and apply the same legal
principles to similar cases unless there are strong reasons to deviate.
Waivers, Releases, and Quitclaims:
Deeds of release and quitclaim are not absolute and can be invalidated if obtained
through fraud or if terms are contrary to law, public order, or public policy.
This case underscores the importance of consistent legal principles, adherence to
precedents, and the invalidation of agreements obtained through misrepresentation.
Phil-Air Conditioning Center vs. RCJ Lines, [G.R. No. 193821,
November 23, 2015
The case involves a dispute between Phil-Air and RCJ Lines over the sale of airconditioning units for buses. Phil-Air sold four units to RCJ Lines, and a dispute arose
when RCJ Lines refused to pay the balance, claiming that the units did not meet cooling
requirements.
Phil-Air filed a complaint for the unpaid balance, repair services, interest, and attorney's
fees. RCJ Lines counterclaimed, seeking reimbursement for replacement costs of the
units, lost profits, and damages due to the enforcement of a writ of attachment.
The key issue addressed was whether Phil-Air's claim was barred by laches. The court
ruled that laches does not apply when the law provides a specific period to enforce a
claim. The ten-year prescriptive period under Article 1144 of the Civil Code applied in
this case.
The court found that Phil-Air filed the complaint within the prescriptive period, rejecting
RCJ Lines' argument of laches. It emphasized that laches is a recourse in equity and is
applied only in the absence, never in contravention, of statutory law.
In conclusion, the court granted Phil-Air's petition, ruling that the claim was not barred
by laches, and the complaint was timely filed within the ten-year prescriptive period.
CHAPTER II – Prescription of Ownership and Other Real Rights
(Articles 1117-1138
Abalos vs. Heirs of Torio [G.R. No. 175444, December 14, 2011]
Facts:
Heirs of Vicente Torio filed a complaint for Recovery of Possession and Damages
against Jaime Abalos and the spouses Felix and Consuelo Salazar.
The complaint stated that the Torio heirs are the children and heirs of Vicente Torio,
who died intestate in 1973, leaving a parcel of land. Jaime and the Spouses Salazar
were allowed to stay on the land by Vicente Torio's tolerance.
The Torio heirs asked Jaime and the Spouses Salazar to vacate in 1985, but they
refused. A legal action was initiated in 1996.
Jaime and the Spouses Salazar, along with intervenors (petitioners in this case), denied
the allegations and claimed ownership through acquisitive prescription.
Issues:
Whether petitioners acquired ownership of the disputed land through ordinary
acquisitive prescription.
Whether the due execution and authenticity of the deed of sale, upon which
respondents' ownership is based, were proven during trial.
Ruling:
The Court of Appeals (CA) reversed the Regional Trial Court's (RTC) decision in favor
of Jaime and the Spouses Salazar, reinstating the Municipal Trial Court's (MTC)
decision. The CA held that petitioners' possession was by mere tolerance, not meeting
the requirements for acquisitive prescription.
The CA also affirmed the validity of the deed of sale, finding it duly notarized and
entitled to the presumption of regularity.
The Supreme Court, in this petition for review, affirmed the CA's decision, rejecting
petitioners' claim of ownership through prescription due to lack of good faith and just
title.
The Court noted that petitioners' acknowledgment in a tax declaration that their houses
were built on Torio's land showed they possessed the land by tolerance, not adverse
possession.
The issue of due execution and authenticity of the deed of sale was dismissed because
it was not raised during trial, and the CA upheld the presumption of regularity for
notarized documents.
Principles:
Possession "in good faith" for acquisitive prescription requires a reasonable belief in
ownership, absent in cases of acknowledgment of another's ownership.
The presumption of regularity applies to notarized documents, and to overcome it, there
must be clear, convincing, and more than merely preponderant evidence.
Points of law not brought to the trial court's attention need not be considered on appeal
to uphold the rules of fair play and due process.
Pabalan vs. Heirs of Maamo, Sr. [G.R. No. 174844, March 20, 2013
Facts:
Onofre Palapo sold land in Barrio Calapian (now Barangay Estela), Liloan, Leyte, to
Placido Sy-Cansoy on December 31, 1910.
Placido, in 1934, affirmed the sale of the land to Miguel's wife, Antonia Bayon.
Antonia filed an ejectment complaint in 1934 against Simplecio Palapo, alleging forcible
entry.
The court decided in favor of Antonia in December 1934, ordering Simplecio to vacate
the land.
In 1981, the heirs of Simeon A.B. Maamo initiated a case for recovery of real property
and damages against Simplecio's children, claiming co-ownership of the land.
The heirs of Simeon A.B. Maamo (respondents) alleged that Simplecio's descendants
refused to return a portion of the land after his death in 1971.
Simplecio's descendants (petitioners) claimed ownership based on long, continuous,
and adverse possession since 1906.
Issues:
Whether respondents are the true owners of the land or if petitioners acquired
ownership through prescription.
Whether the Court of Appeals (CA) correctly reversed the Regional Trial Court's (RTC)
decision in favor of petitioners.
Ruling:
The Regional Trial Court initially ruled in favor of petitioners in 1997, but the Court of
Appeals reversed this decision in 2006. The CA held that the heirs of Simeon A.B.
Maamo were the true owners of the land. The CA based its decision on various factors,
including the 1912 sale from Placido to Antonia, the rejection of petitioners' claims in the
1934 ejectment case, and the inconsistent boundaries provided in the tax declarations
of petitioners.
Arguments (Petitioners' Grounds for Review):
Petitioners argue that they have been in open, public, adverse, and continuous
possession of the land since 1906.
They contend that respondents were not in possession of the property from 1935 until
the filing of their complaint in 1981, constituting estoppel and laches.
Petitioners dispute the CA's reliance on the judgment rendered in Civil Case No. 298 as
a basis for respondents' possession.
They claim that Simplecio's possession was not based on tolerance but through the
legal concept of adverse possession.
Petitioners argue that the CA erred in applying provisions of the new Civil Code
retroactively.
Summary:
The case involves a dispute over land ownership, with respondents claiming title based
on a 1912 sale and a previous ejectment case, while petitioners assert ownership
through adverse possession. The CA favored respondents, prompting petitioners to file
a petition for review on certiorari, disputing various factual findings and legal
interpretations.
Please note that the provided summary is a general overview and may not capture all
nuances of the case. For a more detailed understanding, you may want to refer to the
full text of the decision.
Rodriguez, Sr. vs. Francisco [G.R. No. L-13343, December 29, 1962]
Facts:
Exequiel Ampil, now deceased, was the registered owner of the land under Original
Certificate of Title No. 2497 issued on May 25, 1918 (Exhibit B-1).
On March 24, 1924, Exequiel Ampil sold the land to defendant Maximo Francisco for
P1,500 (Exhibit 4).
Maximo Francisco took possession of the land and continued possession after his death
in 1950.
Despite the sale, the Torrens title remained in the name of the vendor Exequiel Ampil
until 1937.
Exequiel Ampil was indebted to various creditors, and Eulogio Rodriguez, Sr.
guaranteed the payment through a "Venta Condicional" document, registered in 1933.
Plaintiff executed a "Release of Part of the Conditionally Sold Premises" in 1934,
releasing some properties but retaining the land in question as security.
In 1936, plaintiff filed an affidavit consolidating ownership, leading to the issuance of
Transfer Certificate of Title No. 31204 in 1937.
Plaintiff filed a case in 1949 seeking ownership, recovery of possession, and damages.
Issues:
Ownership of the disputed land.
Possession of defendant Maximo Francisco, specifically whether he was a possessor in
good faith.
Ruling: The trial court adjudged the plaintiff as the rightful owner of the land but found
the defendant Maximo Francisco to be a possessor in good faith, hence not liable for
damages. Both parties appealed.
The Supreme Court affirmed the trial court's decision on ownership. However, the issue
of possession in good faith was considered. The Court held that the defendant Maximo
Francisco was not necessarily a possessor in bad faith despite certain circumstances
raised by the appellant. The Court emphasized that the non-registration of the sale did
not make the vendee a possessor in bad faith. While plaintiff obtained ownership
through consolidation, Maximo Francisco, being in possession, had a good and
sufficient title.
Decision:
The Court agreed with the trial court's conclusion that Maximo Francisco was a
possessor in good faith.
Appellant's alternative contention was accepted: On the date of summons (considering
the final judgment declaring the plaintiff as the owner), appellee's possession in good
faith was interrupted, and he lost the right to the fruits.
Damages up to Maximo Francisco's death (June 20, 1950) should be claimed against
his estate, while damages from 1951 onwards are the responsibility of appellee.
Defendant-appellee, as the administrator of Maximo Francisco's estate, is ordered to
pay the plaintiff-appellant P200.00 yearly from 1951 until the restoration of possession,
with interest at the legal rate, plus costs.
The decision was concurred by ten Justices.
Please note that this summary provides a condensed version of the case, and specific
legal nuances may require further analysis.
Heirs of Malabanan vs. Republic [G.R. No. 179987, April 29, 2009]
Facts
Malaban sought to register the parcel of land they have bought from Eduardo Velazco.
He alleged that he and his predecessors-in-interest had been in open, notorious, and
continuous adverse and peaceful possession of the land for more than thirty (30) years.
The Republic of the Philippines opposed the petition. They alleged that for one to
acquire the right to seek registration of an alienable and disposable land of the public
domain, it is not enough that the applicant and his/her predecessors-in-interest be in
possession under a bona fide claim of ownership since 12 June 1945; the alienable and
disposable character of the property must have been declared also as of 12 June 1945.
In other words, the OSG opined that all lands that are certified as alienable and
disposable after June 12, 1945 cannot be registered. Since the subject land was
certified as alienable and disposable on March 15, 1982, it cannot be registered.
Issue
Whether or not the land should be alienable and disposable on June 12, 1945 or earlier
before it can be registered under Section 14(1) of PD 1529.
Whether or not the land can be registered under Section 14(2) of PD No 1529.
Held
First Issue
As ruled in Republic v. Naguit, the land need not be classified as alienable or
disposable on June 12, 1945 or earlier. It is enough that the land be alienable and
disposable at the time of registration. To rule otherwise would result to absurdity, that is,
all lands of the public domain which were not registered before June 12, 1945 cannot be
susceptible for original registration.
In this case, the land was classified as alienable and disposable before it was sought to
be registered. However, there is no substantive evidence to establish that Malabanan or
petitioners as his predecessors-in-interest have been in possession of the property
since 12 June 1945 or earlier. Hence, the subject land cannot be subject to registration
under Section 14(1) even if it was already classified as alienable and disposable prior to
the application for registration. This is because the requisite of possession before June
12, 1945 is not proven.
Second Issue
No. The land cannot be registered under Section 14 (2) of PD 1529.
Under the Civil Code, prescription is a mode of acquiring ownership of patrimonial
property. However, public domain lands can only be converted to patrimonial property
when two requisites are present. One, there must be a declaration that the land is
alienable or disposable. Second, there must be an express government manifestation in
the form of law or Presidential Proclamations that the property is already patrimonial or
it is no longer used for public use, public service, and development of national wealth.
Without both requisites, the property cannot be subject to acquisitive ownership by
prescription.
In addition, the running of the prescriptive period starts after the express declaration that
the land of public domain is already patrimonial.
In this case, even if the subject property was declared as alienable or disposable in
1982, there is no competent evidence that the land is no longer intended for public use,
service or for the development of national wealth in consonance with Art 422 of the Civil
Code.
Therefore, the land in question cannot also be subject to registration under Section 14
(2) of PD 1529.
South City Homes, Inc. v. Republic, [G.R. No. 76564, May 25, 1990
Facts:
The petitioner owns two lots (Lot No. 2381 and Lot No. 2386-A) adjacent to each other
in Calabuso, Biñan, Laguna.
In 1983, a strip of land (Lot No. 5005) between the petitioner's two lots was discovered
during a survey by the Bureau of Lands.
The trial court decreed the registration of Lot No. 5005 in the petitioner's name in 1984.
The respondent court, with two members dissenting, reversed the registration order on
appeal.
The petitioner claims ownership of Lot No. 5005 either because it was omitted from the
original survey due to inaccuracies or through acquisitive prescription, asserting
uninterrupted possession for over forty years.
Issues:
Whether Lot No. 5005 is part of Lots 2381 and 2386-A or a separate lot.
Whether the petitioner acquired Lot No. 5005 through prescription.
The nature of the disputed lot (patrimonial or part of the public domain).
Ruling: The court found that the petitioner's claim to Lot No. 5005 lacked merit.
The technical descriptions of Lots 2381 and 2386-A did not include Lot No. 5005, and
the court rejected the argument that the omission was due to survey inaccuracies.
The court disagreed with the Republic's argument that Lot No. 5005, originally a canal,
remained part of the public domain. It deemed the Friar Lands Act inapplicable since the
canal had dried up, and Lot No. 5005 was now a separate lot.
The court dismissed the petitioner's claim of acquisitive prescription, citing insufficient
evidence. The possession of the lot was not exclusive, shared with predecessors-ininterest, and the claimed possession period was not enough to establish prescriptive
title.
Tacking of possession was disallowed because the petitioner did not acquire Lot No.
5005 from the previous owners of Lots 2381 and 2386-A. Privity was lacking, and the
possession could not be connected to the petitioner's ownership of the adjacent lots.
The court deemed it unnecessary to determine the nature of the disputed lot
(patrimonial or part of the public domain) due to the failure to establish ownership.
Conclusion: The petition was denied, and costs were imposed on the petitioner. The
court held that the petitioner failed to establish its title to Lot No. 5005, regardless of its
nature.
Ruiz v. Court of Appeals [G.R. No. L-29213, October 21, 1977]
Facts:
Private respondents (Jovencio Q. Tancontian, Socorro T. Aguilon, Salvacion T. Diao,
Imelda T. Noel, Jesus Aguilon, and Alfredo Noel, Jr.) filed a case in the Court of First
Instance of Davao (Civil Case 5003) on March 21, 1966, seeking the recovery of a
parcel of land against petitioners Manuel B. Ruiz, Marcial Quiñ;ones, Filomena
Quiñ;ones, and the spouses Macario Quicio and Alejandra Balico.
The private respondents alleged that they are legitimate heirs of Meliton Quiñ;ones, the
deceased owner of the land. Marcial Quiñ;ones and Filomena Quiñ;ones, claiming to be
the legal heirs, filed a previous case (Civil Case No. 904) in 1952, won the case with the
assistance of petitioner Manuel B. Ruiz, and subsequently sold the land to Macario
Quicio in April 1956.
Issues:
Whether the complaint filed by private respondents states a cause of action.
Whether the cause of action, if it exists, is barred by the statute of limitations.
Whether the sales contracts over the land in dispute to petitioners Quicio and Ruiz are
null and void ab initio.
Whether acquisitive prescription applies to the case.
Ruling:
The Court finds that the complaint sufficiently states a cause of action against
petitioners Quicio and Ruiz, even if the phraseology leaves room for improvement.
Ambiguity is not sufficient justification for dismissal, and the complaint allows for a valid
judgment based on the facts alleged.
The plea of prescription is not sustained. The action for the declaration of the
inexistence of a contract does not prescribe under Article 1410 of the Civil Code.
The Court acknowledges the argument that the sales contracts may be voidable, but the
private respondents assert that the sales were null and void ab initio due to collusion,
violation of public policy, and absolute simulation. The Court finds that the private
respondents' amended complaint sufficiently states a cause of action against petitioners
Quicio and Ruiz.
Acquisitive prescription does not apply because less than ten years had elapsed
between the registration of the land in dispute in 1956 and the filing of the complaint in
1966. Moreover, the fraudulent registration creates a constructive trust in favor of the
defrauded party, allowing recovery within ten years.
The petition is denied, and the Court finds no sufficient reason to reverse the order of
dismissal. Marcial Quiñ;ones and Filomena Quiñ;ones are allowed to withdraw as copetitioners. The complaint states a cause of action against petitioners Quicio and Ruiz,
and the plea of prescription is not sustained. The sales contracts are considered null
and void ab initio.
Limcoma Multi-Purpose Cooperative v. Republic [G.R. No. 167652,
July 10, 2007]
Facts:
On September 24, 2001, petitioner Limcoma Multi-Purpose Cooperative filed an
application for registration and confirmation of title over a parcel of land, Lot 972-A No.
Csd-04-015172-D, Cad 426, Rosario Cadastre, consisting of 646 square meters under
the Property Registration Decree.
The subject lot was originally part of Lot 972 and was subsequently segregated as Lot
972-A.
Petitioner claimed ownership in fee simple and asserted open, exclusive, peaceful, and
continuous possession for more than 30 years, based on the possession of its
predecessors-in-interest.
In the alternative, petitioner invoked Section 485 of the Public Land Act, citing open,
exclusive, and continuous possession of the subject lot for over 30 years.
The Regional Trial Court (RTC) allowed petitioner to present evidence ex-parte, and
witnesses testified to the possession and ownership of the subject lot.
The RTC granted the application, but the Court of Appeals (CA) reversed the decision,
citing petitioner's failure to prove open, continuous, exclusive, and notorious possession
and the presumption that the subject lot is public and alienable land.
Issues:
Whether the subject lot is public and alienable land, and if petitioner has been in open,
continuous, exclusive, and notorious possession since June 12, 1945, or earlier, under
a bona fide claim of ownership.
Corollarily, whether the subject lot acquired a private character in 1968, within the
operation of the laws on prescription.
Applicable Laws:
Property Registration Decree, Section 14:
Conditions for land registration, including open, continuous, exclusive, and notorious
possession since June 12, 1945, or earlier.
Public Land Act, Section 48(b):
Conditions for confirmation of claims and issuance of a certificate of title, requiring open,
continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
Civil Code, Article 1138:
Rules for the computation of time necessary for prescription, including the tacking of
possession.
Ruling:
Affirmative on Alienability:
Petitioner presented documents, including a DENR-CENRO Certification, proving that
the subject lot is alienable public land.
Affirmative on Possession:
Petitioner adequately established open, continuous, exclusive, and notorious
possession of the subject lot since 1938, and tacked its possession to that of its
predecessors-in-interest.
Prescription:
The subject lot had already been converted to private property by 1968 due to more
than 30 years of possession by predecessors-in-interest.
Petitioner, having possessed the lot for 10 years in good faith, acquired registrable title
under ordinary acquisitive prescription.
Decision:
The CA decision was reversed, and the RTC order granting petitioner's application for
registration was reinstated. No costs were awarded.
I hope this breakdown helps you understand the case better! If you have further
questions or need clarification on specific points, feel free to ask.
CHAPTER III – Prescription of Actions (Articles 1139-1155
Virtucio vs. Alegarbes [G.R. No. 187451, August 29, 2012
Facts:
Petitioner, Limcoma Multi-Purpose Cooperative, applied for registration and
confirmation of title for Lot 972-A No. Csd-04-015172-D in Rosario, Batangas,
consisting of 646 square meters under the Property Registration Decree.
The subject lot was initially part of Lot 972 and was later segregated as Lot 972-A.
Petitioner claimed ownership of the subject lot and its improvements, asserting open,
exclusive, peaceful, and continuous possession for more than 30 years.
In the alternative, petitioner invoked Section 485 of the Public Land Act, citing open,
exclusive, and continuous possession for over 30 years.
The RTC issued an Order allowing petitioner to present evidence ex-parte as there
were no private oppositors.
Petitioner presented witnesses and evidence, including testimonies from Olivia P.
Gomez, Arsenia P. Alcantara, and Lorenzo P. Limbo.
The RTC granted the application, ordering the registration of the subject lot in the name
of Limcoma Multi-Purpose Cooperative.
On appeal, the Court of Appeals (CA) reversed the RTC decision, dismissing the
application.
Issues:
Whether the subject lot is public and alienable land, and if petitioner has been in open,
continuous, exclusive, and notorious possession since June 12, 1945, or earlier, under
a bona fide claim of ownership.
Corollarily, whether the subject lot acquired a private character in 1968, falling within the
laws on prescription.
Ruling:
The CA ruled against the petitioner, stating that they failed to demonstrate the required
possession since June 12, 1945, and did not overcome the presumption that the lot is
public and alienable.
The Supreme Court (SC), however, disagreed with the CA. It affirmed that the subject
lot is public and alienable based on evidence such as a certification from the DENRCENRO.
The SC found that the petitioner adequately proved open, continuous, exclusive, and
notorious possession of the subject lot since 1938, meeting the requirements for
registration.
The SC emphasized that the possession of predecessors-in-interest can be tacked to
that of the petitioner, leading to the conclusion that the subject lot had already been
converted to private property by 1968.
Consequently, the SC reversed the CA decision, reinstating the RTC order granting the
application for registration of the subject lot in favor of Limcoma Multi-Purpose
Cooperative.
Overseas Bank of Manila v. Geraldez [G.R. No. L-46541, December 28,
1979]
Facts:
The Overseas Bank of Manila appealed from the orders of the Court of First Instance of
Manila, dated January 4 and February 9, 1977, dismissing its complaint against
Teodosio Valenton and Andres A. Juan for the recovery of P150,000 plus interest and
attorney's fees.
The complaint alleged that on February 16, 1966, Valenton and Juan obtained a credit
accommodation of P150,000 from the bank, secured by a chattel mortgage.
The bank claimed to have made written extrajudicial demands on the debtors, asserting
that their obligation was assumed by a third party without the bank's consent.
The trial court dismissed the complaint on the ground of prescription, stating that the
cause of action accrued on February 16, 1966, and the complaint, filed on October 22,
1976, exceeded the ten-year prescriptive period.
The trial court held that the written extrajudicial demands only interrupted the
prescriptive period for the period indicated in the demand letter, which was interpreted
to be one day for each letter.
Issues:
Whether the bank's written extrajudicial demands effectively interrupted the prescriptive
period for the action against Valenton and Juan.
Ruling:
The court held that the trial court erred in its interpretation of the effect of written
extrajudicial demands. The interruption of the prescriptive period means that it starts
anew from the receipt of the demand, wiping out the time that has already elapsed.
The court cited Civil Code provisions stating that the prescription of actions is
interrupted by a written extrajudicial demand by the creditor. The interruption results in
the commencement of a new prescriptive period.
The court disagreed with the trial court's view that each demand letter suspended the
prescriptive period for one day only. Instead, it ruled that the interruption erased the
time that had passed and initiated a completely new period, starting from the date of the
last demand.
The court reversed the lower court's order of dismissal and directed it to conduct further
proceedings in the case.
Additional Notes:
The court referred to legal principles and precedents to support its interpretation of the
interruption of the prescriptive period.
Various cases were cited to emphasize that interruption leads to the renewal of the
original prescriptive term.
The court concluded that the action was not barred by prescription and instructed the
lower court to proceed with the case.
This format provides a concise summary of the facts, issues, and the court's ruling in
the case.
Nestle Philippines, Inc. v. Court of Appeals [G.R. No. 134114, July 6,
2001]
Facts:
In February 1983, Nestle Philippines Inc. (Nestle) increased its authorized capital stock
from P300 million to P600 million.
Nestle sought approval from the Securities and Exchange Commission (SEC), which
was granted.
Nestle, having only two principal stockholders (San Miguel Corporation and Nestle
S.A.), decided to issue 344,500 additional shares exclusively to these stockholders.
On March 28, 1985, Nestle filed a letter with the SEC, seeking exemption from
registration and payment of fees for the proposed issuance of additional shares.
Nestle argued that Section 6(a)(4) of the Revised Securities Act exempted the issuance
of additional capital stock from registration requirements.
Issues:
Whether the proposed issuance of additional shares by Nestle falls under the exemption
provided in Section 6(a)(4) of the Revised Securities Act.
Whether Nestle is exempt from the payment of fees under Section 6(c) of the Revised
Securities Act.
Ruling:
The Court upheld the SEC's interpretation that Section 6(a)(4) applies only to issuances
made in the course of increasing the authorized capital stock of a corporation.
Nestle's claim for exemption from payment of fees was denied, as the fees were for a
different service – exemption from registration requirements under the Revised
Securities Act.
Reasoning:
The Court gave great weight to the SEC's interpretation of the statute, acknowledging
the agency's expertise in interpreting and implementing securities laws.
The Court considered the underlying purpose of Section 6(a)(4) to protect the investing
public, and limiting the exemption to issuances during an increase in authorized capital
stock allows the SEC to scrutinize the issuances for the public's benefit.
Nestle's proposed construction would create an inflexible rule of automatic exemption,
potentially limiting the SEC's ability to protect investors.
In conclusion, the Court affirmed the decision of the Court of Appeals, sustaining the
ruling of the SEC and denying Nestle's petition for review. Nestle was required to
comply with the SEC's procedures and pay the applicable fees for the proposed
issuance of additional shares.
Intercontinental Broadcasting Corporation v. Panganiban, [G.R. No.
151407, February 6, 2007]
Facts:
Ireneo Panganiban, the respondent, was employed as Assistant General Manager of
Intercontinental Broadcasting Corporation (IBC) from May 1986 to his preventive
suspension on August 26, 1988. He resigned on September 2, 1988.
On April 12, 1989, Panganiban filed a case against the members of the Board of
Administrators (BOA) of IBC, alleging, among others, non-payment of his unpaid
commissions.
The Regional Trial Court (RTC) initially denied a motion to dismiss filed by one of the
defendants on the ground of lack of jurisdiction.
A petition for certiorari was filed with the Court of Appeals (CA), docketed as CA-G.R.
SP No. 23821, which granted the petition, ruling that the RTC lacked jurisdiction.
Panganiban was elected by the BOA as Vice-President for Marketing in July 1992 and
resigned in April 1993.
On July 24, 1996, Panganiban filed a complaint against IBC for illegal dismissal,
separation pay, retirement benefits, unpaid commissions, and damages.
The Labor Arbiter (LA) ruled in favor of Panganiban, ordering reinstatement with full
backwages and payment of unpaid commissions.
IBC's appeal to the National Labor Relations Commission (NLRC) was dismissed due to
the failure to post a bond.
IBC's motion for reconsideration was denied by the NLRC.
IBC filed a petition with the Court of Appeals, which granted the petition, annulling the
NLRC's decision and dismissing Panganiban's complaint for lack of jurisdiction.
Panganiban filed a motion for reconsideration, and the CA modified its decision,
ordering IBC to pay Panganiban ₱2,521,769.77 as unpaid commissions.
Issues:
Whether Panganiban's claim for unpaid commissions has prescribed.
Whether the CA erred in declaring that Panganiban's claim has not prescribed due to
the filing of Civil Case No. Q-89-2244 and an acknowledgment of the claim by IBC.
Ruling:
The Court held that Panganiban's claim for unpaid commissions has prescribed. The
filing of Civil Case No. Q-89-2244 did not interrupt the prescriptive period because the
case was dismissed for lack of jurisdiction. The three-year prescriptive period had
lapsed on September 2, 1991, three years after Panganiban's cessation of employment.
The acknowledgment by IBC of the debt through a letter sent by Pio S. Kaimo, Jr., Audit
Group Head, did not alter the fact that Panganiban's claim had already prescribed. The
acknowledgment only pertained to a portion of the claimed amount and was irrelevant to
the issue of prescription.
The Court set aside the CA's resolutions and reinstated its decision dated July 30, 1999,
dismissing Panganiban's complaint.
Permanent Savings and Loan Bank v. Velarde [G.R. No. 140608,
September 23, 2004]
Facts:
Respondent Mariano Velarde sought reconsideration of the Court's Decision dated
September 23, 2004, which ordered him to pay petitioner Permanent Savings and Loan
Bank the sum of ₱1,000,000.00 plus 25% interest and 24% penalty charge per annum
beginning October 13, 1983, until fully paid, as well as attorney's fees.
Respondent argued that the circumstances of the case and the interest of substantial
justice justified the suspension or relaxing of procedural rules to allow the review of the
petition.
Issues:
Whether there are valid grounds to reconsider the Court's previous decision regarding
the amount awarded to petitioner.
Whether equity justifies a review of the excessive interest rate, penalty charge, and
attorney's fees imposed on respondent.
Ruling:
The Court noted that no substantial arguments were presented by respondent in the
motion for reconsideration.
The Court had previously ordered respondent to pay the specified amount based on the
finding that he did not specifically deny the genuineness and due execution of the
Promissory Note, which served as proof of the loan.
However, the Court deemed it proper and just to reconsider the amount of the award
due to the excessive interest rate, onerous penalty, and resulting excessive attorney's
fees.
The Court acknowledged procedural lapses on the part of respondent's counsel but
considered it inequitable to penalize respondent with huge interests and penalties given
the circumstances, including the trial court and the Court of Appeals initially ruling that
petitioner failed to prove the existence of the loan.
To address the inequitable consequences, the Court reduced the award, specifying the
principal amount, interest, and attorney's fees to be paid by respondent.
Revised Award:
Principal of loan: ₱1,000,000.00
12% interest per annum on principal from default (October 13, 1983) to date of Decision
of RTC (January 26, 1996): ₱1,554,000.00
Attorney’s fees: ₱50,000.00
12% legal interest per annum on principal from the date of receipt of this resolution until
fully paid.
Conclusion:
The motion for reconsideration is partly granted, and the revised amount to be paid by
respondent is specified.
Ledesma v. Court of Appeals [G.R. No. 106646 (Resolution), June 30,
1993
Facts:
Rizal Commercial Banking Corporation (private respondent) filed a case against Jaime
Ledesma (petitioner) in 1980 to enforce a Trust Receipt Agreement. The case was
dismissed without prejudice in 1981 due to the inability to serve summons on Ledesma.
In 1988, the bank filed a new case against Ledesma on the same cause of action and
subject matter.
Ledesma's motion to dismiss based on prescription was denied. The trial court ruled in
favor of the bank, ordering Ledesma to pay a specified amount with interest, attorney's
fees, and costs.
The Court of Appeals affirmed the trial court's decision, and Ledesma's motion for
reconsideration was denied.
Issues:
Whether the second action filed by the bank had already prescribed.
Interpretation of Article 1155 of the Civil Code regarding the interruption of the
prescriptive period by the filing of an action in court.
Ruling:
Ledesma filed a motion for reconsideration, arguing that the second action filed by the
bank had already prescribed. He invoked rulings in other cases and invited the court to
review conflicting jurisprudence.
Article 1155 of the Civil Code provides that the prescription of an action is interrupted by
the filing of an action, a written extrajudicial demand by the creditor, and a written
acknowledgment of the debt by the debtor.
The court cited Overseas Bank of Manila vs. Geraldez, stating that the interruption of
the prescriptive period by written extrajudicial demand means the period commences
anew from the receipt of the demand.
The court also referred to Philippine National Railways vs. National Labor Relations
Commission, which held that the interruption of the prescriptive period by a written
acknowledgment of the debt by the debtor means the period starts to run anew.
The court rejected Ledesma's argument that the prescriptive period is merely tolled
when an action is filed in court. It emphasized that such an interpretation would lead to
a bifurcated understanding of Article 1155.
The court concluded that the correct interpretation of Article 1155 is reflected in
Overseas Bank of Manila and Philippine National Railways, and Ledesma failed to
provide substantial arguments to reconsider the court's previous resolution.
Ledesma's motion for reconsideration was denied with finality.
Conclusion:
The court affirmed its previous resolution, stating that the second action filed by the
bank had not prescribed, and rejected Ledesma's argument regarding the interpretation
of Article 1155. The motion for reconsideration was denied with finality.