1

Universal Robina Sugar Milling Corp. (URSUMCO) vs. Heirs of Angel Teves
G.R. No. 128574, September 18, 2002

FACTS: Andres Abanto owned two parcels of lot in Campuyo, Manjuyod, Negros Oriental. Lot 1 with 55,463 sq.m. is
registered in his name (TCT H-37). Lot 2 with an area of 193, 789 sq.m. is unregistered. He died in 1973. On
October 1974 Abantos heirs executed an extrajudicial settlement of estate with sale. The lot measuring 193,789
sq.m. was sold to United Planters Sugar Milling Co. Inc. (UPSUMCO) while TCT H-37 was sold to Angel Teves.
Sale was unregistered. Teves verbally allowed UPSUMCO to use H-37 for pier and loading facilities free of
charge on the condition UPSUMCO will pay the property taxes and its use shall be co-terminus with its existence.

Years later UPSUMCOs properties were acquired by PNB, transferred to Asset Privatization Trust (APT) and
sold to URSUMCO. Teves heirs demanded the return of H-37 from URSUMCO, which the latter refused.

RTC ruled in favour of Heirs of Teves except where pier and guest house are concerned. CA affirmed RTC
decision

ISSUE: (1) Does respondents have cause of action?
(2) Does petitioner have legal capacity to question the sale?
(3) Is barangay conciliation needed?

RULING: (1) Yes, respondents have cause of action since the transfer of H-37 was a contract of sale. In addition, it was
Teves who allowed UPSUMCO to construct the pier and guest house, clearly manifestations of acts of ownership
over the land by Teves.

(2) No, petitioner cannot hide behind the veil of an innocent purchaser for value as two important factors are
absent: (1) property bought for consideration and (2) lack of knowledge of adverse claim prior to sale. In addition,
H-37 was not included in the property acquired by URSUMCO from APT which was limited to UPSUMCO
properties foreclosed by PNB.

(3) No, Sec. 1, Rule VI of IRR exempts from barangay conciliation if one party is a juridical entity.

Petition denied, CA decision affirmed.

Leticia Agbayani vs. CA, DOJ and Loida Genabe
G.R. No. 183623, June 25, 2012

FACTS: Petitioner and private respondent are employees of Branch 275, Las Pinas City working as Court Stenographer
and Legal Researcher II. On December 29, 2006 Agbayani filed a complaint for grave oral defamation against
Genabe. City Prosecutor of Las Pinas City found probable cause for grave oral defamation, upon petition for
review by Genabe, DOJ Undersecretary Ernesto Pieda found only for slight oral defamation as it was uttered in
the heat of anger. DOJ also moved for dismissal of the complaint for failure to comply with RA 7160, Sec. 408 and
409 (d). Motion for Reconsideration of Agbayani was denied. Petition for review on certiorari was filed with CA
and dismissed.


ISSUE: (1) Did DOJ abuse its discretion when it set aside the findings of the City Prosecutor of Las Pinas City?
(2) Is barangay conciliation applicable to the case at bar?
(3) Was the DOJ correct to downgrade the complaint to slight oral defamation?

RULING: (1) No, the rules of procedure, in this case DOJ Circular No. 70, Sec. 5 and Sec. 6 should be viewed as
instruments to facilitate the attainment of justice and are not to be applied with severity and rigidity. Indeed, there
was substantial compliance with said DOJ rules as respondent Genabe actually mentioned the name of petitioner
as private complainant. CA also found there was proper service of petition as petitioner was able to file his
comment. In addition, in Guy vs. Asia United Bank, a motion for reconsideration from the resolution of the
secretary of justice filed four (4) days beyond the non-extendible period of 10 days under Sec. 13, NPS Rules on
Appeal in instances where he finds absence of prima facie evidence is not time-barred but subject to the approval
of the court.

(2) Yes, both Agbayani and Genabe are residents of Las Pinas City and both work there. Pursuant to Sec. 408
and 409 of RA 7160 the case is subject to barangay conciliation before filing of court complaint unless it falls
under the exception stated in Sec. 412, RA 7160.

(3) Yes, in Villanueva vs. People, oral defamation or slander is the speaking of base and defamatory words which
tend to prejudice another in his reputation, office, trade, business or means of livelihood. It is grave when it is of a
serious or insulting nature. The gravity depends upon (1) expressions used, (2) personal relations of the parties
involved, (3) special circumstances of the case, the antecedents or relationships between the offended party and
the offender, which may prove the intention of the offender at the time.

In case at bar, Genabe was about to punch her time card on 12/27/2006 when she was informed she had been
suspended for failing to meet her deadline in a case, which was done by Agbayani to the presiding judge. This
event precipitated the words uttered by Genabe, hence being under heat of anger and obfuscation, clearly a
slight oral defamation only.

Petition denied, CA decision affirmed.
2





Teresita Montoya vs. Escayo et al.
G.R. No. 82211-12, March 21, 1989

FACTS: Escayo et al. were former salesgirls in petitioners store in Bacolod City. On different dates they filed complaints
separately for collection of sums of money against petitioner for overtime pay, holiday pay, 13
th
month pay,
ECOLA, and service leave pay among others.

Petitioner filed for dismissal of complaints for failure to comply with the Katarungang Pambarangay law as stated
in PD 1508. Labor Arbiter ruled in favour of petitioner, this was reversed by the NLRC which directed the Labor
Arbiterto proceed with the case.


ISSUE: Are labor disputes under PD 1508 covered by the Lupong Tagapamayapa before such cases can be filed with the
court or any government offices?

RULING: No, Sec. 6, PD 1508 applies only to courts of justice and not to labor relations commissioners or labor arbiters
office. In addition, Art. 226, PD 442 grants original and exclusive jurisdiction over the conciliation and mediation of
disputes, grievances, or problems in the regional offices of the DOLE. It is the said Bureau and its divisions, and
not the barangay Lupong Tagapamayapa, which are vested by law with original and exclusive authority to
conduct conciliation and mediation proceedings on labor controversies before their endorsement to the
appropriate labor arbiter for adjudication.

Petition dismissed.