LANDBANK OF THE PHILIPPINES, petitioner,

SPOUSES VICENTE BANAL and LEONIDAS ARENAS-BANAL, respondents.

FACTS: Spouses Vicente and Leonidas Banal, respondents, are the registered owners of
agricultural land situated in San Felipe, Basud, Camarines Norte.   A portion of the land was
compulsorily acquired by the Department of Agrarian Reform (DAR) pursuant to Republic Act
(R.A.) No. 6657,[1] as amended, otherwise known as the Comprehensive Agrarian Reform Law of
1988.
Respondents rejected the valuation of petitioner hence a summary administrative proceeding was
conducted before the Provincial Agrarian Reform Adjudicator (PARAD) to determine the valuation
of the land.  Eventually, the PARAD rendered its Decision affirming the Landbank’s valuation.
Dissatisfied with the Decision of the PARAD, respondents filed with the RTC a petition for
determination of just compensation.
In determining the valuation of the land, the trial court based the same on the facts established in
another case pending before it.
ISSUE: W/N the trial court erred in taking judicial notice of the average production figures in
another case pending before it and applying the same to the present case without conducting a
hearing and without the knowledge or consent of the parties
HELD: Well-settled is the rule that courts are not authorized to take judicial notice of the contents
of the records of other cases even when said cases have been tried or are pending in the same
court or before the same judge. They may only do so “in the absence of objection” and “with
the knowledge of the opposing party,” which are not obtaining here.
Furthermore, as earlier stated, the Rules of Court shall apply to all proceedings before the Special
Agrarian Courts.  In this regard, Section 3, Rule 129 of the Revised Rules on Evidence is explicit
on the necessity of a hearing before a court takes judicial notice of a certain matter, thus:
“SEC. 3.  Judicial notice, when hearing necessary. – During the trial, the court, on its own initiative,
or on request of a party, may announce its intention to take judicial notice of any matter and
allow the parties to be heard thereon.
“After the trial, and before judgment or on appeal, the proper court, on its own initiative or on
request of a party, may take judicial notice of any matter and allow the parties to be heard
thereon if such matter is decisive of a material issue in the case.”  (emphasis added)
The RTC failed to observe the above provisions.

 
Case Digest_The People of the Philippines v Jailon Kulais
GR NO. 100901, July 16, 1998
Facts:
On August 22, 1990, five Informations for kidnapping for ransom and three
informations for kidnapping were filed before the RTC of Zamboanga City against
Carlos Falcasantos, Jailon Kulais, Jumatiya Amlani, Norma Sahiddan de Kulais, Jalina
Hassan de Kamming, Salvador Mamaril, Hadjirul Plasin, Jaimuddin Hassan, Imam
Taruk Alah, Freddie Manuel and several John and Jane Does. The informations for 
kidnapping for ransom, which set forth identical allegations save for the names of the
victims. The three informations for kidnapping, also under Article 267 of the Revised
Penal Code, likewise alleged identical facts and circumstances, except the names of the
victims. Of the twelve accused, only nine were apprehended.
The trial court found Appellant Kulais guilty of five counts of kidnapping for ransom and
one count of kidnapping a woman and public officer, for which offenses it imposed upon
him six terms of life imprisonment. It also found him guilty of two counts of slight illegal
detention for the kidnapping of Monico Saavedra and Calixto Francisco.
On May 7, 1991, Jailon Kulais, Jumatiya Amlani de Falcasantos, Norma Sahiddan de
Kulais and Jaliha Hussin filed their Joint Notice of Appeal. In a letter dated February 6,
1997, the same appellants, except Jailon Kulais, withdrew their appeal because of their 
application for amnesty. In a Resolution dated March 19, 1997, it granted the motion.
Hence, only the appeal of Kulais remains for the consideration of this Court.
Issue:
Whether or not the trial court is faulted with the following errors:
a. In taking judicial notice of a material testimony given in another case by Lt.
Melquiades Feliciano
b. On the as
sumption that Lt. Feliciano’s testimony could be validly taken judicial
notice of 
Held:
Wherefore, the conviction of appellant Kulais as principal in five counts of 
kidnapping for ransom and in three counts of kidnapping is affirmed, but the penalty
imposed is modified.
 As a general rule, courts should not take judicial notice of the evidence presented in
other proceedings, even if these have been tried or are pending in the same court, or 
have been heard and are actually pending before the same judge. This is especially
true in criminal cases, where the accused has the constitutional right to confront and
cross-examine the witnesses against him.
Having said that, we note, however, that even if the court a quo did take judicial notice
of the testimony of Lieutenant Feliciano, it did not use such testimony in deciding the
cases against the appellant. Hence, appellant Kulais was not denied due process. His
conviction was based mainly on the positive identification made by some of the kidnap
victims.
The elements of kidnapping for ransom, as embodied in Article 267 of the Revised
Penal Code, having been sufficiently proven, and the appellant, a private individual,
having been clearly identified by the kidnap victims, this Court thus affirms the trial
court’s finding of appellant’s guilt on five counts of kidnapping for ransom

 
LAUREANO V. CA
324 SCRA 414 (2000)
FACTS
Laureano, Director of Flight Operations and Chief Pilot of Air Manila, applied for employment
with Singapore Airlines [herein private respondent] through its Area Manager in Manila. He was
then accepted. Sometime in 1982, Singapore Airline, hit by a recession, initiated cost-cutting
measures. Seventeen (17) expatriate captains in the Airbus fleet were found in excess of the
defendant's requirement. Consequently, defendant informed its expatriate pilots including
 plaintiff of the situation and advised them to take advance leaves. Realizing that the recession
would not be for a short time, defendant decided to terminate its excess. It did not, however,
immediately terminate it's A-300 pilots. It reviewed their qualifications for possible promotion to
the B-747 fleet. Among the 17 excess Airbus pilots reviewed, twelve were found qualified.
Unfortunately, Laureano was not one of the twelve.
Laureano instituted a case for illegal dismissal before the Labor Arbiter. Singapore Airline
moved to dismiss on jurisdictional grounds. Before said motion was resolved, the complaint was
withdrawn. Thereafter, Laureano filed the instant case for damages due to illegal termination of
contract of services before the RTC.
CA reversed the decision of the RTC, it held that the action has already prescribe, the
 prescriptive period was 4 years and action was filed beyond the prescriptive period.
ISSUES
(a) W/N Philippine law must be applied and not Singaporean law.
(b) W/N action has already prescribe.
RULING
(a) Philippine law must be applied. SC quoted the findings of the RTC, it says: "Neither can the
Court determine whether the termination of the plaintiff is legal under the Singapore Laws
 because of the defendant's failure to show which specific laws of Singapore Laws apply to this
case. As substantially discussed in the preceding paragraphs, the Philippine Courts do not take
 judicial notice of the laws of Singapore. The defendant that claims the applicability of the
Singapore Laws to this case has the burden of proof. The defendant has failed to do so.
Therefore, the Philippine law should be applied." Also Respondent Court of Appeals acquired
 jurisdiction when defendant filed its appeal before said court. On this matter, respondent court
was correct when it barred defendant-appellant below from raising further the issue of
 jurisdiction.
(b) YES. Neither Article 1144 nor Article 1146 of the Civil Code is here pertinent. Wha

 
PARILLA, MAY ANN C.ELECTION LAW
LLB 2-1MONDAYS/CW8
G.R. No. 195649 Ap !" 16, 2#1$
MA%&ILING 'S. COMMISSION ON ELECTIONS
()*+
Arnado was a natural born Filipino citizen, but lost his citizenship upon naturalization as
citizen of United States of America. Sometime on 2008 and 2009, his repatriation was
granted and he subse uentl! e"ecuted an A#da$it of %enunciation of foreign citizenship.
&n 'o$ember 2009, Arnando (led for a certi(cate of candidac! and won the said
election. )ut prior from his declaration as winner, a pending action for dis uali(cation
was (led b! )alua, one of the contenders for the position. )alua alleged that Arnando
was not a citizen of the *hilippines, with a certi(cation issued b! the )ureau of 
+mmigration that Arnando s nationalit! is USA-American and a certi(ed true cop! of 
computer-generated tra$el record that he has been using his American passport e$en
after renunciation of American citizenship. A di$ision of the &/ 1 ruled against
Arnando but this decision was re$ersed b! the &/ 1 en )anc stating that continued
use of foreign passport is not one of the grounds pro$ided for under Section of 
ommonwealth Act 'o. 34 through which *hilippine citizenship ma! be lost. /eanwhile,
/a uiling petition that should be declared winner as he gained the second highest
number of $otes.
I
5hether or not continued use of a foreign passport after renouncing foreign citizenship
a6ects one s uali(cations to run for public o#ce.
0 "
 7es. he use of foreign passport after renouncing one s foreign citizenship is a positi$e
and $oluntar! act of representation as to one s nationalit! and citizenship it does not
di$est Filipino citizenship regained b! repatriation but it recants the &ath of %enunciation
re uired to ualif! one to run for an electi$e position which ma:es him dual citizen.
itizenship is not a matter of con$enience. +t is a badge of identit! that comes with
attendant ci$il and political rights accorded b! the state to its citizens. +t li:ewise
demands the concomitant dut! to maintain allegiance to one s ;ag and countr!.

People vs Baharan GR No 188314

10
Facts: Trinidad and Baharan were trained by Abu Sayyaf group and
bombed a bus on 2005 Valentines. After the bombing, Trinidad gave
ABS-CBN News Network an exclusive interview some time after the
incident, confessing his participation in the Valentines Day bombing
incident. In another exclusive interview on the network, accused
Baharan likewise admitted his role in the bombing incident.
Only Baharan, Trinidad, Asali, and Rohmat were arrested, while the other
accused remain at-large. They were then charged with multiple murder
and multiple frustrated murder. On arraignment they pleaded guilty on
the charge of multiple murder. On multiple frustrated murder, Trinidad
and Baharan pleaded not guilty.
In the light of the pretrial stipulations, the trial court asked whether
accused Baharan and Trinidad were amenable to changing their not
guilty pleas to the charge of multiple frustrated murder, considering that
they pled guilty to the heavier charge of multiple murder, creating an
apparent inconsistency in their pleas. Defense counsel conferred with
accused Baharan and Trinidad and explained to them the consequences
of the pleas. The two accused acknowledged the inconsistencies and
manifested their readiness for re-arraignment. After the Information was
read to them, Baharan and Trinidad pled guilty to the charge of multiple
frustrated murder.
Issue: WON the trial court gravely erred in accepting Trinidad and
Baharan plea of guilt despite insufficiency of searching inquiry into the
voluntariness and full comprehension of the consequences of the said
plea.
Decision: The Court observed that accused Baharan and Trinidad
previously pled guilty to another charge multiple murder based on the
same act relied upon in the multiple frustrated murder charge.
The Court further noted that prior to the change of plea to one of guilt,
accused Baharan and Trinidad made two other confessions of guilt one
through an extrajudicial confession (exclusive television interviews, as
stipulated by both accused during pretrial), and the other via judicial
admission (pretrial stipulation).
Considering the foregoing circumstances, the Court deem it unnecessary
to rule on the sufficiency of the searching inquiry in this
instance. Remanding the case for re-arraignment is not warranted, as
the accused plea of guilt was not the sole basis of the condemnatory
judgment under consideration