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Philippine Supreme Court Jurisprudence > Year 2016 > July 2016 Decisions > G.R. No. 195147, July 11, 2016 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. PHILIPPINE NATIONAL BANK, Respondent.:




G.R. No. 195147, July 11, 2016 - COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. PHILIPPINE NATIONAL BANK, Respondent.

PHILIPPINE SUPREME COURT DECISIONS

FIRST DIVISION

G.R. No. 195147, July 11, 2016

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. PHILIPPINE NATIONAL BANK, Respondent.

D E C I S I O N

BERSAMIN, J.:

At issue is whether or not the respondent bank's interbank call loans transacted in 1997 were subject to documentary stamp taxes.

The petitioner appeals the September 21, 2010 decision rendered in C.T.A. EB Case No. 512,1 whereby the Court of Tax Appeals (CTA) En Bane affirmed the cancellation of Assessment No. 97-000064 for deficiency documentary stamp taxes imposed on the interbank call loans of respondent Philippine National Bank (PNB); and the resolution issued on January 10, 20112 denying the petitioner's motion for reconsideration.

Antecedents

On March 23, 2000, the petitioner issued Letter of Authority No. 00058992, which PNB received on March 28, 2000. The letter of authority authorized the examination of PNB's books of accounts and other accounting records in relation to its internal revenue taxes for taxable year 1997.3 On May 12, 2003, PNB received the preliminary assessment notice with details of discrepancies dated March 31, 2003, which indicated that PNB had deficiency payments of documentary stamp taxes (DST), withholding taxes on compensation, and expanded withholding taxes for taxable year 1997.4 On May 26, 2003, the petitioner issued a formal assessment notice, together with a formal letter of demand and details of discrepancies, requiring PNB to pay the following deficiency taxes: 5chanrobleslaw

Assessment No. 97-000064 for deficiency DST rising from PNB's interbank call loans and special savings account
P39,550,963.50
Assessment No. 97-000067 for deficiency expanded withholding tax
2,173,972.25
TOTAL
P41,724,935.75

PNB immediately paid Assessment No. 97-000067 on May 30, 2003, but filed a protest against Assessment No. 97-000064. The petitioner denied PNB's protest through the final decision on disputed assessment dated December 10, 2003. 6chanrobleslaw

On January 16, 2004, PNB filed its petition for review in the CTA (C.T.A. Case No. 6850). 7chanrobleslaw

On March 3, 2009, after trial, the CTA (First Division) rendered judgment, disposing:

chanRoblesvirtualLawlibrary
WHEREFORE, the instant Petition for Review is hereby PARTIALLY GRANTED. Accordingly, the assessment for deficiency documentary stamp taxes on petitioner's Interbank Call Loans for taxable year 1997 is hereby CANCELLED. However, the assessment for deficiency documentary stamp tax on petitioner's Special Savings Account for taxable year 1997 is hereby AFFIRMED.

Petitioner is hereby ORDERED to PAY respondent the amount of FOURTEEN MILLION SIX HUNDRED EIGHTY EIGHT THOUSAND FOUR HUNDRED SIXTY THREE PESOS AND FIFTEEN CENTAVOS (P14,688,463.15), representing deficiency documentary stamp tax for taxable year 1997, computed as follows:
Special Savings Account
7,833,847,016.00
Documentary Stamp Tax (0.30/200)
11,750,770.52
Surcharge - 25%
       2,937,692.63
Total Amount Due
14,688,463.15
In addition, petitioner is hereby ORDERED to PAY a penalty equivalent to twenty five percent (25%) and a delinquency interest equivalent to twenty percent (20%) per annum on the amount of P14,688,463.15 from February 15, 2004 until such amount is paid in full, pursuant to Sections 248 and 249 of the Tax Code.

SO ORDERED.8chanroblesvirtuallawlibrary
Both parties moved for partial reconsideration. 9 On July 7, 2009, the CTA in Division denied the petitioner's motion for partial reconsideration but held in abeyance the resolution of PNB's motion for partial reconsideration pending its submission of its supplemental formal offer of evidence to admit tax abatement documents. 10chanrobleslaw

Consequently, the petitioner appealed to the CTA En Banc on August 10, 2009.

On September 21, 2010, the CTA En Banc promulgated its assailed decision, viz.:

WHEREFORE, the instant Petition for Review is hereby DENIED for lack of merit. The assailed Decision dated March 3, 2009 and Resolution dated July 7, 2009 insofar as the cancellation of the assessment for Documentary Stamp Taxes on PNB's Interbank Call Loans for the taxable year 1997 is concerned, are AFFIRMED. No pronouncement as to costs.

SO ORDERED.11

The petitioner sought reconsideration,12 but the CTA En Banc denied the motion through the resolution dated January 10, 2011.13chanrobleslaw

Hence, this appeal by the petitioner.

The sole issue concerns whether or not PNB's interbank call loans for taxable year 1997 are subject to DST. The petitioner argues that:

chanRoblesvirtualLawlibrary
I

THE PNB'S TRANSACTIONS UNDER INTERBANK CALL LOANS ARE CONSIDERED LOAN AGREEMENTS BETWEEN PNB AND THE OTHER BANKS, HENCE, THEY ARE SUBJECT TO DOCUMENTARY STAMP TAXES (DST) UNDER SECTION 180 OF THE NATIONAL INFERNAL REVENUE CODE (NIRC) OF 1977, AS AMENDED BY REPUBLIC ACT (R.A.) NO. 7660 OF 1994.

II

THE FURTHER AMENDMENTS OF SECTION 180 OF THE 1977 NIRC (AS AMENDED BY R.A. NO. 7660 OF 1994) BY R.A. NO. 8424 OF 1998 AND R.A. NO. 9243 OF 2004 CONFIRM THE NATURE AND CHARACTER OF INTERBANK CALL LOANS AS LOAN AGREEMENTS AND/OR DEBT INSTRUMENTS, HENCE, THEY ARE SUBJECT TO DST.  

III

THERE IS NO LAW OR PROVISION IN THE 1977 NIRC, AS " AMENDED BY R.A. NO. 7660 OF 1994, THAT SPECIFICALLY AND EXPRESSLY EXEMPTS PNB'S INTERBANK CALL LOANS FOR THE TAXABLE YEAR 1997 FROM THE PAYMENT OF DST.14chanroblesvirtuallawlibrary

Ruling

The appeal lacks merit.

The petitioner claims that while interbank call loans were not considered as deposit substitute debt instruments, PNB's interbank call loans, which had a maturity of more than five days, were included in the concept of loan agreements; hence, the interbank call loans were subject to DST.15chanrobleslaw

The petitioner's claim cannot be upheld.

Firstly, the maturity of PNB's interbank call loans was irrelevant in determining its DST liability for taxable year 1997, relation to which the applicable law was the National Internal Revenue Code of 1977 (1977 NIRC), as amended by Presidential Decree No. 195916 and Republic Act No. 7660.17 The five-day maturity of interbank call loans came to be introduced only by Section 22(y)18 of the National Internal Revenue Code of 1997 (1997 NIRC), to wit:

chanRoblesvirtualLawlibrary
x x x x

(y) The term 'deposit substitutes' shall mean an alternative from of obtaining funds from the public (the term 'public means borrowing from twenty (20) or more individual or corporate lenders at any one time) other than deposits, through the issuance, endorsement, or acceptance of debt instruments for the borrowers own account, for the purpose of relending or purchasing of receivables and other obligations, or financing their own needs or the needs of their agent or dealer. These instruments may include, but need not be limited to bankers' acceptances, promissory notes, repurchase agreements, including reverse repurchase agreements entered into by and between the Bangko Sentral ng Pilipinas (BSP) and any authorized agent bank, certificates of assignment or participation and similar instruments with recourse: Provided, however, That debt instruments issued for interbank call loans with maturity of not more than five (5) days to cover deficiency in reserves against deposit liabilities, including those between or among banks and quasi-banks, shall not be considered as deposit substitute debt instruments. (Bold underscoring supplied for emphasis)

x x x x

The provisions of the 1997 NIRC cannot be given retrospective effect to the prejudice of PNB. This is because tax laws are prospective in application, unless their retroactive application is expressly provided.19chanrobleslaw

Secondly, PNB's interbank call loans are not taxable under Section 180 of the 1977 NIRC, as amended by R.A. No. 7660, which states:

chanRoblesvirtualLawlibrary
Sec. 180. Stamp tax on all loan agreements, promissory notes, bills of exchange, drafts, instruments and securities issued by the government or any of its instrumentalities, certificates of deposit bearing interest and others not payable on sight or demand. - On all loan agreements signed abroad wherein the object of the contract is located or used in the Philippines; bills of exchange (between points within the Philippines), drafts, instruments and securities issued by the Government or any of its instrumentalities o r certificates of deposits drawing interest, or orders for the payment of any sum of money otherwise than at sight or on demand, or on all promissory notes, whether negotiable or non- negotiable, except bank notes issued for circulation, and on each renewal of any such note, there shall be collected a documentary stamp tax of Thirty centavos (P0.30) on each two hundred pesos, or fractional part thereof, of the face value of any such agreement, bill of exchange, draft, certificate of deposit, or note: Provided, That only one documentary stamp tax shall be imposed on either loan agreement, or promissory notes issued to secure such loan, whichever will yield a higher tax: Provided, however, That loan agreements or promissory notes the aggregate of which does not exceed Two hundred fifty thousand pesos (P250,000) executed by an individual for his purchase on installment for his personal use or that of his family and not for business, resale, barter or hire of a house, lot, motor vehicle, appliance or furniture shall be exempt from the payment of the documentary stamp tax provided under this section." (Bold underscoring supplied for emphasis)

The petitioner insists that PNB's interbank call loans fell under the definition of a loan agreement found in Section 3(b) of Revenue Regulations No. 9-94, to wit:

chanRoblesvirtualLawlibrary
x x x x

(b) 'Loan agreement' refers to a contract in writing where one of the parties delivers to another money or other consumable thing, upon the condition that the same amount of the same kind and quality shall be paid. The term shall include credit facilities, which may be evidenced by credit memo, advice or drawings.

The terms "Loan Agreement" under Section 180 and "Mortgage" under Section 195, both of the Tax Code, as amended, generally refer to distinct and separate instruments. A loan agreement shall be taxed under Section 180, while a deed of mortgage shall be taxed under Section 195.20chanrobleslaw

x x x x

The insistence is bereft of merit.

An interbank call loan refers to the cost of borrowings from other resident banks and non-bank financial institutions with quasi-banking authority that is payable on call or demand.21 It is transacted primarily to correct a bank's reserve requirements.22 Under the Manual of Regulation for Banks (MORB) issued by the Bangko Sentral ng Pilipinas (BSP), interbank borrowings,23 which include interbank call loans, shall be evidenced by deposit substitute instruments containing the minimum features prescribed -under Section X235.3 of the MORB, except those that are settled through the banks' respective demand deposit accounts with the BSP via Philpass.24chanrobleslaw

Simply put, an interbank call loan is considered as a deposit substitute transaction by a bank performing quasi-banking functions to cover reserve deficiencies. It does not fall under the definition of a loan agreement. Even if it does, the DST liability under Section 180, supra, will only attach if the loan agreement was signed abroad but the object of the contract is located or used in the Philippines, which was not the case in regard to PNB's interbank call loans.

We note, however, that for taxation purposes interbank call loans are not considered as deposit substitutes by express provision of Section 20(y) of the 1977 NIRC, as amended by P.D. No. 1959, viz.:

Sec. 1. A new subsection (y) is inserted in Sec. 2 of the National Internal Revenue Code to read as follows:

chanRoblesvirtualLawlibrary x x x x

(y) 'Deposit substitutes' shall mean an alternative form of obtaining funds from the public, other than deposit, through the issuance, endorsement, or acceptance of debt instruments for the borrower's own account, for the purpose of relending or purchasing of receivables and other obligations, or financing their own needs or the needs of their agent or dealer. These instruments may include but need not be limited to banker's acceptances, promissory notes, repurchase agreements, certificates of assignment or participation and similar instruments with recourse as may be authorized by the Central Bank of the Philippines, for banks and non-bank financial intermediaries or by the Securities and Exchange Commission of the Philippines for commercial, industrial, finance companies and other non-financial

companies: Provided, however, that only debt instruments issued for inter-bank call loans to cover deficiency in reserves against deposit liabilities including those between or among banks and quasi-banks shall not be considered as deposit substitute debt instruments. (Bold Emphasis supplied.)

The foregoing notwithstanding, it can readily be discerned from Section 180, supra, that the DST of P0.30 on each P200.00, or fractional part thereof, shall only be imposed on the face value of: (1) loan agreements; (2) bills of exchange; (3) drafts; (4) instruments and securities issued by the Government or any of its instrumentalities; (5) certificates of deposits drawing interest; (6) orders for the payment of any sum of money otherwise than at sight or on demand; and (7) promissory notes, whether negotiable or non-negotiable, except bank notes issued for circulation, and on each renewal of any such note. Interbank call loans, although not considered as deposit substitutes, are not expressly included among the taxable instruments listed in Section 180; hence, they may not be held as taxable. As the Court has pointedly pronounced in Commissioner of Internal Revenue vs. Fortune Tobacco Corporation:25cralawredchanrobleslaw

xxx The rule in the interpretation of tax laws is that a statute will not be construed as imposing a tax unless it does so clearly, expressly, and unambiguously. A tax cannot be imposed without clear and express words for that purpose. Accordingly, the general rule of requiring adherence to the letter in construing statutes applies with peculiar strictness to tax laws and the provisions of a taxing act are not to be extended by implication. In answering the question of who is subject to tax statutes, it is basic that in case of doubt, such statutes are to be construed most strongly against the government and in favor of the subjects or citizens because burdens are not to be imposed nor presumed to be imposed beyond what statutes expressly and clearly import. As burdens, taxes should not be unduly exacted nor assumed beyond the plain meaning of the tax laws.

In fine, the cancellation of Assessment No. 97-000064 was in order.

WHEREFORE, the Court DENIES the petition for review on certiorari; and AFFIRMS the decision promulgated on September 21, 2010 in C.T.A. EB Case No. 512. No pronouncement on costs of suit.

SO ORDERED.

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

Endnotes:


1Rollo, pp. 36-49; penned by Associate Justice Cielito N. Mindaro-Grulla, with Presiding Justice Ernesto D. Acosta, Associate Justice Juanito C. Castafieda, Jr., Associate Justice Lovell R. Bautista, Associate Justice Erlinda P. Uy, Associate Justice Caesar A. Casanova and Associate Justice Olga Palanca- Enriquez concurring. Associate Justice Esperanza R. Fabon-Victorino was on leave.

2 Id. at 61-67.

3 Id. at 38.

4 Id. at 38-39.

5 Id. at 39-40.

6 Id. at 40-41.

7 Id. at 41.

8 Id. at 37.

9 Id. at 41.

10 Id. at 37-38, 41-42.

11 Id. at 48.

12 Id. at 50-60.

13 Id. at 67.

14 Id. at 14.

15 Id. at 21-22, 46-47.

16 Effective on October 10, 1984.

17 Effective on January 14, 1994.

18 Effective on January 1, 1998.

19 The Provincial Assessor of Marinduque v. Court of Appeals, G.R. No. 170532 April 30 2009 587 SCRA 285, 303.

20 Rollo, p. 16; see also Commissioner of Internal Revenue v. Filinvest Development Corporation, G.R. No. 163653, July 19, 2011, 654 SCRA 56, 80-81.

21 BSP Circular No. 512, February 3, 2006.

22 http://www.bsp.gov.ph/financial/open.asp. Last visited on July 6, 2016.

23 Section X343, Manual of Regulations for Banks Volume 1.

24 Section X235.4, Manual of Regulations for Banks Volume 1.

25cralawred G.R.Nos. 167274-75, July 21. 2008, 559 SCRA 160, 185.



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  • G.R. No. 211028, July 13, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JONATHAN ARCILLO, Accused-Appellant.

  • G.R. No. 191442, July 27, 2016 - THE MUNICIPALITY OF ALFONSO LISTA, IFUGAO, REPRESENTED BY CHARLES L. CATTILING, IN HIS CAPACITY AS MUNICIPAL MAYOR AND ESTRELLA S. ALIGUYON, IN HER CAPACITY AS MUNICIPAL TREASURER, Petitioner, v. THE COURT OF APPEALS, SPECIAL FORMER SIXTH DIVISION AND SN ABOITIZ POWER-MAGAT, INC.., Respondents.

  • G.R. No. 206927, July 13, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. DARIUS RENIEDO Y CAUILAN, Accused-Appellants.

  • G.R. No. 204267, July 25, 2016 - LUZ S. ALMEDA, Petitioner, v. OFFICE OF THE OMBUDSMAN (MINDANAO) AND THE PEOPLE OF THE PHILIPPINES, Respondents.

  • G.R. Nos. 205963-64, July 07, 2016 - AMANDO A. INOCENTES, Petitioner, v. PEOPLE OF THE PHILIPPINES, HON. ROLAND B. JURADO, IN HIS CAPACITY AS CHAIRPERSON, SANDIGANBAYAN, FIFTH DIVISION, HON. CONCHITA CARPIO MORALES, IN HER CAPACITY AS OMBUDSMAN, AS COMPLAINANT; AND HON. FRANCIS H. JARDELEZA, OFFICE OF THE SOLICITOR GENERAL (OSG), IN ITS CAPACITY AS COUNSEL FOR THE PEOPLE, Respondents.

  • G.R. No. 205839, July 07, 2016 - LAND BANK OF THE PHILIPPINES, Petitioner, v. NARCISO L. KHO, Respondent.; G.R. No. 205840 - MA. LORENA FLORES AND ALEXANDER CRUZ, Petitioners, v. NARCISO L. KHO, Respondent.

  • G.R. No. 206888, July 04, 2016 - PEOPLE OF THE PHILIPPINES, Appellee, v. MARITESS CAYAS Y CALITIS @ "TETET", Appellant.

  • G.R. No. 204222, July 04, 2016 - NEPTUNE METAL SCRAP RECYCLING, INC., Petitioner, v. MANILA ELECTRIC COMPANY AND THE PEOPLE OF THE PHILIPPINES, Respondents.

  • G.R. No. 191492, July 04, 2016 - PATRICIA SIBAYAN REPRESENTED BY TEODICIO SIBAYAN, Petitioner, v. EMILIO COSTALES, SUSANA ISIDRO, RODOLFO ISIDRO, ANNO ISIDRO AND ROBERTO CERANE., Respondents.

  • A.M. No. RTJ-14-2369 [Formerly OCA I.P.I. No. 12-3907-RTJ], July 26, 2016 - DEPARTMENT OF JUSTICE, REPRESENTED BY SECRETARY LEILA M. DE LIMA, Petitioner, v. JUDGE ROLANDO G. MISLANG, PRESIDING JUDGE, BRANCH 167, REGIONAL TRIAL COURT, PASIG CITY, RESPONDENT.; A.M. No. RTJ-14-2372 [FORMERLY OCA I.P.I. No. 11-3736-RTJ] - HOME DEVELOPMENT MUTUAL FUND (HDMF), REPRESENTED BY ATTY. JOSE ROBERTO F. PO, Petitioner, v. JUDGE ROLANDO G. MISLANG, PRESIDING JUDGE, BRANCH 167, REGIONAL TRIAL COURT, PASIG CITY, Respondent.

  • G.R. No. 210192, July 04, 2016 - ROSALINDA S. KHITRI AND FERNANDO S. KHITRI, Petitioners, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • A.M. OCA IPI No. 12-204-CA-J, July 26, 2016 - RE: VERIFIED COMPLAINT FOR DISBARMENT OF AMA LAND, INC. (REPRESENTED BY JOSEPH B. USITA) AGAINST COURT OF APPEALS ASSOCIATE JUSTICES HON. DANTON Q. BUESER, HON. SESINANDO E. VILLON AND HON. RICARDO G. ROSARIO.

  • G.R. No. 200537, July 13, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. RODRIGO QUITOLAY BALMONTE, Accused-Appellants.

  • G.R. No. 183934, July 20, 2016 - ERNESTO GALANG AND MA. OLGA JASMIN CHAN, Petitioners, v. BOIE TAKEDA CHEMICALS, INC. AND/OR KAZUHIKO NOMURA, Respondents.

  • G.R. No. 183645, July 20, 2016 - HEIRS OF GAMALIEL ALBANO, REPRESENTED BY ALEXANDER ALBANO AND ALL OTHER PERSON LIVING WITH THEM IN THE SUBJECT PREMISES, Petitioners, v. SPS. MENA C. RAVANES AND ROBERTO RA VANES, Respondents.

  • G.R. No. 212426, July 26, 2016 - RENE A.V. SAGUISAG, WIGBERTO E. TAŅADA, FRANCISCO "DODONG" NEMENZO, JR., SR. MARY JOHN MANANZAN, PACIFICO A. AGABIN, ESTEBAN "STEVE" SALONGA, H. HARRY L. ROQUE, JR., EVALYN G. URSUA, EDRE U. OLALIA, DR. CAROL PAGADUAN-ARAULLO, DR. ROLAND SIMBULAN, AND TEDDY CASIŅO, Petitioners, v. EXECUTIVE SECRETARY PAQUITO N. OCHOA, JR., DEPARTMENT OF NATIONAL DEFENSE SECRETARY VOLTAIRE GAZMIN, DEPARTMENT OF FOREIGN AFFAIRS SECRETARY ALBERT DEL ROSARIO, JR., DEPARTMENT OF BUDGET AND MANAGEMENT SECRETARY FLORENCIO ABAD, AND ARMED FORCES OF THE PHILIPPINES CHIEF OF STAFF GENERAL EMMANUEL T. BAUTISTA, Respondents.; G.R. No. 212444 - BAGONG ALYANSANG MAKABAYAN (BAYAN), REPRESENTED BY ITS SECRETARY GENERAL RENATO M. REYES, JR., BAYAN MUNA PARTY-LIST REPRESENTATIVES NERI J. COLMENARES, AND CARLOS ZARATE, GABRIELA WOMEN'S PARTY-LIST REPRESENTATIVES LUZ ILAGAN AND EMERENCIANA DE JESUS, ACT TEACHERS PARTY-LIST REPRESENTATIVE ANTONIO L. TINIO, ANAKPAWIS PARTY-LIST REPRESENTATIVE FERNANDO HICAP, KABATAAN PARTY-LIST REPRESENTATIVE TERRY RIDON, MAKABAYANG KOALISYON NG MAMAMAYAN (MAKABAYAN), REPRESENTED BY SATURNINO OCAMPO, AND LIZA MAZA, BIENVENIDO LUMBERA, JOEL C. LAMANGAN, RAFAEL MARIANO, SALVADOR FRANCE, ROGELIO M. SOLUTA, AND CLEMENTE G. BAUTISTA, Petitioners, v. DEPARTMENT OF NATIONAL DEFENSE (DND) SECRETARY VOLTAIRE GAZMIN, DEPARTMENT OF FOREIGN AFFAIRS SECRETARY ALBERT DEL ROSARIO, EXECUTIVE SECRETARY PAQUITO N. OCHOA, JR., ARMED FORCES OF THE PHILIPPINES CHIEF OF STAFF GENERAL EMMANUEL T. BAUTISTA, DEFENSE UNDERSECRETARY PIO LORENZO BATINO, AMBASSADOR LOURDES YPARRAGUIRRE, AMBASSADOR J. EDUARDO MALAYA, DEPARTMENT OF JUSTICE UNDERSECRETARY FRANCISCO BARAAN III, AND DND ASSISTANT SECRETARY FOR STRATEGIC ASSESSMENTS RAYMUND JOSE QUILOP AS CHAIRPERSON AND MEMBERS, RESPECTIVELY, OF THE NEGOTIATING PANEL FOR THE PHILIPPINES ON EDCA, Respondents.; KILUSANG MAYO UNO, REPRESENTED BY ITS CHAIRPERSON, ELMER LABOG, CONFEDERATION FOR UNITY, RECOGNITION AND ADVANCEMENT OF GOVERNMENT EMPLOYEES (COURAGE), REPRESENTED BY ITS NATIONAL PRESIDENT FERDINAND GAITE, NATIONAL FEDERATION OF LABOR UNIONS-KILUSANG MAYO UNO, REPRESENTED BY ITS NATIONAL PRESIDENT JOSELITO USTAREZ, NENITA GONZAGA, VIOLETA ESPIRITU, VIRGINIA FLORES, AND ARMANDO TEODORO, JR., Petitioners-In-Intervention,; RENE A.Q. SAGUISAG, JR., Petitioner-In-Intervention.

  • G.R. No. 208527, July 20, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ARDO BACERO Y CASABON, Accused-Appellants.

  • G.R. No. 190408, July 20, 2016 - BENJIE B. GEORG REPRESENTED BY BENJAMIN C. BELARMINO, JR., Petitioner, v. HOLY TRINITY COLLEGE, INC., Respondent.

  • G.R. No. 215764, July 13, 2016 - RICHARD K. TOM, Petitioner, v. SAMUEL N. RODRIGUEZ, Respondent.

  • A.C. No. 10944, July 12, 2016 - NORMA M. GUTIERREZ, Complainant, v. ATTY. ELEANOR A. MARAVILLA-ONA. Respondent.

  • G.R. No. 204605, July 19, 2016 - INTELLECTUAL PROPERTY ASSOCIATION OF THE PHILIPPINES, Petitioner, v. HON. PAQUITO OCHOA, IN HIS CAPACITY AS EXECUTIVE SECRETARY, HON. ALBERT DEL ROSARIO, IN HIS CAPACITY AS SECRETARY OF THE DEPARTMENT OF FOREIGN AFFAIRS, AND HON. RICARDO BLANCAFLOR, IN HIS CAPACITY AS THE DIRECTOR GENERAL OF THE INTELLECTUAL PROPERTY OFFICE OF THE PHILIPPINES, Respondents.

  • A.C. No. 11316, July 12, 2016 - PATRICK A. CARONAN, Complainant, v. RICHARD A. CARONAN A.K.A. "ATTY. PATRICK A. CARONAN," Respondent.

  • G.R. No. 206054, July 25, 2016 - PEOPLE OF THE PHILIPPINES, Appellee, v. MINNIE TUMULAK Y CUENCA, Appellant.

  • G.R. No. 206906, July 25, 2016 - PEOPLE OF THE PHILIPPINES, Appellee, v. FLORDILINA RAMOS, Appellant.

  • G.R. No. 217999, July 26, 2016 - TERESITA P. DE GUZMAN, IN HER CAPACITY AS FORMER GENERAL MANAGER; BERNADETTE B. VELASQUEZ, IN HER CAPACITY AS FINANCE MANAGER; ATTY. RODOLFO T. TABANGIN, ATTY. ANTONIO A. ESPIRITU, ATTY. MOISES P. CATING, IN THEIR CAPACITIES AS FORMER MEMBERS OF THE BAGNIO WATER DISTRICT (BWD) BOARD OF DIRECTORS; AND SONIA A. DAOAS AND ENGR. FELINO D. LAGMAN, IN THEIR CAPACITIES AS INCUMBENT MEMBERS OF THE BOARD OF DIRECTORS, Petitioners, v. COMMISSION ON AUDIT, CENTRAL OFFICE, REPRESENTED BY ITS CHAIRPERSON MICHAEL G. AGUINALDO, COMMISSIONER JUANITO G. ESPINO, JR., COMMISSIONER HEIDI MENDOZA, AND NILDA B. PLARAS, DIRECTOR IV, COMMISSION SECRETARY, Respondents.

  • G.R. No. 213598, July 27, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. MERCELITA1 ARENAS Y BONZO @ MERLY, Accused-Appellants.

  • G.R. No. 208009, July 11, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. EDILBERTO PUSING Y TAMOR, Accused-Appellant.

  • A.M. No. P-16-3471 (Formerly A.M. No. 15-06-197-RTC), July 26, 2016 - OFFICE OF THE COURT ADMINISTRATOR, Complainant, v. JOHN REVEL B. PEDRIŅA, CLERK III, BRANCH 200, REGIONAL TRIAL COURT, LAS PIŅAS CITY, Respondent.

  • G.R. No. 199151-56, July 25, 2016 - PEOPLE OF THE PHILIPPINES, Petitioner, v. THE SANDIGANBAYAN, FIFTH DIVISION, LT. GEN. LEOPOLDO S. ACOT, B/GEN. ILDEFONSO N. DULINAYAN, LT. COL. SANTIAGO B. RAMIREZ, LT. COL. CESAR M. CARINO, MAJ. PROCESO T. SABADO, MAJ. PACQUITO L. CUENCA, 1LT. MARCELINO M. MORALES, M/SGT. ATULFO D. TAMPOLINO, REMEDIOS "REMY" DIAZ, JOSE GADIN, JR., GLENN ORQUIOLA, HERMINIGILDA LLAVE, GLORIA BAYONA AND RAMON BAYONA JR., Respondents.

  • G.R. No. 190158, July 20, 2016 - HEIRS OF LIBERATO CASTILLEJOS AND RURAL BANK OF AGOO, LA UNION, Petitioners, v. LA TONDEŅA INCORPORADA, Respondent.

  • G.R. No. 208837, July 20, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. DONNA RIVERA Y DUMO, Accused-Appellant.

  • G.R. No. 210801, July 18, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ALVIN CENIDO Y PICONES AND REMEDIOS CONTRERAS Y CRUZ, Accused-Appellants.

  • G.R. No. 213529, July 13, 2016 - JANET LIM NAPOLES, Petitioner, v. HON. SECRETARY LEILA DE LIMA, PROSECUTOR GENERAL CLARO ARELLANO, AND SENIOR DEPUTY STATE PROSECUTOR THEODORE M. VILLANUEVA, IN THEIR CAPACITIES AS OFFICERS OF THE DEPARTMENT OF JUSTICE, HON. ELMO M. ALAMEDA, IN HIS CAPACITY AS PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF MAKATI, BRANCH 150, NATIONAL BUREAU OF INVESTIGATION (NBI), ARTURO F. LUY, GERTRUDES K. LUY, ANNABELLE LUY-REARIO, AND BENHUR K. LUY, Respondents.

  • G.R. No. 215340, July 13, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. GLORIA CAIZ Y TALVO, Accused-Appellants.

  • G.R. No. 202514, July 25, 2016 - ANNA MARIE L. GUMABON, Petitioner, v. PHILIPPINE NATIONAL BANK, Respondent.

  • G.R. No. 192477, July 27, 2016 - MOMARCO IMPORT COMPANY, INC., Petitioner, v. FELICIDAD VILLAMENA, Respondent.

  • G.R. No. 210606, July 27, 2016 - GRACE PARK* INTERNATIONAL CORPORATION AND WOODLINK REALTY CORPORATION, Petitioners, v. EASTWEST BANKING CORPORATION, SECURITY BANKING CORPORATION, ALLIED BANKING CORPORATION, REPRESENTED BY THE TRUSTEE AND ATTORNEY-IN-FACT OF EASTWEST BANKING CORPORATION TRUST DIVISION, EMMANUEL L. ORTEGA, IN HIS CAPACITY AS THE EX-OFFICIO SHERIFF OF THE REGIONAL TRIAL COURT, MALOLOS CITY, BULACAN, EDRIC C. ESTRADA, IN HIS CAPACITY AS SHERIFF IV OF THE REGIONAL TRIAL COURT, MALOLOS CITY, BULACAN, Respondent.

  • G.R. No. 172682, July 27, 2016 - SULPICIO LINES, INC., Petitioner, v. NAPOLEON SESANTE, NOW SUBSTITUTED BY MARIBEL ATILANO, KRISTEN MARIE, CHRISTIAN IONE, KENNETH KERRN AND KARISNA KATE, ALL SURNAMED SESANTE, Respondent.

  • G.R. No. 199180, July 27, 2016 - THELMA RODRIGUEZ, JOINED BY HER HUSBAND, Petitioners, v. SPOUSES JAIME SIOSON AND ARMI SIOSON, ET AL., Respondents.

  • G.R. No. 181335, July 27, 2016 - MARIO SALUTA, Petitioner, v. PEOPLE OF THE PHILIPPINES, Respondent.

  • A.C. No. 5951, July 12, 2016 - JUTTA KRURSEL, Complainant, v. ATTY. LORENZA A. ABION, Respondent.

  • G.R. No. 218665, July 20, 2016 - JULIUS BAUTTSTA, ARSENIO LARANANG, REYNALDO BALDEMOR, MANAYAN, NORMA FLORES, CONSUELO ESTIGOY, CARMELITA VALMONTE, SIMEON MARTIN, MAGDALENA GADIAN, JOSE GINNO DELA MERCED, JOVEN SILAN, JR., JULIO DIAZ, GIDEON ACOSTA, AND WENCESLA BAUTISTA, Petitioners, v. LT. COL. BENITO DONIEGO, JR., LT. COL. ALFREDO PATARATA, AND MAJOR GENERAL GREGORIO PIO CATAPANG, Respondent.

  • A.C. No. 9492, July 11, 2016 - PLUTARCO E. VAZQUEZ, Complainants, v. ATTY. DAVID LIM QUECO KHO, Respondent.

  • A.C. No. 6387 [Formerly CBD Case No. 11-3001], July 19, 2016 - GABINO V. TOLENTINO AND FLORDELIZA C. TOLENTINO, Complainants, v. ATTY. HENRY B. SO AND ATTY. FERDINAND L. ANCHETA, Respondents.

  • G.R. No. 215723, July 27, 2016 - DOREEN GRACE PARILLA MEDINA, A.K.A. "DOREEN GRACE MEDINA KOIKE," Petitioner, v. MICHIYUKI KOIKE, THE LOCAL CIVIL REGISTRAR OF QUEZON CITY, METRO MANILA, AND THE ADMINISTRATOR AND CIVIL REGISTRAR GENERAL OF THE NATIONAL STATISTICS OFFICE, Respondent.

  • G.R. No. 204494, July 27, 2016 - JO-ANN DIAZ-SALGADO AND HUSBAND DR. GERARD C. SALGADO, Petitioners, v. LUIS G. ANSON, Respondent.

  • G.R. No. 213601, July 27, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. FRANKIE GERERO, ROLITO GERERO Y ARMIROL, CHRISTOPHER GERERO, ALFIE ESPINOSA Y MENDEZ AND RENATO BARTOLOME Y JAIME, ACCUSED, ROLITO GERERO Y ARMIROL, ALFIE ESPINOSA Y MENDEZ AND RENATO BARTOLOME Y JAIME, Accused-Appellants.

  • G.R. No. 217381, July 20, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. VICENTE R. SALVADOR, Accused-Appellant.

  • A.C. No. 7072, July 27, 2016 - VIRGILIO D. MAGAWAY AND CESARIO M. MAGAWAY, Complainants, v. ATTY. MARIANO A. AVECILLA, Respondent.

  • G.R. No. 212615, July 19, 2016 - LEODEGARIO A. LABAO, JR., Petitioner, v. COMMISSION ON ELECTIONS AND LUDOVICO L, MARTELINO, JR., Respondents.; G.R. NO. 212989 - SHARON GRACE MARTINEZ-MARTELINO, Petitioner, v. COMMISSION ON ELECTIONS AND VICE MAYOR JOSE O. ALBA, JR., Respondent.

  • G.R. Nos. 194763-64, July 20, 2016 - WILFRED GACUS YAMSON, ASSISTANT GENERAL MANAGER A, REY CAŅETE CHAVEZ, DEPARTMENT MANAGER C, ARNOLD DOMINGO NAVALES, DEPARTMENT MANAGER C, ROSINDO JAPAY ALMONTE, DIVISION MANAGER C, ALFONSO EDEN LAID, ASSISTANT GENERAL MANAGER A, AND WILLIAM V. GUILLEN, DEPARTMENT MANAGER C, (ALL OF) DAVAO CITY WATER DISTRICT, BAJADA, DAVAO CITY, Petitioners, v. DANILO C. CASTRO AND GEORGE F. INVENTOR, Respondents.

  • G.R. No. 210710, July 27, 2016 - PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. LUISITO GABORNE Y CINCO, Accused-Appellant.

  • G.R. No. 209271, July 26, 2016 - INTERNATIONAL SERVICE FOR THE ACQUISITION OF AGRI-BIOTECH APPLICATIONS, INC., Petitioner, v. GREENPEACE SOUTHEAST ASIA (PHILIPPINES), MAGSASAKA AT SIYENTIPIKO SA PAGPAPAUNLAD NG AGRIKULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTALAN, ATTY, MARIA PAZ LUNA, JUANITO MODINA, DAGOHOY MAGAWAY, DR. ROMEO QUIJANO, DR. WENCESLAO KIAT, JR., ATTY. H. HARRY ROQUE, JR., FORMER SEN. ORLANDO MERCADO, NOEL CABANGON, MAYOR EDWARD S. HAGEDORN, AND EDWIN MARTHINE LOPEZ, RESPONDENTS. CROP LIFE PHILIPPINES, INC., Petitioner-In-Intervention.; G.R. NO. 209276 - ENVIRONMENTAL MANAGEMENT BUREAU OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, BUREAU OF PLANT INDUSTRY AND THE FERTILIZER AND PESTICIDE AUTHORITY OF THE DEPARTMENT OF AGRICULTURE, Petitioners, v. COURT OF APPEALS, GREENPEACE SOUTHEAST ASIA (PHILIPPINES), MAGSASAKA AT SIYENTIPIKO SA PAGPAPAUNLAD NG AGRIKULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR, ANGELINA GALANG, LEONARDO AVILA HI, CATHERINE UNTALAN, ATTY. MARIA PAZ LUNA, JUANITO MODINA, DAGOHOY MAGAWAY, DR. ROMEO QUIJANO, DR. WENCESLAO KIAT, JR., ATTY. H. HARRY ROQUE, JR., FORMER SEN. ORLANDO MERCADO, NOEL CABANGON, MAYOR EDWARD S. HAGEDORN, AND EDWIN MARTHINE LOPEZ, RESPONDENTS. CROP LIFE PHILIPPINES, INC., Petitioner-In-Intervention.; G.R. NO. 209301 - UNIVERSITY OF THE PHILIPPINES LOS BAŅOS FOUNDATION, INC.,. Petitioner, v. GREENPEACE SOUTHEAST ASIA (PHILIPPINES) MAGSASAKA AT SIYENTIPIKO SA PAGPAPAUNLAD NG AGRIKULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTALAN, ATTY. MARIA PAZ LUNA, JUANITO MODINA, DAGOHOY MAGAWAY, DR. ROMEO QUIJANO, DR. WENCESLAO KIAT, JR., ATTY. H. HARRY L. ROQUE, JR., FORMER SEN. ORLANDO MERCADO, NOEL CABANGON, MAYOR EDWARD S. HAGEDORN, AND EDWIN MARTHINE LOPEZ, Respondents.; G.R. NO. 209430 - UNIVERSITY OF THE PHILIPPINES LOS BAŅOS, Petitioner, v. GREENPEACE SOUTHEAST ASIA (PHILIPPINES), MAGSASAKA AT SIYENTIPIKO SA PAGPAPAUNLAD NG AGRIKULTURA (MASIPAG), REP. TEODORO CASINO, DR. BEN MALAYANG III, DR. ANGELINA GALANG, LEONARDO AVILA III, CATHERINE UNTALAN, ATTY. MARIA PAZ LUNA, JUANITO MODINA, DAGOROY MAGAWAY, DR. ROMEO QUIJANO, DR. WENCESLAO KIAT, JR., ATTY. H. HARRY L. ROQUE, JR., FORMER SEN. ORLANDO MERCADO, NOEL CABANGON, MAYOR EDWARD S. HAGEDORN, AND PROMULGATED: EDWIN MARTHINE LOPEZ, Respondent.

  • A.M. No. 12-8-07-CA, July 26, 2016 - RE: LETTER OF COURT OF APPEALS JUSTICE VICENTE S.E. VELOSO FOR ENTITLEMENT TO LONGEVITY PAY FOR HIS SERVICES AS COMMISSION MEMBER III OF THE NATIONAL LABOR RELATIONS COMMISSION; A.M. NO. 12-9-5-SC - RE: COMPUTATION OF LONGEVITY PAY OF COURT OF APPEALS JUSTICE ANGELITA A, GACUTAN; A.M. NO. 13-02-07-SC - RE: REQUEST OF COURT OF APPEALS JUSTICE REMEDIOS A. SALAZAR- FERNANDO THAT HER SERVICES AS MTC JUDGE AND AS COMELEC COMMISSIONER BE CONSIDERED AS PART OF HER JUDICIAL SERVICE AND INCLUDED IN THE COMPUTATION/ADJUSTMENT OF HER LONGEVITY PAY., Respondent.

  • G.R. No. 202050, July 25, 2016 - PHILIPPINE NATIONAL OIL COMPANY AND PNOC DOCKYARD & ENGINEERING CORPORATION, Petitioners, v. KEPPEL PHILIPPINES HOLDINGS, INC., Respondent.

  • G.R. No. 210991, July 12, 2016 - DUTY FREE PHILIPPINES CORPORATION (FORMERLY DUTY FREE PHILIPPINES) DULY REPRESENTED BY ITS CHIEF OPERATING OFFICER, LORENZO C. FORMOSO, Petitioner, v. COMMISSION ON AUDIT, HON. MA. GRACIA M. PULIDO TAN, CHAIRPERSON AND HON. HEIDI L. MENDOZA, COMMISSIONER, Respondent.

  • A.C. No. 10117, July 25, 2016 - IN RE: RESOLUTION DATED AUGUST 14, 2013 OF THE COURT OF APPEALS IN CA- PRESENT: GR.CV NO. 94656, v. ATTY. GIDEON D.V. MORTEL, Respondent.