April 2023
68decisions- 01G.R. 203867Pilipinas Shell Petroleum Corporation v. Commissioner Napoleon Morales, as Commissioner of Customs, Juan N. Tan, as Collector of Customs of the Port of Batangas, and Simplicio DomingoSomeone accused of indirect contempt for comments about a pending case can be punished only if it is clearly shown, beyond reasonable doubt, that they meant to attack the court or obstruct justice.
- 02G.R. 219637Anselmo P. Bulanon v. Mendco Development Corporation / Pinacle Casting and/or Mastercraft Philippines, Inc., and/or Jacquer International and/or Eric Ng MendozaA worker who claims he was illegally fired must first prove, with solid evidence, that he was really an employee, and a handyman hired from time to time by a family's businesses did not prove it.
- 03G.R. 254787Lucille B. Odilao, Represented by Ariel B. Odilao v. Union Bank of the PhilippinesA venue clause that lets the bank choose between Pasig City and the place where the mortgaged property is located does not stop the borrower from suing in the property's location, so the case should not have been dismissed.
- 04G.R. 230299Jannece C. Peñalosa v. Jose a. Ocampo, JrA private complainant cannot challenge a trial court's grant of the prosecution's motion to withdraw a criminal case, and a 2011 Facebook post could not be punished as libel because the cyber libel law came only in 2012.
- 05G.R. 204568-83Herman G. Limbo v. People of the Philippines Cecilia Li Vs. People of the PhilippinesA government bank officer who let favored clients cash out-of-town checks before they cleared, against bank and central bank rules, is guilty of graft, but a person cannot be convicted for acts different from those stated in the charge.
- 06G.R. 201914Josechito B. Gonzaga, Ruel a. Magsino, and Alfredo B. Santos v. Governor Enrique T. Garcia, Jr., Aurelio C. Angeles, Jr., Emerlinda S. Talento, Rodolfo H. de Mesa, the Office of the Hon. Ombudsman, the Office of the Hon. Overall Deputy Ombudsman, and the Office of the Hon. Secretary of the Department of the Interior and Local Government Office of the Ombudsman Vs. Governor Enrique T. Garcia, Jr., Aurelio C. Angeles, Jr., Emerlinda S. Talento, and Rodolfo H. de MesaThe old doctrine that an official's re-election forgives past misconduct still protects the elected governor for acts before April 12, 2016, but it never protects appointed officials, who can still be investigated and suspended.
- 07G.R. 223808Heirs of Aida Pineda, Represented by Ella Pineda Torcedo v. Office of the President, Department of Environment and Natural Resources, and Any/all Their Subordinate, Agents, and All Other Persons Acting on Its Behalf, and Heirs of Teofilo Pilando, SrIn Baguio City, a Certificate of Ancestral Land Claim alone does not prove ownership of the land, so it cannot defeat another claimant's earlier rights.
- 08G.R. 235737Sps. Melchor and Yolanda Dorao v. Sps. Bbb and Ccc, by Themselves and as Natural Guardians of Their Minor Daughter, AaaAdults who publicly shame a child with insulting words cannot excuse it as discipline, and they can be made to pay damages for violating the child's dignity.
- 09G.R. 216608& 216625 Standard Chartered Bank, Philippine Branch v. Philippine Investment Two (Spv-Amc), Inc., Philippine Investment One (Spv-Amc), Inc., and Mrm Asset Holdings 2, Inc. G.r. No. 216702-03 Philippine Investment Two (Spv-Amc), Inc. Vs. Standard Chartered Bank, Represented by Duncan Van Der Feltz, and Atty. Patricia-Ann T. ProdigalidadA loan made under Philippine law is not treated as paid just because the lender returned security to its true owner in a foreign bankruptcy settlement, so the bank stays in the debtor's rehabilitation.
- 10G.R. 240316Unicorp Finance Limited v. Herma Corporation G.r. No. 241752 Unicorp Finance Limited Vs. Herma CorporationA creditor cannot hold land that its debtor had already sold, so notices of levy on the titles must be cancelled and the new owner may stop the auction sale.
- 11G.R. 230649People of the Philippines v. Noel M. Cariño, Ferdinand T. Santos, Robert John L. Sobrepeña, Exequiel E. Robles, Roberto J. Chan, Susana S. Chan, Ruben C. Sy, Sofia C. Sy, Vicente Santos, and Igmidio RoblesAn estimated project completion date in a registration statement is not an untrue statement when made, and company officers are not criminally liable unless shown to be directly responsible for the violation.
- 12G.R. 249283Po2 Ireneo M. Sosas, Jr. v. People of the Philippines Spo3 Ariel D. Salvador Vs. People of the PhilippinesPolice officers who use their authority to scare a person in their custody into paying money are guilty of robbery by extortion.
- 13G.R. 237558Margarito B. Teves v. Office of the Ombudsman and Field Investigation Office, Represented by Dayid a. Lucero Cyril C. del Callar, Albert C. Balingit, George J. Regalado, and Roberto S. Vergara Vs. Office of the Ombudsman and Field Investigation Office, Represented by Dayid a. Lucero Gilda E. Pico and Carel D. Halog Vs. Office of the Ombudsman and Field Investigation Office, Represented by Dayid a. LuceroGovernment officials are not guilty of entering a grossly disadvantageous contract just because a deal could have been better for the government; the disadvantage must be glaring and shocking.
- 14G.R. 198609-10Department of Finance and Department of Energy v. Philippine Airlines, Inc. G.r. No. 229812 the Department of Finance and the Department of Energy Vs. Philippine Airlines, IncA company cannot escape a tax ruling by going to an ordinary trial court to attack one of the facts the ruling was based on, because tax matters belong to the tax authorities and the Court of Tax Appeals.
- 15G.R. 240883Luzviminda Pascua y Bulan v. People of the PhilippinesA teacher who pinched, tapped and slapped a pupil on the spur of the moment to discipline him is guilty only of slight physical injuries, not child abuse, because the injuries were minor and she did not mean to humiliate him.
- 16G.R. 225722Republic of the Philippines, Represented by the Regional Director of the Department of Education, Region II v. Grelinda D. Espejo, Ma. Carolina D. Espejo, Gregorio v. Espejo, Roger v. Umipig, Alma v. Umipig, Helen v. Umipig, Constance S. Sales, Faustino Llanes, and the Register of Deeds for the Province of IsabelaBuyers of registered land are treated as knowing everything recorded at the Register of Deeds, so they cannot claim to be innocent buyers when the records show the government's earlier claim.
- 17G.R. 244054Gloria F. Quiroz v. Ramon R. NalusWhen a case is decided on the pleadings alone, the amount of damages is not treated as admitted, so the plaintiff must still be allowed to prove it in court.
- 18G.R. 228234Jovencio H. Evangelista v. Philippine Amusement and Gaming Corporation (Pagcor); Andrea D. Domingo; Alfredo C. Lim; Carmen N. Pedrosa; Reynaldo E. Concordia; and Gabriel S. Claudio Miguel Daniel C. Cruz, in His Personal Capacity and as the Representative of Union for National Development and Good Governance-Philippines (Unlad-Philippines) Vs. Philippine Amusement and Gaming Corporation (Pagcor) and Andrea D. Domingo, in Her Capacity as the Chief Executive Officer (Ceo) and Chairperson of the Board of Directors of the Pagcor Anti-Trapo Movement of the Philippines, Inc., Represented by Its Founding Chairperson, Leon Estrella Peralta, and Leon Estrella Peralta Vs. Philippine Amusement and Gaming Corporation, Represented by Andrea D. Domingo, Chairperson of the Board of Directors, Pagcor, and John and Jane Does of Pagcor (Unnamed Public Officers of the Pagcor)The Supreme Court refused to rule on whether PAGCOR's rules for offshore online gambling are valid, because the petitioners skipped the lower courts and could not show they were personally harmed by the rules.
- 19A.C. 10808Daniel Scott Mckinney v. Attys. Jerry Bañares and Rachel S. Miñon-BañaresA lawyer who helps a scheme to get public land for a corporation through a dummy, and who practices law while serving as a mayor, can be suspended even if the complainant withdraws.
- 20A.C. 7526Lazaro G. Javier, Jr. v. Atty. Carlos P. RiveraA lawyer who notarizes documents without a notarial commission breaks the Lawyer's Oath, and a lawyer who has done it before and defies orders can be disbarred, even if already disbarred for something else.
- 21G.R. 256700People of the Philippines v. Jomerito S. SolimanA court may punish online libel with a fine alone instead of imprisonment, and the prosecution cannot get a higher penalty on appeal if the trial court did not gravely abuse its discretion.
- 22A.M. P-23-084Judge Genie G. Gapas-Agbada v. Atty. Louie T. Guerrero, Clerk of Court, Office of the Clerk of Court, Regional Trial Court, Virac, Catanduanes Atty. Louie T. Guerrero, Clerk of Court, Office of the Clerk of Court, Regional Trial Court, Virac, Catanduanes Vs. Judge Genie G. Gapas-Agbada, Presiding Judge, Regional Trial Court, Branch 42, Virac, Catanduanes a.m. No. P-23-086 Atty. Louie T. Guerrero, Clerk of Court, Office of the Clerk of Court, Regional Trial Court, Virac, Catanduanes Vs. Judge Lorna Santiago-Ubalde, Municipal Trial Court, Virac, Catanduanes, Designated as Acting Presiding Judge, Municipal Trial Court in Cities, General Santos City, South Cotabato; Aristotle Ramos, Legal Researcher, Orlando v. Arcilla, Jr., Process Server; and Isidro Guerrero, Utility Worker, All of Regional Trial Court, Branch 42, Virac, Catanduanes Atty. Louie T. Guerrero, Clerk of Court, Office of the Clerk of Court, Regional Trial Court, Virac, Catanduanes Vs. Karina Tabuzo, Former Clerk III, Regional Trial Court, Branch 42, Virac, Catanduanes, Now Clerk of Court, Metropolitan Trial Court, Branch 69, Pasig City Liberty So-Guerrero Vs. Presiding Judge Genie G. Gapas-Agbada, Regional Trial Court, Branch 42, Virac, Catanduanes and Judge Lorna Santiago-Ubalde, Municipal Trial Court, Virac, Catanduanes, Designated as Acting Presiding Judge, Municipal Trial Court in Cities, General Santos City, South CotabatoA court clerk who is also a lawyer and who insulted his judge, secretly recorded and photographed her, threatened witnesses and campaigned for a candidate was disbarred, while the counter-complaints against the judges were dismissed for lack of proof.
- 23G.R. 253480Teodoro B. Bunayog v. Foscon Shipmanagement, Inc., /green Maritime Co., Ltd., /evelyn M. DefensorA seafarer who asks for a third doctor must send a written request with his own doctor's report, and an employer who ignores a valid request is treated as in the wrong, though the seafarer's doctor's report must still have a real medical basis.
- 24G.R. 227004Abs-Cbn Corporation and Jorge Cariño v. Datu Andal Ampatuan, JrA petition to punish a TV network and its reporter for contempt over a pre-trial interview of a Maguindanao Massacre witness must be dismissed when it does not allege the required mental element or the clear and present danger to the court's administration of justice, although the Court said that airing such an interview would otherwise have been contempt.
- 25A.C. 11227(Formerly Cbd Case No. 16-5210) Mercedita v. Cuenca Vs. Atty. Albert VillasecaA lawyer who takes a client's money, neglects her case, hides its dismissal and has already been suspended for similar neglect is disbarred, meaning he loses his license to practice law.
- 26A.M. P-15-3299(Formerly a.m. No. P-14-12-404-RTC) Office of the Court Administrator v. Atty. Robert Ryan H. Esmenda, Clerk of Court Vi, Regional Trial Court, Lipa City, BatangasA clerk of court who fails to deposit court collections on time and ends up with millions of pesos in shortages is dismissed from the service for serious dishonesty and gross neglect of duty.
- 27G.R. 257342Mary Elizabeth Ortiga Ty v. House of Representatives Electoral Tribunal (Hret) and Prospero Arreza Pichay, JrThe Supreme Court dismissed a challenge to a congressman's right to hold office because the issue became moot, since the Court had already upheld the penalty disqualifying him and he was no longer in office or running.
- 28G.r. No. 223767* Commissioner of Internal Revenue, Petitioner, Vs. South Entertainment Gallery, Inc., Respondent.A tax assessment is void if the tax collector cannot prove that the formal demand was properly served on the taxpayer, even if it was delivered to a mall's central receiving office.
- 29G.R. 204687United Coconut Planters Bank, Substituted by Land Bank of the Philippines v. Commissioner of Internal RevenueA corporation that chooses to carry over its excess tax credits to the next year cannot later switch to asking for a refund of the same credits.
- 30G.R. 200466Esteban Yau, Substituted by Heirs Gloricita S. Yau, Lullete S. Yau, Cliffson S. Yau, and Steveson S. Yau v. Hon. Ester M. Veloso, Presiding Judge of Branch Vi, Regional Trial Court, Cebu City, Ricardo C. Silverio, Sr., and Ricardo S. Silverio, JrA judge wrongly cancelled the levy and sale of properties that were seized to pay a final judgment, because the debtor still had a real interest in them, but the sale price had to be redone because the debt was later reduced.
- 31G.R. 248529People of the Philippines v. Mark Alvin Lacson y Marquesses a.k.a "Mac-Mac", Noel Agpalo y Sacay and Moises Dagdag y Corpuz Mark Alvin Lacson y Marquesses a.k.a "Mac-Mac" and Noel Agpalo y SacayPolice cannot search people just because they look suspicious or run away, and a gun or grenade found in such a search cannot be used as evidence, even if the accused did not object to the arrest early.
- 32G.R. 201944Bonifacio Communications Corporation and Philippine Long Distance Telephone Company v. National Telecommunications Commission, Innove Communications, Inc., and Fort Bonifacio Development CorporationA private contract cannot give one company the exclusive right to run telecom facilities and services in an area, and the National Telecommunications Commission can order it to stop blocking a licensed competitor.
- 33G.R. 220824Municipality of Pateros v. City of Taguig and City of MakatiWhen the other local governments ignore a town's attempts to settle a boundary dispute through their councils, the town may go straight to court, and the court has jurisdiction to hear its original case.
- 34G.R. 258126Jonathan Gabriel Biron, Arjay Mendez, and Eric Ebuenga Palomer v. People of the PhilippinesA trial court may allow an accused in a drugs case to plea bargain even over the prosecution's objection, unless the objection is valid and backed by evidence, so the case goes back for the court to hear that objection.
- 35G.R. 236140Josefina C. Billote,• v. Spouses Victor and Remedios T. Badar, Adelaida C. Dalope and Imelda C. SolisA buyer who ignores suspicious signs about the seller's title is not a buyer in good faith, and an earlier buyer keeps ownership of the share validly sold to her.
- 36A.M. P-22-072Executive Judge Jackie B. Crisologo-Saguisag v. Edith P. Haboc, Clerk III, Metropolitan Trial Court of Makati City, Branch 62A court employee convicted of bouncing checks, a crime involving moral turpitude, can be penalized administratively even after being dropped from the rolls, and probation does not erase the penalty.
- 37G.R. 225774Jessie Javier Carlos v. Department of Finance - Revenue Integrity Protection Service (Dof-Rips) and Office of the OmbudsmanA government worker cannot be punished for mistakes or omissions in a Statement of Assets, Liabilities, and Net Worth (SALN) unless the government first points out the problem and gives the worker a chance to fix it.
- 38A.M. 19-01-15-RTCIn Re: Conducted Report on the Judicial Audit Conducted in Branch 24, Regional Trial Court, Cabugao, Ilocos Sur, Under Hon. Raphiel F. Alzate, as Acting Presiding JudgeA judge who skipped required steps in marriage nullity cases was punished with a long suspension and a fine, but the Court dropped his dismissal because the proof of corruption was not enough.
- 39G.R. 211772Integrated Bar of the Philippines Philippine College of Physicians, Philippine Medical Association, Inc., and Philippine Dental Association-in-Intervention; v. Secretary Cesar v. Purisima of the Department of Finance and Commissioner Kim S. Jacinto-Henares of the Bureau of Internal Revenue Association of Small Accounting Practitioners in the Philippines, Inc. Vs. Hon. Secretary of Finance Cesar v. Purisima and Hon. Commissioner of Internal Revenue Kim S. Jacinto-HenaresThe government cannot force doctors, lawyers, accountants and other self-employed professionals to register their appointment books, which list client names and meeting times, because that invades their clients' and patients' right to privacy.
- 40A.C. 9683Court of Appeals Associate Justice Apolinario D. Bruselas, Jr. v. Atty. Eligio P. MallariChallenging a Court of Appeals justice to a public debate over his decision, while the case is still on appeal, is disrespectful to the courts, but a lawyer already disbarred for it cannot be sanctioned again, so the case was dismissed and recorded.
- 41G.R. 193521Power Sector Assets and Liabilities Management Corporation Vs Energy Regulatory Commission and Philippine Electricity Market CorporationThe electricity spot market operator, PEMC, may investigate breaches of the market rules, and the Energy Regulatory Commission shares that power with it.
- 42G.R. 248256Kamera World Inc. v. Reddot Imaging Philippines, IncA signed agreement that names the property, the price and the parties is a binding contract, and later emails or a term sheet proposing changes do not undo it.
- 43G.R. 221781Abs-Cbn Corporation v. Willie B. Revillame Abs-Cbn Corporation Vs. Willie B. Revillame and Abc Development Corp. Willie B. Revillame Vs. Abs-Cbn Corporation and Abc Development CorpA party that deliberately files two cases to get the same relief loses the claim it filed in the case it was trying to protect, and questions that no longer matter will not be decided.
- 44A.C. 13601Mary Ann B. Castro v. Atty. Zeldania D.t. SorianoA lawyer who calls someone a mistress in a legal notice written for a client is not disciplined when the word is relevant to the dispute and written in the performance of her duty to the client.
- 45G.R. 260214Erwin Alvero Tresvalles v. People of the PhilippinesA trial judge who approves a drug plea bargain over the prosecutor's objection, because the objection rests only on a Department of Justice circular, does not commit grave abuse of discretion, but must still check the Montierro conditions.
- 46G.R. 258130Regie David Tsutsumi v. Republic of the PhilippinesA Filipino spouse can have a Japanese divorce by mutual agreement recognized in the Philippines if the divorce papers and the Japanese law on divorce are proven, and courts should be liberal in applying the rules of evidence to such petitions.
- 47G.R. 262473Marilou Palacio y Valmores v. People of the PhilippinesPeople who recruit women and offer them to customers for sexual exploitation, taking advantage of their need for money, commit trafficking in persons, even if the women thought they would only drink and party.
- 48G.R. 265153Iloilo Grain Complex Corporation v. Hon. Ma. Theresa N. Enriquez-Gaspar, in Her Capacity as Presiding Judge of RTC-Iloilo City, Branch 33, and National Grid Corporation of the PhilippinesA court cannot automatically give a company the right to enter and take a landowner's property in an expropriation case when the landowner has questioned the company's authority to expropriate; the court must first hear and decide that question.
- 49G.R. 255324& 255353 Commissioner of Internal Revenue v. Toledo Power CompanyA company that makes only zero-rated sales can claim back its unused input VAT without proving that each purchase was used directly and entirely for those sales.
- 50G.R. 213640Lucia Manuel y Cadiz v. People of the PhilippinesThe Supreme Court acquitted a woman of estafa for bad checks because the prosecution did not prove that the person named as payee was actually defrauded.
- 51G.R. 247002People of the Philippines v. Jun Villegas @ "Pedrito" Basigna, Udebs Gonzales, and Kenneth Matias y Anglo Kenneth Matias y AngloEven when a crime clearly happened, a person cannot be convicted unless the victim's identification of him is reliable, and an identification that was suggested by the police and contradicted by the victim's earlier statements is not enough.
- 52G.R. 257697San Miguel Corporation v. Commissioner of Internal Revenue Commissioner of Internal Revenue Vs. San Miguel CorporationThe Court's earlier ruling that company advances recorded in memos and vouchers are taxable loans applies to past transactions too, because the Court only explained what the tax law already meant.
- 53G.R. 248004Rosa a. Castañeto v. Sps. Ernesto Adame and Mercedes GansanganWhen two titles cover the same lot, the Court traces both back to their source, and the title that was regularly issued and traces to the true owner wins, even if the claimant presented no survey plan.
- 54G.R. 257805Lee Saking y Anniban @ Lee Saking Sanniban v. People of the PhilippinesA person with no license who takes money for jobs abroad is guilty of both illegal recruitment and estafa (swindling), and the victim's lack of receipts does not save him.
- 55G.R. 206005Survivors of Agrichemicals in Gensan (Saging), Inc. With Its Chairperson Arturo G. Luardo and Its Members v. Standard Fruit Company, Standard Fruit and Steamship, Co., DOLE Food Company Inc., DOLE Fresh Fruit Company, Inc., del Monte Fresh Produce N.a. Inc., and del Monte Tropical Fruit CoA foreign company that says it was served court papers only by mail must prove it, and a complaint should not be thrown out over technicalities such as the members of an association not being named in its title.
- 56G.R. 240126Jamel M. Adoma v. People of the PhilippinesPolice can arrest someone without a warrant right after a crime only if they personally saw the facts pointing to that person and act immediately; arresting on tips hours later is not valid, and drugs found in such an arrest cannot be used as evidence.
- 57G.R. 249715M.y. Intercontinental Trading Corporation, Tedwin T. Uy, and Allianz Marketing and Publishing Corporation v. St. Mary'S Publishing Corporation and Jerry Vicente S. CatabijanA forged document cannot transfer a copyright, so a company that imported and sold another publisher's textbooks on the strength of that forged deed committed copyright infringement and must pay damages.
- 58G.R. 256091Icebergs Food Concepts, Inc. and Allan John T. Young v. Filipino Society of Composers, Authors, and Publishers, IncA restaurant that plays radio music over speakers without a license from the music collecting society is liable for copyright infringement, even though the Court urged protection for small businesses.
- 59G.R. 260109Rochard Balsamo y Dominguez v. People of the PhilippinesPunching a police officer in the chest to break free and slamming a gate on his fingers while running away is not serious enough to be direct assault, so the offense is only resistance to an agent of a person in authority.
- 60G.R. 252790Malayan Bank Savings and Mortgage Bank v. Holcim Philippines, IncOnce the Supreme Court has finally upheld an order declaring a party in default, the trial court cannot lift that order again on the same grounds, even if the judge who first ruled has been replaced.
- 61OCA IPI 13-4069-PJocelyn B. Sorensen v. Orville G. Santos, Sheriff IV, Office of the Clerk of Court, Regional Trial Court, Pagadian City, Zamboanga del SurA court employee cannot be punished for not paying a private debt unless the failure is willful, and the current rules on court discipline no longer punish failure to pay an ordinary admitted debt.
- 62G.R. 210984James Cua Ko v. Republic of the PhilippinesA man who is not the mother's husband cannot go to court to have himself recognized as the father of a child born during the mother's marriage, because that would attack the child's legitimacy, but the child herself remains free to prove who her real father is.
- 63G.R. 240892-94Republic of the Philippines v. Manuel O. Gallego, JrA landowner who holds valid owner's duplicates of lost titles may have them reconstituted by the Register of Deeds for the property's location, even if that office never had the original titles in its records.
- 64A.C. 13426Aaa v. Atty. Jon Michael P. AlamisA senior law partner who abuses his position over a junior associate through sexually charged conduct is guilty of immoral conduct and is suspended from law practice for two years.
- 65A.M. 21-06-20-SCRe: Disturbing Social Media Posts of Lawyers/law ProfessorsLawyers can be disciplined for homophobic and disrespectful Facebook comments even when they think the conversation is private, because posts on social media cannot be assumed to stay private.
- 66G.R. 244027Jovit Buella y Abalain v. People of the PhilippinesThe Commission on Elections went beyond what the law allows when it treated all knives and other bladed instruments as deadly weapons banned during the election period, so people charged for carrying them were acquitted.
- 67G.R. 236173Heirs of Nicanor Garcia, as Represented by Spouses Josefina Garcia-Doblada and Jose v. Doblada Vs. Spouses Dominador J. Burgos and Primitiva I. Burgos, Spouses Filip Gerard v. Burgos and Marites a. Burgos, and Ester Gabriel DominguezA farm tenant, and the tenant's heirs, can sue to get land back when it was sold without the tenant's knowledge, and a court cannot throw out such a case without a trial.
- 68G.R. 211146Secretary Proceso J. Alcala, as Secretary of the Department of Agriculture, and as Chairman of the National Food Authority Council, and the Bureau of Customs, Represented by Commissioner John Phillip P. Sevilla v. Honorable Judge Emmanuel C. Carpio, in His Capacity as Presiding Judge of Branch 16, Regional Trial Court in Davao City, and Joseph Mangupag Ngo Secretary Proceso J. Alcala, as Secretary of the Department of Agriculture, and as Chairman of the National Food Authority Council, and the Bureau of Customs, Represented by Commissioner John Phillip P. Sevilla Vs. Honorable Judge Cicero D. Jurado, Jr., in His Capacity as Presiding Judge of Branch 11, Regional Trial Court in Manila, Danilo G. Galang, Doing Business Under the Name and Style St. Hildegard Grains Enterprises, and Ivy M. Souza, Doing Business Under the Name and Style Bold Bidder Marketing and General MerchandiseImporters who brought in rice without the National Food Authority's import permit had no clear legal right to import it, so trial judges gravely abused their discretion by ordering customs not to hold the shipments.