Salenillas v.

Court of Appeals
Case No. 11
G.R. No. 78687 (January 31, 1989)

FACTS:
On December 4, 1973, the property of Petitioners was mortgaged to Philippine National Bank as
security for a loan of P2,500. For failure to pay their loan, the property was foreclosed by PNB
and was bought at a public auction by Private Respondent. Petitioner maintains that they have a
right to repurchase the property under Sec.119 of the Public Land Act. Respondent states that the
sale of the property disqualified Petitioners from being legal heirs vis-à-vis the said property.
Respondent also maintains that the period for repurchase has already prescribed based on Monge
et al. vs. Angeles.

ISSUE:
1. W/N petitioners have the right to repurchase the property under the said Act.
2. W/N the prescription period had already prescribed.

Held:
The provision makes no distinction between the legal heirs. The distinction made by Respondent
contravenes the very purpose of the Act. Petitioners’ contention would be more in keeping with
the spirit of the law. With regard to prescription, the Monge case involved a pacto de retro sale
and not a foreclosure sale and so the rules under the transaction would be different. For foreclosure
sales, the prescription period starts on the day after the expiration of the period of redemption when
the deed of absolute sale was executed.

De Guia v. COMELEC
Case No. 12
G.R. No. 104712 (May 6, 1992)

FACTS:
Petitioner contends that under Par (d) of Sec. 3 of RA 7166, members of the Sangguniang
Panlulungsod and Sangguniang Bayan shall be elected at large.

ISSUE:
W/N par (d) Sec. 3 of RA 7166 should be interpreted to mean that elective officials of the
Sangguniang Panlulungsod and Sangguniang Bayan shall be elected at large.

HELD:
No. Par (d) Sec.3 of the RA refers only to elective officials of the Sangguniang Panlulungsod of
single district cities and elective officials of the Sangguniang Bayan for municipalities outside
Metro Manila. The law specifically stated that provinces with only one legislative district should
be divided into two and therefore should necessarily be elected by districts. Par (d) should be
interpreted in line with the rest of the statute and to follow the interpretation of the petitioner there
would have been no reason for the RA to single out the single district provinces. The court realized
that the language of the law in this case seems abstruse and the key to determine what legislature
intended is the purpose or reason which induced it to enact the statute. The explanatory note in the
proposed bill provided that the reason for the division into two legislative districts is to reduce the
number of candidates to be voted for in the 1992 elections.

Basbacio v. Office of the Secretary, Dept. of Justice

Case No. 13
G.R. No. 109445 (November 7, 1994)

FACTS:
RA 7309, among other things, provides for compensation of persons unjustly accused, convicted,
and imprisoned. Petitioner and his son-in-law Balderrama were charged with murder and frustrated
murder for killing Boyon and wounding his wife and son, due to a land dispute and thus
imprisoned. However, on appeal to the CA, Petitioner was acquitted on the ground that conspiracy
between him and his son-in- law was not proven. What was proven was that he was at the scene
of the crime with Petitioner when the shooting happened and left the place with his son-in-law.
Petitioner claims he was unjustly accused and is entitled to compensation.

ISSUE:
W/N Petitioner is entitled to compensation pursuant to RA 7309.

HELD:
No, he is not. For one to be “unjustly accused” one must be wrongly accused from the very
beginning, unjustly convicted (when a judge knowingly and deliberately rendered an unjust
judgment, whimsical and capricious devoid of any basis for judgment) and imprisoned. In the case
at bar, Petitioner was acquitted because the prosecution was unable to prove beyond
reasonable doubt that Petitioner was guilty. Thus, he does not fall under RA 7309.

Globe-Mackay v. NLRC and Salazar

Case No. 14
G.R. No. 82511 (March 3, 1992)

FACTS:
Petitioner placed Respondent Salazar under preventive suspension because it appeared that she
had full knowledge of the loss and whereabouts of an air conditioner that Delfin
Saldivar had stolen from the company but failed to inform her employer. Respondent Salazar filed
a complaint for illegal suspension and for other damages. On appeal, the Respondent Court
affirmed the decision of the Labor Arbiter with respect to the reinstatement of Private Respondent
but limited back wages to 2 years and deleted award for moral damages.

ISSUE:
1. W/N the Labor Tribunal committed grave abuse of discretion in ordering the reinstatement of
Respondent Salazar.
2. W/N there existed independent legal grounds to hold Respondent Salazar answerable as well
and, thereby, justify her dismissal.
HELD:
The Labor Code clearly provides that an employee who is unjustly dismissed from work shall be
entitled to reinstatement and to his full back wages. An exception to this is when the reinstatement
may be inadmissible due to strained relations between the employer and the employee. The
position of Private Respondent as systems analyst is not one that may be characterized as such.
Moreover, Petitioner merely insinuated that since Respondent Salazar had a special relationship
with Saldivar, she might have had direct knowledge of Saldivar’s questionable activities.

Soccoro D. Ramirez, Petitioner Vs. Honorable Court of Appeals and Ester S. Garcia, Respondents
Case No. 15
G.R. No. 93833, September 28, 1995

FACTS:
The Petitioner Soccoro Ramirez, filed a civil case for damages in the Regional Trial Court of
Quezon City against Private respondent Ester Garcia who, in a confrontation in the latter's office
allegedly vexed, insulted, and humiliated her in a "Hostile and Futile" mood and in a manner
offensive to her dignity and personality contrary to morals, good customs and public policy.

Petitioner produced a verbatim transcript of their argument and sought moral damages, attorney's
fee and other expenses of litigation, all amounting to Php 610,000.00 exclusive of the costs,
interests and other reliefs awardable by the court. Thus, Ester Garcia, Private respondent filed a
criminal case before RTC - Pasay City for a violation of Republic Act 4200 "An act to prohibit
and penalize wiretapping and other related violations of private communication and other
purposes."

Petitioner then filed a motion to Quash the information since the facts charged do not constitute
an offense punishable by RA 4200. The trial court granted the motion to quash agreeing with
petitioner that (1) the facts charged do not constitute an offense under RA 4200 and (2) the
violation punished by RA 4200 refers to taping of a communication by a person other than a
participant to the communication.

Private respondent appealed to the Court of Appeals, which declared the RTC's decision null and
void and holding that the allegations are punishable by RA 4200.

ISSUE:
Whether or Not RA 4200 applies to a taping of a private conversation by one of the parties to a
conversation.

HELD:
Positive. Legislative intent is determined principally from the language of the statute. When the
language of a statute is clear and unambiguous, the law is applied according to its express terms.

Section 1 of RA 4200 states that it shall be unlawful for any person, not be authorized by all the
parties to any private communication or spoken word, to tap any wire or cable, or by using any
other device or arrangement to secretly overhear, intercept or record such communication or
spoken word. The aforesaid provision clearly makes it illegal for any person not authorized by the
parties to record secretly by means of recorder. The law makes no distinction as to who are the
parties which can be a party other than those involved in the private communication. The statute's
intent is to penalize all persons unauthorized to make such recording is underscored by the use of
qualifier "any".

Pascual v. Pascual-Bautista
Case No. 16
G.R. No. 84240 (March 25, 1992)

FACTS:
Petitioners are the acknowledged natural children of the late Eligio Pascual, the latter being the
full blood brother of the decedent Don Andres Pascual, who died intestate without any issue,
legitimate, acknowledged natural, adopted or spurious children.

ISSUE:
W/N Art. 992 of the Civil Code of the Philippines, which states that “An illegitimate child has no
right to inherit ab intestate from the legitimate children and relatives of his father or mother; nor
shall such children or relatives inherit in the same manner from the illegitimate child”, can
be interpreted to exclude recognized natural children from the inheritance of the deceased.

HELD:
In Diaz v. IAC, this Court ruled that “Art. 992 of the Civil Code provides a barrier or iron curtain
in that it prohibits absolutely a succession ab intestate between the illegitimate child and the
legitimate children and relatives of the father or mother of said legitimate child. They may
have a natural tie of blood, but this is not recognized by law for the purposes of Art. 992.”
Eligio Pascual is a legitimate child but petitioners are his illegitimate children. Petitioners herein
cannot represent their father in the succession of the latter to the intestate estate of the decedent
Andres Pascual, full blood brother of their father.

People of the Philippines v. Mapa

Case No. 17
G.R. No. L-22301 (August 30, 1967)

FACTS:
Defendant was accused of illegal possession of firearms. He invokes in his defense that he was an
appointed Secret Agent of the provincial Governor of Batangas. He sought to be acquitted as the
case of People v. Macarandang used the same defense providing evidences of his appointment.

ISSUE:
W/N a Secret Agent falls among those authorized to possess firearms.

HELD:
No. The court held that the law cannot be any clearer. The law does not contain any exception for
secret agent therefore holding this position would not constitute a sufficient defense to a
prosecution for a crime of illegal possession of firearm and ammunitions. Wherefore the
conviction of the accused must stand. The Court’s ruling overturned that of People v.
Macarandang.

People v. Amigo
Case No. 18
G.R. No. 116719 (January 18, 1996)

FACTS:
The Regional Trial Court rendered a decision finding the Accused guilty beyond reasonable doubt
of the crime of murder, and sentenced to the penalty of reclusion perpetua.

Accused-Appellant argues that error was committed by the trial court in imposing or meting out
the penalty of reclusion perpetua against him despite the fact that Sec. 19 (1), Art. 3 of the 1987
Constitution was already in effect when the offense was committed.

Accused-Appellant contends that under the 1987 Constitution and prior to the promulgation of RA
7659, the death penalty had been abolished and hence, the penalty that should have been imposed
for the crime of murder committed by Accused-Appellant should be reclusion temporal in its
medium period to 20 years of reclusion temporal.

ISSUE:
W/N Sec. 19 (1), Article 3 of the 1987 Constitution means to require a corresponding modification
in the other periods as a result of the prohibition against the death penalty.

HELD:
In People vs. Muñoz, the Court held that “A reading of Section 19 (1) of Article III will readily
show that there is really nothing therein which expressly declares the abolition of the death
penalty.”

De Villa v. CA
Case No. 19
G.R. No. 87416 (April 8, 1991)

FACTS:
Petitioner was charged with a violation of BP 22 (Bouncing Checks Law) for issuing a worthless
check. However, he contends that the check was drawn against a dollar account with a foreign
bank, and is therefore, not covered by the said law.

ISSUE:
W/N the Makati Regional Trial Court has jurisdiction over the case in question.

HELD:
The Makati Regional Trial Court has jurisdiction. The determinative factor (in determining venue)
is the place of the issuance of the check. The offense was committed in Makati and therefore, the
same is controlling and sufficient to vest jurisdiction in the Makati Regional Trial Court. The Court
acquires jurisdiction over the case and over the person of the accused upon the filing
of a complaint or information in court which initiates a criminal action. With regard
to Petitioner’s allegation that the check is not covered by BP 22, it will be noted that the law does
not distinguish the currency involved in the case. Thus, the Court revealed that the records of
Batasan, Vol. III unmistakably show that the intention of the lawmakers is to apply the law to
whatever currency may be the subject thereof.

National Police Commission v. De Guzman, Jr.

Case No. 20
G.R. No. 106724 (February 9, 1994)

FACTS:
RA 6975, otherwise known as “An Act Establishing the PNP Under a Reorganized Dept. of the
Interior and Local Government,” laid down the compulsory retirement age of PNP officers.
Respondents argue that the age of retirement (56) of said law cannot be applied to them since they
are covered by Sec. 89 of the same law (which temporarily extended the age of retirement). In
other words, Respondents wanted to be extended the same privileges as the local police. Hence,
they contend that the term “INP” includes both the former members of the Philippine Constabulary
(PC) and the local police force who were earlier constituted as the Integrated National Police (INP).

ISSUE:
W/N the legislative intent was to classify the INP as applicable only to the local police force.

HELD:
The intent was to classify the INP in such manner that Sec. 89 of RA 6975 is applicable only to
the local police force. The use of the term INP is not synonymous with the PC. Had it been
otherwise, the statute could have just made a uniform reference to the members of the whole PNP
for retirement purposes and not just the INP. Indeed, the law distinguishes INP from the PC and it
cannot be construed that “INP” as used in Sec. 89 includes the members of the PC. The legislature
did intend to exclude the members of the PC from the coverage of Sec. 89 insofar
as the retirement age is concerned.