Case digests.
Ready for the cold call.

The cases every Bar subject keeps coming back to — the doctrine in one line, the facts, issue and ruling behind it, and the full decision a tap away.

Study material, not legal advice. Written and checked by the PhilippineLaws team to the best of our knowledge; not reviewed by a lawyer. A digest is a summary — the full decision is the authority, so read it before you cite it.

19 digests16 landmark3 that changed the law19 with the full ruling

19 cases

LandmarkPolitical LawG.R. No. 133250Read the full ruling

Chavez v. Public Estates Authority and AMARI Coastal Bay

Carpio, J. · July 9, 2002 (Resolution May 6, 2003) · Constitutional Law — Regalian Doctrine & National Patrimony (Art. XII, Secs. 2-3)

The doctrine

Submerged lands of the public domain are inalienable; reclaimed lands can only be leased, never transferred in ownership, to private corporations.

If you're called

PEA cannot sell submerged or reclaimed public domain lands to a private corporation like AMARI. Private corporations are constitutionally disqualified under Sec. 3, Art. XII from acquiring alienable lands of the public domain, even after reclamation, except by lease.

Facts

  1. 1On February 4, 1977, President Marcos issued PD 1084 creating the Public Estates Authority (PEA) and PD 1085 transferring to PEA the lands reclaimed in the foreshore and offshore of Manila Bay under the Manila-Cavite Coastal Road and Reclamation Project.
  2. 2On April 25, 1995, PEA entered into a Joint Venture Agreement (JVA) with AMARI, a private corporation, through negotiation and without public bidding, to develop the Freedom Islands and reclaim an additional 250 hectares of submerged areas around them.
  3. 3On April 27, 1998, petitioner Frank I. Chavez, as a taxpayer, filed a petition for mandamus directly with the Supreme Court, seeking disclosure of the renegotiated terms and asserting that the sale of public lands to AMARI violated Section 3, Article XII of the 1987 Constitution.
  4. 4While the case was pending, PEA and AMARI signed an Amended JVA on March 30, 1999, covering a 750-hectare reclamation area and transferring to AMARI title to 367.5 hectares of reclaimed lands and still-submerged areas.

How it got here. Original Petition for Mandamus with Prayer for Temporary Restraining Order before the Supreme Court En Banc. The Court granted the petition, declared the Amended JVA null and void ab initio, and permanently enjoined its implementation. The motions for reconsideration were denied with finality in the Resolution of May 6, 2003.

Issues

  1. 11. Does petitioner Frank Chavez possess locus standi as citizen and taxpayer to challenge the JVA?
  2. 22. Are submerged lands of Manila Bay alienable and disposable lands of the public domain?
  3. 33. May the State, through PEA, transfer ownership of reclaimed public lands to a private corporation like AMARI?

Ruling

Held

The Amended JVA is NULL and VOID ab initio for violating Sections 2 and 3, Article XII of the 1987 Constitution.

Submerged lands are property of public dominion and strictly inalienable. Foreshore and submerged areas become alienable only after they are reclaimed, classified as alienable or disposable lands open to disposition, and declared no longer needed for public service. Even after reclamation, Section 3, Article XII of the 1987 Constitution explicitly forbids private corporations from acquiring alienable lands of the public domain; they can only hold such lands by LEASE not exceeding 25 years renewable for another 25 years. Reclaimed lands transferred to PEA remain public lands so long as they are in PEA's hands, and transferring them to a private corporation in fee simple circumvents the constitutional ban.

Article XII, Section 2 & 3, 1987 Constitution (Regalian Doctrine and Corporate Disqualification)Commonwealth Act No. 141 (Public Land Act), Sections 58-61Civil Code of the Philippines, Articles 420 and 422 (Property of Public Dominion)Civil Code of the Philippines, Article 1409 (Void Contracts)

Key lines

“There can be no dispute that these submerged areas form part of the public domain, and in their present state are inalienable and outside the commerce of man.”
Word for word in the rulingCarpio, J. · Holding that the submerged area covered by the Amended JVA could not be sold at all.
“Nevertheless, any legislative authority granted to PEA to sell its reclaimed alienable lands of the public domain would be subject to the constitutional ban on private corporations from acquiring alienable lands of the public domain.”
Word for word in the rulingCarpio, J. · Why even a lawful sale by PEA could not reach AMARI, a private corporation.

Separate opinions

Bellosillo, J.Separate

Concurring and dissenting (May 6, 2003 Resolution): concurred on the right to information on government contract negotiations, but dissented from nullifying the Amended JVA ab initio, arguing that the reclaimed Freedom Islands were lands of the private domain. No Justice dissented from the July 9, 2002 Decision itself.

Puno, J.Separate

Separate opinion (May 6, 2003 Resolution): voted to give the 2002 Decision prospective application only, because AMARI had relied in good faith on long-standing Department of Justice opinions allowing reclaimers to be paid with reclaimed land.

Ynares-Santiago, J.Dissenting

Dissented from the May 6, 2003 Resolution (as did Sandoval-Gutierrez and Corona, JJ.), voting to grant reconsideration and deny the petition: a historical analysis of the laws on reclaimed lands showed they had been treated by law as alienable, and the sweeping invalidation of the Amended JVA gave scant consideration to the nearly P9.9 billion AMARI had already spent.

LandmarkPolitical LawG.R. No. 101083Read the full ruling

Oposa v. Factoran, Jr.

Davide, Jr., J. · July 30, 1993 · Constitutional Law — Intergenerational Responsibility & Environmental Rights

The doctrine

Minors have locus standi to sue for themselves and generations yet unborn to enforce the constitutional right to a balanced and healthful ecology (Intergenerational Responsibility).

If you're called

Children represented by their parents sued to cancel all commercial Timber License Agreements. The Supreme Court recognized intergenerational standing and held that the right to a balanced and healthful ecology (Art. II, Sec. 16) is a self-executing, judicially enforceable right.

LandmarkCriminal LawG.R. No. 148560Read the full ruling

Estrada v. Sandiganbayan

Bellosillo, J. · November 19, 2001 · Crimes Against Public Office — Plunder (RA 7080), Void-for-Vagueness & Overbreadth

The doctrine

Plunder (RA 7080) is constitutional and malum in se; facial challenges on void-for-vagueness and overbreadth grounds cannot be mounted against penal statutes.

If you're called

Former President Estrada challenged the Plunder Law (RA 7080) as void for vagueness due to terms like "combination", "series", and "pattern". The SC held that facial challenges apply only to free-speech regulations, not penal statutes, and that plunder requires mens rea as a malum in se crime.

LandmarkPolitical LawG.R. Nos. 146710-15Read the full ruling

Estrada v. Desierto

Puno, J. · March 2, 2001 & April 3, 2001 (Resolution) · Executive Department — Resignation of President, Presidential Immunity, Justiciable Controversy

The doctrine

A President can resign constructively through a totality of prior, contemporaneous, and subsequent acts; a non-sitting President enjoys no immunity from criminal prosecution.

If you're called

Estrada claimed he was merely on leave during EDSA II and retained presidential immunity. The SC ruled that Estrada constructively resigned as shown by the Angara Diary and departure from Malacañang, and held that immunity only protects a sitting President from civil/criminal process.

Changed the lawCivil LawG.R. No. 196359Read the full ruling

Tan-Andal v. Andal

Leonen, J. · May 11, 2021 · Persons and Family Relations — Psychological Incapacity (Article 36, Family Code)

This changed the law. It abandoned or reinterpreted the rule in Republic v. Court of Appeals and Molina (G.R. No. 108763, Feb 13, 1997). Modifies (does not wholly discard) the Molina guidelines: drops the requirement that the root cause be medically or clinically identified and proven by experts, and reads incurability in a legal rather than a medical sense.

The doctrine

Psychological incapacity under Art. 36 is a legal concept, not a medical illness; it does not require clinical diagnosis by a psychiatrist, and may be established through lay testimony showing enduring personality structure.

If you're called

The Supreme Court modified the Molina guidelines. Psychological incapacity is NOT a mental disease and does NOT require examination by a psychologist. It is a legal ground proven by clear and convincing evidence showing a personality structure that makes the spouse enduringly incapable of fulfilling essential marital obligations.

Changed the lawRemedial LawG.R. Nos. 217126-27Read the full ruling

Carpio-Morales v. Court of Appeals and Jejomar Erwin S. Binay, Jr.

Perlas-Bernabe, J. · November 10, 2015 · Administrative & Remedial Law — Condonation Doctrine Abandonment & CA Injunctive Power

This changed the law. It abandoned or reinterpreted the rule in Aguinaldo v. Santos (G.R. No. 94115, Aug 21, 1992) and Pascual v. Provincial Board (1959). ABANDONED the Condonation Doctrine that began with Pascual (1959). Reelection of a public official no longer wipes out administrative liability for offenses during a prior term. Per Madreo v. Bayron (G.R. No. 237330, Nov. 3, 2020), the doctrine is unavailable only where the reelection happened on or after April 12, 2016, when Carpio-Morales became final.

The doctrine

The Condonation Doctrine is abandoned for having no legal or constitutional basis; reelection does not condone past administrative offenses. Abandonment operates prospectively.

If you're called

Mayor Junjun Binay was preventively suspended by the Ombudsman over the Makati parking building project, and invoked the Condonation Doctrine since he had been reelected. The SC abandoned the doctrine as having no legal anchorage under the 1987 Constitution, which makes public office a public trust, but made the abandonment prospective.

Changed the lawRemedial LawG.R. No. 217158Read the full ruling

Gios-Samar, Inc. v. Department of Transportation and Communications

Jardeleza, J. · March 12, 2019 · Civil Procedure / Special Civil Actions — Strict Hierarchy of Courts Rule

The doctrine

Direct recourse to the Supreme Court under Rule 65 is strictly prohibited whenever factual issues or mixed questions of fact and law are involved; the Supreme Court is not a trier of facts.

If you're called

An NGO directly petitioned the SC to halt a bundled airport bidding. The SC dismissed the petition and laid down a strict rule: even if an issue is claimed to be transcendental, the SC will not entertain direct petitions if resolution requires assessing evidence. Parties must observe the Hierarchy of Courts.

LandmarkPolitical LawG.R. No. 213948Read the full ruling

Knights of Rizal v. DMCI Homes, Inc. (Torre de Manila Case)

Carpio, J. · April 25, 2017 · Constitutional Law / Administrative Law — Cultural Heritage, Police Power & Mandamus

The doctrine

There is no law prohibiting the construction of a building outside a designated historical monument simply because it affects the background sightline; Mandamus lies only to compel ministerial duties, not discretionary acts.

If you're called

Knights of Rizal petitioned to demolish the 49-story Torre de Manila for ruining the sightline of the Rizal Monument. The SC dismissed the petition because no law or local ordinance restricted sightlines on private property outside the Luneta park boundaries.

LandmarkLabor LawG.R. No. 158693Read the full ruling

Agabon v. National Labor Relations Commission (NLRC)

Ynares-Santiago, J. · November 17, 2004 · Labor Relations — Termination of Employment & Procedural Due Process (Twin-Notice Rule)

This changed the law. It abandoned or reinterpreted the rule in Serrano v. NLRC (G.R. No. 117040, Jan 27, 2000). Abandoned the Serrano rule awarding full backwages from termination to final judgment for lack of procedural due process; reinstated Wenphil but replaced small indemnity with P30,000 nominal damages.

The doctrine

Where dismissal is for a just cause but procedural due process (twin-notice rule) is not observed, the dismissal remains valid but the employer must pay nominal damages of P30,000 for violating statutory rights.

If you're called

Virgilio and Jenny Agabon abandoned their jobs to work for another company, but Riviera Home did not comply with the twin-notice requirement. The Supreme Court En Banc held that the dismissal for just cause was valid, abandoned the Serrano rule of full backwages, and awarded P30,000 nominal damages to each.

LandmarkPolitical LawG.R. No. 208566Read the full ruling

Belgica v. Ochoa (The PDAF / Pork Barrel Case)

Perlas-Bernabe, J. · November 19, 2013 (En Banc) · Constitutional Law — Separation of Powers, Non-Delegability of Legislative Power & Public Trust

The doctrine

The Congressional Pork Barrel System (PDAF) is unconstitutional because it accords legislators post-enactment authority in budget execution, violating separation of powers, non-delegability, and the presidential line-item veto.

If you're called

Greco Belgica and other citizens challenged the constitutionality of the Priority Development Assistance Fund (PDAF) following the Janet Lim-Napoles pork barrel scam. The Supreme Court En Banc declared the PDAF and all similar Congressional pork barrel provisions unconstitutional because allowing legislators to identify, release, or realign funds after passing the General Appropriations Act impermissibly intrudes into executive budget implementation.

LandmarkPolitical LawG.R. No. L-63915Read the full ruling

Tañada v. Tuvera

Cruz, J. · December 29, 1986 (En Banc Resolution) · Constitutional Law & Civil Law — Procedural Due Process & Effectivity of Laws (Article 2, Civil Code)

The doctrine

Publication in the Official Gazette or a newspaper of general circulation is an indispensable prerequisite for the effectivity of all laws, presidential decrees, and administrative rules of general application; secret laws are abhorrent to due process.

If you're called

Lorenzo Tañada and MABINI petitioned for mandamus to compel Executive Secretary Juan Tuvera to publish unpublished presidential decrees, general orders, and letters of instructions issued during martial law. The Supreme Court En Banc held that the phrase "unless it is otherwise provided" in Article 2 of the Civil Code refers solely to the date of effectivity, not to the requirement of publication itself, ruling that all statutes of general application must be published in full to satisfy procedural due process.

LandmarkCivil LawG.R. No. 119190Read the full ruling

Chi Ming Tsoi v. Court of Appeals

Torres, Jr., J. · January 16, 1997 · Persons and Family Relations — Article 36, Family Code (Psychological Incapacity & Marital Obligations)

The doctrine

The senseless, continuous, and protracted refusal of a spouse to engage in sexual intimacy and consummate the marriage despite physical capability constitutes psychological incapacity under Article 36 of the Family Code.

If you're called

Gina Lao-Tsoi petitioned for the annulment/nullity of her marriage under Article 36 after nearly a year of living together without ever engaging in sexual intercourse, despite medical proof that she was a virgin and her husband was physically capable. The Supreme Court affirmed the decree of nullity, ruling that procreation of children through mutual sexual cooperation is an essential marital obligation, and the obstinate refusal to fulfill it reflects psychological incapacity.

LandmarkCivil LawG.R. No. L-12219Read the full ruling

Picart v. Smith

Street, J. · March 15, 1918 · Torts and Damages — Quasi-Delict (Article 2176), Standard of Negligence & Doctrine of Last Clear Chance

The doctrine

Actionable negligence is tested against the conduct of the prudent paterfamilias; under the doctrine of last clear chance, the party who has the last opportunity to avoid the impending peril is solely liable for the resulting injury.

If you're called

Amado Picart was riding his pony on the wrong side of the Carlatan Bridge when Frank Smith approached driving an automobile and failed to stop or yield despite seeing the horse from a distance, causing the pony to panic and die. The Supreme Court reversed the trial court, formulating the classic Philippine test of negligence (the reasonable care of a discreet paterfamilias) and applying the doctrine of last clear chance to hold Smith liable.

LandmarkCriminal LawG.R. No. 135981Read the full ruling

People v. Genosa (Battered Woman Syndrome Case)

Panganiban, J. · January 15, 2004 (En Banc) · Justifying Circumstances — Self-Defense (Art. 11[1], RPC), Battered Woman Syndrome & Mitigating Circumstances

The doctrine

Battered Woman Syndrome (BWS) is recognized as a valid defense; while complete self-defense requires unlawful aggression at the time of the killing, chronic battering operates as two mitigating circumstances (diminished willpower and passion/obfuscation) to reduce penalty.

If you're called

Marivic Genosa, who endured eight years of severe domestic beatings, killed her abusive husband while he was asleep after he assaulted and threatened her while eight months pregnant. The Supreme Court En Banc recognized Battered Woman Syndrome in Philippine law, held that complete self-defense failed because unlawful aggression had ceased while the victim slept, but credited Genosa with two mitigating circumstances and eliminated treachery, drastically reducing her sentence and ordering her release.

LandmarkCommercial LawG.R. No. 108734Read the full ruling

Concept Builders, Inc. v. NLRC

Hermosisima, Jr., J. · May 29, 1996 · Corporation Law — Separate Juridical Personality & Doctrine of Piercing the Veil of Corporate Fiction

The doctrine

The separate corporate entity may be disregarded under the three-prong test: (1) control amounting to complete domination of finances and policy, (2) use of control to commit fraud or wrong, and (3) proximate injury to the plaintiff.

If you're called

After employees obtained a final reinstatement and backwages award against Concept Builders, Inc. (CBI), CBI ceased operations and transferred its premises, officers, machinery, and business to a sister company, Hydro Phils., Inc. (HP), to evade execution. The Supreme Court affirmed the NLRC's order piercing the corporate veil of CBI and holding HP liable, laying down the classic three-prong control test for the alter ego doctrine.

LandmarkRemedial LawG.R. No. 130866Read the full ruling

St. Martin Funeral Home v. NLRC

Regalado, J. · September 16, 1998 (En Banc) · Special Civil Actions — Rule 65 Certiorari & Hierarchy of Courts (Judicial Review of NLRC Decisions)

The doctrine

All judicial challenges to decisions of the National Labor Relations Commission (NLRC) must be initiated via petition for certiorari under Rule 65 exclusively with the Court of Appeals, in strict adherence to the hierarchy of courts.

If you're called

St. Martin Funeral Home filed a Rule 65 petition for certiorari directly with the Supreme Court to challenge an NLRC resolution. The Supreme Court En Banc held that all statutory references to appeals from the NLRC must be construed as Rule 65 certiorari petitions that must be filed initially in the Court of Appeals, establishing the strict procedural pathway for labor appeals and decongesting the High Court's docket.

LandmarkLabor LawG.R. No. 151378Read the full ruling

Jaka Food Processing Corp. v. Pacot

Garcia, J. · March 28, 2005 (En Banc) · Termination of Employment — Authorized Causes (Article 283 / 298), Due Process & Nominal Damages

The doctrine

Where an employee is terminated for a valid authorized cause (retrenchment, redundancy, closure) but the employer fails to observe the statutory 30-day notice, the dismissal is valid, but the employer must pay a stiffer sanction of P50,000 nominal damages (compared to P30,000 for just causes in Agabon).

If you're called

Jaka Food Processing retrenched workers due to severe business losses but failed to serve the mandatory 30-day prior written notice upon them and the DOLE. The Supreme Court En Banc held that the retrenchment remained valid, but established that procedural violations in authorized-cause dismissals warrant a stiffer sanction of P50,000 nominal damages than just-cause dismissals (P30,000 under Agabon) because authorized causes involve no employee wrongdoing.

LandmarkLabor LawG.R. Nos. 204944-45Read the full ruling

Fuji Television Network, Inc. v. Espiritu

Leonen, J. · December 3, 2014 · Employer-Employee Relationship — Four-Fold Test, Economic Dependence Test, Fixed-Term Contracts (Brent Doctrine Exceptions) & Termination for Illness

The doctrine

Media workers repeatedly engaged under successive fixed-term contracts to perform tasks necessary and desirable to the employer's regular business are regular employees, not independent contractors; the four-fold test and economic dependence test govern.

If you're called

Arlene Espiritu served as a news correspondent for Fuji Television for four years under continuously renewed annual "independent contractor" agreements until she was diagnosed with lung cancer, whereupon Fuji refused renewal. The Supreme Court ruled that Arlene was a regular employee because Fuji controlled the means and methods of her work, held that successive fixed-term contracts cannot defeat security of tenure, and declared her dismissal for disease illegal.

LandmarkTaxation LawG.R. No. 187485Read the full ruling

Commissioner of Internal Revenue v. San Roque Power Corp.

Carpio, J. · February 12, 2013 (En Banc) · Value-Added Tax (VAT) — Input Tax Refunds & Credits (Section 112, NIRC), 120+30 Day Rule & Jurisdictional Periods

The doctrine

Compliance with the 120-day administrative waiting period and the subsequent 30-day judicial appeal period under Section 112 of the NIRC is mandatory and jurisdictional for input VAT refund claims; premature judicial appeal deprives the CTA of jurisdiction.

If you're called

San Roque Power Corporation filed an administrative claim for input VAT refund with the BIR and, only 13 days later, filed a petition for review with the Court of Tax Appeals without waiting for the 120-day period for the Commissioner to decide. The Supreme Court En Banc held that the 120+30 day period is mandatory and jurisdictional, ruling that premature judicial filing deprives the CTA of jurisdiction, but recognized prospective equitable relief for taxpayers who relied on BIR Ruling No. DA-489-03 between December 10, 2003 and October 6, 2010.

Digests are study aids written for this site, not the Court's words. Before you rely on one — in class or on the exam — read the ruling it summarises.