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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
 

   
August-2014 Jurisprudence                 

  • A.M. No. P-14-3222 (Formerly A.M. OCA IPI NO. 11-3609-P), August 12, 2014 - PRESIDING JUDGE JOSE B. LAGADO AND CLERK OF COURT II JOSEFINA C. EMPUESTO, BOTH OF THE MUNICIPAL TRIAL COURT, MAHAPLAG, LEYTE, Complainants, v. CLERK II BRYAN ANTONIO C. LEONIDO,, Respondent.

  • G.R. No. 204729, August 06, 2014 - LOURDES SUITES (CROWN HOTEL MANAGEMENT CORPORATION), Petitioner, v. NOEMI BINARAO,, Respondent.

  • G.R. No. 203775, August 05, 2014 - ASSOCIATION OF FLOOD VICTIMS AND JAIME AGUILAR HERNANDEZ, Petitioners, v. COMMISSION ON ELECTIONS, ALAY BUHAY COMMUNITY DEVELOPMENT FOUNDATION, INC., AND WESLIE TING GATCHALIAN,, Respondents.

  • G.R. No. 196117, August 13, 2014 - KRYSTLE REALTY DEVELOPMENT CORPORATION, REPRESENTED BY CHAIRMAN OF THE BOARD, WILLIAM C. CU, Petitioner, v. DOMINGO ALIBIN, AS SUBSTITUTED BY HIS HEIRS, NAMELY: BEATRIZ A. TORZAR, VIRGINIA A. TARAYA, ROSARIO A. MARCO, JESUS A. ALIBIN, AND JAY ALIBIN, AS SUBSTITUTED BY HIS CHILDREN, NAMELY: JAYNES ALIBIN, JAY ALIBIN, AND JESUS ALIBIN, JR., Respondents.; [G.R. NO. 196129] - CARIDAD RODRIGUEZA, AS SUBSTITUTED BY RUFINO RODRIGUEZA, Petitioner, v. DOMINGO ALIBIN, AS SUBSTITUTED BY HIS HEIRS, NAMELY: BEATRIZ A. TORZAR, VIRGINIA A. TARAYA, ROSARIO A. MARCO, JESUS A. ALIBIN, AND JAY ALIBIN, AS SUBSTITUTED BY HIS CHILDREN, NAMELY: JAYNES ALIBIN, JAY ALIBIN, AND JESUS ALIBIN, JR., Respondents.

  • A.C. No. 7766, August 05, 2014 - JOSE ALLAN TAN, Complainant, v. PEDRO S. DIAMANTE, Respondent.

  • A.C. No. 8000, August 05, 2014 - CHAMELYN A. AGOT, Complainant, v. ATTY. LUIS P. RIVERA, Respondent.

  • G.R. No. 171212, August 20, 2014 - INDOPHIL TEXTILE MILLS, INC., Petitioner, v. ENGR. SALVADOR ADVIENTO, Respondents.

  • G.R. No. 193681, August 06, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff, MALAYAN INSURANCE COMPANY, INC. AND HELEN Y. DEE, Private Complainants-Petitioners, v. PHILIP PICCIO, MIA GATMAYTAN, MA. ANNABELLA RELOVA SANTOS, JOHN JOSEPH GUTIERREZ, JOCELYN UPANO, JOSE DIZON, ROLANDO PAREJA, WONINA BONIFACIO, ELVIRA CRUZ, CORNELIO ZAFRA, VICENTE ORTUOSTE, VICTORIA GOMEZ JACINTO, JUVENCIO PERECHE, JR., RICARDO LORAYES, PETER SUCHIANCO, AND TRENNIE MONSOD,, Respondents.

  • G.R. No. 189629, August 06, 2014 - DR. PHYLIS C. RIO, Petitioner, v. COLEGIO DE STA. ROSA-MAKATI AND/OR SR. MARILYN B. GUSTILO, Respondents.

  • G.R. No. 193652, August 05, 2014 - INFANT JULIAN YUSAY CARAM, REPRESENTED BY HIS MOTHER, MA. CHRISTINA YUSAY CARAM, Petitioner, v. ATTY. MARIJOY D. SEGUI, ATTY. SALLY D. ESCUTIN, VILMA B. CABRERA, CELIA C. YANGCO, AND OFFICE OF THE SOLICITOR GENERAL, Respondents.

  • A.M. No. P-14-3232 (Formerly: A.M. No. 14-4-46-MTCC), August 12, 2014 - Re: REPORT OF JUDGE RODOLFO D. VAPOR, MUNICIPAL TRIAL COURT IN CITIES [MTCC], TANGUB CITY, MISAMIS OCCIDENTAL, ON THE HABITUAL ABSENTEEISM OF FILIGRIN E. VELEZ, JR., PROCESS SERVER, SAME COURT.

  • G.R. No. 200746, August 06, 2014 - BENSON INDUSTRIES EMPLOYEES UNION-ALU-TUCP AND/OR VILMA GENON, EDISA HORTELANO, LOURDES ARANAS, TONY FORMENTERA, RENEBOY LEYSON, MA. ALONA ACALDO, MA. CONCEPCION ABAO, TERESITA CALINAWAN, NICIFORO CABANSAG, STELLA BARONGO, MARILYN POTOT, WELMER ABANID, LORENZO ALIA, LINO PARADERO, DIOSDADO ANDALES, LUCENA ABESIA, AND ARMANDO YBAÑEZ, Petitioners, v. BENSON INDUSTRIES, INC., Respondent.

  • G.R. No. 204911, August 06, 2014 - THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. MIKE STEVE Y BASMAN AND RASHID MANGTOMA Y NONI, Accused-Appellants.

  • G.R. No. 201111, August 06, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ALFREDO CERDON Y SANCHEZ, Accused-Appellant.

  • G.R. No. 200250, August 06, 2014 - UPSI PROPERTY HOLDINGS, INC., Petitioner, v. DIESEL CONSTRUCTION CO., INC., Respondent.

  • G.R. No. 182908, August 06, 2014 - HEIRS OF FRANCISCO I. NARVASA, SR., ANDHEIRS OF PETRA IMBORNAL AND PEDRO FERRER,REPRESENTED BY THEIR ATTORNEY-IN-FACT, MRS. REMEDIOS B. NARVASA-REGACHO, Petitioners, v. EMILIANA, VICTORIANO, FELIPE, MATEO, RAYMUNDO, MARIA,AND EDUARDO, ALL SURNAMED IMBORNAL, Respondents.

  • G.R. No. 204651, August 06, 2014 - OUR HAUS REALTY DEVELOPMENT CORPORATION, Petitioner, v. ALEXANDER PARIAN, JAY C. ERINCO, ALEXANDER CANLAS, BERNARD TENEDERO AND JERRY SABULAO, Respondents.

  • G.R. No. 207376, August 06, 2014 - AIDA PADILLA, Petitioner, v. GLOBE ASIATIQUE REALTY HOLDINGS CORPORATION, FILMAL REALTY CORPORATION, DELFIN S. LEE AND DEXTER L. LEE, Respondents.

  • G.R. No. 201483, August 04, 2014 - CONRADO A. LIM, Petitioner, v. HMR PHILIPPINES, INC., TERESA SANTOS-CASTRO, HENRY BUNAG AND NELSON CAMILLER, Respondents.

  • G.R. No. 191015, August 06, 2014 - PEOPLE OF THE PHILIPPINES, Petitioner, v. JOSE C. GO, AIDA C. DELA ROSA, AND FELECITAS D. NECOMEDES, Respondents.

  • G.R. No. 210619, August 20, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. CHARLES REYES Y MARASIGAN, Accused-Appellant.

  • G.R. No. 184982, August 20, 2014 - LAND BANK OF THE PHILIPPINES, Petitioner, v. JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Respondents.; [G.R. NO. 185048] - JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Petitioners, v. LAND BANK OF THE PHILIPPINES, Respondent.

  • G.R. No. 170139, August 05, 2014 - SAMEER OVERSEAS PLACEMENT AGENCY, INC., Petitioner, v. JOY C. CABILES, Respondent.

  • G.R. No. 206368, August 06, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. LEONARDO BATTAD, Accused-Appellant, MARCELINO BACNIS, Accused.

  • G.R. No. 181541, August 18, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. MARISSA MARCELO, Accused-Appellant.

  • G.R. No. 208469, August 13, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. SAMUEL “TIW-TIW” SANICO, Accused-Appellant.

  • G.R. No. 205870, August 13, 2014 - LEI SHERYLL FERNANDEZ, Petitioner, v. BOTICA CLAUDIO REPRESENTED BY GUADALUPE JOSE, Respondent.

  • G.R. No. 194390, August 13, 2014 - VENANCIO M. SEVILLA, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 198367, August 06, 2014 - OSG SHIPMANAGEMENT MANILA, INC., MERCEDES M. RAVANOPOLOUS, OSG SHIPMANAGEMENT (UK) LTD. & M/T DELPHINA, Petitioners, v. JOSELITO B. PELLAZAR, Respondent.

  • G.R. No. 192304, August 13, 2014 - ANCHOR SAVINGS BANK (now EQUICOM SAVINGS BANK), Petitioner, v. PINZMAN REALTY AND DEVELOPMENT CORPORATION, MARYLIN MAÑALAC AND RENATO GONZALES, Respondents.

  • G.R. No. 177845, August 20, 2014 - GRACE CHRISTIAN HIGH SCHOOL, REPRESENTED BY ITS PRINCIPAL, DR. JAMES TAN, Petitioner, v. FILIPINAS A. LAVANDERA, Respondent.

  • G.R. No. 200191, August 20, 2014 - LOURDES C. FERNANDEZ, Petitioner, v. NORMA VILLEGAS AND ANY PERSON ACTING IN HER BEHALF INCLUDING HER FAMILY, Respondents.

  • G.R. No. 206366, August 13, 2014 - PEOPLE OF THE PHILIPPINES, Appellee, v. EDUARDO BALAQUIT Y BALDERAMA, Appellant.

  • G.R. No. 192993, August 11, 2014 - WALLEM MARITIME SERVICES, INC., AND REGINALDO OBEN/WALLEM SHIPMANAGEMENT LIMITED, Petitioners, v. DONNABELLE PEDRAJAS AND SEAN JADE PEDRAJAS, Respondents.

  • G.R. No. 181723, August 11, 2014 - ELIZABETH DEL CARMEN, Petitioner, v. SPOUSES RESTITUTO SABORDO AND MIMA MAHILUM-SABORDO, Respondents.

  • A.M. No. RTJ-14-2390 (Formerly OCA I.P.I. No. 12-3923-RTJ), August 13, 2014 - JOSEPHINE JAZMINES TAN, Petitioner, v. JUDGE SIBANAH E. USMAN, REGIONAL TRIAL COURT, BRANCH 28, CATBALOGAN CITY, SAMAR, Respondent.

  • G.R. No. 212689, August 11, 2014 - ECE REALTY AND DEVELOPMENT, INC., Petitioner, v. HAYDYN HERNANDEZ,, Respondent.

  • G.R. Nos. 208828-29, August 13, 2014 - RICARDO C. SILVERIO, SR., Petitioner, v. RICARDO S. SILVERIO, JR., CITRINE HOLDINGS, INC., MONICA P. OCAMPO AND ZEE2 RESOURCES, INC., Respondents.

  • G.R. No. 171626, August 06, 2014 - OLONGAPO CITY, Petitioner, v. SUBIC WATER AND SEWERAGE CO., INC., Respondent.

  • G.R. No. 162230, August 12, 2014 - ISABELITA C. VINUYA, VICTORIA C. DELA PEÑA, HERMINIHILDA MANIMBO, LEONOR H. SUMAWANG, CANDELARIA L. SOLIMAN, MARIA L. QUILANTANG, MARIA L. MAGISA, NATALIA M. ALONZO, LOURDES M. NAVARO, FRANCISCA M. ATENCIO, ERLINDA MANALASTAS, TARCILA M. SAMPANG, ESTER M. PALACIO, MAXIMA R. DELA CRUZ, BELEN A. SAGUM, FELICIDAD TURLA, FLORENCIA M. DELA PEÑA, EUGENIA M. LALU, JULIANA G. MAGAT, CECILIA SANGUYO, ANA ALONZO, RUFINA P. MALLARI, ROSARIO M. ALARCON, RUFINA C. GULAPA, ZOILA B. MANALUS, CORAZON C. CALMA, MARTA A. GULAPA, TEODORA M. HERNANDEZ, FERMIN B. DELA PEÑA, MARIA DELA PAZ B. CULALA, ESPERANZA MANAPOL, JUANITA M. BRIONES, VERGINIA M. GUEVARRA, MAXIMA ANGULO, EMILIA SANGIL, TEOFILA R. PUNZALAN, JANUARIA G. GARCIA, PERLA B. BALINGIT, BELEN A. CULALA, PILAR Q. GALANG, ROSARIO C. BUCO, GAUDENCIA C. DELA PEÑA, RUFINA Q. CATACUTAN, FRANCIA A. BUCO, PASTORA C. GUEVARRA, VICTORIA M. DELA CRUZ, PETRONILA O. DELA CRUZ, ZENAIDA P. DELA CRUZ, CORAZON M. SUBA, EMERINCIANA A. VINUYA, LYDIA A. SANCHEZ, ROSALINA M. BUCO, PATRICIA A. BERNARDO, LUCILA H. PAYAWAL, MAGDALENA LIWAG, ESTER C. BALINGIT, JOVITA A. DAVID, EMILIA C. MANGILIT, VERGINIA M. BANGIT, GUILERMA S. BALINGIT, TERECITA PANGILINAN, MAMERTA C. PUNO, CRISENCIANA C. GULAPA, SEFERINA S. TURLA, MAXIMA B. TURLA, LEONICIA G. GUEVARRA, ROSALINA M. CULALA, CATALINA Y. MANIO, MAMERTA T. SAGUM, CARIDAD L. TURLA, et al. in their capacity and as members of the “Malaya Lolas Organizations,” Petitioners, v. THE HONORABLE EXECUTIVE SECRETARY ALBERTO G. ROMULO, THE HONORABLE SECRETARY OF FOREIGN AFFAIRS DELIA DOMINGO-ALBERT, THE HONORABLE SECRETARY OF JUSTICE MERCEDITAS N. GUTIERREZ, AND THE HONORABLE SOLICITOR GENERAL ALFREDO L. BENIPAYO,, Respondents.

  • G.R. No. 173082, August 06, 2014 - PALM AVENUE HOLDING CO., INC., AND PALM AVENUE REALTY AND DEVELOPMENT CORPORATION, Petitioners, v. SANDIGANBAYAN 5TH DIVISION, REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT (PCGG), Respondent.; [G.R. No. 195795] - REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, Petitioner, v. HON. SANDIGANBAYAN, PALM AVENUE REALTY AND DEVELOPMENT CORPORATION AND PALM AVENUE HOLDING COMPANY, INC., Respondents.

  • G.R. Nos. 212536-37, August 27, 2014 - COMMISSIONER OF INTERNAL REVENUE AND COMMISSIONER OF CUSTOMS, Petitioners, v. PHILIPPINE AIRLINES, INC., Respondent.

  • G.R. No. 212953, August 05, 2014 - JOSE TAPALES VILLAROSA, Petitioner, v. ROMULO DE MESA FESTIN AND COMMISSION ON ELECTIONS,, Respondent.

  • G.R. No. 211049, August 06, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ROMEO CLOSA Y LUALHATI, Accused-Appellant.

  • G.R. No. 177616, August 27, 2014 - HEIRS OF SPOUSES JOAQUIN MANGUARDIA and SUSANA MANALO, namely: DANILO MANGUARDIA, ALMA MANGUARDIA, GEMMA MANGUARDIA, RODERICK MANGUARDIA, MADELINE MANGUARDIA, joined by her husband, RODRIGO VILLARANTE, ALAN MANGUARDIA, ROSE MANGUARDIA, joined by her husband, LEOPOLDO ADRID, JR., RONALD MANGUARDIA, JOEBERT MANGUARDIA, and RANDY MANGUARDIA; HEIRS OF SPOUSES LEONARDO ARAZA and REBECCA ARROYO, namely: MARY MAGDALENA ARAZA,* joined by her husband CARLITO VILLANUEVA, NENITA ARAZA, joined by her husband, LEONARDO BADE, ANTONIO ARAZA, and the children of ENECITA ARAZA- VARGAS, namely: GADFRY VARGAS, GINA VARGAS, JOEL VARGAS, MARY GRACE VARGAS, ANA MAE VARGAS, and the minor JUNAR VARGAS, represented by his guardian ad litem MAGDALENA ARAZA-VILLANUEVA, and THE REGISTER OF DEEDS OF CAPIZ, Petitioners, v. HEIRS OF SIMPLICIO VALLES and MARTA VALLES, represented by GRACIANO VALLES, SULPICIO VALLES, TERESITA VALLES, joined by her husband, LEOPOLDO ALAIR, and PRESENTACION CAPAPAS-VALLES, Respondents.

  • G.R. No. 193791, August 02, 2014 - PRIMANILA PLANS, INC., HEREIN REPRESENTED BY EDUARDO S. MADRID, Petitioner, v. SECURITIES AND EXCHANGE COMMISSION, Respondent.

  • G.R. No. 198342, August 13, 2014 - REMEDIOS O. YAP, Petitioner, v. ROVER MARITIME SERVICES CORPORATION, MR. RUEL BENISANO AND/OR UCO MARINE CONTRACTING W.L.L., Respondents.

  • G.R. No. 208170, August 20, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. PETRUS YAU A.K.A. “JOHN” AND “RICKY” AND SUSANA YAU Y SUMOGBA A.K.A. “SUSAN”, Accused-Appellants.

  • G.R. No. 207992, August 11, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ROBERTO HOLGADO Y DELA CRUZ AND ANTONIO MISAREZ Y ZARAGA, Accused-Appellants.

  • G.R. No. 171836, August 11, 2014 - DEPARTMENT OF AGRARIAN REFORM, REPRESENTED BY HON. NASSER C. PANGANDAMAN, IN HIS CAPACITY AS DAR-OIC SECRETARY, Petitioner, v. SUSIE IRENE GALLE, RESPONDENT., G.R. NO. 195213 - LAND BANK OF THE PHILIPPINES, Petitioner, v. SUSIE IRENE GALLE, SUBSTITUTED BY HER HEIRS, NAMELY HANS PETER, CARL OTTO, FRITZ WALTER, AND GEORGE ALAN, ALL SURNAMED REITH, Respondents.

  • G.R. No. 196040, August 26, 2014 - FE H. OKABE, Petitioner, v. ERNESTO A. SATURNINO, Respondent.

  • G.R. No. 203048, August 13, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. RUSTY BALA, Accused-Appellant.

  • G.R. No. 213181, August 19, 2014 - FRANCIS H. JARDELEZA, Petitioner, v. CHIEF JUSTICE MARIA LOURDES P. A. SERENO, THE JUDICIAL AND BAR COUNCIL AND EXECUTIVE SECRETARY PAQUITO N. OCHOA, JR., Respondents.

  • G.R. No. 200987, August 20, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. RONALDO BAYAN Y NERI, Accused-Appellant.

  • G.R. No. 207348, August 20, 2014 - ROWENA R. SOLANTE, Petitioner, v. COMMISSION ON AUDIT, CHAIRPERSON MA. GRACIA PULIDO-TAN, COMMISSIONER JUANITO G. ESPINO, JR., COMMISSIONER HEIDI L. MENDOZA, AND FORTUNATA M. RUBICO, DIRECTOR IV, COA COMMISSION SECRETARIAT, in their official capacities, Respondents.

  • G.R. No. 166944, August 18, 2014 - JUANITO MAGSINO, Petitioner, v. ELENA DE OCAMPO AND RAMON GUICO, Respondents.

  • G.R. No. 175689, August 13, 2014 - GEORGE A. ARRIOLA, Petitioner, v. PILIPINO STAR NGAYON, INC. AND/OR MIGUEL G. BELMONTE, Respondents.

  • G.R. No. 189061, August 06, 2014 - MIDWAY MARITIME AND TECHNOLOGICAL FOUNDATION, REPRESENTED BY ITS CHAIRMAN/PRESIDENT PHD IN EDUCATION DR. SABINO M. MANGLICMOT, Petitioner, v. MARISSA E. CASTRO, ET AL., Respondents.

  • G.R. No. 199420, August 27, 2014 - PHILNICO INDUSTRIAL CORPORATION, Petitioner, v. PRIVATIZATION AND MANAGEMENT OFFICE, Respondent.; G.R. NO. 199432 - PRIVATIZATION AND MANAGEMENT OFFICE, Petitioner, v. PHILNICO INDUSTRIAL CORPORATION, Respondent.

  • G.R. No. 195432, August 27, 2014 - EDELINA T. ANDO, Petitioner, v. DEPARTMENT OF FOREIGN AFFAIRS, Respondent.

  • G.R. No. 200645, August 20, 2014 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. WENDEL OCDOL Y MENDOVA, EDISON TABIANAN, AND DANTE BORINAGA, ACCUSED. WENDEL OCDOL Y MENDOVA, Accused-Appellant.

  • G.R. No. 172404, August 13, 2014 - PEOPLE’S TRANS-EAST ASIA INSURANCE CORPORATION, A.K.A. PEOPLE'S GENERAL INSURANCE CORPORATION, Petitioner, v. DOCTORS OF NEW MILLENNIUM HOLDINGS, INC., Respondent.

  • A.M. No. P-06-2227 [Formerly A.M. No. 06-6-364-RTC], August 19, 2014 - OFFICE OF THE COURT ADMINISTRATOR, Complainant, v. ATTY. MARIO N. MELCHOR, JR., FORMER CLERK OF COURT VI, REGIONAL TRIAL COURT, BRANCH 16, NAVAL, BILIRAN (NOW PRESIDING JUDGE, MUNICIPAL CIRCUIT TRIAL COURT, CALUBIAN-SAN ISIDRO, LEYTE), Respondent.

  • G.R. No. 207253, August 20, 2014 - CRISPIN B. LOPEZ, Petitioner, v. IRVINE CONSTRUCTION CORP. AND TOMAS SY SANTOS, Respondents.

  • G.R. No. 200538, August 13, 2014 - CITY OF DAVAO, Petitioner, v. COURT OF APPEALS AND BENJAMIN C. DE GUZMAN, Respondents.

  • G.R. No. 188289, August 20, 2014 - DAVID A. NOVERAS, Petitioner, v. LETICIA T. NOVERAS, Respondent.

  • G.R. No. 203655, August 13, 2014 - SM LAND, INC., Petitioner, v. BASES CONVERSION AND DEVELOPMENT AUTHORITY AND ARNEL PACIANO D. CASANOVA, ESQ., IN HIS OFFICIAL CAPACITY AS PRESIDENT AND CEO OF BCDA, Respondents.

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    G.R. No. 184982, August 20, 2014 - LAND BANK OF THE PHILIPPINES, Petitioner, v. JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Respondents.; [G.R. NO. 185048] - JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Petitioners, v. LAND BANK OF THE PHILIPPINES, Respondent.

      G.R. No. 184982, August 20, 2014 - LAND BANK OF THE PHILIPPINES, Petitioner, v. JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Respondents.; [G.R. NO. 185048] - JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Petitioners, v. LAND BANK OF THE PHILIPPINES, Respondent.

    PHILIPPINE SUPREME COURT DECISIONS

    SECOND DIVISION

    G.R. No. 184982, August 20, 2014

    LAND BANK OF THE PHILIPPINES, Petitioner, v. JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Respondents.

    [G.R. NO. 185048]

    JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Petitioners, v. LAND BANK OF THE PHILIPPINES, Respondent.

    D E C I S I O N

    PERLAS-BERNABE, J.:

    Assailed in these consolidated1 petitions for review on certiorari2 are the Decision3 dated February 26, 2008 and the Resolution4 dated October 17, 2008 of the Court of Appeals (CA) in CA-G.R. SP No. 89545 which affirmed with modification the Decision5 dated March 11, 2004 and the Order6 dated April 15, 2005 of the Regional Trial Court of Cabanatuan City, Branch 23 (RTC) in SP. Civil Case No. 1483-AF, deleting the award of interest at the rate of 6% per annum (p.a.) and imposing interest by way of damages, at the rate of 12% p.a. on the just compensation for the land in controversy at P3,858,912.00, from March 11, 2004 until fully paid.

    The Facts

    Jose T. Lajom (Lajom)7 and his mother Vicenta Vda. De Lajom (Vda. De Lajom)8 were the registered owners of several parcels of land with an aggregate area of 27 hectares (ha.), more or less, located at Alua, San Isidro, Nueva Ecija and covered by Transfer Certificate of Title (TCT) No. NT-707859 issued by the Registry of Deeds of Nueva Ecija (subject land).

    Sometime in 1991, a 24-ha., more or less, portion of the subject land (subject portion) was placed under the government’s Operation Land Transfer Program pursuant to Presidential Decree No. (PD) 27,10 otherwise known as the “Tenants Emancipation Decree,” as amended. Accordingly, the Department of Agrarian Reform (DAR), through the Land Bank of the Philippines (LBP), offered to pay Lajom the following amounts as just compensation for the following constitutive areas of the subject portion: (a) P19,434.00 for 11.3060 has.; (b) P17,505.65 for 2.4173 has.; and (c) P80,733.45 for 10.3949 has. (DAR valuation).11 Records show, however, that despite non-payment of the offered just compensation, DAR granted twelve (12) Emancipation Patents12 between 1994 and 1998 in favor of the following farmer-beneficiaries: Vicente Dela Cruz, Donato Magno,13Eutiquio Gablao,14 Ricardo Bulos, Proceso Julian, Ceferino Dela Cruz, RufinoGripal, Simplicio Pataleta,15 Jovita Vda. De Bondoc, and Julian Pataleta16 (farmer-beneficiaries).17cralawred

    Lajom rejected the DAR valuation and, instead, filed an amended petition18 for determination of just compensation and cancellation of land transfers against the DAR, the LBP, and the said farmer-beneficiaries, docketed as SP. Civil Case No. 1483-AF.19 He alleged, inter alia, that in computing the amount of just compensation, the DAR erroneously applied the provisions of PD 27 and Executive Order No. (EO) 228, Series of 1997, that have been repealed by Section 17 of Republic Act No. (RA) 6657,20 otherwise known as the “Comprehensive Agrarian Reform Law of 1988,” which took effect on June 15, 1988. Thus, he asserted that the value of the subject portion should be computed based on the provisions of RA 6657, and not of PD 27 and/or EO 228. He likewise claimed that the Barrio Committee on Land Production (BCLP) resolution – which fixed the average gross production (AGP) per ha. per year at 120 cavans of palay, and which the DAR used in arriving at its valuation – was falsified and therefore cannot validly serve as basis for determining the value of the land. In sum, Lajom stressed that the DAR valuation was arrived at without due process, highly prejudicial and inimical to his and his heirs’ property rights.21cralawred

    For its part, the LBP agreed with the DAR valuation and insisted that PD 27 and EO 228, on which the DAR valuation was based, were never abrogated by the passage of RA 6657, contrary to Lajom’s stance.22cralawred

    The RTC Ruling

    In a Decision23 dated March 11, 2004, the RTC rejected the DAR valuation and, using the formula Land Value = (AGP x 2.5 Hectares x Government Support Price [GSP] x Area) under PD 27 and EO 228, fixed the just compensation for the subject portion at the total amount of P3,858,912.00, with legal interest at the rate of 6% p.a. from 1991 until fully paid.24cralawred

    The RTC set the AGP at 160 cavans of palay per ha. per year, taking judicial notice of the fact that the normal production of 120 cavans thereof per ha. per year has been increased with the “advent of new modern farm technology” coupled with the utilization of high-breed variety of palay, good weather, and continuous supply of irrigated water.25 With respect to the GSP, the RTC pegged the same at P400.00, per certification from the National Food Authority fixing the GSP at the same amount as of 1991, when the subject portion was actually expropriated.26 Using the above formula, therefore, the RTC computed the just compensation as follows: AGP (160) x 2.5 x GSP (P400.00) x Area (24.1182 has.) = P3,858,912.00.27cralawred

    Dissatisfied, the LBP moved for reconsideration but was, however, denied in an Order28 dated April 15, 2004, prompting it to elevate the matter before the CA via a petition for review, docketed as CA-G.R. SP No. 89545.

    The CA Ruling

    In a Decision29 dated February 26, 2008, the CA affirmed with modification the RTC Decision, deleting the award of 6% interest p.a. and,in lieu thereof, ordered LBP to pay Lajom, through his representatives and/or heirs, interest by way of damages at the rate of 12% p.a. on the just compensation award of P3,858,912.00 from March 11, 2004 until fully paid.30cralawred

    The CA found no error on the part of the RTC in considering 1991 as the time of the subject portion’s actual taking, instead of October 21, 1972 when PD 27 took effect, and in consequently using the higher GSP value of P400.00 prevailing in 1991 instead of P35.00, contrary to the LBP’s claim.31 The CA found it inequitable to determine just compensation based on the guidelines provided by PD 27 and EO 228 considering that the actual taking of the subject property took place in 1991. Hence, just compensation,being the “full and fair equivalent of the property taken from its owner by the expropriator, the equivalent being real, substantial, full and ample,”32 should be determined in accordance with RA 6657, not with PD 27 and EO 228.33cralawred

    However, the CA deleted the award of interest at the rate of 6% p.a. imposed on the amount of just compensation in accordance with DAR Administrative Order No. 13, Series of 1994,34 because the RTC had already used the higher GSP value of P400.00 in 1991. Nonetheless, the CA deemed it necessary to impose legal interest pegged at the rate of 12% p.a.to serve as damages for the delay incurred in the payment of just compensation to the landowner.35cralawred

    Lajom’s representative, Porfirio Rodriguez (Rodriguez), who had substituted him in these proceedings, moved for a partial reconsideration of the CA Decision, while the LBP and the rest of Lajom’s heirs filed separate motions for reconsideration, all of which the CA denied in a Resolution36 dated October 17, 2008, hence, these consolidated petitions.

    The Issues Before the Court

    In its petition,37 the LBP contends that the CA committed reversible error in: (a) retroactively applying the provisions of RA 6657 to land acquired under PD 27 and EO 228; (b) reckoning the period to determine just compensation on the date of actual payment instead of the date of taking;and (c) imposing interest at the rate of 12% p.a.on the just compensation award in the nature of damages from March 11, 2004 until full payment.

    On the other hand, Lajom, through his representatives, raises in his petition38 the sole question of whether or not the CA erred in deleting the award of 6% interest p.a.on the just compensation award from the time of taking until full payment.

    The Court’s Ruling

    The petitions are meritorious.

    Case law instructs that when the agrarian reform process under PD 27 remains incomplete and is overtaken by RA 6657, such as when the just compensation due the landowner has yet to be settled, as in this case, such just compensation should be determined and the process concluded under RA 6657, with PD 27 and EO 228 applying only suppletorily.39 Hence, where RA 6657 is sufficient, PD 27 and EO 228 are superseded.40cralawred

    Records show that even before Lajom filed a petition for the judicial determination of just compensation in May 1993, RA 6657 had already taken effect on June 15, 1988. Similarly, the emancipation patents had been issued in favor of the farmer-beneficiaries prior to the filing of the said petition, and both the taking and the valuation of the subject portion occurred after the passage of RA 6657. Quite evidently, the matters pertaining tothe correct just compensation award for the subject portion were still in contention at the time RA 6657 took effect; thus, as correctly ruled by the CA, its provisions should have been applied, with PD 27 and EO 228 applying only suppletorily.

    As to the proper reckoning point, it is fundamental that just compensation should be determined at the time of the property’s taking.41Taking may be deemed to occur, for instance, at the time emancipation patents are issued by the government. As enunciated in LBP v. Heirs of Angel T. Domingo:42cralawred

    The date of taking of the subject land for purposes of computing just compensation should be reckoned from the issuance dates of the emancipation patents. An emancipation patent constitutes the conclusive authority for the issuance of a Transfer Certificate of Title in the name of the grantee. It is from the issuance of an emancipation patent that the grantee can acquire the vested right of ownership in the landholding, subject to the payment of just compensation to the landowner.43 (Emphasis supplied)

    Since the emancipation patents in this case had been issued between the years 1994 and 1998, the just compensation for the subject portion should then be reckoned therefrom, being considered the “time of taking” or the time when the landowner was deprived of the use and benefit of his property.44 On this score, it must be emphasized that while the LBP is charged with the initial responsibility of determining the value of lands placed under the land reform and, accordingly, the just compensation therefor, its valuation is considered only as an initial determination and,thus, not conclusive. Verily, it is well-settled that it is the RTC, sitting as a Special Agrarian Court, which should make the final determination of just compensation in the exercise of its judicial function.45 In this respect, the RTC is required to consider the factors enumerated in Section 17 of RA 6657, as amended, viz.:chanRoblesvirtualLawlibrary

    SEC. 17. Determination of Just Compensation. — In determining just compensation, the cost of acquisition of the land, the current value of like properties, its nature, actual use and income, the sworn valuation by the owner, the tax declarations, and the assessment made by government assessors shall be considered. The social and economic benefits contributed by the farmers and the farmworkers and by the Government to the property as well as the non-payment of taxes or loans secured from any government financing institution on the said land shall be considered as additional factors to determine its valuation.

    After a punctilious review of the records, however, the Court finds that none of the aforementioned factors had been considered by the RTC in determining the just compensation for the subject portion. Thus, the Court must reject the valuation pronounced in the RTC Decision, as affirmed by the CA, and consequently direct the remand of the case to the trial court in order to determine the proper amount of just compensation anew in accordance with the following guidelines:cralawlawlibrary

    First. Just compensation must be valued at the time of the taking, or the “time when the landowner was deprived of the use and benefit of his property”46 which, in this case, is reckoned from the date of the issuance of the emancipation patents.47 Hence, the valuation of the subject portion must be based on evidence showing the values prevalent on such time of taking for like agricultural lands.48cralawred

    Second. The evidence must conform to Section 17 of RA 6657, as amended, prior to its amendment by RA 9700.49 While RA 9700 took effect on July 1, 2009, which amended further certain provisions of RA 6657, as amended, among them Section 17, declaring “[t]hat all previously acquired lands wherein valuation is subject to challenge by landowners shall be completed and finally resolved pursuant to Section 17 of [RA 6657], as amended,”50 the law should not be applied retroactively to pending cases. Considering that the present consolidated petitions had been filed before the effectivity of RA 9700, or on December 8, 2008 for G.R. No. 184982 and May 18, 2009 for G.R. No. 185048, Section 17 of RA 6657, as amended, prior to its further amendment by RA 9700, should therefore apply.

    Third. With respect to the commonly raised issue on interest, the RTC may impose the same on the just compensation award as may be justified by the circumstances of the case and in accordance with prevailing jurisprudence.51 The Court has previously allowed the grant of legal interest in expropriation cases where there was delay in the payment of just compensation, deeming the same to be an effective forbearance on the part of the State.52To clarify, this incremental interest is not granted on the computed just compensation; rather, it is a penalty imposed for damages incurred by the landowner due to the delay in its payment.53cralawred

    Thus, legal interest shall be pegged at the rate of 12% p.a. from the time of taking until June 30, 2013. Thereafter, or beginning July 1, 2013, until fully paid, just compensation shall earn interest at the new legal rate of 6% p.a., conformably with the modification on the rules respecting interest rates introduced by Bangko Sentralng Pilipinas Monetary Board Circular No. 799, Series of 2013.54cralawred

    Fourth. The RTC, sitting as a Special Agrarian Court, is reminded that while it should take into account the various formulae created by the DAR in arriving at the just compensation for the subject land, it is not strictly bound thereby if the situations before it do not warrant their application. The RTC, in the exercise of its judicial function of determining just compensation, cannot be restrained or delimited in the performance thereof. As explained in LBP v. Heirs of Maximo Puyat:55cralawred

    [T]he determination of just compensation is a judicial function; hence, courts cannot be unduly restricted in their determination thereof. To do so would deprive the courts of their judicial prerogatives and reduce them to the bureaucratic function of in putting data and arriving at the valuation. While the courts should be mindful of the different formulae created by the DAR in arriving at just compensation, they are not strictly bound to adhere thereto if the situations before them do not warrant it. x x x:cralawlawlibrary

    “x x x [T]he basic formula and its alternatives – administratively determined (as it is not found in Republic Act No. 6657, but merely set forth in DAR AO No. 5, Series of 1998) – although referred to and even applied by the courts in certain instances, does not and cannot strictly bind the courts. To insist that the formula must be applied with utmost rigidity whereby the valuation is drawn following a strict mathematical computation goes beyond the intent and spirit of the law. The suggested interpretation is strained and would render the law in utile. Statutory construction should not kill but give life to the law. As we have established in earlier jurisprudence, the valuation of property in eminent domain is essentially a judicial function which is vested in the regional trial court acting as a SAC, and not in administrative agencies. The SAC, therefore, must still be able to reasonably exercise its judicial discretion in the evaluation of the factors for just compensation, which cannot be arbitrarily restricted by a formula dictated by the DAR, an administrative agency. Surely, DAR AO No. 5 did not intend to straightjacket the hands of the court in the computation of the land valuation. While it provides a formula, it could not have been its intention to shackle the courts into applying the formula in every instance. The court shall apply the formula after an evaluation of the three factors, or it may proceed to make its own computation based on the extended list in Section 17 of Republic Act No. 6657, which includes other factors[.] x x x”chanrobleslaw

    As a final word, the Court would like to emphasize that while the agrarian reform program was undertaken primarily for the benefit of our landless farmers,this undertaking should, however, not result in the oppression of landowners by pegging the cheapest value for their lands. Indeed, although the taking of properties for agrarian reform purposes is a revolutionary kind of expropriation, it should not be carried out at the undue expense of landowners who are also entitled to protection under the Constitution and agrarian reform laws.56cralawred

    WHEREFORE, the petitions are GRANTED. The Decision dated February 26, 2008 and the Resolution dated October 17, 2008 of the Court of Appeals in CA-G.R. SP No. 89545 which: (a) upheld the valuation of the subject portion computed by the Regional Trial Court of Cabanatuan City, Branch 23 (RTC) without, however, taking into account the factors enumerated under Section 17 of Republic Act No. 6657, as amended; and (b) deleted the interest award pegged at the rate of 6% per annum (p.a.) from 1991 until fully paid and, instead, awarded the interest at the rate of 12% p.a. in the nature of damages from March 11, 2004 until fully paid, are hereby REVERSED and SET ASIDE. SP. Civil Case No. 1483-AF is REMANDED to the RTC for reception of evidence on the issue of just compensation in accordance with the guidelines set in this Decision. The RTC is directed to conduct the proceedings in said case with reasonable dispatch and submit to the Court a report on its findings and recommended conclusions within sixty (60) days from notice of this Decision.

    SO ORDERED.

    Carpio, (Chairperson), Velasco, Jr.,* Del Castillo, Perez, and Perlas-Bernabe, JJ., concur.

    Endnotes:


    * Designated Additional Member per Special Order No. 1757 dated August 20, 2014.

    1 See Resolution dated November 19, 2008; rollo (G.R. No. 185048), p. 41.

    2 Rollo (G.R. No. 184982), pp. 39-91; rollo (G.R. No 185048), pp. 54-70.

    3Rollo (G.R. No. 184982), pp. 10-35. Penned by Associate Justice Celia C. Librea-Leagogo, with Associate Justices Regalado E. Maambong and Ramon R. Garcia, concurring.

    4 Id. at 7-9.

    5 Id. at 215-221. Penned by Presiding Judge Lydia Bauto Hipolito.

    6 Id. at 222-223. Penned by Pairing Judge Rodrigo S. Caspillo.

    7 Records show that Jose T. Lajom died during the pendency of his petition before the RTC or on June 28, 1999 (see Certificate of Death; id. at 289) and that he was substituted by his heirs Porfirio Rodriguez, et al. (see Orders of the RTC dated May 21, 2002 and May 27, 2001; id. at 320 and 321, respectively).

    8 Died on May 2, 1993; id at 13 and 246.

    9 Id. at 291-293.

    10 Entitled “Decreeing the Emancipation of Tenants from the Bondage of the Soil, Transferring to Them the Ownership of the Land They Till and Providing the Instruments and Mechanism Therefor.”

    11Rollo (G.R. No. 184982), p. 217.

    12 Id. at 300-311.

    13 “Donito Magno” in some parts of the records.

    14 “Estiquio Cabiao” and “Eutiquio Cablao” in some parts of the records.

    15 “Simplicio Patatela” in some parts of the records.

    16 “Julian Patatela” in some parts of the records.

    17Rollo (G.R. No. 184982), p. 217. See also Emancipation Patents; id. at 300-311.

    18 Id. at 245-250. Dated May 12, 1993.

    19 Id. at 249.

    20 Entitled “AN ACT INSTITUTING A COMPREHENSIVE AGRARIAN REFORM PROGRAM TO PROMOTE SOCIAL JUSTICE AND INDUSTRIALIZATION, PROVIDING THE MECHANISM FOR ITS IMPLEMENTATION.”

    21 See rollo (G.R. No. 184982), pp. 217, 247-A, and 248.

    22 Id. at 218.

    23 Id. at 215-221.

    24 See id. at 220-221.

    25 Id. at 219.

    26 Id. at 220.

    27 Id.

    28 Id. at 222-223.

    29 Id. at 10-35.

    30 Id. at 31-32.

    31 Id. at 29.

    32 Id. at 30.

    33 Id. at 29-30.

    34 Entitled “RULES AND REGULATIONS GOVERNING THE GRANT OF INCREMENT OF SIX PERCENT (6%) YEARLY INTEREST COMPOUNDED ANNUALLY ON LANDS COVERED BY PRESIDENTIAL DECREE NO. 27 AND EXECUTIVE ORDER NO. 228.”

    35Rollo (G.R. No. 184982), pp. 30-32.

    36 Id. at 7-9.

    37 Id. at 39-91.

    38Rollo (G.R. No. 185048), pp. 54-70.

    39 See LBP v. Santiago, Jr., G.R. No. 182209, October 3, 2012, 682 SCRA 264, 277-278; citations omitted.

    40 See LBP v. Heirs of Maximo Puyat, G.R. No. 175055, June 27, 2012, 675 SCRA 233, 243-244.

    41 See Secretary of the Department of Public Works and Highways v. Tecson, G.R. No. 179334, July 1, 2013, 700 SCRA 243, 257-258, citing Republic v. Lara, 96 Phil. 170 (1954).

    42 567 Phil. 593 (2008).

    43 Id. at 608.

    44LBP v. Heirs of Salvador Encinas, G.R. No. 167735, April 18, 2012, 670 SCRA 52, 60.

    45 See LBP v. Dumlao, 592 Phil. 486, 504 (2008). See also LBP v. Heir of Trinidad S. Vda. De Arieta, G.R. No. 161834, August 11, 2010, 628 SCRA 43, 66.

    46 LBP v. Livioco, G.R. No. 170685, September 22, 2010, 631 SCRA 86, 112-113.

    47LBP v. Heirs of Angel T. Domingo, supra note 42.

    48 See LBP v. Livioco, supra not 46, at 114.

    49 Entitled “AN ACT STRENGTHENING THE COMPREHENSIVE AGRARIAN REFORM PROGRAM (CARP),  EXTENDING THE ACQUISITION AND DISTRIBUTION OF ALL AGRICULTURAL LANDS, INSTITUTING NECESSARY REFORMS, AMENDING FOR THE PURPOSE CERTAIN PROVISIONS OF REPUBLIC ACT NO. 6657, OTHERWISE KNOWN AS THE COMPREHENSIVE AGRARIAN REFORM LAW OF 1988, AS AMENDED, AND APPROPRIATING FUNDS THEREFOR.”

    50 See Section 5 of RA 9700 which further amended Section 17 of RA 6657, as amended on the “Priorities” in the acquisition and distribution of agricultural lands.

    51LBP v. Livioco, supra note 46, at 116.

    52 See LBP v. Santiago, Jr., supra note 39, at 283-284; citations omitted.

    53DAR v. Goduco, G.R. Nos. 174007 and 181327, June 27, 2012, 675 SCRA 187, 205.

    54 See Nacar v. Gallery Frames, G.R. No. 189871, August 13, 2013, 703 SCRA 439, 454-456.

    55 Supra note 40, at 250-251; citations omitted.

    56 See LBP v. Spouses Chico, 600 Phil. 272, 291 (2009).

    G.R. No. 184982, August 20, 2014 - LAND BANK OF THE PHILIPPINES, Petitioner, v. JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Respondents.; [G.R. NO. 185048] - JOSE T. LAJOM, REPRESENTED BY PORFIRIO RODRIGUEZ, FLORENCIA LAJOM GARCIA-DIAZ, FRANCISCO LAJOM GARCIA, JR., FERNANDO LAJOM RODRIGUEZ, TOMAS ATAYDE, AUGUSTO MIRANDA, JOSEFINA ATAYDE FRANCISCO, RAMON L. ATAYDE, AND BLESILDA ATAYDE RIOS, Petitioners, v. LAND BANK OF THE PHILIPPINES, Respondent.


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