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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
October-2008 Jurisprudence                 

  • A.C. No. 1481 - REBECCA B. ARNOBIT v. ATTY. PONCIANO P. ARNOBIT

  • ADM. CASE No. 4495 - ANTONIO DE ZUZUARREGUI, JR. v. ATTY. APOLONIA A. C. SOGUILON

  • A.C. No. 6972 - JERRY T. WONG v. ATTY. SALVADOR N. MOYA II

  • ADM. CASE NO. 7091 - JOFEL LEGASPI v. ATTYS. RAMON LANDRITO AND MAGNO TORIBIO

  • A.C. No. 7505 - Walter Wilkie v. Atty. Sinarnar E. Limos

  • A.M. No. 06-12-720-RTC - Re: DISAPPROVAL OF THE PERMANENT APPOINTMENT OF MR. GODOFREDO C. DE LEON, as Clerk III, Regional Trial Court, Branch 40, Manila by the Civil Service Commission.

  • A.M. No. 08-8-11-CA - LETTER OF PRESIDING JUSTICE CONRADO M. VASQUEZ, JR., RE: CA-G.R. SP NO. 103692

  • A.M. No. 08-1982-MTJ - DANIEL P. ALMADEN, JR. v. HON. VICTORIO L. GALAPON, JR., Presiding Judge, Municipal Trial Court, Dulag, Leyte

  • A.M. No. MTJ-03-1499 Formerly A.M. OCA IPI No. 02-1310-MTJ and A.M. NO. P-03-1752 : October 6, 2008 Formerly A.M. OCA IPI No. 03-1595-P - CELFRED P. FLORES v. JUDGE RODOLFO B. GARCIA

  • A.M. No. MTJ-08-1721 Formerly A.M. No. IPI-03-1464-MTJ - MICHAEL GAMALIEL PLATA v. JUDGE LIZABETH G. TORRES

  • A.M. No. P-02-1666 Formerly A.M. OCA IPI No. 02-1294-P - JUDGE TRANQUILINO V. RAMOS v. RODRIGO C. BICAD

  • A. M. NO. P-05-1998 Formerly OCA IPI No. 04-1879-P - MAYOR NICASIO M. RAMOS v. CYRIL T. MAYOR, Clerk III, Metropolitan Trial Court, Branch 13, Manila

  • A.M. No. P-06-2165 Formerly OCA I.P.I. No. 05-2220-P - DOLORES MOLINA, ET AL. v. ATTY. GITANJALI BONDOC, ETC.

  • A.M. No. P-06-2249 - JUDGE PLACIDO C. MARQUEZ and ATTY. LYN L. LLAMASARES v. LUCILA C. PACARIEM, Stenographer, Regional Trial Court, Branch 23, Manila

  • A.M. No. P-06-2273 Formerly OCA-I.P.I. No. 06-2435-P - JUDGE REBECCA R. MARIANO v. MARISSA R. MONDALA, Court Legal Researcher II, Regional Trial Court, Branch 136 REYES, Makati City

  • A.M. No. P-07-2402 Formerly OCA I.P.I. No. 07-2591-P - ATTY. REDENTOR S. VIAJE v. ROLANDO A. DIZON

  • A.M. No. P-08-2451 Formerly OCA IPI No. 05-2201-P - ROEL A. FERNANDEZ v. RENATO RUBILLOS, PROCESS SERVER, MUNICIPAL TRIAL COURT, ALBUERA, LEYTE

  • A.M. No. P-08-2552 Formerly OCA I.P.I. No. -06-2370-P - ROBERTO C. PASCUAL v. MARILYN M. MARTIN, Clerk of Court III, Municipal Trial Court in Cities, Branch 1, Tarlac City

  • A.M. No. RTJ-07-2034 - ATTY. NENITA CENIZA-LAYESE v. JUDGE ENRIQUE C. ASIS

  • A.M. No. RTJ-07-2050 Formerly OCA I.P.I. No. 07-2563-P - SPOUSES ARLEEN and LORNA OLIVEROS v. HON. DIONISIO C. SISON, Acting Presiding Judge, Regional Trial Court, Branch 74, Antipolo City

  • A.M. No. RTJ-07-2074 Formerly A.M. No. 07-5-18-SC - OFFICE OF THE COURT ADMINISTRATOR v. RET. JUDGE IRENEO LEE GAKO, JR., Branch Clerk of Court MANUEL G. NOLLORA, Legal Researcher NILDA D. SUYKO, Clerk of Court VII CHICO-NAZARIO, ATTY. JEOFFREY S. JOAQUIN

  • G.R. No. 121833, G.R. NO. 130752 and G.R. NO. 137801 - ABOITIZ SHIPPING CORPORATION v. COURT OF APPEALS, MALAYAN INSURANCE COMPANY, INC., COMPAGNIE MARITIME DES CHARGEURS REUNIS, and F.E. ZUELLIG (M), INC.

  • G.R. No. 133347 - ABS-CBN BROADCASTING CORPORATION, ET AL. v. OFFICE OF THE OMBUDSMAN, ET AL.

  • G.R. No. 141854 - ORLANDO APOSTOL v. COURT OF APPEALS, ET AL.

  • G.R. No. 135808 - SECURITIES AND EXCHANGE COMMISSION v. INTERPORT RESOURCES CORPORATION, ET AL.

  • G.R. No. 143786 - SPOUSES LOURDES V. RUTAQUIO and LEONARDO LIWANAG, and JULIAN VILLAFLOR, represented by his children, ESTER V. PUJALTE, FILIPINA VILLAFLOR MARIA GEMMA VILLAFLOR and REY CONSTANTINO VILLAFLOR v. COURT OF APPEALS, MAURA PENAMORA, and MODEST

  • G.R. No. 146141 - ERNESTO CANADA, doing business under the name and style of HI-BALL FREIGHT SERVICES v. ALL COMMODITIES MARKETING CORPORATION

  • G.R. No. 147423 - TIRSO Z. OPORTO v. MEMBERS OF THE BOARD OF INQUIRY AND DISCIPLINE OF NATIONAL POWER CORPORATION, ETC.

  • G.R. No. 148133 - HERITAGE PARK MANAGEMENT CORPORATION v. CONSTRUCTION INDUSTRY ARBITRATION COMMISSION and ELPIDIO UY, doing business under name and style of EDISON DEVELOPMENT AND CONSTRUCTION

  • G.R. No. 150180 - FLAVIO S. SUAREZ, JR., RENATO A. DE ASIS, FRANCISCO G. ADORABLE, JOVEN ANDALOC, ONOFRE G. BAGAYO, GENITO J. BANGGO, WENDELINO L. BERONDO, NAPOLEON P. BULOS, ISIDRO S. DADANG, TEODORO P. DOTARO, NOIDA T. DUNGOG, EROLITO A. EDROZO, ROBERTO

  • G.R. No. 150746 - SIMEON NICOLAS CHAN, ET AL. v. YOLANDA CHAN, ET AL.

  • G.R. No. 151309 - BISIG MANGGAGAWA SA TRYCO, ET AL. v. NATIONAL LABOR RELATIONS COMMISSION, ET AL.

  • G.R. No. 153624 - JUDGE ADORACION G. ANGELES v. P/INSP. JOHN A. MAMAUAG, SPO2 EUGENE ALMARIO, SPO4 ERLINDA GARCIA and SPO1 VIVIAN FELIPE

  • G.R. No. 154301 - CARLOS MANANGAN v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 154379 - PCI TRAVEL CORPORATION v. NATIONAL LABOR RELATIONS COMMISSION (3rd Division) & NUBE - AMEXPEA/PCI TRAVEL EMPLOYEES UNION

  • G.R. No. 155758 - Heirs of Jose Esplana etc. v. The CA & Heirs of Pedro De Lima Represented by Jaime De Lima

  • G.R. No. 155813 - CECILIA S. BALDUEZA, ETC. v. HON. CA, ET AL.

  • G.R. No. 156850 - NATIONAL HOUSING AUTHORITY v. PERICO V. JAO, representing the estate of the late Spouses ANDREA and IGNACIO JAO TAYAG

  • G.R. No. 156882 - Banco De Oro-Epci, Inc. v. Hon. Zenaida R. Daguna etc. & Phil. Devt. & International Corp.

  • G.R. No. 156962 - VICTORIAS MILLING CO., INC. v. LUIS J. PADILLA, ET AL.

  • G.R. No. 157542 - REBECCA A. BARBO, ET AL. v. COMMISSION ON AUDIT

  • G.R. No. 157592 - PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT v. SANDIGANBAYAN (Second Division) and RODOLFO ARAMBULO (deceased), substituted by Ronald L. Arambulo

  • G.R. No. 157680 - EQUIPMENT TECHNICAL SERVICES or JOSEPH JAMES DEQUITO v. COURT OF APPEALS, ALEX ALBINO, REY ALBINO, JULIUS ABANES, MIGUEL ALINAB, CHRISTOPHER BIOL, NELSON CATONG, RENATO DULOT, FLORO PACUNDO, MARCELITO GAMAS, REYNALDO LIMA, SAMMY MESAGAL,

  • G.R. No. 157707 - Marcial Fajardo v. Hon. CA, et al.

  • G.R. No. 158997 - FORT BONIFACIO DEVELOPMENT CORPORATION v. YLLAS LENDING CORPORATION, ET AL.

  • G.R. No. 160240 - Woodridge School (Now Known as Woodridge College Inc) v. Joanne C. Pe Benito, et al.

  • G.R. No. 160338 - VENTIS MARITIME CORPORATION, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 160541 - RONELO POLO v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 161219 - MARINDUQUE MINING AND INDUSTRIAL CORPORATION, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 163515 - Isidro T.Pajarillaga v. CA, et al.

  • G.R. No. 164052 - ANONAS CONSTRUCTION AND INDUSTRIAL SUPPLY CORPORATION, and ELISEO F. LIBUNAO v. NATIONAL LABOR RELATIONS COMMISSION and LARRY NAFUAR

  • G.R. No. 164326 - SEAOIL PETROLEUM CORPORATION v. AUTOCORP GROUP and PAUL Y. RODRIGUEZ

  • G.R. No. 164632 - Urethane Trading Specialist Inc v. Edwin Ong & Leticia Ong

  • G.R. No. 164964 - NATIONAL POWER CORPORATION v. MARIA BAGUI, VEDASTO BAGUI, FELICIANA BAGUI, EPIFANIA BAGUI, HEIRS OF MARGARITO MACARAIG and WIFE, represented by Dolores Macaraig, NIEVES VALDEZ and JAIME MARQUEZ

  • G.R. No. 165389 - NFD International Manning Agents and A/S VULCANUS OSLO VS NATIONAL LABOR RELATIONS COMMISSION, JOSE I. ILAGAN, JR. and CONSTANTINO CO, JR.

  • G.R. No. 165550 - STANDARD CHARTERED BANK v. STANDARD CHARTERED BANK EMPLOYEES UNION (SCBEU)

  • G.R. No. 165622 - MERCURY DRUG CORPORATION and AURMELA GANZON v. RAUL DE LEON

  • G.R. No. 166408 - TORBEN B. OVERGAARD v. ATTY. GODWIN R. VALDEZ

  • G.R. No. 166502 - FRANCISCO DE GUZMAN v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 166756 - REPUBLIC OF THE PHILIPPINES v. KATRINA ISABEL SAMSON YULO

  • G.R. No. 167215 - REPUBLIC OF THE PHILIPPINES v. HEIRS OF EVARISTO TIOTIOEN

  • G.R. No. 167500 - K-PHIL., INC., SOO MYUNG PARK and NETWORK DEVELOPMENT HOLDING CORP. v. METROPOLITAN BANK & TRUST COMPANY, REGALADO E. EUSEBIO, in his capacity as Clerk of Court VI and Ex-Officio Sheriff, and REYNALDO R. CAMERINO, in his capacity as Sher

  • G.R. No. 167627 - AGUSAN DEL NORTE ELECTRIC COOPERATIVE, INC., ET AL. v. JOEL CAGAMPANG, ET AL.

  • G.R. No. 167707 and G.R. NO. 173775 - THE SECRETARY OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, THE REGIONAL EXECUTIVE DIRECTOR, DENR-REGION VI, REGIONAL TECHNICAL DIRECTOR FOR LANDS, LANDS MANAGEMENT BUREAU, REGION VI PROVINCIAL ENVIRONMENT A

  • G.R. No. 167711 - THE OFFICE OF THE OMBUDSMAN v. RAMON C. GALICIA

  • G.R. No. 168081 - ARMANDO G. YRASUEGUI v. PHILIPPINE AIRLINES, INC.

  • G.R. No. 168166 - PEOPLE OF THE PHILIPPINES v. SALVADOR C. DACO

  • G.R. No. 168299 Formerly G.R. NOS. 156927-29 - PEOPLE OF THE PHILIPPINES v. LUIS AYCARDO

  • G.R. No. 168339 - MA. GREGORIETTA LEILA C. SY v. ALC INDUSTRIES, INC., ET AL.

  • G.R. No. 168394 - AGRARIAN REFORM BENEFICIARIES ASSOCIATION, ETC. v. LORETO G. NICOLAS, ET AL.

  • G.R. No. 168448 - PEOPLE OF THE PHILIPPINES v. FAJARDO NAPUDO

  • G.R. No. 168782 - SPOUSES JOVENAL TORING and CECILIA ESCALONA-TORING v. SPOUSES ROSALIE GANZON-OLAN and GILBERT OLAN, and ROWENA OLAN

  • G.R. No. 169576 - LEONIDES MERCADO, represented by his heirs: Racquel D. Mercado, Jimmy D. Mercado, Henry D. Mercado, Louricar D. Mercado and Virgilio D. Mercado v. COURT OF APPEALS and SAN MIGUEL CORPORATION

  • G.R. No. 170585 - DAVID C. LAO, ET AL. v. DIONISIO C. LAO

  • G.R. No. 170625 - BANK OF THE PHILIPPINE ISLANDS v. COURT OF APPEALS and TF KO DEVELOPMENT CORPORATION

  • G.R. No. 171008 - CARMELITA FUDOT v. CATTLEYLA LAND, INC.

  • G.R. No. 171036 - ADELA G. RAYMUNDO, EDGARDO R. RAYMUNDO, LOURDES R. RAYMUNDO, TERESITA N. RAYMUNDO, EVELYN R. SANTOS, ZENAIDA N. RAYMUNDO, LUIS N. RAYMUNDO, JR. and LUCITA R. DELOS REYES v. ERNESTO LUNARIA, ROSALINDA RAMOS and HELEN MENDOZA

  • G.R. No. 171089 - PEOPLE OF THE PHILIPPINES v. ROGELIO PASCUAL

  • G.R. No. 171452 - PEOPLE OF THE PHILIPPINES v. RICARDO SANTOS

  • G.R. No. 171790 - BRENDO D. MERIN v. NATIONAL LABOR RELATIONS COMMISSION, THROUGH ITS THIRD DIVISION, GREAT SOUTHERN MARITIME SERVICES, CORP., AND/OR IMC SHIPPING CO., PTE., LTD.

  • G.R. No. 172053 - UNION BANK OF THE PHILIPPINES v. PACIFIC EQUIPMENT CORPORATION, ET AL.

  • G.R. No. 172370 - PEOPLE OF THE PHILIPPINES v. FLORENDA CASTRO, ET AL.

  • G.R. No. 172426 - AIR TRANSPORTATION OFFICE v. HONORABLE COURT OF APPEALS (EIGHTEENTH DIVISION) and BERNIE G. MIAQUE

  • G.R. No. 172468 - PEOPLE OF THE PHILIPPINES v. JULIE VILLACORTA GIL (A. K. A. Julie Villasorca Gil)

  • G. R. No. 172800 - MARCIANO L. MASANGCAY v. TRANS-GLOBAL MARITIME AGENCY, INC. AND VENTNOR NAVIGATION, INC.

  • G.R. No. 172901 - American Express International Inc. v. Hon. Judge Marlene Gonzales Sison etc & Maria Teresa Fernando

  • A.C. No. noxxxxx - JESUS E. VERGARA v. HAMMONIA MARITIME SERVICES, INC., ET AL.

  • G.R. No. 173454 and G.R. NO. 173456 - PHILIPPINE NATIONAL BANK v. MEGA PRIME REALTY AND HOLDINGS CORPORATION

  • G.R. No. 174154 - JESUS CUENCO v. TALISAY TOURIST SPORTS COMPLEX, INCORPORATED AND MATIAS B. AZNAR III

  • G.R. No. 174224 - MARCIAL APARECE v. J. MARKETING CORPORATION and/or ROGER L. AGUILLON

  • G.R. No. 174536 - Roberto Y. Ponciano, Jr. v. CA, et al.

  • G.R. No. 174971 - LAND BANK OF THE PHILIPPINES v. AMS FARMING CORPORATION

  • G.R. No. 175162 - Atty. Ernesto A. Tabujara III, et al. v. People of the Phil. and Daisy Afable

  • G.R. No. 175176 - NATIONAL POWER CORPORATION v. SANTA LORO VDA. DE CAPIN and SPS. JULITO QUIMCO and GLORIA CAPIN

  • G.R. No. 175587 - Philippine Commercial International Bank v. Joseph Anthony M. Alejandro

  • G.R. No. 175692 - Angel Ubales Y Velez v. People of the Philippines

  • G.R. No. 175725 - NATIONAL POWER CORPORATION v. ANGEL SUAREZ, CARLOS SUAREZ, MARIA THERESA SUAREZ, AND ROSARIO SUAREZ

  • G.R. No. 175832 - PEOPLE OF THE PHILIPPINES v. SALVADOR SANCHEZ y ESPIRITU

  • G.R. No. 176240 - ROLANDO SASAN, SR., LEONILO DAYDAY, MODESTO AGUIRRE, ALEJANDRO ARDIMER, ELEUTERIO SACIL, WILFREDO JUEGOS, PETRONILO CARCEDO and CESAR PACIENCIA v. NATIONAL LABOR RELATIONS COMMISSION 4TH DIVISION, EQUITABLE-PCI BANK and HELPMATE, INC.

  • G.R. No. 176637 - PEOPLE OF THE PHILIPPINES v. REYNALDO DELA TORRE

  • G.R. No. 176706 - MANIGO K. RAMOS v. SPOUSES PURITA G. ALVENDIA and OSCAR ALVENDIA and SPOUSES JOSE and ARACELI SEVERINO

  • G.R. No. 176724 - MAYOR KENNEDY B. BASMALA v. COMMISSION ON ELECTIONS, ET AL.

  • G.R. No. 176943 - DANILO ALUAD, LEONORA ALUAD, DIVINA ALUAD, PROSPERO ALUAD, and CONNIE ALUAD v. ZENAIDO ALUAD

  • G.R. No. 177135 - ARTURO O. RADAZA, JULITO H. CUIZON, FERNANDO T. TAGA-AN, JR., and ROGELIO D. VELOSO v. THE HONORABLE COURT OF APPEALS, SPECIAL NINETEENTH (19th) DIVISION, OMBUDSMAN MERCEDITAS GUTIERREZ, DEPUTY OMBUDSMAN VIRGINIA PALANCA - SANTIAGO, DEPA

  • G.R. No. 177222 - PEOPLE OF THE PHILIPPINES v. RANILO DE LA CRUZ Y LIZING

  • G.R. No. 177237 - WILLIAM CHING v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 177348 - SPOUSES RAMON PATRON and LUZVIMINDA PATRON v. UNION BANK OF THE PHILIPPINES, THE INTERNATIONAL CORPORATE BANK, and THE QUEDAN AND RURAL CREDIT GUARANTEE CORPORATION

  • G.R. No. 177563 - PEOPLE OF THE PHILIPPINES v. DIOSDADO BALOBALO

  • G.R. No. 177564 - ARTURO REVITA "ALIAS" ARTHUR v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 177598 - ROBERT SAN PEDRO v. WILLY ONG and NORMITA CABALLES

  • G.R. No. 177580 - OFFICE OF THE OMBUDSMAN v. VICTORIO N. MEDRANO

  • G.R. No. 177647 - U-BIX CORPORATION and EDILBERTO B. BRAVO v. VALERIE ANNE H. HOLLERO

  • G.R. No. 177736 - MELANIE P. MONTUERTO v. HON. MAYOR ROLANDO E. TY, ET AL.

  • G.R. No. 177775 - PEOPLE OF THE PHILIPPINES v. ISAIAS DIZON

  • G.R. No. 177825 - PEOPLE OF THE PHILIPPINES v. RENE ROSAS

  • G.R. No. 177982 - FITNESS BY DESIGN, INC. v. COMMISSIONER ON INTERNAL REVENUE

  • G.R. No. 178024 - LAWRENCE B. WACNANG v. COMMISSION ON ELECTIONS and FLOYDELIA R. DIASEN

  • G.R. No. 178271 - Banco De Oro-Epci, Inc. v. Hon. Zenaida R. Daguna etc. & Phil. Devt. & International Corp.

  • G.R. No. 178405 - REYNALDO DEUS Y SANTOS v. PEOPLE OF THE PHILIPPINES

  • G.R. No. 178443 - SPOUSES LORENZO H.LABAYEN, ET AL. v. LEONARDO. SERAFICA

  • G.R. No. 178449 - METROPOLITAN BANK AND TRUST COMPANY v. SPOUSES ELISA TAN AND ANTONIO TAN and SPOUSES LILIAN TAN AND MARCIAL SEE

  • G.R. No. 180451 - PEOPLE OF THE PHILIPPINES v. SPO1 ARNULFO A. AURE and SPO1 MARLON H. FEROL

  • G.R. No. 180512 - PEOPLE OF THE PHILIPPINES v. NOEL CUASAY

  • G.R. No. 181043 - THE PEOPLE OF THE PHILIPPINES v. MILLANO MUIT, SERGIO PANCHO, JR., EDUARDO HERMANO ALIAS "BOBBY REYES," ROLANDO DEQUILLO, ROMEO PANCHO, and JOSEPH FERRAER

  • G.R. No. 180906 - THE SECRETARY OF NATIONAL DEFENSE, ET AL. v. RAYMOND MANALO, ET AL.

  • G.R. No. 181545 - THE PEOPLE OF THE PHILIPPINES v. MARK DELA CRUZ

  • G.R. No. 182084 - LIBRADO M. CABRERA v. THE COMMISSION ON ELECTIONS, ET AL.

  • G.R. No. 182192 - PEOPLE OF THE PHILIPPINES v. AGRIPINO GUEVARRA y MULINGTAPANG alias "BOY DUNGGOL

  • G.R. No. 182232 - PEOPLE OF THE PHILIPPINES v. NENITA B. HU

  • G.R. No. 182347 - PEOPLE OF THE PHILIPPINES v. EMILIO RIVERA y CABLANG alias 'BOY'

  • G.R. No. 182421 - UCPB GENERAL INSURANCE CORPORATION v. OWNER OF M/V 'SARINDERJIT' BLUE RIVE NAVIGATION

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - AZCUNA - SEPARATE OPINION

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - BRION - CONCURRING AND DISSENTING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. NO. 183591, G.R. NO. 183752, G.R. NO. 183893, G.R. NO. 183951 and G.R. NO. 183962 - THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - CARPIO - SEPARATE CONCURRING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - NACHURA - DISSENTING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - YNARES-SANTIAGO - SEPARATE CONCURRING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - TINGA - SEPARATE OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - CHICO-NAZARIO - SEPARATE OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - VELASCO, JR. - DISSENTING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - PUNO - SEPARATE CONCURRING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. NOS. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - REYES - SEPARATE OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183591 - G.R. NOS. 183591, 183572, 183893, 183951 and 183962 - LEONARDO-DE CASTRO - SEPARATE CONCURRING AND DISSENTING OPINION : THE PROVINCE OF COTOBATO v. THE GOV'T OF THE REPUBLIC OF THE PHILIPPINES, ET AL.

  • G.R. No. 183696 - People of the Philippines v. Nelson Arraz

  • G.R. No. 184182 - PEOPLE OF THE PHILIPPINES v. ALFREDO M. PAPA

  • G.R. No. L-26112 / G.R. No. L-30240 - REPUBLIC OF THE PHILIPPINES, ET AL. v. HON. JAIME DELOS ANGELES, ET AL.

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    G.R. No. 177348 - SPOUSES RAMON PATRON and LUZVIMINDA PATRON v. UNION BANK OF THE PHILIPPINES, THE INTERNATIONAL CORPORATE BANK, and THE QUEDAN AND RURAL CREDIT GUARANTEE CORPORATION

      G.R. No. 177348 - SPOUSES RAMON PATRON and LUZVIMINDA PATRON v. UNION BANK OF THE PHILIPPINES, THE INTERNATIONAL CORPORATE BANK, and THE QUEDAN AND RURAL CREDIT GUARANTEE CORPORATION

    PHILIPPINE SUPREME COURT DECISIONS

    SECOND DIVISION

    [G.R. NO. 177348 : October 17, 2008]

    SPOUSES RAMON PATRON and LUZVIMINDA PATRON, Petitioners, v. UNION BANK OF THE PHILIPPINES, THE INTERNATIONAL CORPORATE BANK, and THE QUEDAN AND RURAL CREDIT GUARANTEE CORPORATION, Respondents.

    D E C I S I O N

    CARPIO MORALES, J.:

    The Spouses Ramon and Luzviminda Patron (petitioners), doing business under the name Ala Golden Grains Rice Mill, obtained on September 9, 1988 a P2,000,000 quedan loan from respondent International Corporate Bank (Interbank) which was guaranteed by respondent Quedan and Rural Credit Guarantee Corporation (Quedancor).1

    Upon the maturity of the loan on March 8, 1989, it was renewed, to mature on September 4, 1989.2 On the maturity of the loan on September 4, 1989, it was again renewed, to mature on March 3, 1990.3

    In the meantime or on September 6, 1989, petitioners obtained an additional P1,500,000 loan from Interbank which was to mature on March 5, 1990.4

    On March 1, 1990, petitioners again obtained an additional P1,500,000 loan and renewed their outstanding loans which had amounted to P3,500,000. Petitioners' total P5,000,000 loans were consolidated and covered by Promissory Note No. AGL90-0011 which was to mature on August 28, 1990.5 The consolidated loans covered by this promissory note were renewed several times including that made on February 10, 1993 when Promissory Note No. AGL93-0004 was accomplished, to mature on August 9, 1993.6

    On or before August 9, 1993, petitioners applied for the renewal of the loan covered thereby. Petitioners accomplished Promissory Note No. AGL93-0022 for P4,900,000 (the remaining balance after some payments were made), to mature on February 4, 1994.7

    In the meantime, Interbank8 was merged with respondent Union Bank of the Philippines (UBP).

    On September 14, 1994, on UBP's demand, guarantor Quedancor paid P3,771,348.89. UBP thereafter demanded, by letter of September 30, 1994,9 from petitioners the payment of the balance of their loan computed to be P2,645,889.84,10 but they failed to heed the same.

    Petitioners subsequently filed in November 1994 a complaint against respondents before the Regional Trial Court (RTC) of Iloilo City, for Cancellation of Documents, Declaration of Nullity, Injunction, and Damages. The complaint was docketed as Civil Case No. 22072.11

    Petitioners claimed that in August 1993, they applied for the renewal of their quedan loan for P4,900,000, and after they had submitted the requirements therefor including the duly accomplished Promissory Note No. AGL93-0022, Interbank informed them that it (Interbank) had already been acquired by UBP which stopped, disapproved, and/or cancelled all quedan loan applications; and that Interbank advised them that the documents bearing on their said August 1993 application for renewal of loan would be returned but they never received them, hence, they were surprised to receive a demand for payment of a P4,900,000 loan. They thus prayed as follows:

    A. Declaring as null and void and without legal effect the Quedan Loan application and its supporting papers, especially the promissory note and quedans as proposed collateral therefor, submitted by plaintiffs to defendant Interbank in August 1993;

    b. Declaring the plaintiffs not liable for any and all obligations arising from the said loan application and its supporting documents, which was in fact stopped, disapproved and/or cancelled by defendant banks, and whose proceeds plaintiffs never received;

    c. Directing the defendant banks to restore to plaintiffs the sum of P500,000.00 defendant Interbank appropriated for itself, with interest at the current inter-bank [sic] rate computed from date of said appropriation until full payment thereof to plaintiffs;

    d. Ordering the defendants, jointly and severally, to pay plaintiffs the sum of at least P500,000.00 as moral damages, P300,000.00 as
    attorney's fees, P50,000.00 as expenses of litigation, exemplary damages in such this Honorable Court may deed just and proper, and

    e. The costs of this litigation.12 (Underscoring supplied)cralawlibrary

    UBP thereafter also filed a complaint on December 12, 1994 against petitioners before the RTC of Iloilo City, for collection of the remaining P2,645,889.84 unpaid balance of their loan, plus interests, expenses of litigation, and attorney's fees. The complaint was docketed as Civil Case No. 22105.13

    Both cases were consolidated.14

    UBP presented testimonial evidence that whenever petitioners renewed their loan on maturity, the proceeds of the renewed loan were applied to the maturing loan, hence, no actual cash was released to them.15

    By Decision of March 23, 200416 rendered in both cases, Branch 36 of the Iloilo City RTC, answering in the affirmative the issue of whether there was a valid existing loan between petitioners and Interbank (before it was merged with UBP) which matured on August 9, 1993, rendered judgment in favor of respondents, disposing as follows:

    WHEREFORE, judgment is hereby rendered as follows:

    1. Dismissing the complaint of plaintiffs in Civil Case No. 22072 and their counter-claim in Civil Case No. 22105;

    2. Dismissing the counter-claim of defendant QUEDANCOR in Civil Case No. 22105;

    3. Declaring that Spouses Luzviminda Patron and Ramon Patron have a loan obligation with the Interbank (now Union Bank) in the amount of P2,645,889.84;

    4. Ordering Spouses Luzviminda and Ramon Patron to pay Union Bank the sum of P2,645.889.84 plus 12% interest per annum computed from September 14, 1994 until the same is fully paid.

    SO ORDERED.17 (Underscoring supplied)cralawlibrary

    On appeal, the Court of Appeals, by Decision of September 11, 2006,18 affirmed the RTC decision with modification on the rate of interest on petitioners' obligation, it noting as follows:

    From a perusal of the facts as established and the record of the case, it must be pointed out that the interest stipulated by the parties with regard to PN No. AGL93-0022 [sic] dated August 9, 1993 is 16.5% per annum. However, in the computation of the Spouses Patron's liability for the period August 9, 1993 until September 30, 1994, as evidenced by Union Bank's statement of account as of September 30, 1994, the said bank applied an interest rate of 24% per annum.19 (Emphasis in the original; underscoring supplied)

    The Court notes that the appellate court, in affirming the decision of the trial court, erred in basing petitioners' liability on Promissory Note No. AGL93-0022 which was accomplished by them in support of their application for renewal of their loan covered by Promissory Note No. AGL-93-0004, but which application for renewal was disapproved.

    The Court of Appeals disposed:

    WHEREFORE, in view of the foregoing premises, judgment is hereby rendered by us DISMISSING the appeal filed in this case and AFFIRMING with MODIFICATION the decision dated March 23, 2004 of the Regional Trial Court, Branch 36, in Iloilo City Cases Nos. 22072 and 22105, such that the interest rate to be applied on PN No. AGL93-0022 for the period August 9, 1993 until September 30, 1994 is 16.5% per annum instead of 24% per annum.

    SO ORDERED.20 (Underscoring supplied)cralawlibrary

    Petitioners' Motion for Reconsideration21 having been denied,22 they filed the present Petition for Review on Certiorari23 faulting the appellate court in:

    (a) . . . ignor[ing] the fact that respondent Union Bank has admitted in their pleadings and through their witnesses that the previous loan of the petitioners with the former Interbank were all paid and the [proceeds] of [the subject] Promissory Note No. AGL93-0022 were not released to petitioners;

    (b) . . . holding that the loans of petitioners with respondent Union Bank, guaranteed by QUEDANCOR were consolidated into a single loan and has been renewed for several times, despite the fact that the loan of appellants covered by PN No. AGL93-0022 in the amount of P4.9 Million is separate and distinct from the previous loan, considering that in QUEDAN LOAN, previous loan must be paid before new loan may be released, thus a borrower must borrow money from the outside sources and pay the quedan loan before his loan is renewed;

    (c) . . . ignor[ing] the fact that admission made in pleadings or trial or other proceedings need not be proved and are binding upon the parties making them who are not allowed to contradict them unless they may show clearly that the admissions were made thru palpable mistake;

    (d) . . . not declaring as null and void and without legal effect and canceling PN No. AGL93-0022 despite the fact that the loan of the petitioners with respondent bank was not released to them by the said bank;

    (e) . . . not ordering respondent Union Bank to restore to appellants the amount of Php500,000.00 with interest at the current rate, despite the fact that appellants have no obligation to pay the appellee bank[.]24 (Underscoring and emphasis in the original; italics supplied)

    The petition fails.

    That petitioners' application for renewal of loan was disapproved does not mean that they had been absolved from their obligation which matured on August 9, 1993, subject of Promissory Note No. AGL93-0004. Thus respondent UBP's witness Jonathan de Paz explained:

    x    x    x

    ATTY. SALAS: x x x When you say this was not internally approved this loan application for which Exhibit "O" [-Promissory Note No. AGL93-0022] was signed did not materialize because it was not approved, is that correct?cralawred

    WITNESS' ANSWER: The renewal did not materialize but however as I have said there was already a loan BEFORE it started [in] year 19[89] then it accumulated up to 5 million there was a payment of P100,000 prior to this promissory note. HOWEVER, AT THE TIME THAT WE HAVE THIS APPROVED, THE RENEWAL . . . WAS DISAPPROVED BUT IT DOESN T MEAN THAT THEY DON T HAVE AN EXISTING LOAN.

    ATTY. SALAS: I m not asking about the existing loan. I m asking you about this promissory note because the loan for which the promissory note, Exhibit "O" was not approved necessarily no money came out of that disapproved loan?cralawred

    WITNESS' ANSWER: There is no really money out of this because it is just a payment. As I have said before this is just a renewal in reality there's an exchange of paper. The matured promissory note will be given to them in exchange of the signed promissory note, this one. Actually there was no money out because what has been money
    out it was to be dated back to the original promissory note
    , the first PN 198[9] and some succeeding increase[s] of the renewal which in total is amounted to P5 million then there was a payment of P100,000.00.

    COURT: But you are now very clear that Exhibit "O" which is a renewal of a promissory note marked as Exhibit "L" was not approved?cralawred

    WITNESS' ANSWER: Internally, your Honor.

    COURT: What do you mean by that?cralawred

    WITNESS' ANSWER: The common parlance of the bank if a loan is disapproved and if it is a renewal then our duty now is to collect. It means to say that this renewal has not been approved to them so we are duty bound to collect this one as it is matured already.25 (Emphasis, capitalization and underscoring supplied)

    Petitioner Ramon Patron's letter to UBP dated January 31, 1994 appealing for a condonation and/or reduction of the penalty charges of 2% per annum on the promissory note for P4,900,000 which matured on August 9, 1993 and requesting a restructuring of said loan,26 as well as petitioners' counsel's letter to UBP dated January 10, 1994 seeking clarification on "x x x why [Ramon Patron] should be liable for this additional 2% a month beginning August 9, 1993, when the note falls due only on February 4, 1994,"27 should dissipate any doubts on, and unquestionably reflect the admission by petitioners of, their liability to respondent UBP.

    Thus, petitioners' obligation under Promissory Note No. AGL93-0004 to UBP stands. However, a recomputation of the amount which they owe UBP is in order.

    As earlier mentioned, the Court of Appeals erred in basing petitioners' liability on Promissory Note No. AGL93-0022 which was accomplished by them in support of the August 1993 application for renewal of loan but which was disapproved. Petitioners' liability should be based on Promissory Note No. AGL93-0004, which stipulates an interest of 23% per annum, and that "interest not paid when due shall be added to and constitute a part of the principal and likewise bear interest at the same rate."28 This Court finds such interest rate unconscionable, however, and reduces it to 12% per annum.29 The monthly penalty charge of 2% of the amount due and demandable is, likewise, under the circumstances attendant to this case, unconscionable, considering that partial payments had been made on the principal.30 Thus, in Palmares v. Court of Appeals,31 this Court, citing its earlier minute resolution of May 16, 1994 in G.R. No. 112614, eliminated the penalty charge altogether on the ground that:

    Upon the matter of penalty interest, we agree with the Court of Appeals that the economic impact of the penalty interest of three (3%) per month of the total amount due but unpaid should be equitably reduced. The purpose for which the penalty interest is intended - that is, to punish the obligor - will have been sufficiently served by the effects of compounded interest. Under the exceptional circumstances in the case at bar x x x the penalty stipulated in the parties' promissory note is iniquitious and unconscionable and may be equitably reduced further by eliminating such penalty interest altogether.32

    The penalty charge of 2% per month should thus be eliminated. Petitioners' liability stands then at P1,634,464.44. Following Eastern Shipping Lines, Inc. v. Court of Appeals,33 this amount shall earn 12% interest per annum from the time of extrajudicial demand on September 30, 1994 until it is fully paid.

    In view of the stipulation in Promissory Note No. AGL93-0004 providing for the payment of attorney's fees equivalent to 10% of the amount due and demandable, this Court awards P163,446.44 to UBP as attorney's fees.

    WHEREFORE, the Decision of the Court of Appeals dated September 11, 2006 is AFFIRMED with MODIFICATION. The interest rate in Promissory Note No. AGL93-0004 is reduced to 12% per annum, and the penalty charge is deleted, thus fixing the liability of the petitioner-spouses Ramon and Luzviminda Patron at P1,634,464.44 to bear interest of 12% per annum from the time of extrajudicial demand on September 30, 1994 until it is fully paid. In addition, the petitioner-spouses are ordered to pay P163,446.44 as attorney's fees.

    Costs against petitioners.

    SO ORDERED.

    Endnotes:


    1 Exhibit "B," records of Civil Case No. 22072, p. 298.

    2 Exhibit "C," id. at 299; TSN, June 28, 2002, pp. 15-18.

    3 Exhibit "D," id. at 300; id. at 18-21.

    4 Exhibit "E," id. at 301; id. at 22-25.

    5 Exhibit "F," id. at 302; id. at 25-28.

    6 Exhibits "G" - "N," id. at 303-310.

    7 Exhibit "O," id. at 311.

    8 Exhibit "A," id. at 295-297.

    9 Exhibit "R," id. at 314-315.

    10 Ibid.

    11 Id. at 1-8.

    12 Id. at 7.

    13 Records of Civil Case No. 22105, pp. 1-5.

    14 Records of Civil Case No. 22072, pp. 151-152.

    15 TSN, June 28, 2002, pp. 23, 26; TSN, May 8, 2003, p. 64.

    16 Records of Civil Case No. 22105, pp. 557-581; records of Civil Case No. 22072, pp. 423-447.

    17 Records of Civil Case No. 22105, p. 581.

    18 CA rollo, pp. 177-179. Penned by Justice Isaias P. Dican, with the concurrence of Associate Justices Romeo F. Barza and Priscilla Baltazar-Padilla.

    19 Id. at 177.

    20 Id. at 178-179.

    21 Id. at 180-192.

    22 Id. at 200-203.

    23 Rollo, pp. 9-28.

    24 Id. at 17-18.

    25 TSN, May 8, 2003, pp. 60-65.

    26 Exhibit "P," records of Civil Case No. 22072, p. 312.

    27 Referring to Promissory Note No. AGL93-0022 which would have covered the renewed loan but the application for which was disapproved. Exhibit "Q," id. at 313.

    28 Exhibit "N," id. at 310.

    29 Vide Trade & Investment Development Corporation v. Roblett Industrial Construction Corp., G.R. No. 139290, May 19, 2006, 490 SCRA 1, 7-8.

    30 Vide Civil Code, Article 1229.

    31 Palmares v. Court of Appeals, 351 Phil. 664 (1998).

    32 Id. at 690-691.

    33 G.R. No. 97412, July 12, 1994, 234 SCRA 78.

    G.R. No. 177348 - SPOUSES RAMON PATRON and LUZVIMINDA PATRON v. UNION BANK OF THE PHILIPPINES, THE INTERNATIONAL CORPORATE BANK, and THE QUEDAN AND RURAL CREDIT GUARANTEE CORPORATION


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