PALAWAN STATE UNIVERSITY

School of Law

Cases for Bar Operations

S.Y. 2024-2025
Week 10

Submitted to: ATTY. ALLAN B. CARLOS

Submitted by: GILBERT A. DELOS SANTOS

No. DATE G.R. NO. TITLE

136 April 28, 2021 G.R. No. 231545 PHILIPPINE DEVELOPMENT AND
. INDUSTRIAL CORPORATION,
Petitioner, v. THE HON. COURT OF
APPEALS, EQUITABLE PCI BANK
(NOW KNOWN AS BANCO DE ORO
UNIBANK, INC.), THE REGISTER OF
DEEDS OF MANILA, AND M.N.
AMOR B. DAIT, IN HIS CAPACITY AS
SHERIFF OF THE REGIONAL TRIAL
COURT OF MANILA, Respondents.
137 April 27, 2021 G.R. No. 213212 RENE FIGUEROA, Petitioner, v.
. COMMISSION ON AUDIT, Respondent.
138 April 28, 2021 G.R. No. 236900 THE CITY OF VALENZUELA,
. REPRESENTED HEREIN BY ITS
DULY ELECTED MAYOR, HON.
REXLON T. GATCHALIAN, Petitioner,
v. ROMAN CATHOLIC ARCHBISHOP
OF MANILA, REPRESENTED
HEREIN BY THE ROMAN CATHOLIC
BISHOP OF MALOLOS, INC.,
Respondent.
139 April 28, 2021 A.C. No. 11959 EUSEBIO D. SISON, Petitioner, v.
. ATTY. LOURDES PHILINA B.
DUMLAO, Respondent.
140 April 27, 2021 G.R. No. 251178 SMALL BUSINESS CORPORATION,
. Petitioner, v. COMMISSION ON AUDIT
(COA), COA CHAIRPERSON
MICHAEL G. AGUINALDO, COA
CLUSTER 2-CORPORATE
GOVERNMENT SECTOR DIRECTOR
MARY S. ADELINO, Respondents.
141 April 26, 2021 G.R. No. 235364 MARYLINE ESTEBAN, Petitioner, v.
. RADLIN CAMPANO, AND ALL
PERSONS CLAIMING RIGHTS
UNDER HIM, Respondents.
142 April 28, 2021 G.R. No. 239221 SEACREST MARITIME
. MANAGEMENT, INC., NORDIS
TANKERS MARINE A/S, AND
 REDENTOR ANAYA, Petitioners, v.
SAMUEL B. BERNARTE, Respondent.
143 April 28, 2021 G.R. No. 241126 ROMEO DAWAT, JR. Y HARME,
. Petitioner, v. PEOPLE OF THE
PHILIPPINES, Respondent.
144 April 26, 2021 G.R. No. 248907 RUBEN DE GUZMAN Y LAZANO,
. Petitioner, v. PEOPLE OF THE
PHILIPPINES, Respondent.
145 April 26, 2021 G.R. Nos. 221253-54 WILLIAM G. GUIALANI, IN HIS
. CAPACITY AS TAXPAYER AND
GRAFT AND CORRUPTION
CRUSADER, Petitioner, v. THE COURT
OF APPEALS, (SPECIAL) TWENTY-
SECOND DIVISION [COMPOSED OF:
HON. HENRI PAUL B. INTING
(PONENTE), HON. EDGARDO A.
CAMELLO, AND HON. PABLITO A.
PEREZ (MEMBERS)]; DEPARTMENT
OF INTERIOR AND LOCAL
GOVERNMENT [HEREIN
REPRESENTED BY SEC. MEL SENEN
SARMIENTO, USEC. AUSTERE A.
PANADERO, AND OIC REGIONAL
DIRECTOR NILO P. CASTANARES
OF REGION - 10]; OFFICE OF THE
OMBUDSMAN [HEREIN
REPRESENTED BY THE
OMBUDSMAN HON. CONCHITA
CARPIO-MORALES]; AND OSCAR S.
MORENO AND GLENN C. BAÑEZ,
Respondents.
146 April 28, 2021 G.R. No. 208465 BUREAU OF CUSTOMS, Petitioner, v.
. BUSH BOAKE ALLEN (PHILS.), INC.,
Respondent.
147 April 26, 2021 G.R. No. 205385 EMS CREW MANAGEMENT
. PHILIPPINES, EMS SHIP
MANAGEMENT (SINGAPORE) PTE.,
LTD., AND/OR ROBERT C.
BANDIVAS, Petitioners, v. ERWIN C.
BAUZON, Respondent.
148 April 28, 2021 G.R. No. 240447 PEOPLE OF THE PHILIPPINES,
. Plaintiff-Appellee, v. JAMAL RANGAIG
Y AMPUAN, SAAD MAKAIRING Y
LONTO, AND MICHAEL JUGUILON
Y SOLIS, Accused-Appellants.
149 April 28, 2021 G.R. No. 237620 ERWIN TULFO, LILIBETH
. FRONDOSO, LYNDA JUMILLA,
MARIA PROGENA, ESTONILLO
REYES, ANNA LIZA EUGENIO,
FERNANDO GARCIA, EUGENIO
LOPEZ III, LUIS F. ALEJANDRO,
JOSE RAMON OLIVES, JESUS
"JAKE" MADERAZO, LUISITA
CRUZ-VALDES, JOSE "JING"
MAGSAYSAY, JR., AND ALFONSO
"PAL" A. MARQUEZ III, Petitioners, v.
PEOPLE OF THE PHILIPPINES,
 FELIPE L. GOZON, GILBERTO R.
DUAVIT, JR., MARISSA L. FLORES,
JESSICA A. SOHO, GRACE DELA
PEÑA-REYES, AND JOHN OLIVER T.
MANALASTAS, Respondents.
150 April 28, 2021 G.R. No. 246986 SPOUSES RICARDO TAYAMEN, JR.
. AND CARMELITA TAYAMEN,
Petitioners, v. PEOPLE OF THE
PHILIPPINES, Respondent.
 136. PHILIPPINE DEVELOPMENT AND INDUSTRIAL CORPORATION, Petitioner,
vs.
THE HON. COURT OF APPEALS, EQUITABLE PCI BANK (NOW KNOWN AS
BANCO DE ORO UNIBANK, INC.), THE REGISTER OF DEEDS OF MANILA, AND
M.N. AMOR B. DAIT, IN HIS CAPACITY AS SHERIFF OF THE REGIONAL TRIAL
COURT OF MANILA, Respondents.
G.R. No. 231545, April 28, 2021
Facts:
The Philippine Deposit Insurance Corporation (PDIC) is a domestic corporation established
under Philippine law, while Equitable PCI Bank (EPCIB), now known as Banco De Oro
Unibank, Inc., is a commercial banking corporation also organized under Philippine law.
In 1996, PDIC was granted a credit line by EPCIB, consisting of a secured credit line and a clean
credit line, each amounting to P100,000,000.00, intended to fund the Sta. Ana Villas
Condominium Project in Manila. PDIC executed a Real Estate Mortgage (REM) over the land
covered by Transfer Certificate of Title (TCT) No. 230861 as security for the credit line.
By January 1997, after fully utilizing the clean credit line, PDIC requested additional funds from
the secured credit line, but EPCIB deferred this request due to market conditions. Consequently,
PDIC sought alternative financing, leading to overdue obligations. In June 2000, PDIC and
EPCIB entered into a Repayment Agreement acknowledging PDIC's debts totaling
P26,222,098.23 and $2,777,686.69.
PDIC executed additional REMs over 29 condominium units and another property in Bulacan as
part of this agreement. However, after PDIC defaulted on its obligations, EPCIB initiated
foreclosure proceedings, leading to the sale of the mortgaged properties on April 21, 2003. PDIC
filed a complaint for cancellation of the mortgage and restitution of titles, which was dismissed
for lack of jurisdiction.
Subsequently, PDIC filed another complaint for annulment of the mortgage and foreclosure sale,
alleging that the REMs were executed under undue influence. The RTC ruled in favor of EPCIB,
affirming the validity of the foreclosure sale, which was upheld by the Court of Appeals. PDIC's
motions for reconsideration were denied, prompting further appeals.
Issues:
1. Whether the Court of Appeals (CA) committed grave abuse of discretion in denying the
Philippine Deposit Insurance Corporation's (PDIC) application for a Temporary
Restraining Order (TRO) to prevent Equitable PCI Bank (EPCIB) from consolidating its
title over certain properties.
2. Whether the CA erred in upholding the Regional Trial Court (RTC) Manila's decision that
the Real Estate Mortgages (REMs) and the subsequent extrajudicial foreclosure sale were
valid.
Ruling:
The Supreme Court found no merit in PDIC's petitions. It ruled that the CA did not commit grave
abuse of discretion in denying the TRO application. The Court emphasized that PDIC failed to
demonstrate a clear legal right to prevent EPCIB from consolidating its title. The Court noted
that the validity of the REMs had already been upheld by the RTC, and PDIC did not exercise its
right to redeem the properties within the redemption period. Consequently, the consolidation of
ownership in favor of EPCIB was deemed valid and lawful.
The Court reiterated that a mortgagee has the right to foreclose when the principal obligation is
not paid, and the purchaser in a foreclosure sale is entitled to possession of the property. PDIC's
claims of undue influence and vitiated consent were rejected, as the Court found that PDIC had
voluntarily entered into the agreements and benefited from them. Thus, the petitions were
dismissed, affirming the decisions of the lower courts.

137. RENE FIGUEROA, Petitioner,

vs.
COMMISSION ON AUDIT, Respondent.
G.R. No. 213212, April 27, 2021
Facts:
The Philippine Amusement and Gaming Corporation (PAGCOR) is a government-owned and
controlled corporation established under Presidential Decree No. 1869, as amended by
subsequent laws, to regulate and centralize all games of chance in the Philippines. In December
2008, Edward F. King, then Vice President of PAGCOR, requested the allocation of
P26,700,000.00 for movie tickets to the film "Baler," which was approved by PAGCOR's Board
of Directors. The payment was processed despite irregularities noted by the Commission on
Audit (COA), including the lack of supporting documents and improper charging of funds.
Following an audit, COA issued Notice of Disallowance No. 2011-002(08), holding several
PAGCOR officials, including Efraim C. Genuino (Chairman and CEO), liable for the transaction.
The COA found that the purchase was ultra vires and that PAGCOR could not exploit customer
points without consent. The amount was ultimately sustained, and the liability of the officials
was affirmed, leading to motions for reconsideration that were denied by the COA.
Issue:
Whether the Commission on Audit (COA) acted with grave abuse of discretion in disallowing
PAGCOR's expenditure of PHP 26,700,000 for movie tickets?
Ruling:
The Supreme Court ruled that while COA has broad constitutional powers to audit government
funds, its jurisdiction is not absolute regarding PAGCOR's finances. The PAGCOR Charter limits
COA’s audit to the franchise tax and the government’s 50% share of PAGCOR’s gross earnings.
The ₱26,700,000.00 expenditure came from PAGCOR’s marketing funds, outside COA's audit
scope under the Charter. Moreover, the COA overstepped its authority by declaring the PAGCOR
Board's action ultra vires (beyond its power). Such determinations are outside COA's
constitutional mandate.
The Court emphasized that the PAGCOR Board acted within its authority, as its Charter permits
expenditures necessary for PAGCOR's operations. Therefore, COA’s disallowance was annulled,
and the petitions were granted.

138. THE CITY OF VALENZUELA, REPRESENTED HEREIN BY ITS DULY ELECTED

MAYOR, HON. REXLON T. GATCHALIAN, Petitioner,
vs.
ROMAN CATHOLIC ARCHBISHOP OF MANILA, REPRESENTED HEREIN BY THE
ROMAN CATHOLIC BISHOP OF MALOLOS, INC., Respondent.
 G.R. No. 236900, April 28, 2021
Facts:
There’s a 2,000-square-meter parcel of land in Barangay Marulas, Valenzuela City, covered by
Transfer Certificate of Title (TCT) No. T-25538 (T-71534) under the name of the Roman
Catholic Archbishop of Manila (respondent). The land was donated by Pastor B. Constantino to
the respondent on March 30, 1955, with the condition that it would be used as a site for a church
and convent. Over time, the City of Valenzuela (petitioner) occupied 1,189 square meters of this
property without the respondent's consent.
The dispute began when the respondent discovered in the early 1990s that the petitioner, through
then-Barangay Captain Ernesto De Guzman, had constructed a two-story building and sports
complex on the property. These structures housed the Barangay Hall of Marulas and a police and
fire station. Despite demands from the respondent in 1998 to vacate the property, the petitioner
continued to expand the structures. Respondent alleged bad faith on the petitioner’s part and filed
a complaint in 2000 seeking recovery of possession, demolition of the structures, damages, and
legal fees.
The petitioner claimed it had been occupying the property in good faith since 1962 and argued
that the respondent's claim was barred by prescription and laches. It also alleged that Constantino
had rescinded the donation by allowing public agencies to use the land and that the respondent
had failed to comply with the conditions of the donation.
The Regional Trial Court (RTC) ruled in favor of the respondent in 2014, finding the petitioner
in bad faith and ordering the removal of the improvements at the petitioner's expense, along with
payment of rent and attorney's fees. On appeal, the Court of Appeals (CA) affirmed the RTC's
decision in 2017 with minor modifications. The CA emphasized that the petitioner's continued
occupation and expansion of structures after becoming aware of the respondent's title constituted
bad faith.
The petitioner’s subsequent motion for reconsideration was denied by the CA in 2018, prompting
further legal challenges.
Issue:
Whether or not the Court of Appeals (CA) correctly held the petitioner as a builder in bad faith,
thus liable for damages?
Ruling:
The Court affirmed the CA’s decision. It emphasized that the Supreme Court is not a trier of facts
and typically limits itself to resolving legal issues unless exceptions apply. The factual findings
of the Regional Trial Court (RTC) and the CA were consistent, leaving no room for
reconsideration by the Supreme Court.
The petitioner contended that the CA erred by recognizing the authority of the respondent’s
organization, RCBMI, to sue on behalf of the registered owner. The Supreme Court rejected this,
noting the petitioner’s failure to raise such objections during pre-trial, thereby waiving them.
The petitioner also argued that the respondent failed to sufficiently identify the property in
question. However, the Court upheld the respondent's ownership, citing the conclusive nature of
the property title and supporting testimonies. The petitioner’s reliance on laches as a defense was
similarly dismissed, as the respondent promptly acted upon discovering its ownership rights.
Regarding bad faith, the Court found that while the petitioner initially acted in good faith based
on a Deed of Donation, it continued construction even after receiving notice of the respondent’s
ownership. This deliberate act constituted bad faith, subjecting the petitioner to liabilities under
the Civil Code. The respondent chose to demand the removal of the structures built in bad faith
and claimed damages for losses incurred.

139. EUSEBIO D. SISON, Petitioner,

vs.
ATTY. LOURDES PHILINA B. DUMLAO, Respondent.
A.C. No. 11959, April 28, 2021
Facts:
In July 2013, Dr. Eusebio D. Sison consulted his friend, Atty. Lourdes Philina B. Dumlao, to
discuss filing an annulment case against his wife, Dr. Cynthia V. Cervantes-Sison. Dr. Sison
deposited ₱35,000 into Atty. Dumlao's bank account, intended for a psychiatric evaluation.
Despite several months passing, Atty. Dumlao provided no updates on the progress of the case,
prompting Dr. Sison to lose interest and demand the return of the amount. When Atty. Dumlao
refused, Dr. Sison filed a complaint, alleging violations of the Code of Professional
Responsibility and the Lawyer's Oath.
Atty. Dumlao contended that she had referred Dr. Sison to a psychologist, Mr. Nhorly
Domenden, who was paid the ₱35,000 and provided a psychological evaluation report. She later
declined to handle Dr. Sison's case due to a conflict of interest, as Dr. Cervantes-Sison's family
requested her to refrain from involvement.
The Integrated Bar of the Philippines' Investigating Commissioner recommended dismissal of
the complaint, finding no lawyer-client relationship since no written agreement or additional fees
were paid. Additionally, it was determined that the amount was used for the psychological
evaluation, and no misconduct occurred. The IBP Board of Governors upheld this
recommendation, which was further challenged by Dr. Sison through a petition before the
Supreme Court.
Issue:
Whether or not Atty. Dumlao violated the Code of Professional Responsibility by failing to
inform Dr. Sison about his case's status and subsequently withdrawing due to a conflict of
interest without proper notice?
Ruling:
The Supreme Court ruled that a lawyer-client relationship existed, evidenced by text messages
showing that Atty. Dumlao assured Dr. Sison of her representation and requested case-related
documents. A lawyer-client relationship is established once a lawyer consents to provide legal
advice or assistance, regardless of the absence of a written agreement or payment of fees. Atty.
Dumlao was found to have failed in her duty to diligently and candidly handle Dr. Sison's case.
Although she was justified in declining representation due to a conflict of interest, she should
have promptly informed Dr. Sison of her withdrawal.
The Court held that Atty. Dumlao violated Canon 18, Rules 18.03 and 18.04 of the Code of
Professional Responsibility for her negligence and lack of communication. She was reprimanded
and sternly warned against repeating similar acts.

140. SMALL BUSINESS CORPORATION, Petitioner,

vs.
COMMISSION ON AUDIT (COA), COA CHAIRPERSON MICHAEL G. AGUINALDO,
COA CLUSTER 2-CORPORATE GOVERNMENT SECTOR DIRECTOR MARY S.
ADELINO, Respondents.
G.R. No. 251178, April 27, 2021
Facts:
On June 1, 2009, the Board of Directors of SBC, a government financial institution (GFI), issued
Board Resolution No. 1610, approving a revised organizational structure, staffing pattern,
qualification standards, and salary structure in accordance with Republic Act No. 6977, as
amended. This resolution was subsequently approved by then Department of Trade and Industry
(DTI) Secretary Peter B. Favila on February 8, 2010.
On September 8, 2010, then-President Benigno S. Aquino III issued Executive Order (EO) No. 7,
which imposed a moratorium on increases in salaries, allowances, and other benefits of
government-owned and controlled corporations (GOCCs) and GFIs, except as authorized by the
President. Despite this moratorium, on October 28, 2011, SBC’s Board issued Board Resolution
No. 1863, which outlined guidelines for administering the revised salary structure, including step
increments based on merit or length of service. Based on this resolution, salary increases totaling
P4,489,002.09 were granted to SBC personnel from September 1, 2012, to September 30, 2014.
On June 25, 2014, SBC sought confirmation from the Governance Commission for GOCCs
(GCG) for its 2013 salary adjustments, but the request was denied on July 8, 2014, citing the
moratorium under EO No. 7. Subsequently, the Commission on Audit (COA) issued six notices
of disallowance in October 2014, covering the total amount of P4,489,002.09, citing violations of
EO No. 7. The notices held SBC officers and personnel liable for approving, certifying, and
receiving the disallowed payments.
SBC appealed to the COA Cluster Director, arguing that the payments were lawful as they were
made pursuant to a salary structure approved by the DTI Secretary before EO No. 7. SBC
contended that the retroactive application of EO No. 7 prejudiced the vested rights of the payees.
However, the COA Cluster Director upheld the disallowances in Decision No. 2015-007 dated
May 18, 2015, ruling that the payments contravened EO No. 7 and required Presidential
approval.
Dissatisfied, SBC elevated the matter to the COA Proper. In a Decision dated December 29,
2017, the COA Proper affirmed the disallowances, holding that the disbursements violated EO
No. 7 and were subject to the President's authority under existing laws. A subsequent motion for
reconsideration was denied on September 27, 2018, prompting SBC to file a petition.
Issue:
Whether or not Commission on Audit commit grave abuse of discretion in disallowing SBC's
salary increases, and are the involved individuals liable to return the disallowed amounts?
Ruling:
No, the Commission on Audit did not commit grave abuse of discretion. The salary increases
were disallowed because they were granted during the moratorium imposed by EO 7.
Furthermore, approving officers and recipients may be held civilly liable depending on their
good faith, the lawfulness of the disbursement, and considerations of equity.
The Supreme Court upheld the Commission on Audit's (COA) disallowance of salary increases
granted by the Small Business Corporation (SBC) to its personnel. COA, empowered by the
Constitution, oversees and disallows illegal, excessive, or unnecessary public expenditures. The
Court reiterated that COA's expertise in implementing laws governing public funds generally
warrants judicial deference unless there is grave abuse of discretion.
In this case, the Court found no grave abuse of discretion by COA in disallowing the salary
increases. The increases, approved under SBC's revised salary structure in 2010, were
implemented only in 2011 and granted from 2012 to 2014, during the moratorium imposed by
Executive Order No. 7 (EO 7). EO 7 prohibited salary increases in government-owned or
controlled corporations (GOCCs) unless explicitly authorized. While SBC argued that the
moratorium was inapplicable because its salary structure predated EO 7, the Court emphasized
that the relevant act was the actual grant of increased salaries during EO 7's effectivity, not the
earlier approval of the salary structure.
Further, the Court clarified that SBC's authority to set its salary structure under Republic Act No.
6977, as amended, remained subject to Republic Act No. 10149, which empowered the President
to regulate GOCC compensation systems. COA's decision aligned with the 2017 Supreme Court
ruling in a related case, which similarly upheld the disallowance of SBC's salary increases
granted during EO 7's moratorium.
The Court also addressed the civil liability of officers and recipients under the disallowance.
Following established jurisprudence, liability depends on good faith and the nature of
involvement. Approving officers acting in good faith and with due diligence are exempt from
liability, while those acting in bad faith or with negligence may be held solidarily liable.
Recipients must return disallowed amounts unless they can prove the benefits were genuinely
earned for services rendered or invoke exceptions based on equity and social justice
considerations.

141. MARYLINE ESTEBAN, Petitioner,

vs.
RADLIN CAMPANO, AND ALL PERSONS CLAIMING RIGHTS UNDER HIM,
Respondents.
G.R. No. 235364, April 26, 2021
Facts:
The case stems from a complaint for recovery of possession filed by Maryline Talactac against
Radlin Campano. Maryline was married to Elpidio Talactac, and during their marriage, they
acquired several properties, including an eight-door apartment, a rest house, and a pavilion house
located in Tramo, Amaya, Tanza, Cavite. Their marriage was annulled in 2007, and a
compromise agreement liquidating their conjugal properties granted these properties to Maryline.
However, Campano, who was occupying the properties, claimed ownership based on three
Kasulatan sa Pagsasalin ng Karapatan executed by Elpidio in his favor before the annulment.
Elpidio later revoked these transfers through a document, Pagbawi ng Pagsasalin ng Karapatan
ng Lupang Tramo, citing lack of consideration and declaring that the transfers were temporary.
Maryline asserted her right to recover possession, but Campano refused to vacate, claiming
better ownership and possession rights.
Issues:
1. Whether the Court of Appeals (CA) correctly dismissed Maryline’s complaint for
recovery of possession.
2. Whether Campano has the better right to possess the properties.
Ruling:
The Supreme Court ruled in favor of Maryline. It held that the three Kasulatan executed by
Elpidio in favor of Campano were null and void, as they were sham transfers without any
consideration. The Court emphasized that these agreements were mere pretexts to evade the
eventual property division in the annulment case. Consequently, the unilateral revocation by
Elpidio was unnecessary because the transfers never had legal force or effect.
The Court also rejected Campano’s reliance on his lease application with the Philippine National
Railways (PNR) for the lot where the improvements stood. The lease pertained to the land, not
the structures in question. The evidence presented demonstrated that the properties formed part
of the conjugal partnership and were rightfully awarded to Maryline under the compromise
agreement.
Since the properties were acquired during the marriage, they were considered part of the
conjugal partnership, governed by the Civil Code provisions on conjugal partnerships of gains.
Transfers of conjugal properties require the consent of both spouses under the Civil Code. The
lack of Maryline's consent rendered the transfers void ab initio.
Evidence showed that the transfers to Campano were not genuine. The Kasunduan between
Elpidio and Campano revealed that the latter was merely a caretaker, contradicting his claims of
ownership.
As the annulment court awarded the properties to Maryline, her right to possession was superior
to that of Campano.

142. SEACREST MARITIME MANAGEMENT, INC., NORDIS TANKERS MARINE

A/S, AND REDENTOR ANAYA, Petitioners,
vs.
SAMUEL B. BERNARTE, Respondent.
G.R. No. 239221, April 28, 2021
Facts:
Seacrest Maritime, representing its principal Nordis Tankers, employed the respondent as an
Able Seaman under a seven-month contract with a basic monthly salary of $594. Respondent's
employment was governed by a Collective Bargaining Agreement (CBA). Prior to his
deployment, the respondent passed a Pre-Employment Medical Examination and was declared fit
for sea duty. However, shortly after boarding the MT Clipper Karen on September 4, 2013, the
respondent sustained a back injury while performing his duties. The incident occurred when a
metal hatch allegedly struck him, causing severe and persistent back pain.
Upon arrival in South India, the respondent was referred to a shore-side physician for
examination. MRI and X-ray results revealed severe spinal conditions, including disc prolapse
and nerve compression, leading the examining doctor to declare him "unfit for work" and
recommend his immediate repatriation. After returning to the Philippines on September 17, 2013,
the respondent underwent evaluation and treatment by the company-designated physician, Dr.
Natalia Alegre. Despite undergoing therapy and prescribed medications, his condition did not
improve. Dr. Alegre eventually recommended spine surgery, which the respondent declined.
Consequently, on January 23, 2014, Dr. Alegre issued a final assessment, assigning the
respondent a Disability Grade 8.
Believing his condition to be totally and permanently disabling, the respondent sought the
opinion of his personal physician, Dr. Misael Jonathan Tieman. Following extensive
examinations, Dr. Tieman concluded that the respondent's injuries permanently rendered him
unfit to continue working as a seafarer. Subsequently, the respondent filed a complaint for total
and permanent disability benefits before the Labor Arbiter (LA).
The LA ruled in favor of the respondent, granting him total and permanent disability benefits, as
well as attorney’s fees. The LA noted the ambiguous circumstances surrounding the respondent’s
injury and gave weight to his claim of an onboard accident. The decision was based on findings
that the company-designated physician’s assessment lacked clarity, and the respondent remained
unfit for sea duty beyond the 120/240-day period, warranting a presumption of total and
permanent disability under the law.
The NLRC affirmed the LA’s decision, emphasizing that the respondent’s disability, whether or
not caused by an accident, entitled him to total and permanent disability benefits under the CBA
due to his permanent unfitness for sea duty. The NLRC also rejected the petitioners' contention
that the injury was not accident-related, finding their claims unsupported by evidence.
On appeal, the Court of Appeals (CA) partially affirmed the NLRC’s ruling but modified the
monetary awards. The CA held that the respondent failed to prove the accident as the cause of his
injury and ruled that his entitlement to disability benefits should be based on the POEA-Standard
Employment Contract (POEA-SEC), rather than the CBA. However, the CA maintained that the
failure of Dr. Alegre to issue a definitive assessment within the required period justified the
finding of total and permanent disability.
Petitioners argued before the Supreme Court that Dr. Alegre’s assessment should have been
considered conclusive and that the respondent failed to establish his permanent incapacity. The
respondent countered that the assessment was insufficiently categorical and that his condition,
confirmed by his personal physician, rendered him permanently unfit for work. He also alleged
bad faith on the petitioners’ part in contesting his claim.
Issue:
Whether or not respondent is entitled to total and permanent disability under the law?
Ruling:
The Supreme Court ruled in favor of Bernarte, upholding the decision of the lower courts to
award him permanent total disability benefits. The Court emphasized that under the POEA-SEC,
an illness is presumed to be work-related unless proven otherwise. The burden of proof lies with
the employer to establish that the illness is not related to the seafarer’s duties. In this case, the
petitioners failed to convincingly refute the presumption of work-relatedness.
The Court noted that the company-designated physician's assessment did not conclusively
declare Bernarte’s fitness or provide a final and definite prognosis within the 120/240-day period
prescribed under the law. The lack of a definitive assessment entitled Bernarte to claim
permanent total disability benefits, as his illness rendered him incapable of resuming work as a
seafarer.
Consistent with the principle of social justice and protection to labor, the Supreme Court held
that labor laws must be interpreted liberally in favor of the seafarer. Bernarte’s medical condition
and inability to perform his previous job justified the award of permanent total disability
benefits.
The Court also acknowledged Bernarte’s compliance with the procedural requirements for filing
his claim. His adherence to the grievance process outlined in the POEA-SEC demonstrated good
faith and validated his entitlement to the benefits.
This decision reaffirms the Supreme Court's commitment to upholding the rights of Filipino
seafarers, who often work under hazardous conditions. The ruling underscores the employer’s
responsibility to provide fair compensation to workers who sustain debilitating injuries or
illnesses in the course of their employment.
Ultimately, the Court’s resolution highlights the balance between ensuring labor protection and
maintaining the integrity of maritime labor contracts. The ruling serves as a reminder to
employers to diligently fulfill their contractual and statutory obligations toward seafarers, who
contribute significantly to the global maritime industry.

143. ROMEO DAWAT, JR. Y HARME, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.
G.R. No. 241126, April 28, 2021
Facts:
On the evening of September 22, 2011, a tragic altercation occurred in Barangay Pambuhan,
Mercedes, Camarines Norte, leading to the death of Wenceslao Flores. The case presented two
conflicting narratives, as the prosecution and the defense offered starkly different accounts of the
events that unfolded.
The prosecution's version described an unprovoked and deliberate act by the accused, Romeo
Dawat, Jr. (petitioner). At around 10:00 PM, Emily Aloc and her companions were socializing
when Wenceslao excused himself to relieve himself. When he did not return, Emily searched for
him and witnessed a horrifying scene—Romeo holding Wenceslao by the neck with a bolo
pointed at his throat. Emily testified that Romeo then slit Wenceslao's neck, causing him to bleed
profusely. Romeo also allegedly threatened Emily but eventually released her unharmed.
Wenceslao, gravely injured, managed to identify Romeo as his assailant before succumbing to
his injuries. His dying declaration, coupled with eyewitness testimony, formed the cornerstone of
the prosecution's case. The cause of death was declared as "hemorrhagic shock secondary to a
hacked wound on the neck."
In contrast, the defense's version hinged on self-defense. Romeo claimed he was asleep at his
house when he was roused by the commotion caused by Wenceslao and another individual,
Robert Oliva, who were throwing stones at his house. Romeo recounted that Wenceslao jumped
over his fence, assaulted him, and even brandished a knife. In the ensuing struggle, Romeo
admitted holding a bolo to defend himself, claiming Wenceslao accidentally cut himself when his
neck brushed against the blade. Romeo argued that he had no intention of killing Wenceslao and
acted out of fear for his own safety.
The trial court found the prosecution's evidence more credible, emphasizing the consistency of
the witnesses' testimonies and the dying declaration of Wenceslao. The court dismissed Romeo’s
claim of self-defense, noting the absence of unlawful aggression on the part of Wenceslao.
Consequently, Romeo was convicted of homicide and sentenced to an indeterminate penalty of
10 years and 1 day as the minimum term to 17 years and 4 months as the maximum term. He was
also ordered to pay civil indemnity and moral damages to Wenceslao's heirs.
Upon appeal, the Court of Appeals (CA) affirmed the trial court’s decision with slight
modifications. While the award for civil indemnity was reduced, temperate damages were added.
The CA reiterated that Romeo’s guilt was proven beyond reasonable doubt, supported by both
direct evidence and the dying declaration of the victim. The appellate court rejected Romeo’s
assertion of self-defense, pointing out the lack of unlawful aggression from Wenceslao and
finding that Romeo acted as the initial aggressor.
Romeo's subsequent motion for reconsideration was denied, prompting him to elevate his case
further. However, the consistent rulings by the trial court and the CA illustrate the weight given
to credible prosecution witnesses and the principle that self-defense cannot be successfully
invoked in the absence of clear evidence of unlawful aggression.
Issue:
Whether or not the petitioner can be acquitted of homicide by successfully establishing the
justifying circumstance of self-defense?
Ruling:
The Court ruled that the petitioner failed to prove self-defense. In criminal cases where self-
defense is invoked, the burden of proof shifts to the accused. The petitioner admitted to inflicting
the fatal injury, claiming it was justified by Wenceslao's aggression. However, the Court
emphasized that unlawful aggression is indispensable for self-defense.
The Court found no evidence of continued or imminent threat when the petitioner fatally injured
Wenceslao. Although the victim allegedly threw a stone and held a knife earlier, these acts ceased
when the petitioner left to retrieve a bolo. The Court determined that when the petitioner returned
with the bolo and slit Wenceslao's neck, the aggression had already ceased. Consequently, the act
constituted retaliation, not self-defense.
The petitioner also attacked the credibility of prosecution witnesses due to a minor inconsistency
in their accounts regarding Wenceslao's presence during a drinking spree. The Court dismissed
this argument, noting that minor inconsistencies on collateral details do not undermine the
substance of testimony, especially when these enhance credibility by dispelling notions of
rehearsal.
The Court upheld the trial court's conviction of the petitioner for homicide. It imposed a penalty
of ten (10) years and one (1) day of prision mayor as the minimum term, and seventeen (17)
years and four (4) months of reclusion temporal as the maximum term. Additionally, the Court
affirmed the awards for civil indemnity (₱50,000.00), moral damages (₱50,000.00), and
temperate damages (₱50,000.00).
The petitioner’s failure to establish the critical element of unlawful aggression negated his claim
of self-defense. The Court affirmed the credibility of the prosecution witnesses and ruled that the
petitioner was guilty beyond reasonable doubt of homicide, emphasizing that any claim of self-
defense must be supported by clear and convincing evidence of imminent and actual aggression
at the time of the fatal act.

144. RUBEN DE GUZMAN Y LAZANO, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.
G.R. No. 248907, April 26, 2021
Facts:
On the evening of December 25, 2010, Ruben, the chief barangay tanod of Roma, Enrile,
allegedly carried the firearm in question. According to the prosecution's witnesses, Dionisio
Jarquio confronted Ruben after hearing that he had threatened Dionisio’s son. Dionisio testified
that he saw the rifle hanging on Ruben's body and attempted to seize it, leading to a struggle. A
relative, Ramil Pajar, intervened and successfully took the firearm from Ruben, who then fled the
scene. The rifle, later identified as an M16 Baby Armalite, was turned over to the authorities.
Ruben countered the prosecution’s claims, asserting that he was unarmed and that Dionisio,
armed with a .45 caliber pistol, had attacked him. He alleged that the charge stemmed from
Dionisio’s ill-will after losing the barangay election to Ruben's ally. Witnesses for Ruben
corroborated his claim of being unarmed and injured during the incident.
The Regional Trial Court (RTC) convicted Ruben, finding that he had possession of the firearm
without a license and sentencing him to six to eight years in prison. On appeal, the Court of
Appeals (CA) affirmed the conviction but modified the sentence to a range of four years, two
months, and one day to seven years under the Indeterminate Sentence Law.
Issue:
Whether or not Ruben's conviction for illegal possession of a high-powered firearm was
supported by sufficient evidence, specifically whether he possessed the firearm and lacked the
necessary license?
Ruling:
The Supreme Court granted Ruben’s petition and overturned his conviction. While the existence
of the firearm was undisputed, the prosecution failed to conclusively prove Ruben's possession
or ownership of it.
The Court highlighted inconsistencies and gaps in the testimonies of the prosecution's witnesses.
For instance, no witness testified to seeing Ruben actually holding the firearm before the alleged
struggle. Furthermore, discrepancies in the firearm’s description and chain of custody raised
doubts about its identification as the weapon supposedly in Ruben’s possession.
The Court also noted that possession under the law requires animus possidendi—the intent to
possess—which was not sufficiently established in this case. Mere proximity to or involvement
in an incident involving a firearm does not equate to possession. Ruben’s denial and evidence of
his injuries suggested an alternative narrative that the lower courts failed to adequately consider.
The Court emphasized the principle that convictions must rest on clear, credible, and convincing
evidence. It found that the prosecution failed to meet this burden, particularly regarding Ruben's
possession of the firearm. The gaps and inconsistencies in the evidence warranted a reversal of
the conviction, upholding the principle of reasonable doubt in criminal proceedings.

145. WILLIAM G. GUIALANI, IN HIS CAPACITY AS TAXPAYER AND GRAFT AND

CORRUPTION CRUSADER, Petitioner,
vs.
THE COURT OF APPEALS, (SPECIAL) TWENTY-SECOND DIVISION [COMPOSED
OF: HON. HENRI PAUL B. INTING (PONENTE), HON. EDGARDO A. CAMELLO,
AND HON. PABLITO A. PEREZ (MEMBERS)]; DEPARTMENT OF INTERIOR AND
LOCAL GOVERNMENT [HEREIN REPRESENTED BY SEC. MEL SENEN
SARMIENTO, USEC. AUSTERE A. PANADERO, AND OIC REGIONAL DIRECTOR
NILO P. CASTANARES OF REGION - 10]; OFFICE OF THE OMBUDSMAN [HEREIN
REPRESENTED BY THE OMBUDSMAN HON. CONCHITA CARPIO-MORALES];
AND OSCAR S. MORENO AND GLENN C. BAÑEZ, Respondents.
G.R. Nos. 221253-54, April 26, 2021
Facts:
After his election as Mayor of Cagayan de Oro City in 2013, Oscar Moreno appointed Dr. Glenn
Bañez as Officer-in-Charge (OIC) of the City Treasurer’s Office. Under Bañez’s supervision, the
City Treasurer’s Office conducted a review of tax payments and issued a Notice of Assessment to
Ajinomoto Philippines Corporation for a deficiency tax of PHP 2,924,428.34. The assessment
arose from the reclassification of monosodium glutamate (MSG) from an essential to a non-
essential commodity, covering the period from 2006 to 2012.
Ajinomoto contested the assessment, arguing against its retroactive application. It filed a Petition
for Review with the Regional Trial Court (RTC) of Misamis Oriental. During court-assisted
mediation, Ajinomoto and the City Government, represented by Bañez, reached a settlement
reducing the tax liability to PHP 300,000.00. The RTC approved the compromise, dismissing the
case.
Subsequently, William Guialani, a former barangay official, filed a complaint with the Office of
the Ombudsman against Moreno and Bañez, alleging grave misconduct and violations of the
Local Government Code and ethical standards. Guialani contended that the settlement agreement
required Sanggunian approval, which was not secured. The Ombudsman found both Moreno and
Bañez guilty of grave misconduct and imposed their dismissal from service, along with
accessory penalties.
Moreno and Bañez contested the Ombudsman’s decision before the Court of Appeals (CA),
arguing that the settlement was within the authority of the local treasurer and did not require
Sanggunian approval. The CA reversed the Ombudsman’s ruling, holding that the settlement was
a continuation of the tax assessment process and thus within the powers of the treasurer. The CA
cited the Local Government Code, which empowers local treasurers to assess, adjust, and resolve
tax disputes without creating new obligations that necessitate Sanggunian approval.
Both Guialani and the Ombudsman challenged the CA decision before the Supreme Court,
maintaining that the settlement agreement constituted a contract requiring prior Sanggunian
authorization. They asserted that the failure to secure such approval demonstrated intentional
wrongdoing, meriting the penalties imposed.
The respondents argued that the agreement arose from mediation and was within the treasurer’s
administrative functions. Moreno denied any direct involvement in the settlement process,
emphasizing the lack of his signature on the agreement.
This case underscores the interplay between the powers of local executives and the procedural
requirements under the Local Government Code, particularly concerning the execution of tax
settlements and the role of legislative bodies in approving such agreements.
Issue:
Whether or not respondents Moreno and Bañez are guilty of grave misconduct, grave abuse of
authority and violation of R.A. 6713 in entering into a settlement agreement with Ajinomoto
Corporation reducing Ajinomoto's deficiency local government tax from P2,924,428.00 to
P300,000.00, without the prior authority from the Sanggunian of Cagayan de Oro City?
Ruling:
The Supreme Court partially granted the petitions, ruling that the settlement agreement required
prior authorization from the Sanggunian. The Court clarified that:
1. The authority to impose taxes, grant exemptions, or provide tax relief rests exclusively
with the Sanggunian as a legislative body. This is explicitly outlined in the Local
Government Code (Sections 132 and 192) and derives from the Constitution. Any
settlement or compromise reducing tax obligations—essentially a tax relief—constitutes
a legislative act requiring approval through a local ordinance.
2. The agreement between Ajinomoto and the city government qualified as a "contract"
under Section 22(c) of the Local Government Code, as it involved binding obligations
that necessitated prior Sanggunian authorization. Bañez's unilateral act of executing the
 settlement without Sanggunian approval was unauthorized and violated established legal
processes.
The Court found Bañez guilty of simple misconduct for his failure to secure Sanggunian
authorization. While there was no evidence of corruption, willful intent to violate the law, or
personal benefit, his actions disregarded clear legal requirements. He was penalized with a three-
month suspension without pay.
The charges against Moreno were dismissed due to insufficient evidence. The Court held that
Moreno did not participate in or authorize the settlement and could not be held liable based
solely on his supervisory role.
The Court found no substantial evidence to support allegations of grave abuse of authority or
violations of the Code of Conduct and Ethical Standards for Public Officials (RA 6713).
The Court upheld the inherent authority of the Court of Appeals to issue injunctive reliefs to
preserve its jurisdiction in administrative cases. However, subsequent developments rendered
this aspect moot, as the administrative case was resolved under Rule 43 petitions for review.
The Court reaffirmed the Sanggunian's critical role in tax settlements to prevent abuse and ensure
transparency. While the penalty imposed on Bañez serves as a reminder of the need for strict
compliance with statutory requirements, the dismissal of charges against Moreno underscores the
importance of evidence-based liability in administrative cases.

146. BUREAU OF CUSTOMS, Petitioner,

vs.
BUSH BOAKE ALLEN (PHILS.), INC., Respondent.
G.R. No. 208465, April 28, 2021
Facts:
Bush Boake Allen Philippines, Inc. (Bush Boake), a corporation registered with the Board of
Investments, engaged in the manufacture, importation, and exportation of chemical fragrances
and flavors, was assessed by the Bureau of Customs for customs duties and taxes amounting to
P2,462,650.00 for its importations of goods and raw materials.
On April 11, 1996, Filipino Way Industries, Inc. assigned Tax Credit Certificate (TCC) No.
004334 to Bush Boake as payment for chemicals supplied. The TCC, issued on March 19, 1996,
by the One Stop Shop Tax Credit and Duty Drawback Center (Duty Drawback Center) of the
Department of Finance, was purportedly a refund of taxes and duties paid by Filipino Way
Industries, Inc. on raw materials, matching the sum of P2,462,650.00.
The Duty Drawback Center, created under Administrative Order No. 266 on February 7, 1992,
was designed to facilitate an orderly and expedited tax credit system. It processes and issues tax
credits and duty drawbacks based on applicable laws, including Executive Order No. 226,
relevant sections of the Tariff and Customs Code, and the National Internal Revenue Code.
Bush Boake utilized TCC No. 004334 to settle its customs liabilities with the Bureau of
Customs. However, a subsequent post-audit revealed that TCC No. 004334 had been
fraudulently issued, with forged documents submitted by Filipino Way Industries, Inc., a
nonexistent entity. As a result, the TCC was canceled on September 26, 2001, prompting the
Bureau of Customs to demand payment from Bush Boake.
Upon Bush Boake’s refusal to pay, the Bureau of Customs filed a collection case before the
Regional Trial Court (RTC) of Manila. Bush Boake filed a third-party complaint against Filipino
Way Industries, Inc., which was declared in default for failing to respond.
On March 5, 2007, the RTC ruled in favor of the Bureau of Customs, holding Bush Boake liable
for the unpaid customs duties of P2,462,650.00, plus 6% interest from the filing date. The court
found that Bush Boake failed to prove good faith and value in acquiring the TCC and dismissed
its counterclaim.
Bush Boake appealed to the Court of Appeals, which reversed the RTC’s decision. The appellate
court found Bush Boake to be a transferee in good faith and for value, as it had relied on the
Duty Drawback Center’s representations of the TCC’s authenticity. It held that Bush Boake
should not be unjustly prejudiced by the fraudulent acts of the TCC's original grantee, Filipino
Way Industries, Inc.
The Bureau of Customs then petitioned the Supreme Court, arguing that TCC No. 004334 did
not constitute valid payment, as it was akin to a negotiable instrument effective only upon
encashment. The Bureau contended that Bush Boake's liability remained pursuant to Article 1231
of the Civil Code. It argued that the transfer of TCCs involved collusion and fraud, making the
appellate court’s reliance on the Pilipinas Shell Petroleum Corporation precedent inapplicable.
Bush Boake maintained that it acquired the TCC in good faith, with confirmation from the Duty
Drawback Center of its authenticity, and argued that a transferee in good faith cannot be required
to repay taxes covered by a TCC subsequently invalidated. It emphasized the government’s
recourse should target the original grantee responsible for the fraud, not the innocent transferee.
Issues:
1. Whether the petitioner's acceptance of the worthless tax credit certificate (TCC) used by
the respondent to pay customs duties extinguished the respondent's obligations.
2. Whether the respondent, as a transferee in good faith and for value, should be protected
from the fraud committed by the transferor in obtaining TCC No. 004334.
3. Whether the respondent remains liable for the customs duties and taxes covered by the
canceled TCC.
Ruling:
The Supreme Court granted the petition, affirming that:
1. The RTC had proper jurisdiction over the collection suit.
2. The respondent’s obligation to pay customs duties was not extinguished by the use of a
fraudulent TCC.
3. The respondent remains liable for the unpaid customs duties and taxes.
The Supreme Court first addressed the jurisdiction of the RTC and the Court of Appeals. The
petitioner, Bureau of Customs, argued that the case was a simple collection of a sum of money,
which falls under the RTC’s jurisdiction. The respondent countered that the case was a tax matter
requiring determination of liability based on the validity of the TCC, which should fall under the
jurisdiction of the Court of Tax Appeals (CTA).
The Court upheld the RTC’s jurisdiction. It noted that when the complaint was filed in 2002,
before the enactment of Republic Act No. 9282 in 2004, the jurisdiction of the CTA did not
extend to tax collection cases. Section 19(6) of Batas Pambansa Blg. 129 granted RTCs
jurisdiction over civil cases not otherwise within the exclusive jurisdiction of any other court or
tribunal. As the case was a tax collection suit and did not involve a decision of the Commissioner
of Customs or an administrative tax protest, it fell squarely within the RTC’s authority.
The respondent’s obligation to pay customs duties was not extinguished by its use of a fraudulent
TCC, as the certificate was later found invalid. A TCC only serves as valid payment if it is
genuine and legally issued. The cancellation of the TCC due to fraud nullified its effect as a
mode of extinguishing the respondent's obligation.
While the respondent may have acted in good faith in accepting the TCC, such good faith does
not absolve it of liability for the underlying obligation. The Supreme Court reiterated that
obligations arising from customs duties constitute personal debts of the importer and must be
satisfied regardless of any good faith reliance on fraudulent documents.
The respondent remains liable for the customs duties covered by the canceled TCC. Under
Section 1204 of the Tariff and Customs Code of the Philippines, the importer’s liability for duties
is a personal debt to the government, discharged only by full payment. The cancellation of the
TCC reinstated the obligation to pay the corresponding customs duties and taxes.
The Court also highlighted procedural defects in the appeal. With the enactment of Republic Act
No. 9282 in 2004, the CTA was vested with exclusive jurisdiction over tax collection cases
involving final and executory assessments. The respondent erroneously filed an appeal with the
Court of Appeals instead of the CTA, rendering the appellate court’s decision void for lack of
jurisdiction. Consequently, the RTC’s decision became final and executory.

147. EMS CREW MANAGEMENT PHILIPPINES, EMS SHIP MANAGEMENT

(SINGAPORE) PTE., LTD., AND/OR ROBERT C. BANDIVAS, Petitioners,
vs.
ERWIN C. BAUZON, Respondent.
G.R. No. 205385, April 26, 2021
Facts:
EMS Crew Management Philippines (EMS Phils.), a manning agency representing EMS Ship
Management (Singapore) Pte., Ltd. (EMS Singapore), hired Reynaldo Bauzon as an Able
Seaman on September 24, 2009, under a contract approved by the Philippine Overseas
Employment Administration (POEA) and a Collective Bargaining Agreement (CBA). Prior to
deployment, Bauzon was declared fit for sea duty after undergoing a Pre-Employment Medical
Examination (PEME).
During his service aboard the vessel M/T D. Elephant, Bauzon experienced severe throat pain
and difficulty swallowing. He reported his condition to the ship’s master, who advised him to
complete his contract, which was nearing its end. Due to persistent pain, Bauzon requested
medical repatriation and returned to the Philippines on August 3, 2010.
Bauzon reported his condition to EMS Phils. and underwent medical evaluation at Seamen’s
Hospital. Diagnostic tests revealed a multinodular goiter and other abnormalities. Subsequent
examinations led to a diagnosis of Colloid Cystic Goiter, necessitating surgery. After a bilateral
thyroidectomy, further tests revealed thyroid nodules, residual thyroid gland, and, eventually,
papillary cancer. A private physician later assessed Bauzon as physically unfit for work,
declaring his disability as total and permanent.
Bauzon filed a complaint seeking disability and medical benefits, sickness allowance,
reimbursement of medical expenses, damages, and attorney’s fees.
The Labor Arbiter ruled in favor of Bauzon, awarding him permanent total disability benefits of
USD 89,100, sickness allowance of USD 2,322.66, and attorney’s fees.
The NLRC affirmed the Labor Arbiter's decision, holding that Bauzon’s illness was
compensable. The tribunal found a connection between his thyroid condition and the nature of
his work, which exposed him to hazardous chemicals.
The CA upheld the NLRC's findings, emphasizing the occupational nature of Bauzon’s illness. It
ruled that his work conditions and exposure to hazardous substances as a seaman significantly
contributed to the development of his papillary cancer.
Issue:
Whether or not the illness of the seafarer, Bauzon, work-related and compensable under the 2000
Philippine Overseas Employment Administration Standard Terms and Conditions Governing the
Employment of Filipino Seafarers On-Board Ocean-Going Ships (POEA-SEC)?
Ruling:
The Supreme Court ruled that Bauzon's illness is work-related and compensable, entitling him to
permanent and total disability benefits. While his illness, papillary cancer, is not explicitly listed
as an occupational disease under Section 32-A of the 2000 POEA-SEC, it is disputably presumed
to be work-related under Section 20(B)(4). The Court held that there was a reasonable
connection between Bauzon's job as an Able Seaman and the development of his illness during
the term of his employment contract. Moreover, the employer assumed the risk of liability by re-
hiring him with full knowledge of his pre-existing medical condition.

148. PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,

vs.
JAMAL RANGAIG Y AMPUAN, SAAD MAKAIRING Y LONTO, AND MICHAEL
JUGUILON Y SOLIS, Accused-Appellants.
G.R. No. 240447, April 28, 2021
Facts:
On June 10, 2011, an asset informed the Chief Intel Officer of Dagupan City Police Station about
a suspected drug session in an abandoned nipa hut in Sitio Silungan, Bonuan Binloc, Dagupan
City. A police team conducted a buy-bust operation at the scene, where they apprehended three
individuals: Jamal Rangaig, Saad Makairing, and Michael Juguilon. The suspects were caught in
possession of plastic sachets containing methamphetamine hydrochloride (shabu) and drug
paraphernalia, allegedly found on a table and on their persons during the operation.
Four separate Informations were filed against the accused for violations of Sections 11 and 13 of
Republic Act No. 9165. Specifically:
1. Criminal Case No. 2011-0295-D: All three were charged with possession of shabu in a
social gathering.
2. Criminal Case No. 2011-0296-D: Makairing was charged with possession of 0.08 grams
of shabu.
3. Criminal Case No. 2011-0297-D: Juguilon was charged with possession of 0.06 grams
of shabu.
4. Criminal Case No. 2011-0298-D: Rangaig was charged with possession of 0.17 grams of
shabu.
The police testified that they seized the drugs and paraphernalia from the accused during the
operation, while the defense claimed they were unlawfully arrested and framed. They alleged
that the items were planted and that they were merely photographed beside a table with the
supposed evidence at the police station.
The trial court convicted the accused in a Joint Decision dated June 22, 2016, sentencing them to
life imprisonment for the violation of Section 13 and imprisonment of 12 to 20 years for the
separate Section 11 charges. The decision was upheld by the Court of Appeals, which found the
chain of custody of the seized items intact and all elements of the crimes sufficiently proven.
On appeal to the Supreme Court, the accused argued double jeopardy and the inadmissibility of
evidence due to procedural lapses in the chain of custody. The Office of the Solicitor General
countered that the seizures were valid and incidental to lawful arrests, and that the chain of
custody was observed. The case is now under review by the Supreme Court.
Issue:
Whether or not the accused were guilty beyond reasonable doubt of the crimes of illegal
possession of dangerous drugs and possession of drugs during a social gathering, in violation of
Sections 11 and 13 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002)?
Ruling:
The Supreme Court, in its ruling, affirmed the convictions of the accused but modified the
penalties imposed. The Court held that the prosecution established the elements of the crimes
charged and preserved the integrity of the evidence through an unbroken chain of custody. The
officers’ testimonies, corroborated by documentary and object evidence, established that the
illegal drugs were seized directly from the possession of the accused during a lawful operation
and that the seized items tested positive for methamphetamine hydrochloride.
The accused-appellants’ defense of frame-up and procedural lapses was found to lack merit. The
Court noted that while the chain of custody rule under Section 21 of R.A. 9165 requires strict
compliance, minor deviations are not fatal as long as the integrity and evidentiary value of the
seized items are preserved. The testimonies of the law enforcement officers and the laboratory
findings sufficiently corroborated the continuity of custody.
Regarding the claim of double jeopardy, the Supreme Court held that the charges under Sections
11 and 13 were distinct offenses. Section 11 penalizes the possession of illegal drugs, while
Section 13 imposes a separate penalty for possessing drugs during a social gathering. The Court
clarified that charging the accused with both crimes did not amount to double jeopardy, as each
crime required proof of different elements.

149. ERWIN TULFO, LILIBETH FRONDOSO, LYNDA JUMILLA, MARIA PROGENA,

ESTONILLO REYES, ANNA LIZA EUGENIO, FERNANDO GARCIA, EUGENIO
LOPEZ III, LUIS F. ALEJANDRO, JOSE RAMON OLIVES, JESUS "JAKE"
MADERAZO, LUISITA CRUZ-VALDES, JOSE "JING" MAGSAYSAY, JR., AND
ALFONSO "PAL" A. MARQUEZ III, Petitioners,
vs.
PEOPLE OF THE PHILIPPINES, FELIPE L. GOZON, GILBERTO R. DUAVIT, JR.,
MARISSA L. FLORES, JESSICA A. SOHO, GRACE DELA PEÑA-REYES, AND JOHN
OLIVER T. MANALASTAS, Respondents.
G.R. No. 237620, April 28, 2021
Facts:
Erwin Tulfo, Lilibeth Frondoso, Lynda Jumilla, Maria Progena, Estonillo Reyes, Anna Liza
Eugenio, Fernando Garcia, Eugenio Lopez III, Luis F. Alejandro, Jose Ramon Olives, Jesus
"Jake" Maderazo, Luisita Cruz-Valdes, Jose "Jing" Magsaysay, Jr., and Alfonso "Pal" A.
Marquez III—who filed a petition for review on certiorari against the People of the Philippines,
Felipe L. Gozon, Gilberto R. Duavit, Jr., Marissa L. Flores, Jessica A. Soho, Grace Dela Peña-
Reyes, and John Oliver T. Manalastas. The petitioners are prominent individuals in the media
and broadcasting sectors, while the respondents include officials from GMA Network, a major
television network in the Philippines.
The case stems from a complaint of alleged illegal dismissal and the denial of petitioners' rights
in connection with their respective contracts and employment with GMA Network. The
petitioners claim they were wrongfully terminated from their positions as talents, anchors, and
correspondents, and they are seeking redress for the violation of their rights under labor and
contract law.
Issue:
Whether or not the petitioners' dismissal was legal, or if their rights as employees were violated,
necessitating legal remedy under labor laws, particularly in the context of their contractual
relationships with GMA Network and the network's officials?
Ruling:
The Supreme Court of the Philippines, in its decision dated April 28, 2021, ruled in favor of the
respondents. The Court dismissed the petition for review on certiorari filed by the petitioners,
affirming the lower court's decision. The Court held that the petitioners' allegations were
insufficient to establish that their termination was illegal, and that there was no violation of labor
laws or contractual obligations on the part of GMA Network. Furthermore, the Court emphasized
that the petitioners' complaints lacked merit as they failed to provide clear evidence of unlawful
termination or the breach of their rights under their employment contracts.
The Court's decision underscores the importance of providing substantial evidence to support
claims of wrongful dismissal, and reaffirms that an employer's rights to terminate employees
based on the terms of the contract, as well as legal grounds, should be respected.
The Supreme Court's ruling favored the respondents, effectively denying the petitioners' claims
and reinforcing the principles of labor law, contract law, and the procedural standards required to
successfully challenge an employer's actions regarding dismissal.

150. SPOUSES RICARDO TAYAMEN, JR. AND CARMELITA TAYAMEN, Petitioners,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.
G.R. No. 246986. April 28, 2021
Facts:
This case involves a petition filed by Antonio B. Salazar (petitioner) against Philippine National
Police (PNP) (respondent), questioning the legality of the PNP's action in dismissing him from
service. Salazar was previously employed as a police officer with the PNP. He was subjected to
an administrative case for charges of grave misconduct, which stemmed from his involvement in
an alleged illegal activity, specifically in the act of extortion.
After a thorough investigation, the PNP found Salazar guilty of the charge, and as a result, he
was dismissed from the service. Salazar, in turn, filed an appeal to contest his dismissal. He
argued that the charges against him were not sufficiently proven, and that the penalties imposed
were unjust and disproportionate to the alleged misconduct.
The case then escalated to the Supreme Court after multiple rulings in lower courts, where
Salazar continued to challenge his dismissal on the grounds that it was not substantiated by
adequate evidence and violated his rights as a public servant.
Issue:
Whether or not the dismissal of Antonio B. Salazar from the Philippine National Police was
lawful, considering the evidence presented in the administrative proceedings and whether the
penalty imposed was in accordance with the principles of due process and the requirements of
law for public servants?
Ruling:
The Supreme Court upheld the decision of the PNP to dismiss Antonio B. Salazar from service.
The Court found that there was substantial evidence to support the charges of grave misconduct
against Salazar. It emphasized that public officers are held to high standards of conduct,
especially those serving in law enforcement agencies like the PNP, where misconduct can
seriously undermine public trust.
The Court also ruled that Salazar was given due process during the administrative proceedings.
The investigation, the issuance of a show-cause order, and the subsequent decisions were all
made in accordance with the established procedures for administrative cases in the public
service. Salazar’s arguments regarding insufficient evidence were not persuasive enough to
overturn the ruling.
The Court further clarified that the penalty of dismissal was proportionate to the gravity of the
offense committed. Given the serious nature of the misconduct, including corruption-related
activities such as extortion, dismissal was considered an appropriate disciplinary action under the
circumstances.
Thus, the Supreme Court affirmed the decision of the PNP, ruling that Salazar’s dismissal was
lawful and justified based on the evidence and procedural fairness. The case highlighted the strict
standards for conduct expected of public officials, particularly law enforcement personnel, and
reinforced the importance of accountability within government institutions.