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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-2015 Jurisprudence                 

  • G.R. No. 197709, August 03, 2015 - JOSE YULO AGRICULTURAL CORPORATION, Petitioner, v. SPOUSES PERLA CABAYLO DAVIS AND SCOTT DAVIS, Respondents.

  • G.R. No. 200969, August 03, 2015 - CONSOLACION D. ROMERO AND ROSARIO S.D. DOMINGO, Petitioners, v. ENGRACIA D. SINGSON, Respondent.

  • G.R. No. 213847, August 18, 2015 - JUAN PONCE ENRILE, Petitioner, v. SANDIGANBAYAN (THIRD DIVISION), AND PEOPLE OF THE PHILIPPINES, Respondents.

  • A.C. No. 8708 (CBD Case No. 08-2192), August 12, 2015 - SPOUSES BYRON AND MARIA LUISA SAUNDERS, Complainants, v. ATTY. LYSSA GRACE S. PAGANO-CALDE, Respondent.

  • G.R. No. 177803, August 03, 2015 - SPOUSES EMILIANO L. JALBAY, SR. AND MAMERTA C. JALBAY, Petitioners, v. PHILIPPINE NATIONAL BANK, Respondent.

  • G.R. No. 201365, August 03, 2015 - THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. MANUELA FLORES Y SALAZAR @ WELLA Accused-Appellant.

  • G.R. No. 198908, August 03, 2015 - VIRGINIA OCAMPO, Petitioner, v. DEOGRACIO OCAMPO, Respondent.

  • G.R. No. 195175, August 10, 2015 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. TOLEDO POWER COMPANY, Respondent.; G.R. NO. 199645 - TOLEDO POWER COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

  • G.R. No. 213233, August 05, 2015 - BLISS DEVELOPMENT CORP./HOME GUARANTY CORPORATION, Petitioner, v. MONTANO DIAZ, DOMINGO TAPAY, AND EDGAR H. ARREZA, Respondents.

  • G.R. No. 197953, August 05, 2015 - PEOPLE OF THE PHILIPPINES, Petitioner, v. SANDIGANBAYAN (2ND DIVISION), QUINTIN SALUDAGA Y BORDEOS, ARTHUS ADRIATICO Y ERUDA AND ROMEO DE LUNA, Respondents.

  • G.R. No. 187524, August 05, 2015 - SPOUSES MARIA BUTIONG AND FRANCISCO VILLAFRIA, SUBSTITUTED BY DR. RUEL B. VILLAFRIA, Petitioners, v. MA. GRACIA RIÑOZA PLAZO AND MA. FE RIÑOZA ALARAS, Respondents.

  • G.R. No. 209447, August 11, 2015 - PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT (PCGG), Petitioner, v. HON. WINLOVE M. DUMAYAS, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 59, MAKATI CITY AND UNITED COCONUT PLANTERS BANK (UCPB), Respondents.; G.R. NO. 210901 - PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT (PCGG), Petitioner, v. HON. WINLOVE M. DUMAYAS, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH 59, MAKATI CITY AND UNITED COCONUT PLANTERS LIFE ASSURANCE CORPORATION (COCOLIFE), Respondents.

  • G.R. No. 188739, August 05, 2015 - BENJAMIN E. RAVAGO, Petitioner, v. METROPOLITAN BANK & TRUST COMPANY, SUBSTITUTED BY BRIGHT VENTURES REALTY, INC., Respondents.

  • G.R. No. 215714, August 12, 2015 - OF THE PHILIPPINES, Plaintiff-Appellee, v. EFREN BASAL CAYAS, Accused-Appellant.

  • A.M. No. 11238-Ret., August 18, 2015 - IN RE: EXPIRATION OF FIXED TERM OF OFFICE OF ATTY. SAADUDDIN A. ALAUYA, OFFICE OF THE JURISCONSULT, ZAMBOANGA CITY

  • G.R. No. 167838, August 05, 2015 - JOSE V. TOLEDO, GLENN PADIERNOS AND DANILO PADIERNOS, Petitioner, v. COURT OF APPEALS, LOURDES RAMOS, ENRIQUE RAMOS, ANTONIO RAMOS, MILAGROS RAMOS AND ANGELITA RAMOS AS HEIRS OF SOCORRO RAMOS, GUILLERMO PABLO, PRIMITIVA CRUZ AND A.R.C. MARKETING CORPORATION, REPRESENTED BY ITS PRESIDENT, ALBERTO C. DY, Respondents.

  • A.C. No. 10635, August 26, 2015 - NOEL S. SORREDA, Complainant, v. ATTY. DAVID L. KHO, Respondent.

  • A.M. No. P-14-3253, August 19, 2015 - NICETAS TANIEZA-CALAYOAN, Complainant, v. ELMER JERRY C. CALAYOAN, PROCESS SERVER, REGIONAL TRIAL COURT, BRANCH 2, BANGUED, ABRA, Respondent.

  • A.C. No. 8084, August 24, 2015 - PATROCINIA H. SALABAO, Complainant, v. ATTY. ANDRES C. VILLARUEL, JR., Respondent.

  • A.C. No. 9834, August 26, 2015 - SAMUEL B. ARNADO, Complainant, v. ATTY. HOMOBONO A. ADAZA, Respondent.

  • A.C. No. 7314, August 25, 2015 - MARY ANN T. FLORES, Complainant, v. ATTY. JOVENCIO LL. MAYOR, JR., Respondent.

  • A.M. No. CA-12-26-P, August 17, 2015 - OFFICE OF THE COURT ADMINISTRATOR, Complainant, v. ANA MARIE ABARENTOS, RECORDS OFFICER IV, COURT OF APPEALS, CEBU CITY, Respondent.

  • G.R. No. 206220, August 19, 2015 - LUIS UY, SUBSTITUTED BY LYDIA UY VELASQUEZ AND SHIRLEY UY MACARAIG, Petitioner, v. SPOUSES JOSE LACSAMANA AND ROSAURA* MENDOZA, SUBSTITUTED BY CORAZON BUENA, Respondents.

  • G.R. No. 214865, August 19, 2015 - ROSVEE C. CELESTIAL, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 201822, August 12, 2015 - MARINA PORT SERVICES, INC., Petitioner, v. AMERICAN HOME ASSURANCE CORPORATION, Respondent.

  • G.R. No. 202967, August 05, 2015 - ALICIA Y. LAUREL, SUBSTITUTED BY HER SOLE HEIR AND LEGAL REPRESENTATIVE JUAN MIGUEL Y. LAUREL, Petitioner, v. FERDINAND M. VARDELEON, Respondent.

  • G.R. No. 183869, August 03, 2015 - LEONARDO L. VILLALON, Petitioner, v. RENATO E. LIRIO, Respondent.

  • G.R. No. 179751, August 05, 2015 - HERMINIA L. MENDOZA, IN HER CAPACITY AS OIC OF THE REGISTER OF DEEDS OF LUCENA CITY, Petitioner, v. SPOUSES ARMANDO AND ANGELA GARANA AND FAR EAST BANK & TRUST CO., INC., Respondents.

  • G.R. No. 208320, August 19, 2015 - GRACE DAVID Y CESAR, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 174542, August 03, 2015 - KAREN GO, Petitioner, v. LAMBERTO ECHAVEZ, Respondent.

  • G.R. No. 196875, August 19, 2015 - TEDDY MARAVILLA, Petitioner, v. JOSEPH RIOS, Respondent.

  • G.R. No. 205113, August 26, 2015 - HONORLITA ASCANO-CUPINO AND FLAVIANA ASCANO-COLOCADO, Petitioners, v. PACIFIC REHOUSE CORPORATION, Respondent.

  • G.R. No. 205823, August 17, 2015 - PEOPLE OF THE PHILIPPINES, Appellee, v. REGIE BREIS Y ALVARADO AND GARY YUMOL Y TUAZON,* Appellants.

  • G.R. No. 198643, August 19, 2015 - MARSMAN & COMPANY AND QUIRINO R. ILEDAN, Petitioners, v. ARTEMIO M. LIGO, Respondent.

  • G.R. No. 214054, August 05, 2015 - NG MENG TAM, Petitioner, v. CHINA BANKING CORPORATION, Respondent.

  • A.M. No. P-11-2982 (Formerly O.C.A. IPI No. 08-2913-P), August 17, 2015 - FORMER JUDGE FERNANDO VIL PAMINTUAN, Complainant, v. SALVADOR G. COMUYOG, JR., CLERK III, Respondent.

  • G.R. No. 187882, August 24, 2015 - PHILIPPINE NATIONAL BANK, Petitioner, v. SPOUSES HIPPOCRATES AND MELANIE PIMENTEL, Respondents.

  • G.R. No. 190984, August 19, 2015 - ACOMARIT ACOMARIT LIMITED, PHILS., AND/OR HONGKONG, Petitioners, v. GOMER L. DOTIMAS, Respondent.

  • G.R. No. 170706, August 26, 2015 - PRUDENCIO CARANTO, Petitioner, v. BERGESEN D.Y. PHILS. AND/OR BERGESEN D.Y. A.S.A., Respondents.

  • G.R. No. 194617, August 05, 2015 - LA TONDEÑA, INC., Petitioner, v. REPUBLIC OF THE PHILIPPINES Respondent.

  • G.R. No. 206612, August 17, 2015 - TOYOTA ALABANG, INC., Petitioner, v. EDWIN GAMES, Respondent.

  • G.R. No. 203142, August 26, 2015 - THE PHILIPPINE PORTS AUTHORITY (PPA), Petitioner, v. COALITION OF PPA OFFICERS AND EMPLOYEES, REPRESENTED BY HECTOR E. MIOLE, ET AL., Respondents.

  • G.R. No. 182157, August 17, 2015 - ANLUD METAL RECYCLING CORPORATION, AS REPRESENTED BY ALFREDO A. DY, Petitioner, v. JOAQUIN ANG, Respondent.

  • A.C. No. 5161, August 25, 2015 - RE: IN THE MATTER OF THE PETITION FOR REINSTATEMENT OF ROLANDO S. TORRES AS A MEMBER OF THE PHILIPPINE BAR.

  • G.R. Nos. 191370-71, August 10, 2015 - RODOLFO BASILONIA, LEODEGARIO CATALAN AND JOHN BASILONIA, Petitioners, v. HON. DELANO F. VLLLARUZ, ACTING IN HIS CAPACITY AS PRESIDING JUDGE OF THE REGIONAL TRIAL COURT, ROXAS CITY, BRANCH 16, AND DIXON ROBLETE, Respondents.

  • G.R. No. 165146, August 12, 2015 - SECURITIES AND EXCHANGE COMMISSION AND VERNETTE G. UMALI, Petitioners, v. BAGUIO COUNTRY CLUB CORPORATION, Respondent.; G.R. N0. 165209 - RAMON K. ILUSORIO AND ERLINDA K. ILUSORIO, Petitioners, v. BAGUIO COUNTRY CLUB CORPORATION, Respondent.

  • G.R. No. 203066, August 05, 2015 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. RODELIO LLOBERA Y OFIZA, Accused-Appellant.

  • G.R. No. 190892, August 17, 2015 - VICENTE H. MANULAT, JR., Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 183370, August 17, 2015 - NATION PETROLEUM GAS, INCORPORATED, NENA ANG, MARIO ANG, ALISON A. SY, GUILLERMO G. SY, NELSON ANG, LUISA ANG, RENATO C. ANG, PAULINE T. ANG, RICKY C. ANG,1 AND MELINDA ANG, Petitioners, v. RIZAL COMMERCIAL BANKING CORPORATION, SUBSTITUTED BY PHILIPPINE ASSET GROWTH ONE, INC., Respondent.

  • G.R. No. 213455, August 11, 2015 - JUAN PONCE ENRILE, Petitioner, v. PEOPLE OF THE PHILIPPINES, HON. AMPARO M. CABOTAJE-TANG, HON. SAMUEL R. MARTIRES, AND HON. ALEX L. QUIROZ OF THE THIRD DIVISION OF THE SANDIGANBAYAN, Respondents.

  • G.R. No. 201405, August 24, 2015 - LIWAYWAY ANDRES, RONNIE ANDRES, AND PABLO B. FRANCISCO, Petitioners, v. STA. LUCIA REALTY & DEVELOPMENT, INCORPORATED, Respondent.

  • G.R. No. 153810, August 12, 2015 - WINSTON R. GARCIA, IN HIS CAPACITY AS PRESIDENT AND GENERAL MANAGER OF THE GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), Petitioners, v. ANGELITA TOLENTINO, EDELITO ZOLLO EDRALINDA, KATHLYN A. UMALI, VIVIAN ROSIELLE CERVANTES, EDITH MEDINA, ROMELO CABANGON, ET AL., Respondents.; G.R. NO. 167297 - MELINA I. GARCIA, CECILIA V. LAS, NIMFA PENALOSA, ROSANA R. ZEPEDA, RACHELLE L. JACOB, MARIBEL B. TENA, AND EDUVIGIS S. ANGELES (IN LIEU OF ANGELITA TOLENTINO FOR THE NATIONAL FORESTATION DEVELOPMENT OFFICE-DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, ET AL.), Petitioners, v. WINSTON GARCIA, ET AL., Respondents.

  • G.R. No. 192943, August 12, 2015 - UNITED DUMANGAS PORT DEVELOPMENT CORPORATION, Petitioner, v. PHILIPPINE PORTS AUTHORITY, ATTY. OSMAR M. SEVILLA, GENERAL MANAGER, ATTY. FERNANDO B. CLAVERINA, PORT MANAGER, PORT MANAGEMENT OFFICER-ILOILO; AND RAUL T. SANTOS, PORT DISTRICT MANAGER, PORT DISTRICT OFFICE-VISAYAS, Respondents.

  • G.R. No. 200114, August 24, 2015 - SOCIAL SECURITY SYSTEM, Petitioner, v. DEBBIE UBAÑA, Respondent.

  • G.R. No. 177168, August 03, 2015 - NAVY OFFICERS' VILLAGE ASSOCIATION, INC. (NOVAI), Petitioner, v. REPUBLIC OF THE PHILIPPINES, Respondent.

  • G.R. No. 163598, August 12, 2015 - AGRARIAN REFORM BENEFICIARIES ASSOCIATION (ARBA), AS REPRESENTED BY ISAIAS "ACE" NICOLAS IN HIS CAPACITY AS PRESIDENT, VIOLETA BATADHAY, JESUS F. DANAO, DOMINADOR RIOSA, EVA I. FLORIDO, VIRGINIA CARIAS, WILLIAM D. DORONELA, ELSA MENGOLIO, FEDELINA AMENGYAO, REBECCA REBAMBA, MELANI CADAG, SOFRONIA SABORDO, MYRNA SANTIAGO, JOSELYNDA MANALANZAN, NORA I. REBUZANO, NATIVIDAD PLACIDO, ALGERICO L. GAEGUERA, RUBEN G. ACEBEDO, MARGIE M. VALDEZ, HELEN S. BUNI, EMELINDA FERNANDEZ, JULIETA J. AVENGONZA, VIOLETA C. ASIS, CARINA C. CABRERA, EDUARDO M. DILAY, SIMEONA V. ROLEDA, EVELYN SANTO ELEUTERIA A. NOLASCO, TERESA CRUZ, MELBA ABRENICA, BESAME VILLACORTA, ROSALINA HERNANDEZ, VERONICA DOMULOT, LUCIA SOUN, ILUMENADA RONQUILLO, REGINA LOPEZ, AMPARO GREY, HIPOLITO MANDAO, JUAN DELA VEGA, PRESCILIANA LLEMIT, LEBERETA IGNACIO, FRANCISCO VALDEMOR, Petitioners, v. FIL-ESTATE INC., PROPERTIES, Respondent.; G.R. NO. 164660 - THE DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB), AGRARIAN REFORM BENEFICIARIES, INC., ET AL., Petitioners, v. KINGSVILLE CONSTRUCTION AND DEVELOPMENT CORP. AND JOHNSON ONG, Respondents.; G.R. NO. 164779 - AGRARIAN REFORM BENEFICIARIES ASSOCIATION (ARBA), VIOLETA BATADHAY, NATIVIDAD PLACIDO, JESUS F. DANAO, EVA I. FLORIDO, VIRGINIA CARIAS, WILLIAM D. DORONELA, ELSA MENGOLIO, ROBERTO ISIP, REBECCA REBAMBA, SOFRONIA SABORDO, MYRNA SANTIAGO, JOSELYNDA MANALANZAN, NORA I. REBUZANO, ALGERICO L. GALQUERA, RUBEN G. ACEBEDO, MARGIE M. VALDEZ, HELEN S. BUNI, JULIETA J. AVENGONZA, VIOLETA C. ASIS, CARINA C. CABRERA, EDUARDO M. DILAY, ELEUTERIA A. NOLASCO, TERESA CRUZ, MELBA ABRENICA, VERONICA DOMULOT, LUCIA SUN, ILUMENADA RONQUILLO AND PRESCILIANA LLEMIT, Petitioners, v. KINGSVILLE CONSTRUCTION AND DEVELOPMENT CORPORATION AND JOHNSONONG, Respondent.

  • G.R. No. 164974, August 05, 2015 - CHARLIE TE, Petitioner, v. HON. AUGUSTO V. BREVA, IN HIS CAPACITY AS THE PRESIDING JUDGE OF THE REGIONAL TRIAL COURT, 11TH JUDICIAL REGION, BRANCH 10, DAVAO CITY; U R. BAHINTING, IN HIS CAPACITY AS SPECIAL INVESTIGATOR OF THE NATIONAL BUREAU OF INVESTIGATION, SARANGGANI DISTRICT OFFICE; AND PRYCE GASES, INC., Respondents.

  • G.R. No. 211302, August 12, 2015 - PHILIPPINE TRANSMARINE CARRIERS, INC., CARLOS C. SALINAS, AND NORWEGIAN CREW MANAGEMENT A/S, Petitioners, v. CESAR C. PELAGIO, Respondent.

  • G.R. No. 210164, August 18, 2015 - ROMMEL C. ARNADO, Petitioner, v. COMMISSION ON ELECTIONS AND FLORANTE CAPITAN, Respondents.

  • G.R. No. 211649, August 12, 2015 - AQA GLOBAL CONSTRUCTION, INC., Petitioner, v. PLANTERS DEVELOPMENT BANK, Respondent.; G.R. No. 211742 - JE-AN SUPREME BUILDERS AND SALES CORPORATION, Petitioner, v. PLANTERS DEVELOPMENT BANK, Respondent.

  • G.R. No. 203355, August 18, 2015 - LEO R. ROSALES, EDGAR SOLIS JONATHAN G. RANIOLA, LITO FELICIANO, RAYMUNDO DIDAL, JR., NESTOR SALIN, ARNULFO S. ABRIL, RUBEN FLORES, DANTE FERMA AND MELCHOR SELGA, Petitioners, v. NEW A.N.J.H. ENTERPRISES & N.H. OIL MILL CORPORATION, NOEL AWAYAN, MA. FE AWAYAN, BYRON ILAGAN, HEIDI A. ILAGAN AND AVELINO AWAYAN, Respondents.

  • A.M. No. RTJ-14-2383 (Formerly A.M. OCA I.P.I No. 05-2301-RTJ), August 17, 2015 - DR. CORAZON D. PADERANGA, DULCE P. GUIBELONDO, PATRIA P. DIAZ, CARMENCITA P. ORSENO, AND DR. AMOR P. GALON, Complainants, v. HONORABLE RUSTICO D. PADERANGA, IN HIS CAPACITY AS THE PRESIDING JUDGE OF THE REGIONAL TRIAL COURT, BRANCH 28, IN MAMBAJAO, CAMIGUIN, Respondent.; A.M. No. RTJ-07-2033 (FORMERLY A.M. OCA I.P.I No. 06-2485-RTJ) - PATRIA PADERANGA DIAZ, Complainant, v. HON. RTC JUDGE RUSTICO D. PADERANGA, AS THE PRESIDING JUDGE OF THE REGIONAL TRIAL COURT, BRANCH 28, IN MAMBAJAO, CAMIGUIN, Respondent.

  • G.R. No. 160924, August 05, 2015 - TERELAY INVESTMENT AND DEVELOPMENT CORPORATION, Petitioner, v. CECILIA TERESITA J. YULO, Respondent.

  • G.R. No. 213286, August 26, 2015 - MAMERTA LOPEZ CLAUDIO, EDUARDO L. CLAUDIO, ASUNCION CLAUDIO-CONTEGINO, ANA CLAUDIO-ISULAT, DOLORES CLAUDIO-MABINI, AND FERMIN L. CLAUDIO, Petitioners, v. SPOUSES FEDERICO AND NORMA SARAZA, Respondent.

  • G.R. No. 200295, August 19, 2015 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. EDGAR BOLO Y FRANCO, Accused-Appellant.

  • G.R. No. 209331, August 24, 2015 - DEPARTMENT OF FINANCE, REPRESENTED BY HON. CESAR V. PURISIMA IN HIS OFFICIAL CAPACITY AS SECRETARY, AND THE BUREAU OF CUSTOMS, REPRESENTED BY HON. ROZZANO RUFINO B. BIAZON, IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF CUSTOMS, Petitioners, v. HON. MARINO M. DELA CRUZ, JR., IN HIS CAPACITY AS EXECUTIVE JUDGE, REGIONAL TRIAL COURT, MANILA, HON. FELICITAS O. LARON-CACANINDIN, IN HER CAPACITY AS PRESIDING JUDGE, REGIONAL TRIAL COURT, MANILA, BRANCH 17, RONNIE C. SILVESTRE, EDWARD P. DELA CUESTA, ROGEL C. GATCHALIAN, IMELDA D.CRUZ, LILIBETH S. SANDAG, RAYMOND P. VENTURA, MA. LIZA S. TORRES, ARNEL C. ALCARAZ, MA. LOURDES V. MANGAOANG, FRANCIS AGUSTIN Y. ERPE, CARLOS T. SO, MARIETTA D. ZAMORANOS, CARMELITA M. TALUSAN,1] AREFILES H. CARREON,2] AND ROMALINO G. VALDEZ, Respondents.

  • A.C. No. 6738, August 12, 2015 - GABRIELA CORONEL, Petitioner, v. ATTY. NELSON A. CUNANAN, Respondent.

  • G.R. No. 170671, August 19, 2015 - FILADELFA T. LAUSA, LORETA T. TORRES, PRIMITIVO TUGOT AND ANACLETO T. CADUHAY, Petitioners, v. MAURICIA QUILATON, RODRIGO Q. TUGOT, PURIFICACION T. CODILLA, TEOFRA T. SADAYA, ESTRELLITA T. GALEOS AND ROSITA T. LOPEZ, Respondents.

  • G.R. No. 202322, August 19, 2015 - LIGHT RAIL TRANSIT AUTHORITY, Petitioner, v. ROMULO S. MENDOZA, FRANCISCO S. MERCADO, ROBERTO M. REYES, EDGARDO CRISTOBAL, JR., AND RODOLFO ROMAN, Respondents.

  • G.R. No. 198751, August 19, 2015 - FLOR CAÑAS-MANUEL, Petitioner, v. ANDRES D. EGANO, Respondent.

  • G.R. No. 181111, August 17, 2015 - JACKSON PADIERNOS Y QUEJADA, JACKIE ROXAS Y GERMAN AND ROLANDO MESINA Y JAVATE, Petitioners, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 202645, August 05, 2015 - FORTUNATO R. BARON, MANOLO B. BERSABAL, AND RECTO A. MELENDRES, Petitioners, v. EPE TRANSPORT, INC. AND/OR ERNESTO P. ENRIQUEZ, Respondents.

  • G.R. No. 211263, August 05, 2015 - OKS DESIGNTECH, INC. REPRESENTED BY ZAMBY O. PONGAD, Petitioner, v. MARY JAYNE L. CACCAM, Respondent.

  • G.R. No. 175098, August 26, 2015 - ISMAEL V. CRISOSTOMO, Petitioner, v. MARTIN P. VICTORIA, Respondent.

  • A.M. No. CA-15-33-P [Formerly OCA IPI No. 13-207-CA-P], August 24, 2015 - TERESITA R. MARIGOMEN, CLERK OF COURT, COURT OF APPEALS, MANILA, Complainant, v. RONELO G. LABAR, DRIVER, MAILING AND DELIVERY SECTION, COURT OF APPEALS, CEBU STATION, Respondent.

  • G.R. No. 168157, August 19, 2015 - HILARIO P. SORIANO, Petitioner, v. DEPUTY OMBUDSMAN FOR LUZON VICTOR C. FERNANDEZ, FLORIZA A. BRIONES, GRAFT INVESTIGATION AND PROSECUTION OFFICER II, DONNA B. PASCUAL, GRAFT INVESTIGATION AND PROSECUTION OFFICER II, AND ATTY. ADONIS C. CLEOFE, Respondents.

  • G.R. No. 200841-42, August 26, 2015 - CE LUZON GEOTHERMAL POWER COMPANY, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

  • G.R. No. 171582, August 19, 2015 - ALBERTO T. LASALA, PREVIOUSLY DOING BUSINESS UNDER THE STYLE PSF SECURITY AGENCY, Petitioner, v. THE NATIONAL FOOD AUTHORITY, Respondent.

  • G.R. No. 169343, August 05, 2015 - SAN MIGUEL PROPERTIES, INC., Petitioner, v. BF HOMES, INC., Respondent.

  • G.R. No. 166102, August 05, 2015 - MANILA ELECTRIC COMPANY, Petitioner, v. THE CITY ASSESSOR AND CITY TREASURER OF LUCENA CITY, Respondents.

  • A.M. No. 99-7-01-SC, August 18, 2015 - RE: REQUEST OF RETIRED SUPREME COURT AND COURT OF APPEALS JUSTICES FOR INCREASE/ADJUSTMENT OF THEIR DECEMBER 1998 PENSIONS

  • A.M. No. RTJ-15-2439 (Formerly: OCA I.P.I. No. 12-3989-RTJ), August 26, 2015 - ARIEL "AGA" MUHLACH, Complainant, v. EXECUTIVE JUDGE MA. ANGELA ACOMPAÑADO-ARROYO, REGIONAL TRIAL COURT, SAN JOSE CITY, CAMARINES SUR, Respondent.

  • G.R. No. 169385, August 26, 2015 - TEOFILO GIANGAN, SANTOS BONTIA (DECEASED), AND LIBERATO DUMAIL (DECEASED), Petitioners, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 205722, August 19, 2015 - REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, Petitioners, v. LEGAL HEIRS OF JOSE L. AFRICA, Respondents.

  • G.R. No. 169710, August 19, 2015 - REPUBLIC OF THE PHILIPPINES, Petitioner, v. JOSE ALBERTO ALBA, REPRESENTED BY HIS ATTORNEY-IN-FACT, MANUEL C. BLANCO, JR., Respondent.

  • G.R. No. 162692, August 26, 2015 - NILO V. CHIPONGIAN, Petitioner, v. VICTORIA BENITEZ-LIRIO, FEODOR BENITEZ AGUILAR, AND THE COURT OF APPEALS, Respondents.

  • G.R. No. 206032, August 19, 2015 - JOSE RUDY L. BAUTISTA, Petitioner, v. ELBURG SHIPMANAGEMENT PHILIPPINES, INC., AUGUSTEA SHIPMANAGEMENT ITALY, AND/OR CAPTAIN ANTONIO S. NOMBRADO, Respondents.

  • G.R. No. 208354, August 26, 2015 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. RICARDO BACUS, Accused-Appellant.

  • G.R. No. 168258, August 17, 2015 - RICARDO V. QUINTOS, Petitioner, v. DEVELOPMENT BANK OF THE PHILIPPINES AND PHILIPPINE NATIONAL BANK, Respondents.

  • G.R. No. 181111, August 17, 2015 - JACKSON PADIERNOS Y QUEJADA, JACKIE ROXAS Y GERMAN AND ROLANDO MESINA Y JAVATE, Petitioners, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • G.R. No. 202645, August 05, 2015 - FORTUNATO R. BARON, MANOLO B. BERSABAL, AND RECTO A. MELENDRES, Petitioners, v. EPE TRANSPORT, INC. AND/OR ERNESTO P. ENRIQUEZ, Respondents.

  • G.R. No. 175098, August 26, 2015 - ISMAEL V. CRISOSTOMO, Petitioner, v. MARTIN P. VICTORIA, Respondent.

  • G.R. No. 211263, August 05, 2015 - OKS DESIGNTECH, INC. REPRESENTED BY ZAMBY O. PONGAD, Petitioner, v. MARY JAYNE L. CACCAM, Respondent.

  • A.M. No. CA-15-33-P [Formerly OCA IPI No. 13-207-CA-P], August 24, 2015 - TERESITA R. MARIGOMEN, CLERK OF COURT, COURT OF APPEALS, MANILA, Complainant, v. RONELO G. LABAR, DRIVER, MAILING AND DELIVERY SECTION, COURT OF APPEALS, CEBU STATION, Respondent.

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  •  





     
     

    G.R. No. 169710, August 19, 2015 - REPUBLIC OF THE PHILIPPINES, Petitioner, v. JOSE ALBERTO ALBA, REPRESENTED BY HIS ATTORNEY-IN-FACT, MANUEL C. BLANCO, JR., Respondent.

      G.R. No. 169710, August 19, 2015 - REPUBLIC OF THE PHILIPPINES, Petitioner, v. JOSE ALBERTO ALBA, REPRESENTED BY HIS ATTORNEY-IN-FACT, MANUEL C. BLANCO, JR., Respondent.

    PHILIPPINE SUPREME COURT DECISIONS

    FIRST DIVISION

    G.R. No. 169710, August 19, 2015

    REPUBLIC OF THE PHILIPPINES, Petitioner, v. JOSE ALBERTO ALBA, REPRESENTED BY HIS ATTORNEY-IN-FACT, MANUEL C. BLANCO, JR., Respondent.

    D E C I S I O N

    BERSAMIN, J.:

    Under appeal is the decision promulgated on September 8, 2005,1 whereby the Court of Appeals (CA) upheld the judgment rendered on January 31, 2001 by the 7th Municipal Circuit Trial Court (MCTC) of Ibajay-Nabas, stationed in Ibajay, Aklan granting the application of the respondent for the registration of five parcels of land with a total area of 213,037 square meters, more or less, all situated in Barangay Rizal, Municipality of Nabas, Province of Aklan.2

    Antecedents

    The respondent was the purchaser for value of the parcel of land known as Lot No. 9100 situated in Barangay Rizal, Municipality of Nabas, Province of Aklan, and subdivided and designated in the approved survey plan as Lot No. 9100-A, with an area of 50,000 square meters, more or less; Lot No. 9100-B, with an area of 49,999 square meters, more or less; Lot No. 9100-C, with an area of 50,000 square meters, more or less; Lot No. 9100-D, with an area of 35,001 square meters, more or less; and Lot No. 9100-E, with an area of 28,037 square meters, more or less. He applied for the original registration of title over the parcels of land in the MCTC.3

    The Office of the Solicitor General (OSG), in behalf of the Republic of the Philippines, opposed the application for original registration of title, contending that the respondent and his predecessors-in-interest had not been in open, continuous, exclusive and notorious possession and occupation of the lands in question since June 12, 1945.4

    After trial, the MCTC rendered judgment on the application on January 31, 2001, disposing:cralawlawlibrary

    WHEREFORE, premises considered, judgment is hereby rendered GRANTING the application for registration of the parcel of land designated in the approved Survey Plan (Exhibit "C") known as Lot No. 9100, Cad.758-D, Nabas Cadastre and described in the Technical Description (Exhibit "D") with an area of FIFTY THOUSAND (50,000) square meters, more or less, Exhibit "D-l" with an area of FORTY NINE THOUSAND NINE HUNDRED NINETY NINE (49,999) Exhibit "D-2" with an area of FIFTY THOUSAND (50,000) square meters, more or less, Exhibit "D-3" with an area of THIRTY FIVE THOUSAND ONE (35,001) square meters, more or less, and Exhibit "D-4" with an area of TWENTY EIGHT THOUSAND THIRTY SEVEN (28,037) square meters, more or less, or a total area of TWO HUNDRED THIRTEEN THOUSAND THIRTY SEVEN (213,037) SQUARE METERS, more or less, situated at Barangay Rizal, Municipality of Nabas, Province of Aldan, Island of Panay, Philippines, under the Property Registration Decree (PD 1529), and title thereto registered and confirmed in the name of JOSE ALBERTO ALBA, of legal age, married to Maria Beatris Morales, Filipino citizen, and presently residing at 34 Derby, White Plains, Quezon City, Metro Manila, and herein represented by his attorney-in-fact Manual C. Blanco, whose residence is at Viscarra Subdivision, Andagao, Kalibo, Aldan.

    After this decision shall have become final and executory, an order for the issuance of Decree of Registration of Title shall issue in favor of the applicant.

    SO ORDERED.5
    chanrobleslaw

    The OSG appealed the judgment to the CA upon the following errors, to wit:cralawlawlibrary

    1. That the lower court did not acquire jurisdiction over the application for registration due to the following:chanRoblesvirtualLawlibrary

      1. applicant-appellee's failure to show that the land subject of the application falls under the jurisdiction of the MCTC;ChanRoblesVirtualawlibrary

      2. applicant-appellee's failure to adduce the Official Gazette as evidence;ChanRoblesVirtualawlibrary

      3. applicant-appellee's failure to submit the original tracing cloth plan of the land subject of the application; and

    2. That the lower court erred in granting the application for registration when the applicant-appellee failed to prove possession of an alienable and disposable land of the public domain for the period and in the concept required by law.6
    Decision of the CA

    On September 8, 2005,7 the CA, finding that the trial court did not disregard evidence that affected the results of the case, and that there was no cogent reason to disturb its factual findings, decreed thusly:cralawlawlibrary

    WHEREFORE, in view of the foregoing premises, judgment is hereby rendered by us DISMISSING the appeal filed in this case and AFFIRMING the Decision dated January 31, 2001 rendered by the lower court in LRC Case No. N-057, LRA Record No. N-69758.

    SO ORDERED.8
    chanrobleslaw

    Issues

    Hence, this appeal, with the petitioner insisting, through the OSG, that:cralawlawlibrary

    I.

    THE COURT A QUO DID NOT ACQUIRE JURISDICTION OVER THE SUBJECT APPLICATION FOR REGISTRATION OF TITLE FOR FAILURE OF RESPONDENT TO SUBMIT THE ORIGINAL TRACING CLOTH PLAN OR SEPIA OF THE LAND APPLIED FOR REGISTRATION

    II.

    RESPONDENT FAILED TO PROVE POSSESSION OVER THE PROPERTY APPLIED FOR REGISTRATION IN THE CONCEPT REQUIRED BY LAW.9chanrobleslaw

    Ruling

    The appeal is meritorious.

    I
    Requirement for the submission of the approved tracing
    cloth plan may be excused if other competent means of
    proving identity and location of the lands subject of the
    application are available and produced in court

    Although conceding the mandatory requirement for the tracing cloth plan, the CA nonetheless ruled in favor of the respondent upon the authority of jurisprudence, including Director of Lands v. Court of Appeals,10 wherein the Court, citing the purpose for the requirement of submitting the tracing cloth plan to be the establishment of the true identity and location of the land subject of the application for registration in order to avoid boundary overlaps with adjacent lands,11 held that the respondent satisfied this purpose by submitting the approved plan and the technical descriptions of Lot No. 9100 (and its derivative lots);12 that the approved plan and the technical descriptions settled the identity and location of Lot No. 9100;13 and that considering that there was no glaring and irreconcilable discrepancy,14 the purpose of submitting the tracing cloth plan was fully served.

    The OSG maintains, however, that the submission of the tracing cloth plan was a statutory requirement of mandatory character, rendering the non-submission fatal to the application;15 that the submission could not be waived expressly or impliedly;16 that to fix the exact or definite identity of the land as shown in the approved plan and technical descriptions was the primary purpose of the submission;17 and that upon the respondent's failure to "actually" present the tracing cloth plan, the trial court did not acquire jurisdiction over the res, rendering the proceedings a nullity.18

    Section 17 of Presidential Decree No. 1529 (The Property Registration Decree of 1978) provides:cralawlawlibrary

    Section 17. What and where to file.-The application for land registration shall be filed with the Court of First Instance of the province or city where the land is situated. The applicant shall file, together with the application, all original muniments of titles or copies thereof and a survey plan of the land approved by the Bureau of Lands.

    The clerk of court shall not accept any application unless it is shown that the applicant has furnished the Director of Lands with a copy of the application and all annexes.
    chanrobleslaw

    Section 17 shows, indeed, that it is mandatory for the applicant for original registration to submit to the trial court not only the original or duplicate copies of the muniments of title but also the copy of the duly approved survey plan of the land sought to be registered. The survey plan is crucial because it provides reference of the property's exact identity and location.

    Did the respondent's submission of the approved plan and technical description, both of which had been approved by Regional Technical Director of the Land Management Services, satisfy the requirement?

    The answer is in the affirmative. In Republic v. Guinto-Aldana,19 this Court has relaxed the requirement for the submission of the tracing cloth plan by holding that:cralawlawlibrary

    Yet if the reason for requiring an applicant to adduce in evidence the original tracing cloth plan is merely to provide a convenient and necessary means to afford certainty as to the exact identity of the property applied for registration and to ensure that the same does not overlap with the boundaries of the adjoining lots, there stands to be no reason why a registration application must be denied for failure to present the original tracing cloth plan, especially where it is accompanied by pieces of evidence—such as a duly executed blueprint of the survey plan and a duly executed technical description of the property—which may likewise substantially and with as much certainty prove the limits and extent of the property sought to be registered.
    chanrobleslaw

    To the same effect were the rulings in Republic v. Court of Appeals,20Recto v. Republic21 and Republic v. Hubilla22 where the Court has pointed out that although the best means to identify a piece of land for registration purposes is the original tracing cloth plan approved by the Bureau of Lands (now the Lands Management Services of the Department of Environment and Natural Resources), other evidence could provide sufficient identification. In particular, the Court has said in Hubilla, citing Recto:cralawlawlibrary

    While the petitioner correctly asserts that the submission in evidence of the original tracing cloth plan, duly approved by the Bureau of Lands, is a mandatory requirement, this Court has recognized instances of substantial compliance with this rule. In previous cases, this Court ruled that blueprint copies of the original tracing cloth plan from the Bureau of Lands and other evidence could also provide sufficient identification to identify a piece of land for registration purposes, x x x23chanrobleslaw

    Here, the submission of the approved plan and technical description of Lot No. 9100 constituted a substantial compliance with the legal requirement of ascertaining the identity or location of the lands subject of the application for registration. The plan and technical description had been approved by the Regional Technical Director of the Land Management Services,24 and were subsequently identified, marked, and offered in evidence during the trial. Verily, no error can be attributed to the CA when it declared that:cralawlawlibrary

    It is our view that the original tracing cloth plan need not be presented in evidence because the identity and location of Lot No. 9100 were clearly established by the approved plan and the technical description thereof It must be noted that, during the hearing of the case, no person appeared and answered within the time allowed by the trial court to oppose the application filed by the applicant-appellee except the oppositor-appellant. As a result thereof, the testimonial and documentary evidence submitted and offered by the applicant-appellee were admitted as unrebutted and unopposed.

    Another point to consider is the fact that there is no glaring and irreconcilable discrepancy of the actual area of Lot No. 9100. Thus, there is no need to present in evidence the original tracing cloth plan.25
    chanrobleslaw

    II
    Respondent did not establish his required possession

    The CA upheld the finding of the MCTC that the respondent had established his title through documentary evidence like the tax declarations and the deed of sale from his predecessors-in-interest; and through evidence showing possession in the concept of an owner for over 50 years. It observed that although the tax declarations or realty tax payments relevant to the lands were not conclusive evidence of ownership, they were good indicia of his possession in the concept of owner, for "no one in his right mind would be paying taxes for a property that is not in his actual or at least constructive possession."26

    The OSG counters that the CA should not have upheld the application for registration on the basis of mere tax declarations and the testimonies of respondent's attorney-in-fact Manuel Blanco and Atty. Gideon de Pedro; and that their testimonies of possession since time immemorial did not meet the standard required by law to warrant the grant of the application.27 Essentially, the OSG contends that in order for the respondent as the applicant for the original registration of title to prove possession of alienable public land for the period prescribed by law that was open, exclusive and uninterrupted,28 he should not simply declare such possession as his and that of his predecessor-in-interest;29 that general statements or phrases were nothing more than conclusions of law that were not evidence of possession;30 that instead the respondent as the applicant should present specific acts showing the nature of the alleged possession;31 and that, accordingly, he did not discharge his burden of substantiation of his application.32

    We agree with the insistence of the OSG.

    Section 14(1) of P.D. No. 1529 provides:cralawlawlibrary

    SEC. 14. Who may apply. - The following persons may file in the proper Court of First Instance an application for registration of title to land, whether personally or through their duly authorized representatives:chanRoblesvirtualLawlibrary

    (1) Those who by themselves or through their predecessors-in-interest have been in open, continuous, exclusive and notorious possession of alienable and disposable lands of the public domain under a bonafide claim of ownership since June 12, 1945, or earlier.

    x x x x
    There are three requisites for the filing of an application for registration of title under Section 14(1) of PD 1529, namely: (1) that the property in question is alienable and disposable land of the public domain; (2) that the applicant by himself or through his predecessors-in-interest have been in open, continuous, exclusive and notorious possession and occupation; and (3) that such possession is under a bona fide claim of ownership since June 12, 1945, or earlier. In short, the right to file the application for original registration derives from a bona fide claim of ownership dating back to June 12, 1945, or earlier, by reason of the claimant's open, continuous, exclusive and notorious possession of alienable and disposable land of the public domain.

    Anent the aforecited requisites, the OSG controverted only the second, that is, that the respondent did not sufficiently prove his and his predecessors-in-interest's open, continuous, exclusive and notorious possession and occupation of the lands.

    The respondent did not satisfactorily demonstrate that his or his predecessors-in-interest's possession and occupation were of the nature and character contemplated by the law. None of his witnesses testified about any specific acts of ownership exercised by him or his predecessors-in-interest on the lands. The general statements of his witnesses on the possession and occupation were mere conclusions of law that did not qualify as competent and sufficient evidence of his open, continuous, exclusive and notorious possession and occupation. As we see it, the OSG has correctly observed that his witnesses did not testify on the specific acts of possession of the respondent or of his predecessors-in-interest.

    In Republic v. Alconaba,33 this Court has explained that the intent behind the law's use of the terms possession and occupation is to emphasize the need for actual and not just constructive or fictional possession, thus:cralawlawlibrary

    The law speaks of possession and occupation. Since these words are separated by the conjunction and, the clear intention of the law is not to make one synonymous with the other. Possession is broader than occupation because it includes constructive possession. When, therefore, the law adds the word occupation, it seeks to delimit the all encompassing effect of constructive possession. Taken together with the words open, continuous, exclusive and notorious, the word occupation serves to highlight the fact that for an applicant to qualify, his possession must not be a mere fiction. Actual possession of a land consists in the manifestation of acts of dominion over it of such a nature as a party would naturally exercise over his own property.34
    chanrobleslaw

    The Court reverses the CA. The respondent did not competently account for any act of occupation, development, cultivation or maintenance of the lands subject of his application, either on his part or on the part of his predecessors-in-interest for the entire time that they were supposedly in possession of the lands. Witnesses Manuel Blanco and Atty. Gideon de Pedro only testified of their possession since time immemorial but did not offer any details of specific acts indicative of possession and occupation. To prove possession, the offer of general statements or phrases is a merely self-serving, unsubstantiated assertion. Atty. de Pedro alleged that his uncle, Basilio de Pedro, had once possessed the lands that were cogonal, and used them for pasture and planting of coconut trees, but did not adduce any specific details indicating such activities as manifestations of ownership or possession that could be ultimately attributed to the respondent. That the lands were cogonal or planted with coconut trees did not conclusively disclose that the lands had been actively and regularly, not merely casually or occasionally, cultivated and maintained.

    The respondent's claim of ownership on the basis of the tax declarations alone did not also suffice. In Cequeña v. Bolante,35 the Court has pointed out that only when tax declarations were coupled with proof of actual possession of the property could they become the basis of a claim of ownership.36 Indeed, in the absence of actual public and adverse possession, the declaration of the land for tax purposes did not prove ownership.37 It is well-settled that tax declarations are not conclusive proof of possession or ownership, and their submission will not lend support in proving the nature of the possession required by the law.

    In sum, the respondent did not prove that he and his predecessors-in-interest have been in continuous, exclusive, and adverse possession and occupation thereof in the concept of owners. Hence, his application for original land registration fails.

    WHEREFORE, the Court GRANTS the petition for review on certiorari; REVERSES and SETS ASIDE the decision promulgated on September 8, 2005; DISMISSES the application for land registration of the respondent; and ORDERS the respondent to pay the costs of suit.

    SO ORDERED.chanroblesvirtuallawlibrary

    Sereno, C.J., Leonardo-De Castro, Perez, and Perlas-Bernabe, JJ., concur.

    Endnotes:


    1Rollo, pp. 27-36; penned by Associate Justice Isaias P. Dicdican (retired), with Associate Justice Ramon M. Bato, Jr. and Associate Justice Enrico A. Lanzanas (retired) concurring.

    2 CA rollo, pp. 15-22.

    3 Id. at 15.

    4 Records, pp. 42-43.

    5 Supra note 2, at 20-21.

    6Rollo, pp. 29-30.

    7 Supra note I.

    8 Id. at 35.

    9Rollo, p. 18.

    10 G.R. No. L-56613, March 14, 1988, 158 SCRA 568.

    11Rollo , pp. 32-33.

    12 Id. at 33.

    13 Id.

    14 Id.

    15 Id. at 19.

    16 Id. at 20.

    17 Id.

    18 Id.

    19 G.R. No. 175578, August 11, 2010,628 SCRA 210, 220.

    20 G.R. No. L-62680, November 9, 1988, 167 SCRA 150, 154, citing Republic v. Intermediate Appellate Court, No. L-70594, October 10, 1986, 144 SCRA 705, 708 and Director of Lands v. Court of Appeals, No. L-56613, March 14, 1988, 158 SCRA 568.

    21 G.R. No. 160421, October 4, 2004, 440 SCRA 79.

    22 G.R. No. 157683, February 11, 2005, 451 SCRA 181.

    23 Id. at 184-185.

    24 Supra note 8.

    25 Id. at 33.

    26 Id. at 34.

    27 Id. at 21.

    28 Id.

    29 Id.

    30 Id.

    31 Id.

    32 Id.

    33 G.R. No. 155012, April 14, 2004, 427 SCRA 611.

    34 Id. at 619-620.

    35 G.R. No. 137944, April 6, 2000, 330 SCRA 217.

    36 Id. at 226-227.

    37 Id. at 228.

    G.R. No. 169710, August 19, 2015 - REPUBLIC OF THE PHILIPPINES, Petitioner, v. JOSE ALBERTO ALBA, REPRESENTED BY HIS ATTORNEY-IN-FACT, MANUEL C. BLANCO, JR., Respondent.


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