Case Digest: G.R. No.

78206, March 19, 1990

Paulino Zamora, et al. v. Court of Appeals, Medina Recreation Center, Inc., et al.

Facts:

The petitioners and private respondents were initially part of an unregistered partnership called
the Medina People's Cockpit Association (MPCA) formed in 1966. In 1976, the Medina
Recreation Center, Inc. (MRC), a corporation, was established with the properties of the MPCA
transferred to it. The petitioners contested the transfer of properties, alleging fraud and other
irregularities. They filed a complaint against the private respondents in 1979 with the Securities
and Exchange Commission (SEC) and later in 1980 with the Court of First Instance (CFI) of
Misamis Oriental. The petitioners claimed to be suing as members of the MPCA, not
stockholders of MRC. The private respondents, however, argued that the dispute was an intra-
corporate matter under the jurisdiction of the SEC. The issue was whether the CFI or the SEC
had jurisdiction over the case.

Issues:

1. Whether the CFI or the SEC has jurisdiction over the dispute between the petitioners and
private respondents.
2. Whether the petitioners are estopped from amending their complaint to assert their status
as members of the MPCA after filing the complaint with the SEC as stockholders of
MRC.

Ruling:

The Supreme Court affirmed the decision of the Court of Appeals, which ruled that the SEC had
exclusive jurisdiction over the dispute, not the CFI. The Court held that the petitioners were
suing as stockholders of MRC, as evidenced by their initial complaint filed with the SEC, where
they explicitly identified themselves as stockholders of the corporation. The petitioners could not
amend their complaint to change their status after filing with the SEC. Therefore, the dispute was
an intra-corporate matter under Presidential Decree No. 902-A, and the SEC, not the CFI, had
jurisdiction.

Doctrine/Principle:

1. Jurisdiction over the Subject Matter: Jurisdiction is determined by law and cannot be
altered by the agreement or actions of the parties. The proper court or agency must be
determined based on the nature of the dispute, not on the forum chosen by the parties.
2. Estoppel and Jurisdiction: The filing of a complaint in a forum that lacks jurisdiction
does not preclude a party from later filing the same complaint in the proper court.
However, in this case, the petitioners' initial admission that they were stockholders of
MRC bound them to that characterization, and they were estopped from claiming
otherwise later on.
 3. Intra-Corporate Disputes: Disputes involving stockholders and officers of a
corporation fall under the jurisdiction of the SEC under P.D. No. 902-A, particularly
those related to allegations of fraud, mismanagement, or issues regarding the governance
of a corporation.

Conclusion:

The Supreme Court concluded that the SEC had jurisdiction over the case because the dispute
was intra-corporate in nature, involving the petitioners' claims as stockholders of MRC. The
Court affirmed the Court of Appeals' decision, directing the petitioners to pursue their claims
with the SEC.

G.R. No. 132601. January 19, 1999 (Case Brief / Digest)

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### Title
Echegaray vs. Secretary of Justice: The Pivotal Case on the Execution of a Death Convict
in
the Philippines
### Facts
Leo Echegaray, a death row convict, filed a petition questioning the constitutionality of R.A.
No. 8177, or the Lethal Injection Law, and its implementing rules and regulations. The
Supreme Court initially resolved to deny the petition, declaring R.A. No. 8177 constitutional
but invalidated certain sections of its implementing rules. This decision became final and
executory on November 6, 1998. Subsequently, Echegaray filed a Very Urgent Motion for
Issuance of TRO on December 28, 1998, alleging movements within Congress to repeal or
review the death penalty law. Given the seriousness of the matter, the execution scheduled
for January 4, 1999, was temporarily restrained by the Supreme Court to allow deliberation
on the newly filed motion.
### Issues
1. Whether the Supreme Court lost its jurisdiction over the case after its judgment became
final, and thus, could no longer restrain the execution of Echegaray.
2. Whether the issuance of the TRO by the Court encroached upon the executive domain of
granting reprieves.
3. Whether there were compelling reasons for the Supreme Court to control the execution of
its final decisions in light of supervening events in Congress.
### Court’s Decision
1. The Court held that its jurisdiction to execute and enforce its judgments does not wane
even after they become final and executory, distinguishing between the jurisdiction to alter
a final judgment and the jurisdiction to execute it. Since the TRO aimed not to change the
Court’s decision but to temporarily hold its execution, the Court deemed its issuance within
its constitutional power of judicial review.
2. The Court rejected the notion that its issuance of the TRO was a usurpation of the
President’s power of reprieve, emphasizing the judiciary’s inherent power to control and
supervise the execution of its decisions to ensure fairness and justice.
3. Given the substantial allegations of legislative movements to potentially repeal or modify
the death penalty law and recognizing the Court’s duty to exercise caution where life is at
stake, the issuance of the TRO was deemed prudent and reasonable by the majority of the
justices.
G.R. No. 132601. January 19, 1999 (Case Brief / Digest)
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### Doctrine
The Supreme Court has the inherent power and jurisdiction to control the execution of its
decisions to adjust the rights of the litigants and prevent unfairness, even when such
decisions have attained finality.
### Class Notes
– Jurisdiction over Execution of Judgments: The judiciary retains control over the execution
of its decisions, even those that are final and executory, to ensure they conform to law and
justice.
– Temporary Restraining Order (TRO): The Supreme Court can issue a TRO to temporarily
halt the execution of a decision if there are compelling reasons or supervening events that
justify such a measure.
– Power of Judicial Review: The Supreme Court has the constitutional authority to review,
modify, or restrain the execution of its decisions without encroaching upon the powers
vested in the executive branch, such as granting reprieves or commutations.
### Historical Background
The Echegaray case marked a critical moment in the Philippine judicial system,
demonstrating the balance between the finality of court decisions and the inherent power of
the Court to revisit those decisions in light of new, compelling circumstances. It highlights
the judiciary’s role in safeguarding constitutional rights and its capacity to adapt its rulings
in response to evolving legal and societal contexts, especially in matters involving the right
to life.

### Title: Lorenzo M. Tañada and Diosdado Macapagal vs. Mariano Jesus Cuenco,
Francisco A. Delgado, Alfredo Cruz, Catalina Cayetano, Manuel Serapio, Placido Reyes,
and Fernando Hipólito
—
### Facts:
Petitioner Lorenzo M. Tañada, a senator and president of the Citizens Party, and petitioner
Diosdado Macapagal, a member of the House of Representatives and official candidate of the
Liberal Party, challenged the election of certain senators to the Senate Electoral Tribunal. The
elections were held in November 1955, resulting in the proclamation of several senators, whose
election Macapagal, along with others, contested before the Senate Electoral Tribunal. The
Senate, by nomination of its members primarily from the Nacionalista Party, chosen Senators
Jose P. Laurel, Fernando Lopez, and Cipriano Primicias, and petitioners Lorenzo M. Tañada to
be part of the Tribunal. On behalf of the Senate Committee on Rules, Senator Primicias
nominated Senators Mariano J. Cuenco and Francisco A. Delgado as Tribunal members, which
was objected to by Senators Tañada and Sumulong. These nominations extended to the
appointment of technical assistants and secretaries for Cuenco and Delgado, contested by Tañada
and Macapagal through petitions and motions to oust the appointments and prevent Cuenco and
Delgado from exercising powers in the Tribunal.
### Procedural Posture:
The case was escalated to the Supreme Court of the Philippines after Senator Tañada and
Congressman Macapagal filed petitions against Senators Cuenco and Delgado, among other
respondents, challenging their nomination and election to the Tribunal as unconstitutional and
seeking preliminary injunction to restrain their appointments. The respondents acknowledged the
factual allegations but contested the legal validity of the petition.
### Issues:
1. Whether the nominations of Senators Cuenco and Delgado as members of the Senate Electoral
Tribunal were valid under the Constitution.
2. Whether the petitions presented a political question beyond the court’s jurisdiction.
3. Whether Tañada’s refusal to nominate two additional members constituted a waiver of the
minority party’s right to nominate three members to the Tribunal.
### Court’s Decision:
**Issue 1: Nominations of Senators Cuenco and Delgado**
– The court held that the nominations of Senators Cuenco and Delgado were invalid. The
Constitution mandates that the minority party should nominate three members to the Tribunal.
Because the Citizens Party, represented solely by Tañada, held the second-largest number of
votes, it exclusively held the right to nominate the remaining members. The nomination and
election of Cuenco and Delgado by the majority party violated this provision.
**Issue 2: Political Question Doctrine**
– The court determined that the issue at hand was justiciable and not a political question as it
required interpreting the Constitutional provisions about the composition and selection process
of the Tribunal members. The court concluded that ensuring the Tribunal’s compliance with the
Constitution was within judicial purview, distinguishing this case from instances purely about
internal legislative procedures.
**Issue 3: Waiver by Tañada’s Refusal to Nominate**
– The court found that Tañada’s refusal to nominate additional members did not waive the
minority party’s right as per the Constitution. Tañada’s refusal was due to the necessity to uphold
the balance intended by the Constitutional design of the Tribunal and protect the purposes for
having an equitable representation.
### Doctrine:
The court confirmed that under Article VI, Section 11 of the Constitution, the party with the
second-largest representation in the Senate has the exclusive right to nominate three members to
the Senate Electoral Tribunal. If such nomination process is violated, nominations from other
parties cannot replace those constitutionally reserved for the minority party.
### Class Notes:
– **Electoral Tribunals**:
– Comprised of nine members: 3 Supreme Court Justices, 3 Senate members nominated by the
majority party, and 3 members by the minority party.
– The Constitution mandates strict adherence to these nomination processes.
– **Political Question Doctrine**:
– Courts have the authority to judge the constitutionality of legislative actions relating to
structure and membership of statutorily outlined bodies.
– **Waiver and Estoppel**:
– No waiver exists when constitutional rights protecting public policy are dismissed by the
subjective refusal due to strategic safeguarding.
### Historical Background:
The case arose during a politically turbulent period post-World War II, as the Philippines
transitioned from colonial governance to developing its own legislative framework with
integrity. The case addressed deeply ingrained partisan challenges in electoral processes aiming
to achieve impartiality and fairness through constitutionally mandated checks and balances.
### Title:
Manila Electric Company vs. Pasay Transportation Company, Inc.,
et al. (1933)
### Facts:
The Manila Electric Company (MERALCO) petitioned the Philippine Supreme Court, under the
mandate of Section 11 of Act No. 1446, to act as a board of arbitrators. This action was to
determine the terms and compensation for various transportation companies’ use of the Pasig
bridge, owned by MERALCO. Act No. 1446, granting MERALCO its franchise, specified that
when any other corporation is granted a franchise or right of way over MERALCO’s lines, the
Supreme Court, sitting as arbitrators, would determine the usage terms and compensation. Upon
filing the petition, the Supreme Court ordered MERALCO to inform the Attorney-General and
the affected transportation companies. Opposition to the petition came from several public utility
operators, leading to an oral hearing and the submission of memoranda, setting the stage for the
Supreme Court’s resolution.
### Issues:
1. The validity of Section 11 of Act No. 1446, particularly whether it improperly delegates
judicial power to the Supreme Court members, not as a judicial entity but as arbitrators, and if it
attempts to make their arbitration decision final and binding.
2. Whether the Supreme Court, or its members sitting as a board of arbitrators, can lawfully
perform non-judicial functions, potentially conflicting with their judicial responsibilities.
3. The potential violation of democratic government principles through the enactment of Section
11 of Act No. 1446.
### Court’s Decision:
The Supreme Court held that Section 11 of Act No. 1446 was improper and illegal as it
conflicted with democratic principles and the separation of powers by assigning non-judicial
functions to the Supreme Court members. The Court emphasized the strict judicial nature of its
powers and duties, ruling that it cannot be compelled to undertake or exercise non-judicial
functions not expressly or implicitly assigned by the constitution or law. The Court declined to
proceed further as arbitrators, marking a significant stance on the separation of judicial duties
from administrative or quasi-judicial roles.
### Doctrine:
The doctrine established from this case reiterates the principle of separation of powers,
emphasizing that the Supreme Court and its members are confined to exercising judicial powers
exclusively. It highlighted that statutory provisions must not infringe upon the constitutional role
and functions of the judiciary, reinforcing the judiciary’s independence from legislative or
executive encroachments.
### Class Notes:
– **Separation of Powers and Judicial Independence**: The case underscores the importance of
maintaining distinct boundaries among the legislative, executive, and judicial branches,
particularly emphasizing the judiciary’s role in interpreting law and administering justice, not
engaging in administrative or quasi-judicial functions outside its constitutional mandate.
– **Judicial Functionality**: The Supreme Court, as a judicial entity, cannot assume roles or
duties that are non-judicial in nature. This principle ensures the court’s impartiality and
adherence to its core function of adjudication according to law.
– **Statutory Interpretation Principles**: Any legislative enactment that potentially conflates the
roles of government branches or assigns inappropriate functions to the judiciary could be deemed
invalid. The integrity and independence of judicial proceedings must be preserved against
encroachments that could undermine the courts’ objectivity or operational integrity.
– **Contract and Arbitration in Public Utilities**: While arbitration is generally favored for
resolving disputes amicably, any arrangement that prevents judicial review or access to courts is
considered contrary to public policy, ensuring that aggrieved parties retain the right to seek
judicial intervention.
### Historical Background:
The context of this case reflects a period in Philippine legal history where the boundaries
between governmental branches were being tested and defined. It also illustrates the
complexities involved in managing public utilities and infrastructure within a legal framework
that respects both the rights of corporations and the regulatory responsibilities of the state,
emphasizing balanced governance and the preservation of judicial integrity amidst evolving
societal and economic needs.

G.R. No. L-30001 | June 23, 1970

THE DIRECTOR OF PRISONS and THE EXECUTIVE SECRETARY, Petitioners,
vs.
ANG CHO KIO @ ANG MING HUY and THE COURT OF APPEALS, Respondents.

Ponente: Zaldivar, J.
Concurring Justices: Concepcion, C.J., Reyes, J.B.L., Dizon, J.
Justices Not Taking Part: Teehankee, Barredo, Villamor

Facts:

Ang Cho Kio (also known as Ang Ming Huy) had been convicted of various crimes in the
Philippines and sentenced to serve a total of 45 years, 10 months, and 21 days of imprisonment,
plus a lifetime sentence for other offenses. After serving part of his sentence, he was granted a
conditional pardon on July 4, 1959, by the President. The pardon stated that he must voluntarily
leave the Philippines and never return. If he violated this condition, he would serve the
remaining term of his sentence and be deported.

Ang Cho Kio accepted the pardon, left the Philippines for Taipei, and lived abroad. However, in
June 1966, he re-entered the Philippines under an assumed name, "Ang Ming Huy," and was
caught by immigration authorities. He applied for a visa extension, violating the conditions of his
pardon.

As a result, the Executive Secretary ordered his recommitment to prison to serve the remaining
portion of his sentence, and after serving it, he was to be deported. Ang Cho Kio filed a petition
for a writ of habeas corpus, challenging his recommitment, which was dismissed by the Court of
First Instance.

On appeal, the Court of Appeals affirmed the dismissal but included a recommendation for the
Executive Secretary to allow Ang Cho Kio to leave the country on the first available flight. The
Solicitor General filed a motion for reconsideration, arguing that the Court of Appeals had no
authority to make such a recommendation.

Issue:
Whether the Court of Appeals had the authority to recommend that Ang Cho Kio be allowed to
leave the country voluntarily, and whether the court's recommendation interfered with the
executive power of the President.

Ruling:

The Supreme Court ruled that the Court of Appeals erred in including the recommendation to
allow Ang Cho Kio to leave the country. The Court emphasized that the judiciary's role is to
interpret and apply the law, not to make recommendations on matters that fall within the
exclusive discretion of the executive branch, such as the deportation or voluntary departure of
undesirable aliens. This power lies solely with the President.

The Court also highlighted the principle of separation of powers: the executive branch, not the
judiciary, has the authority to determine whether an individual who violates the conditions of a
pardon should be deported. Judicial interference with the exercise of this executive power, as
suggested by the recommendation, was inappropriate.

Therefore, the Supreme Court denied the petition for certiorari (filed by the Solicitor General)
and upheld the decision of the Court of Appeals, although it disagreed with the recommendation
portion.

Doctrine:

 Separation of Powers: The judiciary cannot interfere with the executive's discretionary
powers, particularly in political matters such as the deportation of aliens or decisions
regarding the enforcement of conditional pardons.
 Judicial Limits: Courts should refrain from expressing opinions or making
recommendations outside the scope of the case at hand, particularly on matters that are
not related to the legal issues being adjudicated.

Principle:

The case reinforces the judicial restraint in political matters and emphasizes the limited role of
the courts in issues related to the executive's powers, particularly those that fall under the
President's discretion, such as pardons, deportations, and the enforcement of such decisions. The
judiciary’s function is to apply the law, not to influence or intervene in the political actions of the
executive branch.

Case Digest: Angara vs. Electoral Commission

G.R. No. L-45081 | July 15, 1936

Facts:

Petitioner Angara was elected as a member of the National Assembly in 1935. Later, a fellow
candidate contested his eligibility, and the case was brought before the Electoral Commission,
created under the 1935 Philippine Constitution. Angara filed a petition with the Supreme Court
challenging the Electoral Commission's authority to act on the case, asserting that the legislature
should resolve issues of electoral disputes among its members, as it had traditionally done before
the creation of the Commission.

Issue:

Whether the Supreme Court has jurisdiction to review actions of the Electoral Commission and
whether the judiciary can intervene in the Commission's decisions on electoral matters involving
members of the National Assembly.

Ruling:

The Supreme Court ruled in favor of the Electoral Commission, holding that the Commission has
exclusive jurisdiction over election disputes involving members of the National Assembly. This
power was granted by the 1935 Constitution, removing the Assembly's previous authority to
decide on electoral contests.

Doctrine/Principle:

The Court introduced the doctrine of Separation of Powers and Judicial Review. It ruled that
each branch of government has its exclusive powers and responsibilities, which must not
interfere with the roles of other branches. The judiciary's role is to interpret laws, including
assessing the constitutionality of governmental actions. The Court affirmed that while it respects
the powers of the Electoral Commission, it retains jurisdiction to determine whether a
government entity is acting within its constitutional limits.

Significance:

This landmark decision established the principle of judicial review in the Philippines, asserting
the Supreme Court’s role in ensuring that all branches of government, including independent
commissions, act within their constitutional limits. The case cemented the judiciary's power to
interpret and protect constitutional boundaries, a fundamental aspect of the checks and balances
system.

G.R. No. 128448. February 01, 2001 (Case Brief / Digest)

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### Title: Spouses Alejandro Mirasol and Lilia E. Mirasol vs. The Court of Appeals,

Philippine National Bank, and Philippine Exchange Co., Inc.

### Facts:

The Mirasols, sugarland owners, produced substantial sugar quantities for export supported

by loans from PNB under specific credit agreements. Post-issuance of P.D. No. 579 by

President Marcos, empowering PHILEX, under PNB’s finance, to acquire export sugar and
remit profits to the government, the Mirasols, alleging sufficient sales proceeds to cover

their debts, sought accounting from PNB, which was declined. Continued demand from PNB

led to dacion en pago by the Mirasols, not fully settling their obligations. With rising debt

and demands unmet, PNB foreclosed the Mirasols’ properties, leading them to file a suit

against PNB and subsequently PHILEX, raising issues on the decrees’ legality and their

financial dealings’ accounting.

### Issues:

1. The trial court’s jurisdiction to declare a statute unconstitutional without notice to the

Solicitor General.

2. The constitutionality of P.D. No. 579 and related issuances.

3. The application of the doctrine of piercing the corporate veil between PNB and PHILEX.

4. The validity of the property foreclosure and dacion en pago agreement.

5. The trial court and appellate court’s handling of damages awards to the petitioners.

### Court’s Decision:

1. Regional Trial Courts are indeed vested with the authority to consider the

constitutionality of laws. However, a mandatory duty is imposed by Rule 64, Section 3 of the

Rules of Court requiring notice to the Solicitor General, which was not fulfilled in this case,

rendering the trial court’s ruling on constitutionality improper.

2. The court avoided ruling on the constitutionality of P.D. No. 579, emphasizing the

absence of necessary conditions for judicial review and highlighting that the controversy

can be settled on other legal grounds.

3. PNB and PHILEX were found to be separate entities, and no evidence supported the

piercing of the corporate veil.

4. The foreclosure and dacion en pago were deemed valid, finding no legal basis for

compensation since neither party owed the other under P.D. No. 579’s stipulated

arrangements.

5. The Court of Appeals’ decision to not award damages was upheld due to the petitioners’

failure to prove bad faith or malice on PNB’s part in failing to render an accounting.

G.R. No. 128448. February 01, 2001 (Case Brief / Digest)

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### Doctrine:

– Jurisdiction on constitutionality: Regional Trial Courts have jurisdiction to decide on the

constitutionality of statutes or executive orders but are obliged to notify the Solicitor

General as a mandatory party.

– Requisites for judicial review include actual case, ripeness, standing, the issue raised at

the earliest opportunity, and the constitutionality question being the lis mota of the case.

– Legal compensation requirements as per Articles 1278 and 1279 of the Civil Code must be

met fully, which was not the case here.

### Class Notes:

– The ruling underscores the procedural requirement of notifying the Solicitor General in

cases involving constitutional questions.

– It highlights the criteria for conducting a legal review, emphasizing the avoidance of

constitutional questions if other legal grounds for a decision exist.

– It illustrates the refusal to apply legal compensation and the doctrine of piercing the

corporate veil without the presence of its stringent requirements.

– It confirms that damages, including moral damages and attorney’s fees, require proof of

bad faith or malice, which were lacking in this case.

### Historical Background:

The backdrop of this case includes the issuance of Presidential Decrees under Martial Law,

influencing commercial and legal transactions in the Philippines, particularly in the sugar

industry. The case illustrates the intersection of law, commerce, and politics, showcasing

how legal frameworks operate within broader governmental policies and economic

strategies.

### Title:
**Teodoro C. Santiago, Jr., represented by Mrs. Angelita C. Santiago vs. Miss Juanita Bautista, et al.**

### Facts:
In mid-1965, Teodoro C. Santiago, Jr., a Grade VI pupil at Sero Elementary School in Cotabato City, was
assigned third place honors by a “Committee On The Rating Of Students For Honor” at the school. This
committee, chaired by the school principal and comprising Grade VI teachers, selected Socorro Medina
as first honor and Patricia Liñgat as second honor.

Three days before the scheduled graduation on May 21, 1965, Santiago’s mother filed Civil Case No.
2012 in the Court of First Instance of Cotabato challenging the rankings. The complaints included:
1. Santiago, Jr. was a consistent honor student, while Liñgat had not been a close rival until Grade V.
2. Socorro Medina’s tutoring by her English teacher Mrs. Alpas during summer 1964 led to an unfair
advantage.
3. The committee’s composition violated the Service Manual for Teachers, which required inclusion of
Grade V and VI teachers.
4. Allegations of grade tampering in favor of Medina and Liñgat.
5. Disallowed district exams played a major role in the final ratings.
6. Mysterious changes to Santiago’s Grade I certificate suggesting bias.
7. Petitioner’s personal appeals to school authorities were ignored.

Petitioners sought invalidation of the honor ranking and an injunction to prevent the announcement at
graduation. The court denied the injunction the day before graduation, reasoning that the disruption
would be inappropriate. Graduation proceeded as planned. Then, three days later, respondents moved
to dismiss the case, claiming it had become academic and improper for certiorari relief.

### Procedural Posture:

The trial court dismissed the case, citing several grounds:
1. Improper filing because the alleged facts did not warrant certiorari.
2. Failure to exhaust administrative remedies.
3. Lack of substantial showing of grave abuse of discretion by the defendants.

Upon denial of their motion for reconsideration, the petitioners appealed.

### Issues:
1. Whether the “Committee on the Rating of Students for Honor” exercised judicial or quasi-judicial
functions amenable to certiorari proceedings under Rule 65.
2. Whether the procedural flaws, particularly the failure to attach pertinent documents, including an
official judgment or order, to the petition warranted dismissal.
3. Whether judicial intervention was appropriate without exhausting administrative remedies.

### Court’s Decision:

**Issue 1: Judicial or Quasi-Judicial Functions**
The Supreme Court upheld that the committee did not exercise judicial or quasi-judicial functions. Rule
65 applies to tribunals, boards, or officers with such functions, but the committee’s task was
administrative and evaluative, not legal adjudication.

**Issue 2: Procedural Flaws**

The Court affirmed the lower court’s ruling that the failure to attach relevant documents (official
judgment/order, grading sheets, Service Manual pages) to the petition was indeed a fatal flaw. This
procedural non-compliance rendered the petition defective and indefinite.

**Issue 3: Administrative Remedies**

The Court noted that Santiago neglected formal administrative remedies. It emphasized the necessity of
exhausting these remedies before seeking judicial intervention. While personal appeals were made, the
specific and structured reliefs provided by administrative protocols within the Department of Education
were not utilized.

### Doctrine:
1. **Judicial/Quasi-Judicial Functions**: Certiorari under Rule 65 requires that the contested authority
exercises judicial or quasi-judicial functions, which involve determining rights and obligations legally.
2. **Procedural Compliance in Certiorari**: Compliance with procedural requirements under Rule 65,
including attaching relevant documents, is mandatory. Failure to do so can result in case dismissal.
3. **Exhausting Administrative Remedies**: Where administrative remedies are available and
adequate, judicial intervention is premature and typically unwarranted until those remedies have been
fully exploited.

### Class Notes:

– **Judicial/Quasi-Judicial Functions** (Rule 65): Necessitates the exercise of legal adjudicative power.
– **Procedural Compliance** (Rule 65, Sec 1): Mandatory requirement to attach the judgment/order
and relevant documents.
– **Exhaustion of Administrative Remedies**: Essential before seeking judicial intervention.

Relevant Statutes/Provisions:
– **Rule 65, Section 1** of the Rules of Court
– Requirement for certified true copies of judgments and other relevant documents.

### Historical Background:

During the mid-1960s in the Philippines, educational evaluations and their fairness were heavily
scrutinized, often reflecting broader societal concerns about equity and transparency in public
institutions. This case epitomized these tensions, highlighting the emerging struggle for procedural
correctness in administrative actions within public schools.

This case underscores strict adherence to procedural rules in legal filings and the proper delineation of
administrative versus judicial functions in educational settings.

Case Digest: Ramon A. Gonzales v. Hon. Andres R. Narvasa, et al. (G.R. No. 140835,
August 14, 2000)

Facts:

In this case, Ramon A. Gonzales, a lawyer and taxpayer, questioned the constitutionality of the
Preparatory Commission on Constitutional Reform (PCCR), a body created by then-
President Joseph Estrada to study possible amendments to the 1987 Constitution. Gonzales
argued that only Congress could create such a body. He also challenged the appointments of
numerous presidential consultants, advisers, and assistants, claiming that these positions were
created without clear legal basis. Lastly, he sought information on officials holding multiple
positions and a list of luxury vehicles seized by the Bureau of Customs and turned over to
Malacañang.
Respondents, including former Chief Justice Andres Narvasa (as PCCR Chairman) and
Executive Secretary Ronaldo B. Zamora, contended that the PCCR had already been dissolved,
making Gonzales' claims moot. They also argued that Gonzales had no legal standing, as he
hadn’t shown any direct injury caused by the PCCR’s creation or the appointments of
presidential advisers.

Issues:

1. Mootness: Is the issue regarding the constitutionality of the PCCR moot, given that it has
already completed its work and dissolved?
2. Standing: Does Gonzales have the legal standing to challenge the creation of the PCCR
and the positions of presidential consultants, advisers, and assistants?
3. Right to Information: Is Gonzales entitled to the requested information regarding
government appointments and seized luxury vehicles?

Ruling:

The Supreme Court ruled as follows:

1. Mootness: The Court held that the issue regarding the PCCR’s constitutionality was
moot and academic. The PCCR had completed its mandate, submitted its
recommendations, and was dissolved by the end of 1999. Since prohibition is a
preventive remedy, it cannot apply to something that no longer exists (fait accompli).
2. Standing: The Court found that Gonzales lacked standing as he had not shown a direct,
personal injury from the creation of the PCCR or the appointments. Generally, taxpayers
only have standing in cases where Congress exercises its taxing or spending powers,
which was not involved here. The funds for the PCCR came from the President’s office,
not from a congressional appropriation.
3. Right to Information: The Court affirmed Gonzales’ right to access certain public
information under the Constitution. It ordered Executive Secretary Zamora to provide
Gonzales with the information regarding officials holding multiple positions and the
distribution of seized luxury vehicles, recognizing that citizens have a constitutional right
to information on matters of public concern.

Relation to Judicial Power:

This case highlights the limits of judicial power. The Court emphasized its role as a neutral
arbiter rather than an advisor or commentator. It underscored that courts do not decide on issues
that are no longer active, especially when the disputed actions are already completed or moot, as
was the case with the dissolved PCCR. The Court also showed restraint by rejecting Gonzales'
taxpayer standing, adhering to the principle that judicial power should only be invoked when
there is a real, personal stake or injury.

Furthermore, the decision illustrates judicial enforcement of constitutional rights. While

declining Gonzales’ demands for prohibition and other relief, the Court still honored his right to
information, underscoring the judiciary’s commitment to protecting constitutional freedoms.
Here, the judiciary fulfilled its function by ordering access to information while staying within
the bounds of actual cases and controversies—reflecting a balanced exercise of judicial power.
Case Digest: David v. Macapagal-Arroyo, G.R. No. 171396, May 3, 2006

Facts:

In February 2006, then-President Gloria Macapagal-Arroyo issued Presidential Proclamation

No. 1017, declaring a state of national emergency in response to alleged destabilization plots and
attempted coup d'état. This proclamation granted the President authority to call upon the armed
forces to suppress "lawless violence, invasion, or rebellion." It also ordered the police to take
necessary measures to maintain law and order.

In conjunction with this proclamation, General Order No. 5 was issued, directing the military to
prevent and suppress all lawless violence. Following these orders, several actions were taken by
the government, including warrantless arrests, dispersals of protests, and a raid on a media office.

Several groups, including journalists, activists, and legislators, filed petitions challenging the
constitutionality of Proclamation No. 1017 and General Order No. 5, arguing that these measures
violated the Constitution and posed a serious threat to civil liberties.

Issues:

1. Constitutionality of Proclamation No. 1017 and General Order No. 5: Did the
President exceed her powers in declaring a state of national emergency and ordering the
military to suppress lawless violence?
2. Violation of Civil Liberties: Did the actions taken under Proclamation No. 1017, such as
warrantless arrests, dispersal of protests, and interference with media, constitute
violations of constitutional rights?

Ruling:

The Supreme Court ruled as follows:

1. Validity of Proclamation No. 1017: The Court held that Proclamation No. 1017 was
constitutional insofar as it merely declared a state of national emergency. The President
has the authority under Section 18, Article VII of the Constitution to declare such a state
and call on the armed forces to prevent or suppress lawless violence, invasion, or
rebellion. However, the Court emphasized that a declaration of a state of national
emergency does not grant the President any additional powers, such as the power to issue
decrees or take over private institutions.
2. Limitations of Military and Police Powers: General Order No. 5 was deemed valid
only as it authorized the military to aid in law enforcement. However, the Court found
that the proclamation and order did not authorize the military to carry out warrantless
arrests, disperse peaceful assemblies, or conduct raids on media outlets. These actions
were held unconstitutional as they infringed upon civil liberties guaranteed by the
Constitution.
3. Violation of Civil Liberties: The Supreme Court found that certain actions taken under
Proclamation No. 1017, such as warrantless arrests, dispersal of lawful assemblies, and
media interference, violated constitutional rights, particularly the right to freedom of
speech, peaceful assembly, and freedom of the press. The Court declared these specific
 actions unconstitutional, as they were not justifiable under a mere state of national
emergency.

Relation to Judicial Power:

This case is significant in showcasing the judicial check on executive power, particularly in
situations where civil liberties are at risk. The judiciary asserted its authority to review the scope
and limits of the President’s powers, ensuring that constitutional rights remain protected, even in
times of national emergency. The Court’s decision underscored that while the President has
broad powers to address emergencies, these powers are not unlimited and must conform to
constitutional standards.

The case demonstrates the judiciary’s role as a guardian of the Constitution, affirming that
emergency declarations cannot override fundamental rights and freedoms. It established a
precedent that emergency powers must be exercised within strict constitutional boundaries,
emphasizing the judiciary's responsibility to intervene when executive actions threaten
democratic rights and freedoms.

Case Digest: Telecommunications and Broadcast Attorneys of the Philippines, Inc. and GMA
Network, Inc. v. Commission on Elections, G.R. No. 132922, April 21, 1998

Facts:

The case involves a petition filed by the Telecommunications and Broadcast Attorneys of the
Philippines, Inc. (TBA) and GMA Network, Inc. against the Commission on Elections
(COMELEC). The petitioners sought to challenge a COMELEC resolution that prohibited
television and radio networks from airing political advertisements within a specified period
before elections.

The issue arose during the 1998 Presidential elections, when the COMELEC issued Resolution
No. 2300, which imposed a ban on political advertisements from February 13 to May 11, 1998
—the campaign period for national candidates. The COMELEC argued that it was enforcing
restrictions under Batas Pambansa Blg. 881 (the Omnibus Election Code), which limits
political ads to a prescribed period during the campaign.

However, the petitioners contended that the ban violated freedom of speech and freedom of the
press, as it restricted media outlets from airing political advertisements outside the official
campaign period. They argued that such a prohibition unreasonably curtailed the media’s role in
informing the public during the election period.

Issues:

1. Constitutionality of the ban on political advertisements: Did the COMELEC have the
authority to impose a total ban on political advertisements outside the official campaign
period, thereby restricting freedom of expression?
 2. Balance between free speech and electoral fairness: Did the imposition of the
advertisement ban violate the constitutional guarantee of freedom of speech, press, and
expression?

Ruling:

The Supreme Court ruled in favor of the petitioners, declaring that the total ban on political
advertisements outside the official campaign period was unconstitutional.

1. Authority of the COMELEC: While the Court recognized the COMELEC’s role in
regulating elections to ensure fairness, the Court held that this authority did not extend to
infringing upon the fundamental rights of free speech and expression. The Court ruled
that the restriction on political advertisements went beyond what was necessary to
maintain fairness and order during the elections.
2. Freedom of Speech and the Press: The Supreme Court emphasized that the freedom of
speech and the freedom of the press are essential to a functioning democracy. These
freedoms must be protected, even during an election period, unless there is a compelling
reason for the government to regulate them. The Court found that the total ban imposed
by the COMELEC was overbroad and unreasonable, violating the constitutional
protections of expression, especially since it restricted the right to political speech.
3. Election Law and the Media's Role: The Court did not entirely negate the COMELEC’s
authority to regulate political advertising but stated that the regulation must be narrowly
tailored to serve a valid governmental interest (such as preventing undue influence or
ensuring fairness), and should not unduly infringe upon basic freedoms. Restrictions must
be reasonable, specific, and temporary, in line with the purpose of fair elections.

Relation to Judicial Power:

This case highlights the judiciary’s role in safeguarding fundamental constitutional rights
against overreach by government institutions, even during the election period. It is an example of
the judicial power of review, where the Supreme Court checks whether the actions of a
governmental body, in this case, the COMELEC, violate the Constitution.

In this case, the Court reinforced the principle that fundamental rights, particularly freedom
of speech and the press, must be carefully weighed against the government's interests. The
Court's intervention reaffirmed the judiciary’s power to protect individual liberties, ensuring
that the government cannot impose broad restrictions that infringe upon these freedoms without
clear justification.

The case also underscores the judiciary’s role in maintaining the balance between electoral
fairness and constitutional rights, a crucial function in ensuring that the democratic process is
not undermined by overregulation or unjustified restrictions on free expression.

Title: Dumlao vs. Commission on Elections

Facts:
The case originates from a petition filed by Patricio Dumlao, a former Governor of Nueva
Vizcaya, Romeo B. Igot, a taxpayer, qualified voter, and a member of the Bar, and Alfredo
Salapantan, Jr., a taxpayer and qualified voter, against the Commission on Elections
(COMELEC). The petitioners sought to enjoin COMELEC from implementing certain
provisions of Batas Pambansa Blg. 51, 52, and 53, claiming these provisions to be
unconstitutional.
Dumlao challenged the constitutionality of Section 4 of Batas Pambansa Blg. 52, which
disqualifies retired officials who are 65 years old at the commencement of the term they are
seeking, and have received retirement benefits, from running for the same elective local office
from which they retired. Igot and Salapantan challenged the validity of various statutory
provisions on different grounds, including allegations of discrimination and the constitutionality
of accrediting certain political parties.
Upon filing their petition, the procedural posture moved towards a request for immediate
resolution given the impending elections set for January 30, 1980. However, the PET recognized
procedural infirmities in the petition, such as misjoinder of parties and actions, and the lack of a
substantive actual case and controversy for Dumlao, as well as a clear personal and substantial
interest from Igot and Salapantan.
Issues:
The Supreme Court addressed several pivotal issues, including:
1. Whether the petitioners were proper parties with a significant interest and whether there was a
genuine controversy warranting judicial intervention.
2. The constitutionality of Section 4 of Batas Pambansa Blg. 52 regarding the disqualification of
certain retired officials based on age and receipt of retirement benefits.
3. The apparent discrimination and denial of equal protection under the law as raised by the
petitioners against various provisions of Batas Pambansa Blg. 51, 52, and 53.
Court’s Decision:
On procedural grounds, the Court highlighted misjoinder of actions and lack of actual case or
controversy for Dumlao, and no personal and substantial interest for Igot and Salapantan,
traditionally grounds for dismissing the petition. However, it proceeded to rule on the substance
due to the paramount public interest involved and the proximate elections.
1. The Court declared the first paragraph of Section 4 of Batas Pambansa Blg. 52 constitutionally
valid, citing the legitimacy of classifying retirees aged 65 differently based on the rationale for
promoting younger leadership in local governance and the retirees’ previously expressed
disinterest in government work by retiring.
2. The Court found part of the second paragraph of Section 4 of Batas Pambansa Blg. 52, which
disqualified candidates based on mere filing of charges for certain crimes, as null and void. It
violated the constitutional presumption of innocence and fundamentally equated mere accusation
with guilt, significantly endangering candidates’ rights and electoral freedom.
Doctrine:
– The doctrine established in this case reiterates the principle that the equal protection clause
permits rational classification if it is based on substantial distinctions, relevant to the legislative
objective, and applies to all members within the class.
– A legislative or administrative determination of guilt should not substitute for a judicial
determination, especially in the context of disqualifying candidates for public office based on
unproven charges.
Class Notes:
– The principle of judicial review obliges the presence of an actual case or controversy, a direct
and personal interest by the party raising a constitutional question, and the indispensability of
resolving the constitutional question to the case at hand.
– The equal protection clause requires that classifications in law be based on substantial
differences that justify disparate treatment of groups.
– The presumption of innocence until proven guilty is a constitutional safeguard that cannot be
overridden by presumptive evidence established by legislative action for disqualifying candidates
from public office.
Historical Background:
This case reflects the tensions and challenges in the pre-1986 Philippine political landscape,
where electoral processes, qualifications for public office, and the balancing of retirees’ rights
against the public interest in governance reform were contentious issues. It underscores the
judiciary’s role in interpreting statutory provisions against constitutional principles and resolving
disputes aimed at ensuring fairness, equality, and justice in electoral contests.

G.R. No. 113375. May 05, 1994 (Case Brief / Digest)

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Title: Kilosbayan, Inc. vs. Guingona, Jr.
Facts: The controversy stems from a special civil action filed by Kilosbayan, Incorporated
and several co-petitioners, including prominent public figures and members of Congress,
against the implementation of a “Contract of Lease” between the Philippine Charity
Sweepstakes Office (PCSO) and the Philippine Gaming Management Corporation (PGMC).
The contract was for the operation of an online lottery system, also known as “lotto.”
The PCSO, as authorized by its charter (R.A. No. 1169, as amended by B.P. Blg. 42), decided
to establish an online lottery system to increase its revenue base. The Berjaya Group
Berhad, through PGMC, expressed interest in offering its services and resources to PCSO
for the online lottery project. Following a formal Request for Proposal (RFP) issued by
PCSO, PGMC submitted its bid and was eventually given the go-signal by the Office of the
President.
Despite strong opposition on moral and legal grounds from various sectors, including
Kilosbayan, Incorporated, the Contract of Lease was executed on December 17, 1993, and
later approved by the President. Kilosbayan and its co-petitioners then filed a petition with
the Supreme Court, questioning the legality and constitutionality of the contract, arguing
that it violated PCSO’s charter, as well as other laws and constitutional provisions.
Issues:
1. Whether the petitioners have the legal standing (locus standi) to file the case.
2. Whether the Contract of Lease between PCSO and PGMC violates PCSO’s charter by
constituting a form of collaboration or association in conducting lottery operations, which is
prohibited.
3. Whether the PCSO’s establishment of a telecommunications system through PGMC
without a congressional franchise violates Act No. 3846.
4. Whether PGMC, being a corporation with significant foreign equity, is prohibited from
operating a public utility like the telecommunications system required for the lotto
operations under Section 11, Article XII of the Constitution.
5. Whether the Contract of Lease is invalid for operating within the negative list of the
Foreign Investments Act since it involves forms of gambling.
Court’s Decision: The Supreme Court ruled that Kilosbayan, Inc. and its co-petitioners have
the legal standing to file the case owing to the immense public interest it entails. The Court
also found that the Contract of Lease between PCSO and PGMC is invalid as it violates the
G.R. No. 113375. May 05, 1994 (Case Brief / Digest)
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PCSO’s charter. Specifically, it constitutes a form of collaboration or association in
conducting lottery operations, which is explicitly prohibited. The Court did not find it
necessary to address the remaining issues given its finding on the violation of PCSO’s
charter.
Doctrine:
1. The legal standing or locus standi of a party can be given a more liberal interpretation in
cases of paramount public interest or in cases that transcend the personal interests of the
litigants.
2. A contract that violates the explicit terms of a government agency’s charter, especially
provisions that restrict forms of partnership or collaboration in conducting its operations, is
invalid.
Class Notes:
– Legal Standing: Locus standi requirements may be relaxed in cases involving significant
public interest.
-Public Utility and Franchise Requirement: Entities operating a public utility in the
Philippines must have the necessary congressional franchise, as dictated by law and the
Constitution.
– Charter Restrictions: Government agencies and corporations must operate strictly within
the bounds set by their charters. Contracts that violate such charters are legally infirm.
– Negative List of the Foreign Investments Act: Certain business operations, including those
related to gambling, are subject to ownership requirements and limitations for foreign
investors.
Historical Background:
The case reflects a period in Philippine history when the expansion of government-run
gambling operations sparked significant legal and moral debates. It underscores the tension
between the government’s efforts to increase revenue through gambling operations and the
legal and societal implications of such strategies. The controversy highlights the important
role of the judiciary in interpreting the law and constitutional provisions in the context of
changing societal values and government policies.

Case Digest: G.R. No. 97787, August 1, 1996

Title:
The Anti-Graft League of the Philippines, Inc., vs CA

Facts: The Anti-Graft League of the Philippines, Inc., a civic organization, filed a petition for
certiorari seeking the nullification of a compromise agreement approved by the Regional Trial
Court (RTC) of Pasig, which involved the reconveyance of four parcels of land from the
Province of Rizal to Ortigas & Co., Ltd. The issue stemmed from a sale of land by the Province
to Ortigas in 1975 for the construction of educational institutions, which was later resold to
Valley View Realty Development Corporation (Valley View) in 1987. The sale to Valley View
was contested by Ortigas, leading to a compromise agreement in 1989, wherein the Province
agreed to reconvey the lands to Ortigas at a higher price than the previous sale to Valley View.

The petitioner, a non-governmental organization, alleged that the reconveyance at an excessively

high price violated public interest and involved the illegal disbursement of public funds. The
respondents, on the other hand, denied the allegations and contended that the petition lacked
merit, questioning the standing of the petitioner to file the case and the propriety of the action.
Issue:

1. Does the Anti-Graft League of the Philippines, Inc. have the legal standing to file
this action as a taxpayer’s suit?
2. Is the Supreme Court the proper forum for this petition?
3. Is the petition barred by laches (failure to take action within a reasonable period)?

Ruling: The Supreme Court dismissed the petition, ruling in favor of the respondents. The Court
held that the petitioner lacked legal standing (locus standi) to file the suit because:

1. Lack of Standing: The Court explained that for a taxpayer's suit to be valid, the
petitioner must show that public funds are being illegally disbursed by a political
subdivision or instrumentality, and that the petitioner is directly affected by the alleged
ultra vires act. In this case, while the petitioner claimed the reconveyance of land
involved illegal public funds, the Court found no evidence of unlawful disbursement of
public money. The purchase of the land in 1975 was not contested as an illegal
disbursement of public funds, and the sale to Ortigas at a higher price did not involve any
public funds being misused. As such, the petitioner did not have the legal standing to
challenge the actions of the Provincial Board of Rizal.
2. Improper Forum: The Court pointed out that the petitioner had incorrectly filed the
petition with the Supreme Court. The proper remedy would have been to file a petition
for review of the trial court’s decision before the Court of Appeals, as the case primarily
involved a challenge to the compromise agreement approved by the trial court. The Court
noted that the petitioner was questioning the wisdom of the trial court’s action, which is a
factual issue, not one that involves a legal question within the jurisdiction of the Supreme
Court.
3. Laches: The petition was also barred by laches, as the decision of the RTC approving the
compromise agreement became final and executory on April 5, 1989, but the petitioner
did not file the petition until April 1, 1991—almost two years later. The Court found no
valid reason for the delay and ruled that the petitioner had waived its right to challenge
the decision by waiting too long.

Legal Principles and Doctrines:

1. Taxpayer’s Suit: For a taxpayer's suit to be valid, two conditions must be met: (1) public
funds are disbursed by a political subdivision or instrumentality, and (2) the petitioner is
directly affected by the alleged illegal act. The Court emphasized that standing in
taxpayer suits is only granted when the taxpayer can demonstrate a direct injury, which
was not the case here.
2. Locus Standi: Standing is a crucial element in filing a lawsuit. A party must have a
personal stake in the outcome of the case. The Court reiterated that standing is a
fundamental requirement for a party to pursue legal action, especially in matters
involving constitutional issues or significant public interest.
3. Laches: Laches refers to the unreasonable delay in asserting a right, which may result in
the waiver of that right. The Court applied the doctrine of laches, dismissing the petition
because it was filed after a long delay without sufficient justification.

Conclusion: The petition was dismissed on the grounds of lack of legal standing, improper
forum, and laches. The Court ruled that the petitioner, as a non-governmental organization, did
not have the legal capacity to challenge the transactions of the Provincial Board of Rizal, and
even if it had, the petition was filed too late. Consequently, the decision of the RTC, which
approved the compromise agreement, remained final and executory.

Title: **Ma. J. Angelina G. Matibag vs. Alfredo L. Benipayo et al. (G.R. No. 149036, April 2,
2002)**
Facts:
Ma. J. Angelina G. Matibag, the petitioner, was appointed in various capacities to the Education
and Information Department (EID) of the Commission on Elections (COMELEC), ending with
her appointment as “Acting Director IV” by different COMELEC Chairpersons from 1999 to
2001. On March 22, 2001, President Gloria Macapagal Arroyo made several ad interim
appointments to the COMELEC, including Alfredo L. Benipayo as Chairman, and Resurreccion
Z. Borra and Florentino A. Tuason, Jr. as Commissioners, each serving a term of seven years.
Benipayo took office and executed a memorandum reassigning Matibag to the Law Department
and designating Velma J. Cinco as Officer in Charge of the EID. Matibag objected, invoking
election period transfer prohibitions, but her challenge was denied by Benipayo. Matibag then
filed a petition in the Supreme Court, questioning the legal validity of the appointments and her
reassignment.
Issues:
1. Whether the petition meets the requirements for judicial review.
2. Whether the ad interim appointments are temporary, thus violating the Constitution.
3. Assuming the first ad interim appointments and assumptions of office are legal, whether the
renewal of these appointments violates the constitutional prohibition on reappointments.
4. Whether Benipayo’s removal of Matibag is illegal for lacking COMELEC en banc approval.
5. Whether the disbursements of salaries and emoluments to the appointed officials are lawful.
Court’s Decision:
1. The Court held that the petition satisfies the requisites for judicial review and has legal
standing.
2. It ruled that ad interim appointments are permanent and effective until disapproved by the
Commission on Appointments or the next adjournment of Congress, not violating the prohibition
of temporary appointments.
3. The renewals of the ad interim appointments do not violate the prohibition on reappointments,
as the Constitution does not preclude the issuance of another ad interim appointment due to the
nature of ad interim appointments.
4. Benipayo, as COMELEC Chairman and Chief Executive Officer, had the authority to reassign
Matibag; hence, the action was not illegal.
5. The disbursements to the appointed officials were deemed lawful, given the valid exercise of
the appointing and disbursing authority’s powers.
Doctrine:
The ruling reaffirmed that ad interim appointments are permanent in nature and can be renewed
in the absence of a disapproval by the Commission on Appointments. It emphasized the
independence of constitutional bodies like the COMELEC while simultaneously acknowledging
the President’s power to make appointments.
Class Notes:
– **Ad Interim Appointments**: Permanent unless disapproved by the Commission on
Appointments or by the next adjournment of Congress.
– **Reappointment Prohibitions**: Specifically applies to those instances where a prior
confirmed appointment exists; does not apply to renewed ad interim appointments when the
Commission on Appointments has not acted.
– **Transfer and Reassignment Authority**: Heads of government, including the COMELEC
Chairman, have authority to reassign personnel within legal bounds.
– **Judicial Review Requirements**: Existence of actual controversy, personal and substantial
interest, timely pleading of constitutional issues, and the constitutional issue being the lis mota of
the case.
Historical Background:
This case reflects on the constitutionality and implications of the President’s power to issue ad
interim appointments to the COMELEC, balancing the independence of constitutional
commissions with the necessity of filling vacancies to avoid disruptions in government services.
It illustrates the judicial interpretation of constitutional provisions on appointments and
reappointments, amidst concerns over the appointment process during election periods and the
internal management autonomy of constitutional bodies.

**Title: The People of the Philippine Islands and The Hongkong & Shanghai
Banking Corporation vs. Judge Jose O. Vera and Mariano Cu Unjieng**
**Facts:**
1. **Initial Filing and Trial**:
– On October 15, 1931, a criminal information was filed against Mariano Cu Unjieng in the
Court of First Instance of Manila. The Hongkong and Shanghai Banking Corporation intervened
as a private prosecutor.

– After a lengthy trial that produced a substantial volume of testimony and exhibits, the Court of
First Instance convicted Cu Unjieng on January 8, 1934, imposing a prison sentence and
reserving civil actions for the private prosecutor.
2. **Appeals and Final Judgment**:
– Cu Unjieng appealed, and on March 26, 1935, the Supreme Court modified his sentence while
affirming the conviction.
– After his multiple motions for reconsideration and new trials were denied, the final judgment
by the Supreme Court was rendered on December 18, 1935.
– Cu Unjieng attempted certiorari to the United States Supreme Court but was denied in
November 1936. Subsequently, the case was remanded for execution of the judgment.
3. **Application for Probation**:
– Cu Unjieng filed for probation under Act No. 4221 in November 1936, asserting his innocence
and promising good behavior.
– The Court referred the application to the Insular Probation Office, which recommended denial.
– Despite opposition from the City Fiscal and private prosecution, Judge Jose O. Vera announced
Cu Unjieng as “innocent by rational doubt” but denied the probation on grounds of public
perceptions and the controversial nature of probation in his context.
**Issues:**
1. **Jurisdiction of Probation**:
– Can Act No. 4221’s probation provisions be applied to the City of Manila?
– Whether the Judge exceeded jurisdiction by entertaining a motion for reconsideration post the
denial of probation.
2. **Constitutionality of Act No. 4221**:
– Does Act No. 4221 violate the Constitution by delegating undue legislative power to provincial
boards?
– Does the Act violate the equal protection clause by allowing non-uniform application across
provinces?
**Court’s Decision:**
1. **Jurisdiction and Application**:
– The Court affirmed that probation cannot apply uniformly due to the Act’s confinement to
provinces and contingent on provincial boards’ appropriations, excluding chartered cities like
Manila without specific provision.
– The Judge’s continuance of probation consideration post-denial and failure to commit Cu
Unjieng to prison were beyond jurisdictional limits.
2. **Constitutionality of Delegation**:
– The Supreme Court declared Section 11 of Act No. 4221 unconstitutional as it improperly
delegated legislative power to provincial boards without sufficient guiding principles, entrusting
them with quasi-absolute discretion contrary to the principle that legislative powers are non-
delegable.
3. **Equal Protection**:
– The Court ruled that the Act violated the equal protection clause since it subjected individuals
to differing treatments based on discretionary and variable provincial board decisions.
**Doctrine:**
– **Non-delegation Doctrine**: Legislative power cannot be delegated to another body without
clear statutory guidelines. In this case, the Court held that provincial boards should not arbitrate
the applicability of probation laws, reaffirming the separation of powers principle.
– **Equal Protection Clause**: Any law permitting or causing unequal treatment among
similarly situated individuals is unconstitutional. The application of probation depending on
provincial board decisions is inherently discriminatory.
**Class Notes:**
1. **Non-delegation Doctrine**: Power conferred upon legislative bodies cannot be passed to
others unless permissible by specific provisions. Essential in maintaining checks and balances.
– **Reference**: Cooley on Constitutional Limitations, Locke on Civil Government.
2. **Equal Protection**: Prohibits legislative acts that lead to differential treatment not justified
by a rational state interest. Requires uniformity of law application.
– **Reference**: Yick Wo vs. Hopkins, Gulf, C. & S.F. Ry Co. vs. Ellis.
**Historical Background:**
– The case arises during a period transitioning from colonial governance under the Jones Law to
self-governed commonwealth, emphasizing constitutional delimitation of powers.
– The Probation Act (No. 4221), enacted by the defunct Philippine Legislature, intended to
humanize criminal penalties by granting courts discretion in sentencing. However, the legal
landscape was still adapting to uniform statutory applications across newly structured political
and legal systems.

Case Digest: Francisco Zandueta vs. Sixto De La Costa

G.R. No. 46267, November 28, 1938

Facts:
Judge Francisco Zandueta served as the Judge of the Fifth Branch of the Court of First Instance
of Manila under an appointment confirmed by the National Assembly. Following the enactment
of Commonwealth Act No. 145 (the Judicial Reorganization Law), which reorganized judicial
districts, Zandueta received a new ad interim appointment from the President to serve as a judge
in the Fourth Judicial District, covering the Courts of First Instance of both Manila and Palawan.
Zandueta accepted this new appointment, took his oath, and began performing his duties.

Later, the Commission on Appointments disapproved Zandueta’s new appointment.

Consequently, the President appointed Sixto De La Costa to the position, which was confirmed
by the Commission on Appointments. Zandueta then filed a petition for quo warranto, arguing
that De La Costa’s occupancy of the office was illegal and claiming a right to repossess the
position, asserting that Commonwealth Act No. 145 was unconstitutional.

Issue:
Is Judge Zandueta entitled to challenge the validity of Commonwealth Act No. 145 and reclaim
his former position as Judge of the Fifth Branch of the Court of First Instance of Manila after
accepting and serving under a new appointment?

Ruling:
The Supreme Court held that Zandueta was estopped from questioning the validity of
Commonwealth Act No. 145. By accepting the new appointment, taking the oath of office, and
performing the duties of a judge under the reorganization law, Zandueta effectively abandoned
his former office and could not subsequently claim entitlement to it. The Court found that
accepting the new appointment created an implied abandonment of his old position. Since he had
voluntarily accepted the reappointment under the new judicial district, he forfeited the right to
contest the law’s constitutionality.

The Court underscored that when a public official voluntarily accepts an appointment to a
reorganized office, the acceptance bars them from challenging the law that created or
reorganized the position. The Court dismissed Zandueta’s petition, upholding De La Costa’s
occupancy of the office.

Relation to Judicial Power:

This case exemplifies the judicial principle that courts exercise judicial restraint in constitutional
challenges, particularly where the plaintiff has acted in a way that implicitly supports the law’s
validity. Judicial power includes the authority to decide on the constitutionality of laws, but the
Court avoids ruling on such issues if procedural bars—like estoppel—apply. Here, Zandueta’s
voluntary acceptance and discharge of duties under the reorganization law prevented the Court
from needing to rule on its constitutionality, reinforcing the limits on judicial power when a
party’s actions negate their standing to bring a constitutional claim.

Case Title: Intestate Estate of Carmen de Luna (deceased), represented by Catalina Morales
Gonzales, Administratrix, Petitioner, vs. Intermediate Appellate Court and Esperanza de Luna
Gonzales Azupardo & Isidoro de Luna Gonzales, Respondents

Facts: In 1964, Jose de Luna Gonzales and Judge Ramon Icasiano were appointed co-
administrators of the estate of Carmen de Luna. Following Judge Icasiano’s death in 1968,
Gonzales continued as sole administrator until his own death in 1980. Shortly before his passing,
Gonzales had requested compensation for his administration services over the years. His heirs
filed motions to claim P100,000 initially and later increased the amount to P500,000 as
administrator’s commission. The trial court allowed the claim and granted P500,000, citing the
significant effort Gonzales had invested in managing and expanding the estate, valued at
approximately P10 million.

However, other heirs contested this, arguing that the claim was excessive and unsupported. They
suggested a reduced fee based on the statutory rates outlined in Rule 85, Section 7 of the Rules
of Court. The Court of Appeals initially affirmed the trial court’s decision, but upon
reconsideration, it reduced Gonzales’ commission to P4,312.50, reasoning that the increase in
estate value was not directly attributable to Gonzales' efforts.

Issue: Is the late Jose de Luna Gonzales entitled to the full P500,000 as compensation for his
services as the administrator of Carmen de Luna’s estate?

Ruling: The Supreme Court ruled in favor of the administrator’s heirs, reinstating the trial
court's original order to award P500,000. It found that the lower court had broad discretion under
Rule 85, Section 7, which allows greater compensation when an estate is large, and its
administration has required substantial effort and skill. The Court noted that Gonzales had
meticulously managed the estate for 16 years, increased its assets significantly, and fulfilled his
role without objections from the heirs. Therefore, the Court found the trial court's decision
justified and overturned the Court of Appeals' modification, restoring the P500,000
compensation.

Key Takeaway on Judicial Power: This case underscores the judicial power and discretion
granted to trial courts in determining compensation for estate administrators. The Court
emphasized that unless there is a clear abuse of discretion, appellate courts should defer to trial
court judgments, especially in matters requiring nuanced understanding of the case’s complexity,
the size of the estate, and the administrator's diligent efforts.

Case Digest: Cutaran v. DENR (G.R. No. 134958, January 31, 2001)

Facts:
Petitioners Patricio Cutaran, David Dangwas, and Pacio Dosil filed a case to prevent the
Department of Environment and Natural Resources (DENR) from implementing special orders
that allowed processing of ancestral land claims in the Cordillera Administrative Region. These
orders, including Special Orders Nos. 31, 31-A, and 31-B (1990) and Special Order No. 25
(1993), empowered the DENR to accept and delineate ancestral claims, including granting
Certificates of Ancestral Land Claim (CALC). Petitioners, who occupy land within the Camp
John Hay Reservation, argued that the DENR lacked the legislative authority to issue titles for
ancestral land and that this power was later expressly granted to the National Commission on
Indigenous Cultural Communities (NCIP) under the Indigenous Peoples Rights Act of 1997.

The Court of Appeals nullified the DENR’s Special Orders Nos. 31, 31-A, and 31-B but upheld
the validity of Special Order No. 25 and its implementing rules, DAO No. 02 (1993), citing its
alignment with the National Integrated Protected Areas System (NIPAS) Act.

Issues:
 1. Whether the DENR had authority under the NIPAS Act to issue ancestral land titles or
certifications.
2. Whether there was an actual justiciable controversy for the court to resolve.

Ruling:
The Supreme Court dismissed the case, finding no justiciable controversy. It held that a dispute
must present actual or imminent harm, not speculative issues. In this case, the DENR had not yet
issued any CALC to the heirs of Carantes, who had applied for overlapping land claims. As the
application was still pending and no title had been granted, the petitioners’ concerns about
eviction were hypothetical. The Court emphasized that judicial review applies only to concrete
disputes and that anticipatory cases or advisory opinions fall outside the judiciary’s scope.

Significance:
This case underscores the judiciary's limits in addressing speculative claims and reinforces that
judicial power can only be invoked in cases with real, direct, or imminent legal injury. The
decision clarifies that mere administrative actions without actual harm do not constitute a basis
for judicial intervention.

DUMLAO, ET AL. VS COMELEC

2de160b6c58794ccc0b895e46550d261G.R. No. L-52245 January 22, 1980

FACTS:
Dumlao was the former governor of Nueva Viscaya. He has already retired from his office and
has been receiving retirement benefits. In 1980, he filed for reelection to the same office.
Meanwhile, BP Blg. 52 was enacted. This law provides that retirees from public office are
disqualified to run for office. Dumlao assailed the law avvering that it is class legislation hence
unconstitutional. In general, he invoked equal protection of law. His petition was joined by Atty.
Romeo Igot and Alfredo Salapantan, Jr. These two, however, have different issues. The suits of
Igot and Salapantan are more of a taxpayer’s suit assailing the other provisions of BP Blg. 52
regarding the term of office of the elected officials, the length of the campaign, and the provision
which bars person charged for crimes from running for public office as well as the provision that
provides that the mere filing of complaints against them after preliminary investigation would
already disqualify them from office.
ISSUE:
Whether or not Dumlao, Igot, and Salapantan have a cause of action.

RULING:
NO. The Supreme Court pointed out the procedural lapses of this case for the latter should have
never been merged. Dumlao’s issue is different from Igot and Salapantan. They have different
issues. Further, this case does not meet all requisites to be eligible for judicial review, namely:
(1) the existence of an appropriate case; (2) an interest personal and substantial by the party
raising the constitutional question; (3) the plea that the function be exercised at the earliest
opportunity; and (4) the necessity that the constitutional question be passed upon in order to
decide the case.

In this case, only the 3rd requisite was met.

The SC ruled however that the provision barring persons charged for crimes may not run for
public office and that the filing of complaints against them after preliminary investigation would
already disqualify them from office as null and void.

The assertion that BP Blg. 52 is contrary to the safeguard of equal protection is neither well
taken. The constitutional guarantee of the equal protection of the laws is subject to rational
classification. If the groupings are based on reasonable and real differentiation, one class can be
treated and regulated differently from another class. For purposes of public service, employees
65 years of age, have been validly classified differently from younger employees. Employees
attaining that age are subject to compulsory retirement, while those of younger ages are not so
compulsorily retirable.

In respect of election to provincial, city, or municipal positions, to require that candidates should
not be more than 65 years of age at the time they assume office, if applicable to everyone, might
or might not be a reasonable classification although, as the Solicitor General has intimated a
good policy of the law should be to promote the emergence of younger blood in our local
governments. On the other hand, it might be that persons more than 65 years old may also be
good elective local officials.

Retirement from government service may or may not be reasonable disqualification for elective
local officials. But, in the case of a 65-year old elective local official (Dumlao), who has retired
from a provincial, city, or municipal office, there is reason to disqualify him from running for the
same office from which he had retired, as provided for in the challenged provision.

HACIENDA LUISITA, INCORPORATED vs.

PRESIDENTIAL AGRARIAN REFORM COUNCIL

G.R. No. 171101, Case Digest September 12, 2020

Hacienda Luisita de Tarlac, once a 6,443 hectare mixed agricultural-industrial-residential

expanse several municipalities of Tarlac and owned by Compania General de Tabacos de
Filipinas (Tabacalera). Tarlac Development Corporation (Tadeco) then owned and controllec by
Jose Cojuangco Sr. Group.

On May 9, 1989, some 93% of the then farmworker-beneficiaries (FWBs) complement of

Hacienda Luisita signified in a referendum their acceptance of the proposed HLI’s Stock
Distribution Option Plan. On May 11, 1989, the Stock Distribution Option Agreement (SDOA),
styled as a Memorandum of Agreement (MOA), was entered into by Tadeco, HLI, and the 5,848
qualified FWBs and attested to by then DAR Secretary Philip Juico. The SDOA embodied the
basis and mechanics of the SDP, which would eventually be submitted to the PARC for
approval.

On December 22, 2005, the PARC issued the assailed Resolution No. 2005-32-01, approve and
confirm the recommendation of the PARC Executive Committee adopting in toto the report of
the PARC ExCom Validation Committee affirming the recommendation of the DAR to
recall/revoke the SDO plan of Tarlac Development Corporation/Hacienda Luisita Incorporated.
On August 31, 2010, the Court, in a bid to resolve the dispute through an amicable settlement,
issued a Resolution84 creating a Mediation Panel composed of then Associate Justice Ma. Alicia
Austria-Martinez, as chairperson, and former CA Justices Hector Hofileña and Teresita Dy-
Liacco Flores, as members. Meetings on five (5) separate dates, i.e., September 8, 9, 14, 20, and
27, 2010, were conducted. Despite persevering and painstaking efforts on the part of the panel,
mediation had to be discontinued when no acceptable agreement could be reached.

Issues:

WON the PARC’s has the authority to revoke the Stock Distribution Plan
WON Section.31 of RA 6657 is unconstitutional
WON the operative act is applicable in the instant case
Held:

Yes, PARC has the authority to revoke the Stock Distribution Plan.

Under Sec. 31 of RA 6657, as implemented by DAO 10, the authority to approve the plan for
stock distribution of the corporate landowner belongs to PARC. However, contrary to petitioner
HLI’s posture, PARC also has the power to revoke the SDP which it previously approved. It may
be, as urged, that RA 6657 or other executive issuances on agrarian reform do not explicitly vest
the PARC with the power to revoke/recall an approved SDP. Such power or authority, however,
is deemed possessed by PARC under the principle of necessary implication, a basic postulate
that what is implied in a statute is as much a part of it as that which is expressed.

The court explained that “every statute is understood, by implication, to contain all such
provisions as may be necessary to effectuate its object and purpose, or to make effective rights,
powers, privileges or jurisdiction which it grants, including all such collateral and subsidiary
consequences as may be fairly and logically inferred from its terms.” Further, “every statutory
grant of power, right or privilege is deemed to include all incidental power, right or privilege.

II.

The court answer is negative. The instant challenge on the constitutionality of Sec. 31 of RA
6657 and necessarily its counterpart provision in EO 229. It is not the lis mota of the case and it
was not property raised and presented.

The Court cannot be goaded into resolving a constitutional issue that FARM failed to assail after
the lapse of a long period of time and the occurrence of numerous events and activities which
resulted from the application of an alleged unconstitutional legal provision.

It has been emphasized in a number of cases that the question of constitutionality will not be
passed upon by the Court unless it is properly raised and presented in an appropriate case at the
first opportunity. FARM is, therefore, remiss in belatedly questioning the constitutionality of
Sec. 31 of RA 6657. The second requirement that the constitutional question should be raised at
the earliest possible opportunity is clearly wanting.
The last but the most important requisite that the constitutional issue must be the very lis mota of
the case does not likewise obtain. The lis mota aspect is not present, the constitutional issue
tendered not being critical to the resolution of the case. The unyielding rule has been to avoid,
whenever plausible, an issue assailing the constitutionality of a statute or governmental act.

III

The “operative fact” doctrine is a legislative or executive act, prior to its being declared as
unconstitutional by the courts, is valid and must be complied with.

This doctrine was reiterated in the more recent case of City of Makati v. Civil Service
Commission, wherein we ruled that: Moreover, we certainly cannot nullify the City
Government’s order of suspension, as we have no reason to do so, much less retroactively apply
such nullification to deprive private respondent of a compelling and valid reason for not filing
the leave application. For as we have held, a void act though in law a mere scrap of paper
nonetheless confers legitimacy upon past acts or omissions done in reliance thereof.
Consequently, the existence of a statute or executive order prior to its being adjudged void is an
operative fact to which legal consequences are attached. It would indeed be ghastly unfair to
prevent private respondent from relying upon the order of suspension in lieu of a formal leave
application.

In the instant case, although the assailed Resolution No. 2005-32-01 states that it revokes or
recalls the SDP, what it actually revoked or recalled was the PARC’s approval of the SDP
embodied in Resolution No. 89-12-2. Consequently, what was actually declared null and void
was an executive act, PARC Resolution No. 89-12-2, and not a contract (SDOA). It is, therefore,
wrong to say that it was the SDOA which was annulled.

Francisco vs House of Representatives GR No 160261 10 November 2003

11WednesdayMar 2015

Posted by Rachel Chan in Case Digests, Constitutional Law I

≈ Leave a comment
Facts: An impeachment complaint against Chief Justice Hilario Davide and seven Asociate
Justices was filed on 2 June 2003 but was dismissed by The House Committee on Justice on 22
October 2003 for being insufficient in substance. On 23 October 2003, Representative Gilbert
Teodoro and Felix Fuentabella filed a new impeachment complaint against the Chief Justice.
Thus arose the instant petitions against the House of Representatives et al, most of which
contend that the filing of the second impeachment complaint is unconstitutional as it violates the
provision of Section 5, Article XI of the Constitution, “no impeachment proceedings shall be
initiated against the same official more than once within the period of one year.” Senator
Aquilino Pimintel Jr, filed a Motion to Intervene, stating that the consolidated petitions be
dismissed for lack of jurisdiction of the Court and that the sole power, authority and jurisdiction
of the Senate as the impeachment court be recognized and upheld pursuant to the provision of
Article XI of the Constitution.
Issue: Whether or not the certiorari jurisdiction of the court may be invoked to determine the
validity of the second impeachment complaint pursuant to Article XI of the Constitution.
Decision: The second impeachment complaint is barred under Section 3 (5) of Article XI of the
Constitution.
Applying the principles of constitutional construction, ut magis valeat quam pereat. The
Constitution is to be interpreted as a whole, the said provision should function to the full extent
of its substance and form and its terms, in conjunction with all other provisions of the
Constitution. Pursuant to Section 1 Article VIII of the Constitution, “the judicial power shall be
vested in one Supreme Court.” Judicial power includes the duty of the courts of justice to settle
actual controversies involving rights which are legally demandable and enforceable and to
determine whether or not there has been a grave abuse of discretion amounting to lack or excess
of jurisdiction on part of any branch of the government. The courts of justice determine the limits
of power of the agencies and offices of the government as well as its officers , this is not only a
judicial power but a duty to pass judgment.
The Constitution itself has provided for the instrumentality of the judiciary as the rational way.
And when the judiciary mediates to allocate constitutional boundaries, it does not assert any
superiority over the other departments; it does not in reality nullify or invalidate an act of the
legislature, but only asserts the solemn and sacred obligation assigned to it by the Constitution to
determine conflicting claims of authority under the Constitution and to establish for the parties in
an actual controversy the rights which that instrument secures and guarantees to them.

### Title: People of the Philippines vs. Hon. Eustaquio Z. Gacott, Jr., et al.
### Facts:

This case involves the Philippine Supreme Court’s review of an administrative matter regarding
Hon. Eustaquio Z. Gacott, Jr., presiding judge of RTC, Branch 47, Puerto Princesa City. It
originated from Judge Gacott’s dismissal of Criminal Case No. 11529, which led the Supreme
Court to annul his order and impose sanctions for gross ignorance of the law. Judge Gacott filed
motions for reconsideration, raising multiple legal and procedural issues. The case underscores
the complexities of judicial administration, the appellate review process, and the standards
expected of judicial officers.

### Issues:

1. Whether Judge Gacott gravely abused his discretion in dismissing Criminal Case No. 11529.
2. The appropriateness of the sanctions imposed on Judge Gacott for gross ignorance of the law.

3. The procedural concerns raised by Judge Gacott regarding the review and decision-making
processes of the Supreme Court.

### Court’s Decision:

The Supreme Court, through Justice Regalado, decisively denied Judge Gacott’s motions for
reconsideration. The Court underscored that the dismissal of the criminal case demonstrated not
just an error in judgment but a significant lack of judicial competence impacting public
confidence in the judiciary. Furthermore, the Court clarified the procedural matters raised by
Judge Gacott, reaffirming its internal processes and the constitutional mandates regarding the
division of labor within the Supreme Court. The Court emphasized that its initial sanctions were
proportionate and necessitated by Judge Gacott’s actions, which were deemed incompatible with
the expected standards of judicial conduct.

### Doctrine:

The decision reiterated several key doctrines, including:

– The duty of judges to be well-informed of the laws and judicial developments.
– The authority of the Supreme Court to discipline lower court judges for actions constituting
gross ignorance of the law.
– The procedural mechanisms within the Supreme Court for reviewing cases and administrative
matters, specifically the division of cases between its en banc and divisional formats.

### Class Notes:

– **Judicial Discretion and Abuse Thereof**: A judge’s decision-making must be informed,
prudent, and within the bounds of law. Discretionary decisions, when made in ignorance of legal
mandates, can constitute abuse.
– **Administrative Discipline in Judiciary**: Demonstrates the Supreme Court’s authority to
impose disciplinary actions, including reprimands and fines, on judges for gross ignorance of the
law.
– **Supreme Court Procedural Aspects**: Highlights the internal rules of the Supreme Court in
dealing with administrative matters and clarifies misconceptions about the division and en banc
functions as they relate to disciplinary actions.

### Historical Background:

This case reflects the challenges within the Philippine judiciary concerning the maintenance of
high standards of judicial conduct and competence. It underscores the vital role of the Supreme
Court in overseeing lower courts and ensuring that judicial officers uphold the law with integrity
and informed judgment. The procedural dimensions of the case also provide insight into the
court’s mechanisms for managing its diverse and complex caseload, balancing between
divisional reviews and en banc deliberations to maintain efficiency and uphold justice.

Case Digest: G.R. No. 131457 (August 19, 1999) - Fortich v. Corona

Facts:
This case involves the petitioners Fortich, Baula, and NQSR Management, who challenged a
“Win-Win” Resolution issued by the Office of the President (OP) on November 7, 1997, which
altered an earlier decision in favor of their right to develop land in Bukidnon. The original OP
decision dated March 29, 1996, allowing such development, had already become final and
executory. The respondents and intervenors requested reconsideration, asserting that a tie vote on
the reconsideration motion warranted referral to the Supreme Court en banc under Article VIII,
Section 4(3) of the Constitution.

Issues:
 1. Whether the Supreme Court’s division must refer a tied vote on a motion for
reconsideration to the en banc.
2. Whether the “Win-Win” Resolution, issued after the initial OP decision became final,
was valid.

Ruling:

1. Referral to En Banc: The Court ruled that only “cases,” not “matters” (such as motions
for reconsideration), require referral to the en banc when votes are tied. Since the original
decision was already final, the tie in voting simply meant the reconsideration was denied,
upholding the prior ruling.
2. Finality of the Original Decision: The Court affirmed that the March 29, 1996, OP
decision was final, thus nullifying the “Win-Win” Resolution. The rights granted to
petitioners in the final decision are protected and cannot be overturned by subsequent
motions after the finality of the judgment.

Significance to Judicial Power:

This case underscores the judiciary's authority to uphold the finality of decisions, affirming that
procedural clarity serves to protect substantive rights. It also clarifies the distinction between
matters resolved within divisions and those needing en banc review, reinforcing judicial
consistency and procedural integrity.

Case Digest: Motion to Refer Cases En Banc (Republic of the Philippines and Firestone
Ceramics, Inc.)

Facts:
In this case, the petitioners, Republic of the Philippines and Firestone Ceramics, Inc., filed
motions to refer to the Supreme Court en banc their pending motions for reconsideration on a
decision rendered by the Court’s Third Division. The consolidated cases concern a 99-hectare
tract of land allegedly owned by the government but adjudicated to private parties by a court that
petitioners claim lacked jurisdiction. The petitioners argue that the cases raise questions of such
importance and complexity that they should be resolved by the full court, referencing Supreme
Court Circular No. 2-89 and its list of cases eligible for en banc consideration, specifically
Section 9, which allows the en banc to hear cases deemed of sufficient importance.

Issues:

1. Whether the cases should be referred to the Supreme Court en banc due to their
significant public interest and the questions they raise.
2. Whether there are compelling reasons that necessitate the en banc’s intervention in the
case.

Ruling:
The Court ruled to treat the cases as en banc matters, finding them of sufficient public
importance to justify the full Court’s review under Circular No. 2-89, as amended by the 1993
Resolution. The decision rested on the Court’s residual power to elevate cases deemed crucial to
en banc status, especially where they involve substantial public interest, such as government
property disputes. The Court also clarified that referring the cases en banc does not imply any
inadequacy on the part of the division that originally handled them but is instead an
acknowledgment of the need for broader deliberation due to the high stakes involved.

Significance:
This ruling underscores the judiciary's power to bring complex or publicly significant cases
before the full Court to ensure comprehensive review and equitable justice. The Court further
clarified that a decision to hear cases en banc is grounded not in numerical majority but in
substantive legal importance, thus reinforcing procedural flexibility to uphold the public interest
and the rule of law.

Case Digest: Oil and Natural Gas vs. Court of Appeals, GR No. 114323 (July 23, 1998)

Facts:
The petitioner, Oil and Natural Gas Corporation (ONGC), a foreign corporation owned by the
Government of India, entered into a contract with the private respondent, a Philippine
corporation, on February 26, 1983. The contract involved the supply of 4,300 metric tons of oil
well cement, with the ONGC agreeing to pay $477,300 through an irrevocable letter of credit.
However, due to a shipping dispute, the cement was delayed and never reached its destination.
Even after receiving payment, the private respondent failed to deliver the cement, which led to
negotiations where the respondent agreed to replace the cement. However, the replacement
cement did not meet ONGC's specifications. ONGC then invoked arbitration as per their
contract, and the arbitrator ruled in favor of ONGC in July 1988. The private respondent's
objections to the ruling were dismissed by a foreign court for failure to pay the necessary filing
fees. The issue arose regarding whether the foreign judgment could be enforced in the
Philippines.

Issue:
Whether the foreign judgment issued in favor of ONGC should be enforced in the Philippines.

Ruling:
Yes, the foreign judgment is enforceable in the Philippines. The Supreme Court held that the
procedural differences between the Philippine court system and the foreign court (in India) did
not affect the validity of the foreign judgment. The Court emphasized that enforcement of a
foreign judgment is governed by the principles of reciprocity and respect for foreign court
rulings. Despite the private respondent's claim of a due process violation—arguing that the
foreign court had not responded to its fee inquiries and had rejected its objections—the Court
found that the private respondent had sufficient opportunity to be heard. The respondent’s failure
to act with due diligence, especially in paying the required fees, resulted in the rejection of its
objections. Thus, the Supreme Court concluded that there was no violation of due process, and
the foreign judgment, being valid, should be enforced without further proceedings.

Significance:
This case reaffirms that foreign judgments may be enforced in the Philippines, even if the
procedures in the foreign court differ from Philippine law, provided that the foreign judgment is
valid and issued with due process. It also underscores the importance of due diligence in legal
proceedings, where failure to act promptly (like paying legal fees) can result in the loss of legal
rights.

### Title: Ampong vs. Civil Service Commission

### Facts:
On November 10, 1991, during the Professional Board Examination for
Teachers (PBET) in Davao City, Sarah P. Ampong impersonated Evelyn
Junio-Decir, taking the exam on her behalf and subsequently passing. At
the time, both were employed as public school teachers under the
Department of Education, Culture and Sports (DECS). Ampong later
transferred to the judiciary as a Court Interpreter III at the Regional Trial
Court in Alabel, Sarangani Province, on August 3, 1993.

The Civil Service Regional Office No. XI (CSRO) discovered the

impersonation on July 5, 1994, when “Decir” appeared to claim her PBET
Certificate of Eligibility, but the photo and signatures didn’t match the
examination records. A preliminary investigation identified Ampong as the
impersonator and initiated formal charges against both for Dishonesty,
Grave Misconduct, and Conduct Prejudicial to the Best Interest of the
Service.

Ampong confessed to the wrongdoing in February and March 1995,

waiving her right to counsel, and was subsequently dismissed from
service by the CSC on March 21, 1996. Ampong challenged the CSC’s
jurisdiction, arguing it lay with the Supreme Court given her judicial
position. The CSC and later the Court of Appeals (CA) rejected her
arguments, the latter under the principle of estoppel due to her active
participation in CSC’s proceedings.

### Issues:
1. Whether the Civil Service Commission (CSC) has jurisdiction to
discipline a judicial employee for acts committed prior to joining the
judiciary.
2. Application of the principle of estoppel against Ampong’s challenge to
CSC jurisdiction.

### Court’s Decision:

The Supreme Court ruled against Ampong, holding that while generally,
the CSC has jurisdiction over civil service employees and the Supreme
Court oversees judiciary employees, in this case, Ampong was estopped
from challenging CSC’s jurisdiction. Her voluntary participation in the
proceedings and admission of guilt ratified CSC’s jurisdiction over her
actions as a then-teacher. However, the Court noted that proper
procedure would typically require the CSC to file charges with the Office
of the Court Administrator given Ampong’s judicial position at the time of
the institution of action.

### Doctrine:
1. **Jurisdiction over Civil Service Employees**: The Civil Service
Commission (CSC) has jurisdiction over civil service employees, but
administrative supervision over judiciary employees lies exclusively with
the Supreme Court.

2. **Principle of Estoppel in Administrative Proceedings**: A party may

not be allowed to challenge the jurisdiction of a tribunal or body in
administrative proceedings if they have actively participated in those
proceedings and have sought to obtain a favorable decision from the
body.

### Class Notes:

– **Jurisdiction at Time of Action vs. Time of Offense**: The jurisdiction
over a case is determined at the time of the institution of the action, not
at the time of commission of the offense.
– **Estoppel and Participation in Proceedings**: Active participation in
proceedings before a tribunal can estop a party from later contesting its
jurisdiction.
– **Dishonesty in Civil Service Examinations**: Acts of cheating, collusion,
impersonation, or assisting in such acts constitute dishonesty, a ground
for disciplinary action including dismissal.

### Historical Background:

The case underscores the delineation of jurisdiction between the CSC and
the Supreme Court over disciplinary actions within the Philippine
government’s branches, highlighting the evolving interpretation of
jurisdictional boundaries and principles of estoppel in administrative law.
This decision reaffirms the exclusive authority of the Supreme Court over
judiciary employees while recognizing the CSC’s broad jurisdiction over
civil service examination integrity.

Title
Fuentes vs. Office of the Ombudsman-Mindanao
Case
G.R. No. 124295
Decision Date
Oct 23, 2001

Facts:
 The case "Fuentes v. Office of the Ombudsman-Mindanao" involves petitioner Judge
Renato A. Fuentes and respondents from the Office of the Ombudsman-Mindanao.
  Respondents include Graft Investigation Officer II Marivic A. Trabajo-Daray, Antonio E.
Valenzuela (Director for Fact Finding and Intelligence), and Margarito P. Gervacio, Jr.
(Deputy Ombudsman for Mindanao).
 The case originated from an expropriation case in Davao City for the construction of the
city's first fly-over.
 The Republic of the Philippines, represented by the Department of Public Works and
Highways (DPWH), filed the expropriation case against property owners Tessie Amadeo,
Reynaldo Lao, and Rev. Alfonso Galo.
 Judge Fuentes presided over the case, which resulted in a favorable decision for the
government, but the DPWH still owed the defendants P15,510,415.00.
 On April 5, 1994, the lower court granted a motion for a writ of execution against the
DPWH to satisfy the unpaid claim of Tessie Amadeo.
 The writ was issued on April 6, 1994, and served on April 15, 1994.
 A Notice of Levy was issued on May 3, 1994, targeting scrap iron/junks at the DPWH
depot in Panacan, Davao City.
 An auction was held on May 18, 1994, where Alex Bacquial was the highest bidder.
 Bacquial and Sheriff Paralisan attempted to withdraw the auctioned properties but were
initially prevented by DPWH personnel.
 Judge Fuentes granted a "break through" order on May 20, 1994, allowing Bacquial to
haul off the equipment, including repairable items, over five days.
 On June 21, 1994, the lower court upheld the validity of the writ of execution.
 Following complaints from Congressman Manuel M. Garcia and Engineer Ramon A.
Alejo, the Supreme Court directed an investigation into Judge Fuentes and Sheriff
Paralisan.
 The Supreme Court dismissed Sheriff Paralisan from service and directed an
investigation into Judge Fuentes.
 On January 15, 1996, Director Valenzuela recommended charging Judge Fuentes with
violation of Republic Act No. 3019, Section 3(e) and filing an administrative charge
before the Supreme Court.
 A criminal complaint was filed on January 22, 1996, and an order was issued directing
Judge Fuentes to submit a counter-affidavit.
 Judge Fuentes moved to dismiss the complaint, but his motion was denied, leading to this
petition.
Issue:
 Can the Ombudsman conduct an investigation of a judge's actions in the exercise of his
official functions, alleged to be in violation of the Anti-Graft and Corrupt Practices Act,
without an administrative charge for the same acts before the Supreme Court?
Ruling:
 The Supreme Court granted the petition, directing the Ombudsman to dismiss the case
and refer the complaint against Judge Renato A. Fuentes to the Supreme Court for
appropriate action.
Ratio:
 The Supreme Court held that the Ombudsman does not have the authority to investigate a
judge's actions in the exercise of his official functions, as this power is vested exclusively
in the Supreme Court under Article VIII, Section 6 of the 1987 Philippine Constitution.
 The Court emphasized that administrative supervision over all courts and court personnel
is the sole prerogative of the Supreme Court.
 The Ombudsman Act of 1989 (Republic Act No. 6770) specifies that the Ombudsman
does not have disciplinary authority over members of the Judiciary.
  The Court underscored the principle of separation of powers, asserting that no other
branch of government may intrude into the judiciary's domain.
 The Court concluded that the Ombudsman must indorse the case to the Supreme Court
for appropriate action, thus maintaining the independence of the judiciary and preventing
any encroachment on its exclusive powers.

Case Digest: Venancio Inonog vs. Judge Francisco B. Ibay

Facts:

In 2005, Venancio Inonog, a driver for the Makati City Hall’s Business Permit Division, parked
in a basement slot that Judge Francisco B. Ibay claimed was reserved for him. Believing this
caused a delay in his court proceedings, Judge Ibay cited Inonog for indirect contempt, fined him
₱1,000, and sentenced him to five days’ imprisonment. Inonog appealed, explaining he was
unaware of the reservation and had not intended to disrespect the court. Judge Ibay denied his
motion for reconsideration, increased the fine to ₱2,000, but withdrew the jail sentence.

Aggrieved, Inonog filed an administrative complaint alleging that Judge Ibay abused his
contempt powers. The Office of the Court Administrator (OCA) found that Judge Ibay acted
disproportionately, as Inonog’s action did not obstruct justice nor show disrespect.

Issues:

1. Did Judge Ibay abuse his judicial power by excessively punishing Inonog for contempt over a
minor parking infraction?
2. How should judges exercise their contempt power in relation to preserving the authority and
dignity of the judiciary?

Ruling:

The Supreme Court found Judge Ibay guilty of grave abuse of authority. The Court ruled that
Inonog’s parking in the judge’s reserved spot, though inconvenient, did not meet the standards
for indirect contempt, which requires obstructive or disrespectful conduct towards the court.
Judges are expected to exercise restraint and only use contempt powers for upholding justice and
court order, not for personal grievances.

The Court fined Judge Ibay ₱40,000, to be deducted from his retirement benefits, noting his prior
similar misconduct. This case emphasizes the judiciary’s power to enforce respect through
contempt proceedings, balanced by the obligation of judges to use that power judiciously and in
service to justice—not for personal retaliation.

Title: Francisco I. Chavez vs. Judicial and Bar Council, et al.

Facts:
The case originated from the vacancy left by the departure of Chief Justice Renato C. Corona
from the Supreme Court on May 29, 2012. Subsequently, Francisco I. Chavez was nominated as
a potential successor, prompting him to question the numerical composition of the Judicial and
Bar Council (JBC). Chavez filed a petition asking the Supreme Court to resolve whether the
Constitution permits more than one member of Congress to sit in the JBC and whether the
practice of having two representatives from Congress, each with one vote, is constitutional.
The Court initially handed down a decision on July 17, 2012, declaring the current composition
of the JBC unconstitutional and directing the JBC to reconstitute itself to include only one
member from Congress. Following a motion for reconsideration filed by the respondents,
represented by the Office of the Solicitor General, oral arguments were scheduled, and
memoranda filed. The Court eventually denied the respondents’ motion for reconsideration,
affirming its original decision.
Issues:
1. Whether the Constitution allows more than one member of Congress to sit in the JBC.
2. Whether the practice of having two Congressional representatives in the JBC, each wielding
one vote, violates the Constitution.
Court’s Decision:
The Supreme Court maintained its original decision, concluding that the Constitution requires
only one Congressional representative to be part of the JBC. It elaborated that the use of the
singular form “a representative of Congress” in the Constitution implied the Framers’ intent for a
single legislative representative in the JBC. Additionally, adjustments recognizing bicameralism
in other constitutional provisions suggested that any omission of such adjustments related to JBC
representation was deliberate.
The Court rejected the argument that having only one representative from Congress in the JBC
would be absurd due to its bicameral nature, stating that Congress was envisioned to participate
in the JBC not as a legislative but a single body with a non-legislative role.
Doctrine:
This case reiterated the doctrine that the Constitution’s language is deliberate and must be
interpreted based on its clear wording unless there is ambiguity. Any act done in violation of the
Constitution, no matter the frequency of practice, remains void and cannot be the source of any
authority. The principle of the operative fact doctrine applies as an exception, legitimizing
actions taken before the declaration of unconstitutionality.
Class Notes:
– Interpretation of constitutional provisions proceeds from the presumption that the language
used expresses the intent of the Framers.
– The doctrine of operative fact legitimizes acts performed based on a statute before it was
declared unconstitutional, provided application does not result in unjust consequences.
– A bicameral legislature in the context of constitutional interpretation implies that adjustments
for recognizing each chamber’s distinct roles should be explicit unless intentionally omitted.
– When interpreting the Constitution, every word is presumed chosen for a specific purpose, and
its plain meaning should generally be respected.
Historical Background:
The background to this case reflects the evolution of the Philippine Republic’s judicial
appointments process. Initially, judicial appointments were subject to legislative confirmation.
Recognizing the need to insulate judicial appointments from political influence, the 1987
Constitution established the JBC to recommend appointees to the President, with representation
from various stakeholders, including Congress. However, the Constitution’s framing left the
question of Congress’ representation in the JBC ambiguous, leading to the dispute resolved in
this case.
Title
Nitafan vs. Commissioner of Internal Revenue
Case
G.R. No. 78780
Decision Date
Jul 23, 1987

Facts:
 The case "Nitafan v. Commissioner of Internal Revenue" (G.R. No. 78780) was decided
on July 23, 1987, by the Philippine Supreme Court.
 Petitioners David G. Nitafan, Wenceslao M. Polo, and Maximo A. Savellano, Jr. were
judges of the Regional Trial Court in Manila.
 They sought to stop the Commissioner of Internal Revenue and the Financial Officer of
the Supreme Court from deducting withholding taxes from their salaries.
 Petitioners argued that such deductions violated Section 10, Article VIII of the 1987
Constitution, which states that judicial salaries shall not be decreased during their tenure.
 They claimed that these deductions undermined judicial independence.
 The issue had been previously addressed administratively, with the Court affirming the
Chief Justice's directive to continue the deductions.
 The petition prompted the Court to resolve the issue judicially.
Issue:
 Does the deduction of withholding taxes from judges' salaries constitute a decrease or
diminution of their salaries, contrary to Section 10, Article VIII of the 1987 Constitution?
Ruling:
 The Supreme Court dismissed the petition, ruling that the deduction of withholding taxes
from judges' salaries does not constitute a decrease or diminution of their salaries and
aligns with the intent of the Constitutional Commission.
Ratio:
 The Court based its decision on the clear intent of the Constitutional Commission to
exclude an express tax exemption for the judiciary.
 Commissioner Rigos articulated that this intent was to ensure equality among the three
branches of government.
 Deliberations, particularly Commissioner Joaquin F. Bernas' accepted amendment,
clarified that judicial salaries would be subject to general income tax.
 The 1987 Constitution lacks a provision similar to Section 6, Article XV of the 1973
Constitution, which exempted public officers' salaries from income tax.
 The framers' intent, as revealed in the Constitutional Commission's debates, was to make
judicial salaries taxable.
 The Court emphasized that constitutional construction aims to realize the framers' and the
people's purpose in adopting the Constitution.
 The Court highlighted the principle that all citizens should equitably share the burden of
general income taxation.
 Consequently, the Court discarded previous rulings in Perfecto vs. Meer and Endencia vs.
David, which had exempted judicial salaries from income tax, considering such
exemptions as a diminution of salaries during their tenure
Title

Senate of the Philippines vs. Ermita

Case

G.R. No. 169777

Decision Date

Apr 20, 2006

Facts:

 The case "Senate of the Philippines v. Ermita" involves multiple petitions challenging the
constitutionality of Executive Order No. 464 (E.O. 464).

 E.O. 464 was issued by President Gloria Macapagal-Arroyo on September 28, 2005.

 Petitioners include the Senate of the Philippines, represented by Senate President Franklin M.
Drilon and other senators, as well as various organizations and individuals such as Bayan Muna,
Francisco I. Chavez, and the Integrated Bar of the Philippines.

 E.O. 464 required heads of executive departments and other high-ranking officials to secure the
President's consent before appearing in congressional inquiries.

 The order followed a series of Senate investigations into issues like the NorthRail project and
alleged wiretapping activities.

 Several executive officials were invited to testify but were barred from attending due to E.O.
464.

 Petitioners argued that the order unduly restricted Congress's power to conduct inquiries in aid
of legislation and violated the principle of separation of powers.

 The case was consolidated and brought before the Supreme Court, which heard oral arguments
and received memoranda from the parties involved.

Issue:

1. Does E.O. 464 contravene the power of inquiry vested in Congress?

2. Does E.O. 464 violate the right of the people to information on matters of public concern?

3. Did respondents commit grave abuse of discretion by implementing E.O. 464 prior to its
publication in a newspaper of general circulation?

Ruling:

 The Supreme Court partly granted the petitions.

 Sections 2(b) and 3 of E.O. 464 were declared void.

 Sections 1 and 2(a) of E.O. 464 were upheld as valid.

  The requirement for executive officials to secure the President's consent before appearing in
congressional inquiries, as stipulated in Sections 2(b) and 3, was ruled unconstitutional.

 Section 1, concerning the appearance of department heads during the question hour, and
Section 2(a), providing guidelines on executive privilege, were found valid.

Ratio:

 The power of inquiry is inherent in the legislative function and essential for Congress to legislate
wisely and effectively.

 The 1987 Constitution allows for executive privilege, but such privilege must be clearly asserted
and justified.

 E.O. 464's provisions allowing for implied claims of executive privilege were insufficient and
invalid, as they did not provide specific reasons for withholding information.

 Transparency and accountability are crucial in a democratic society, with a presumption favoring
disclosure over secrecy.

 E.O. 464 should have been published before its implementation, as it directly affected the
public's right to information.

 The decision underscored the need to balance the executive's confidentiality interests with the
public's right to know and Congress's legislative functions.