6. Saudi Arabian Airlines v.

Rebesencio, January 14, 2015

Facts:
Respondents were employees as permanent flight attendants of Saudi Arabian
Airlines (Saudia) which is a foreign corp with office in Manila. The respondents then
were separated from service from various dates in 2006 by virtue of resignation.
The respondents contended that they were illegally dismissed from employment
due to their pregnancies and that they file their resignation letters because of the
threat of termination which would entail loss of benefits. Saudia argued that under
their Employment Contract for Female Cabin Attendants if the Air Hostess becomes
pregnant at any time during the term of this contract, this shall render her
employment contract as void and she will be terminated due to lack of medical
fitness.
Issue:
Whether or not the respondents were illegally terminated?
Held:
Yes, respondents were illegally terminated. The respondents resignation lacked
voluntariness on their part and the constructive dismissal happened when they
were pregnant and expecting to incur cost on account of child delivery and infant
rearing. The threat of termination upon their failure to resign is enough reason to
compel any person to abandon employment thus resulting in constructive dismissal
which further amounts to illegal termination. Since the respondents were illegally
terminated, they were entitled to backwages, benefits from the time of their
termination until finality of this decision, moral and exemplary damages and
attorneys fees.

7. Valcurza vs Tamparong September 04, 2013

Facts:
Tamparong was the registered owner of a landholding with an area of 412, 004
sqm. The Sangguniang Bayan of Villanueva, Misamis Oriental allegedly passed a
Comprehensive Zoning Ordinance Resolution No. 51- 98, Series of 1982
classifying respondents land from agricultural to industrial. Also, the DAR issued a
notice of coverage on 3 November 1992 over 276,411 square meters out of the
412,004 sqm of respondents land which were awarded to the petitioners by virtue
of a CLOA. Tamparong contended that his land exempted from CARP coverage
because his land was an industrial not agricultural. The PARAB held that the CARP
coverage irregular and anomalous because the issuance of the CLOA, as well as its
registration with the Register of Deeds, happened before the survey plan was
approved by the DENR and ordered the ejectment of the petitioners from the
disputed landholding. The DARAB concluded that the DAR Secretary had exclusive
jurisdiction over the matter. Hence, the DARAB reversed the PARAB, maintained the

validity of the CLOA, and dismissed the complaint for lack of merit. Petitioners
claimed that respondents complaint before the PARAB concerns the DARs
implementation of the agrarian law and implementation of CLOA as an incident
thereof and the PARAB had no jurisdiction.
Issue:
Whether the DARAB or DAR has exclusive jurisdiction to determine if the subject
landholding is exempt from CARP coverage
Whether the land is exempt from CARP coverage
Held:
The DAR has exclusive jurisdiction to determine if the subject landholding is exempt
from CARP coverage, a matter involving the administrative implementation of the
CARP law. Section 50 of Executive Order (E.O.) No. 229 vests the DAR with quasijudicial powers to determine and adjudicate agrarian reform matters, as well as with
exclusive original jurisdiction over all matters involving the implementation of
agrarian reform. Also the complaint does not involve agrarian dispute to be within
the jurisdiction of DARAB.
No, the land is not exempt from CARP coverage. Sec 49 of the CARL provides that
for a land to be outside the ambit of CARP the land the land has been classified in
town plans and zoning ordinances as residential, commercial or industrial; and 2.
the town plan and zoning ordinance embodying the land classification has been
approved by the HLURB or its predecessor agency prior to 15 June 1988. In this
case, the records show the absence of HLURB Certifications approving
Comprehensive Zoning Ordinance Resolution No. 51-98, Series of 1982, and Zoning
Ordinance No. 123, Series of 1997. Hence, it cannot be said that the land is
industrial and outside the ambit of CARP.
8. Soriano v. Bravo, December 15, 2010
Facts:
Respondent Ernesto S. Bravo entered into a Compromise Agreement on November
3, 1992 with the petitioners, people cultivating the land among others to be
relocated on the same landholding to prepare for the development of Bravo AgroIndustrial Complex. However, the respondents filed before the DARAB a complaint
for Ejectment, Collection of Unpaid Rentals, Recomputation of Rentals, Specific
Performance and Damages against the petitioners on the ground that the
petitioners refused to comply with the compromise agreement and instead
demanded that the MARO put the subject properties under the OLT program
provided in the Tenants Emancipation Decree and CARL. The MARO already ruled
that the subject properties were not covered by the OLT program because each of
the respondents and their predecessors-in-interest did not own more than five
hectares of the subject properties. Respondents further averred that since 1992,

defendants had refused to pay lease rentals on the portions of rice lands they were
tilling. DARAB held that the landholding were outside the coverage of of PD 27 and
RA 6657 because the respondents does not own more than 5 hectares of the subject
landholdings. The petitioners contended that it was the Office of the DAR Secretary,
not the DARAB, which had jurisdiction to determine the properties falling within the
coverage of the Tenants Emancipation Decree and CARL.
Issue:
Whether or not DARAB has jurisdiction over the case?
Held:
Yes, the DARAB has jurisdiction over the case. Jurisdiction over agrarian disputes lies
with the DARAB. Section 3(d) of the CARL defines an agrarian dispute to any
controversy relating to tenurial arrangements, whether leasehold, tenancy,
stewardship or otherwise, over lands devoted to agriculture,
including disputes concerning farmworkers associations or representation of
persons in negotiating, fixing, maintaining, changing or seeking to arrange terms or
conditions of such tenurial arrangements.
It includes any controversy relating to compensation of lands acquired under this
Act and other terms and conditions of transfer of ownership from landowners to
farmworkers, tenants and other agrarian reform beneficiaries, whether the
disputants stand in the proximate relation of farm operator and beneficiary,
landowner and tenant, or lessor and lessee.
The material allegations and reliefs sought in respondents Complaint essentially
established a case involving the rights and obligations of respondents and
defendants as landlords and agricultural tenants/lessees, respectively, taking into
account their Compromise Agreement as well as the fixing and collection of lease
rentals. The DARAB properly took cognizance of the case as it constituted agrarian
disputes, wellwithin the jurisdiction of the DARAB under Rule II, Section 1,
paragraphs (a) and (b) of the 1994 DARAB Rules.
9. DFI v. Southern Philippines Federation of Labor Workers, January 2016.
Facts:
DFI was the owner of 800-hectare banana plantation in Davao which was subjected
under the automatic compulsory acquisition and distribution under the CARL. The
698.88 hectares was turned over to ARBs who subsequently organized themselves
into a multi-purpose cooperative named DARBMUPCO, which is one of the
respondents in this case. DARBMUPCO entered into a Banana Production and
Purchase Agreement (BPPA) with DFI. Due to lack of manpower, DFI engaged the
services of the
respondent-contractors, who in turn recruited the respondent-workers. Respondent
Southern Philippines Federation of Labor (SPFL)a legitimate labor organization
with a local chapter in the

awarded plantationfiled a petition for certification election in the Office of the

Med-Arbiter in Davao City. DARBMUPCO and DFI denied that they are the employers
of the respondent-workers. They claimed, instead, that the respondent-workers are
the employees of the respondent-contractors.
Issue:
Who is the statutory employer of the 400 employees?
Held:
The court ruled that DFI is the employer. Under Article 106 of the Labor Code, a
principal or employer refers to the person who enters into an agreement with a job
contractor, either for the performance of a specified work or for the supply of
manpower. In labor-only contracting, it is the law which creates an employeremployee relationship between the principal and the workers of the labor only
contractor. The DFI is the employer on the ground that DFI exercises control over
the respondent-workers. DFI, through its manager and supervisors provides for the
work assignments and performance targets of the respondent-workers. The
managers and supervisors also have the power to directly hire and terminate the
respondent-workers which satisfy the control test.
10. Landbank v. Santos, January 2016.
Facts:
Santos was the owner of the three parcels of land which were subjected under PD
27 in 1984. On May 2000, the LBP received the claim folder covering the subject
lands and allowed Santos to collect the initial valuation for Land 3. It withheld the
release of the valuation for Lands 1 and 2 until the
submission of the certificates of title thereto, since it was discovered that they were
covered by Decree Nos. N-82378 and 622575. Finding the valuation unreasonable,
Santos filed three (3) petitions for summary administrative proceedings for the
determination of just compensation of the subject lands before the PARAD of
Camarines Sur which used the recent govt support price for corn. Santos
unconditionally accepted and called for the immediate payment of the valuations
for Lands 2 and 3.
On May 5, 2009, Santos filed before the RTC a motion to release the initial valuation
for Lands 1 and 2 as fixed by the DAR, which was granted on June 2, 2009,
conditioned on the submission of several documentary requirements.Santos moved
for reconsideration, pointing out that what was sought was the initial valuation only
and not its full payment, but nonetheless, committed (a) to submit two (2) valid ID
cards, two (2) latest ID pictures and his CTC for the current year, and ( b) to execute
a Deed of
Assignment, Warranties and Undertaking in favor of the LBP. In opposition, the LBP
insisted that Santos must: (a) first establish his ownership over the said properties

and ( b) submit a real estate tax clearance to prove that there were no
encumbrances burdening the property and that the taxes thereon had
been fully paid until 1972. The RTC ruled in favor of Santos, holding that since Land
1 was processed as an untitled property and the LBP had admitted in its petitions
for just compensation that Santos was the owner of the untitled lands covered by
PD 27 as reflected in the tax declarations, the LBP cannot maintain an inconsistent
position by requiring Santos to prove his ownership thereto.

Issue:
Whether the RTC have acted with grave abuse of discretion in allowing the release
of the initial valuation of lands 1 and 2 without submitting the documents listed
under DAR AO No. 2, series of 2005
When to reckon the award of 12 interest?
Held:
No, the leniency accorded by the RTC cannot be construed as a capricious exercise
of' power as it merely expedited the procedure for payment which is inherently
fairer under the circumstances considering that: (a) Santos has been "deprived of
his right to enjoy his properties as early as 1983, and has not yet received any
compensation therefor since then;" ( b) the existence of the certificates of title over
Lands 1 and 2 which the LBP insists to be submitted had not been sufficiently
established;(c) the LBP had judicially admitted, that Santos is the owner of Lands 1
and 2 which were identified as covered by tax declarations;88 and (d) compliance
with the required documents may still be directed before the full payment of the
correct just compensation which, up to this time, has not yet been finally
determined. Moreover, as aptly pointed out by the CA, Santos' failure to produce the
titles to Lands 1 and 2 was not motivated by any obstinate refusal to abide by the
requirements but due to impediments beyond his
control.
Accordingly, the award of twelve percent (12%) annual interest on the unpaid
balance of the just compensation for Land 3 should be computed from the time of
taking.
Doctrine:
It is doctrinal that the concept of just compensation contemplates of just and timely
payment. It embraces not only the correct determination of the amount to be paid
to the landowner, but also the payment of the land within a reasonable time from its
taking, as otherwise, compensation cannot
be considered "just," for the owner is made to suffer the consequence of being
immediately deprived of his land while being made to wait for years before actually
receiving the amount necessary to cope with his loss