August 2023

73decisions
  1. 01G.R. 220145People of the Philippines v. XxxA man with mild mental retardation was still held criminally responsible for raping his sister-in-law, who has moderate retardation, because his disability did not completely take away his ability to tell right from wrong.
  2. 02G.R. 238714Annaliza C. Singson,* v. Spouses Nar Christian Carpio and Cecilia Cao CarpioA lender who holds a property as security for a loan cannot simply take ownership of it, and must first foreclose the mortgage.
  3. 03G.R. 259282Spouses Antonio and Monette Prieto v. Bank of the Philippine Islands Substituted by Philippine Asset Investment , as Further Substituted by Philippine Investment One , IncA bank's successor that fails to formally offer its evidence and then sits on its case for over ten years cannot recover a loan deficiency, and the court cannot let it fix its mistakes through a mislabelled motion.
  4. 04G.R. 259709Pilipinas Shell Petroleum Corporation v. Angel y. Pobre and Gino Nicholas PobreA court may issue a writ of preliminary attachment, which freezes a debtor's property before judgment, only when fraud is specifically shown and no other security exists, and the writ should generally cover only the principal claim.
  5. 05G.R. 249274Syrus J. Aluzan, Jose Henry L. Arellano and Ferdinand M. Lavin v. Eddie FortunadoOfficers who hold a person in custody must promptly send the case for preliminary investigation, and delay without explanation is simple neglect of duty even if the person first came to them voluntarily.
  6. 06G.R. 255014Presidential Commission on Good Government v. C&o Investment and Realty Corp. and Miguel CojuangcoThe government's anti-ill-gotten-wealth commission cannot hold on to a property through a sequestration letter signed by someone who had no power to issue it, and a void order cannot be saved by estoppel.
  7. 07G.R. 248584Felix G. Valenzona v. the People of the PhilippinesA corporation's president cannot be convicted of a crime under a special law just because he holds the title; the prosecution must show he himself took part in, or had the power to prevent, the violation.
  8. 08G.R. 266439Teresito Radonis Quiqui v. People of the PhilippinesA trial court may approve a drug accused's plea to a lesser offense even if the prosecutor objects only because of a Department of Justice circular, as long as the plea fits the Supreme Court's plea bargaining framework.
  9. 09G.R. 244017Rosalia T. Caballero v. Laverne Realty & Development Corporation, Vivian P. Razote,* Treasurer of Las Piñas City and Registrar of Deeds of Las Piñas CityA property sold at a tax delinquency sale is lost only if the city followed every required step, including making sure the owner (or the occupant or administrator) actually received the warrant of levy; otherwise the sale is void.
  10. 10G.R. 254206People of the Philippines v. Tito Pajarilla y AlasA rape victim's clear and credible testimony can convict the accused, and a weak alibi from a neighbor living 20 meters away cannot defeat it.
  11. 11G.R. 260912The Department of Energy v. Commissioner of Internal RevenueThe Court refused to reconsider its ruling that a tax dispute between two government agencies, the Department of Energy and the BIR, must be settled administratively and not in the Court of Tax Appeals.
  12. 12G.R. 259469Buyayo Aliguyon v. Jeffrey a.k.a. 'Napadawan' Dummang, Johnny a.k.a. 'Bidang' Dummang, Minda Dummang, and Donato DummangA landowner who orally agreed to give one hectare to his son's creditors for the son's debt and P8,000.00 is bound by that deal, which was already partly carried out, even though no deed was signed and his wife never consented.
  13. 13G.R. 267487Jose P. Singh v. Perfecto S. Corpus, Jr. and Marlene S. CorpusFiling a baseless disbarment complaint to pressure a lawyer into returning his acceptance fee is malicious prosecution, but the damages awarded must be kept within amounts the Court has allowed in similar cases.
  14. 14G.R. 258873People of the Philippines v. Abdul Azis y Sampaco a.k.a. "Mohammad Macapundag Guimbor" @ "Major" and Alibair Macadato y Macadato @ "Ongkay,"Police who see a suspect hand over a bag of shabu may arrest him without a warrant, and missing witnesses at the inventory do not free the accused if the police gave good reasons and the drugs' integrity was preserved.
  15. 15A.C. 8219Office of the Provincial Prosecutor of Cavite, Department of Justice. v. Atty. Leonuel N. MasA lawyer who was already disbarred cannot be disbarred a second time, but the Court can still record the penalty, make him return the money, and bar him from judicial clemency.
  16. 16A.M. 17-12-02-SCRe: Consultancy Services of Helen P. MacasaetThe eight consultancy contracts with Helen P. Macasaet stay void, but because everyone acted in good faith she may keep a fair payment for the work she actually did, to be computed by the Court itself.
  17. 17A.C. 12443Bernaldo E. Valdez v. Atty. Winston B. HipeA suspended lawyer may go back to practice as soon as he files a sworn statement that he served his suspension, without waiting for the Court to confirm it.
  18. 18G.R. 232778Republic of the Philippines v. Spouses Rolly D. Tan and Grace TanA land registration case still pending when the new law (Republic Act No. 11573) took effect must be sent back so the applicants can meet the new, simpler rules on proving that the land is alienable and on how long they or their predecessors possessed it.
  19. 19G.R. 261670Allan Gacasan y Langamin v. People of the PhilippinesA person who hands over fake bank notes and takes payment for them cannot claim he did not know they were fake, and he is guilty of illegal possession and use of false bank notes.
  20. 20G.R. 247439Sheriff Albert a. dela Cruz of the Sandiganbayan Security and Sheriff Services, the Sandiganbayan Security and Sheriff Services v. Wellex Group, IncA company that borrowed money from funds later found to be ill-gotten wealth cannot use the defense that the State waited too long to collect, because the State's right to recover ill-gotten wealth never expires.
  21. 21G.R. 255931Xxx255931,* v. People of the PhilippinesWhen a minor aged 12 to below 18 is forced into sex, the crime is rape under the Revised Penal Code, which carries a heavier penalty, and not a violation of the child abuse law.
  22. 22G.R. 228919Luzviminda Palo v. Spouses Rey C. Baquirquir and Fleurdeline B. Baquirquir, Takeshi Nakamura, Atty. Orpha T. Casul-ArendainA mortgage clause that merely says the property may be foreclosed judicially or extrajudicially does not give the lender the express power to sell the property, so a foreclosure without that power is void.
  23. 23G.R. 226098Roberto Bacar v. People of the Philippines and Vicente Tan Vicente Tan Vs. Michael MercadoTenants already declared by the agrarian adjudication board to be tenants of a landowner cannot be convicted of stealing the produce they harvested from that land.
  24. 24G.R. 261972People of the Philippines v. Mark Angelo Concepcion y BacuñoA person who claims insanity as a defense must prove with clear and convincing evidence that he had completely lost his mind at the time of the crime, and killing a toddler is murder because the child cannot defend himself.
  25. 25A.C. 9162(Formerly Cbd Case No. 06-1698) Teresa P. Sierra v. Atty. Joseph Anthony M. Alejandro and Atty. Carmina a. AbbasWhen a trial court has already taken up and decided a forum shopping issue in a case, the Integrated Bar of the Philippines cannot decide that same issue in a disbarment case against the lawyers.
  26. 26G.R. 261156Robert Catan y Masangkay v. People of the PhilippinesDemanding money from two teenagers by threatening to post a girl's nude photos online, and picking up the payment, is simple robbery, and doing it through the internet raises the penalty by one degree.
  27. 27A.C. 8471Judge Ray Alan T. Drilon and Atty. Corazon P. Romero v. Atty. Ariel D. MaglalangA lawyer who gave his client a fake court order was disbarred, meaning he lost his license to practice law.
  28. 28G.R. 239350J. Paul Q. Octaviano v. Board of Architecture of the Professional Regulation Commission, Professional Regulation Commission and United Architects of the PhilippinesThe Court upheld the rules requiring architects to be members of, and pay dues to, the United Architects of the Philippines, because the Architecture Act allows these requirements and they are a valid regulation of the profession.
  29. 29A.M. RTJ-21-2604Office of the Court Administrator v. Hon. Jesus B. Mupas, Former Presiding Judge, Atty. Melben Rey M. Madrid, Branch Clerk of Court, Liza I. Doctolero, Court Stenographer, and Hermito dela Cruz III, Criminal Clerk-in-Charge, All of the Regional Trial Court of Pasay City, Branch 112A court employee who ignores the judge's clear orders on how to safeguard cash evidence, and loses it as a result, can be dismissed from the service for gross neglect of duty.
  30. 30G.R. 261207Topbest Printing Corporation, as Duly Represented by Shirley L. Dionisio v. Sofia C. Gemora, in Her Capacity as Director IV of the Commission on Audit, Edna P. Salaguban, Supervising Auditor, Fahad Bin Abdul Malik N. Tomawis, Audit Team LeaderA company that lets a COA audit decision become final by filing a petition in the Supreme Court instead of appealing to the COA Commission Proper cannot reopen the case, and must return the money it received under a disguised subcontract.
  31. 31G.R. 240632Librado C. Navarro v. Commission on Audit, Director Roland a. Rey, Regional Director, Commission on Audit, Regional Office No. Xiii, Caraga Region, Butuan City Charlito R. Lerog, Aprodecio a. Alba, Roberto v. Viduya, Daisy a. Ronquillo, Lorna S. Salgado, and Belma K. Lomantas Vs. Commission on Audit, Represented by Chairperson Michael G. Aguinaldo, Commissioner Jose a. Fabia, and Commissioner Isabel D. Agito Racquel L. Bautista, Estefa R. Maata, and Laila P. Manlucob Vs. Commission on Audit, Represented by Chairperson Michael G. Aguinaldo, Commissioner Jose a. Fabia, and Commissioner Isabel D. Agito Gilbert P. Abugan Vs. Commission on Audit and Regional Director, COA Regional Office No. XiiiThe Commission on Audit cannot disallow a city's purchase of an excavator when the machine actually met the bid requirements, and the city officials who followed the procurement rules are cleared.
  32. 32G.R. 245855Romeo Dc. Resulta v. Public Assistance and Corruption Prevention Office (Pacpo)-Luzon, Represented by Marivic B. dela CruzA government employee cannot be dismissed for grave misconduct just because of his position or because he signed documents; there must be evidence of his own deliberate wrongdoing.
  33. 33G.R. 258060People of the Philippines v. Edward Dalisay y BagroPolice can frisk a person when there are at least two suspicious circumstances, but even then they must follow the drug-evidence rules, including a complete chain of custody, or the drug charge fails.
  34. 34G.R. 255740Pastor Corpus, Jr. y Belmoro v. People of the PhilippinesA person cannot be convicted of a lesser crime that had already prescribed (the time to file had run out) when the case was filed, even if he was charged with a graver crime.
  35. 35G.R. 262581People of the Philippines v. Sps. Xxx262581 and Yyy262581A father who rapes his minor daughter, with the mother holding the girl down, is guilty of qualified rape, and the mother is equally liable as a conspirator.
  36. 36A.M. 22-09-16-SCRe: Statements Made by Lorraine Marie T. Badoy Allegedly Threatening Judge Marlo a. Magdoza-Malagar. Atty. Rico v. Domingo, Dean Antonio Gabriel M. La Viña, Dean Ma. Soledad Deriquito-Mawis, Dean Anna Maria D. Abad, Dean Rodel a. Taton, Atty. Artemio P. Calumpong, Atty. Christianne Grace F. Salonga, Atty. Ray Paolo J. Santiago, and Atty. Ayn Ruth Z. Tolentino-Azarcon Vs. Lorraine Marie T. Badoy-PartosaFreedom of expression lets people criticize judges, but social media posts that threaten a judge and incite violence over a pending case are not protected speech and are punishable as contempt of court.
  37. 37G.R. 262197People of the Philippines v. Joko Celis y Pine a.k.a. "Jaztine" or "Joco/joko,"A man who recruited girls and offered them to customers for sex was convicted of qualified trafficking in persons, and the crime is complete even if no sex act has happened yet.
  38. 38G.R. 264958People of the Philippines v. Jonnel Delos Reyes y TungolTying up a 15-year-old and pushing him into a 20-foot pit, where he stayed for two days, is serious illegal detention, and the accused was sentenced to reclusion perpetua.
  39. 39G.R. 251872People of the Philippines v. Vanessa Banaag y BaylonThe Court held that a trafficker's conviction could not be for the qualified (child) version because the prosecution did not properly prove the victim's age, but it still convicted her of ordinary trafficking.
  40. 40G.R. 263706People of the Philippines v. Annie Frency Nuñez y Adolfo a.k.a. "Faith,"Recruiting minors to be offered to a customer for sex in exchange for money is qualified trafficking in persons, and the minors' consent is meaningless.
  41. 41G.R. 246942People of the Philippines v. Josephine Angsico, Virgilio v. Dacalos, Felicisimo F. Lazarte, Jr., Josephine T. Espinosa, and Noel a. Lobrido; Josephine Casenas-Hottle (Formerly Angsico), Virgilio v. Dacalos, Felicisimo F. Lazarte, Jr., and Noel a. Lobrido People of the Philippines Vs. Josephine Angsico, Robert Balao, Virgilio v. Dacalos, Felicisimo F. Lazarte, Jr., Josephine T. Espinosa, Noel a. Lobrido, and Jose M. Cruz; Josephine T. EspinosaGovernment officials who sign off on an inflated final payment to a contractor, knowing the required approval for extra work is missing, are guilty of graft, and a boss cannot simply rely on subordinates when red flags are present.
  42. 42G.R. 258257Pedro "Pepe" Talisay v. People of the PhilippinesPlacing a man's penis on top of a girl's vagina, without proof of any penetration or intent to penetrate, is lascivious conduct against a child, not rape, but it is still punished heavily.
  43. 43G.r. No. 235484* the City Government of Antipolo and the City Treasurer of Antipolo, Petitioners, Vs. Transmix Builders & Construction, Inc., Respondent.A city treasurer must send the warrant of levy for unpaid real property tax to the owner named on the land title, not just the person named in the tax declaration, or the levy, auction and forfeiture are void.
  44. 44G.r. No. 199539* Sioland Development Corporation, as Represented by Ceo Elizabeth Sio, Petitioner, Vs. Fair Distribution Center Corporation, Represented by Esteban L. Alba, Jr., Respondent.A buyer who lets a deadline to answer a lawsuit pass can be declared in default, and a claim of payment fails without receipts, since invoices only prove delivery and later deliveries do not prove earlier bills were paid.
  45. 45G.R. 221060Marken, Incorporated,* v. Landbank of the Philippines, Department of Agrarian Reform, and Department of Agrarian Reform Adjudication Board (Darab)A landowner who disagrees with the agrarian board's land price must go to the Special Agrarian Court, not straight to the Court of Appeals, and idle land is not exempt from agrarian reform just because it was once a fishpond.
  46. 46G.R. 226176National Commission on Indigenous Peoples (Ncip), Zenaida Brigida Hamada­pawid, Dionesia O. Banua, Conchita C. Calzado, Percy Brawner, Cosme Lambayon, Santos Unsad, and Basilio Wandag v. Macroasia Corporation (Based on Compromise Agreement)The Supreme Court approved a settlement between the National Commission on Indigenous Peoples and a mining company and closed the case.
  47. 47G.R. 257410Edwin Aguilar y Duron v. People of the PhilippinesA trial court may overrule the prosecution's objection to a drug plea bargain that rests only on the Department of Justice's guidelines, but it must still check whether the accused is disqualified or the evidence of guilt is strong.
  48. 48G.R. 261610Jaroslav Dobes, Barbora Plaskova, and Bono Lukas Plasek (Minor) v. the Honorable Court of Appeals , Office of the President, Through Salvador C. Medialdea, in His Capacity as Executive Secretary, the Department of Justice, Through Chief State Counsel, Honorable Ricardo v. Paras III, and Bureau of Immigration, Through Commissioner Jaime H. MorenteThe Court dismissed a refugee-status challenge because the petitioners had already lost the same issue in an earlier Supreme Court petition and filed a false certification against forum shopping.
  49. 49G.R. 258694People of the Philippines v. Yyy258694* and Xxx258694When an adult has sexual intercourse with a minor by force, the crime is prosecuted as rape under the Revised Penal Code, and a person who lures and holds down the victim is equally liable as a conspirator.
  50. 50G.R. 256233People of the Philippines v. Nixon Cabanilla y Crisologo, Michael Cabardo y Cordevilla, and Gomer Valmeo y ComilangPolice cannot arrest and search people who are merely sitting in a parked jeepney just because one of them is shirtless, so the drugs found there cannot be used against them.
  51. 51G.R. 260650Roberto "Pinpin" T. Uy, Jr. v. Commission on Elections, Verly Tabancura-Adanza, in Her Capacity as Provincial Election Supervisor and Chairperson of the Provincial Board of Canvassers for the Province of Zamboanga del Norte, Provincial Board of Canvassers for the Province of Zamboanga del Norte, and Romeo M. Jalosjos, Jr. Frederico P. Jalosjos Vs. Romeo M. Jalosjos, Jr., and the Commission on ElectionsThe Comelec cannot suspend the proclamation of the top vote-getter without hearing him in a nuisance-candidate case, and it cannot declare someone a nuisance candidate on guesswork, so the winner with the most votes must be proclaimed.
  52. 52G.R. 264029Joenar Vargas Agravante v. Commission on Elections, Municipal Trial Court of Goa, Camarines Sur, and Joseph Amata BlanceA candidate who skips the required paperwork for his appeal and forgets to formally offer his evidence cannot ask the Court to bend the rules just because it is an election case.
  53. 53G.R. 247737Mcdonald'S Philippines Realty Corporation v. Commissioner of Internal RevenueThe tax collector can use the extended 10-year period to assess taxes only when a return is false on purpose, and must prove it and tell the taxpayer the basis; an honest mistake does not extend the usual 3-year deadline.
  54. 54OCA IPI 17-4749-PJudge Ananson E. Jayme (Ret). v. Erla Joie L. Roco, Legal Researcher II and Glenn L. Namol, Court Interpreter III, Both of Branch 63, Regional Trial Court, Bayawan City, Negros OrientalCourt employees who take money from litigants, do business with them, moonlight for a private lawyer, or issue subpoenas without a court order commit misconduct, and an employee who left the service can still be penalized if the complaint was filed while he or she was in office.
  55. 55G.R. 264146Nena Bagcat-Gullas v. Joselito F. Gullas, Joie Marie F. Gullas Yu, and John Vincent F. GullasAn adoption decree is void if the adopter's legitimate children aged ten or older were never personally served summons, so the rule that final judgments cannot be changed does not protect it.
  56. 56G.R. 261084Leo I. Gerunda v. People of the PhilippinesA government employee who knowingly passes a bribe from a lawyer to his boss can be convicted of direct bribery as an accomplice, even if the charge named him as a principal and no conspiracy was proved.
  57. 57G.R. 256022Pedro J. Amarille v. People of the PhilippinesA man who harvested coconuts honestly believing the land was his family's was acquitted of qualified theft because the prosecution did not prove he intended to steal, though he must hand over the sale proceeds to the land's owners.
  58. 58G.R. 217417& 217914 People of the Philippines Development Bank of the Philippines-in-Intervention, v. Reynaldo G. David, Roberto v. Ongpin, Josephine a. Manalo, Ma. Lourdes a. Torres, Patricia a. Sto. Tomas, Alexander I. Magno, Floro F. Oliveros, Miguel L. Romero, Edgardo F. Garcia, Armando O. Samia, Rolando S.c. Geronimo, Perla S. Soleta, Jesus S. Guevara II, Cresenciana R. Bundoc, Arturo C. Baliton, Franklin M. Velarde, Joseph N. Pangilinan, Nelson P. Macatlang, Marissa S. Cayetano, Renato S. Velasco, Ramon R. Durano IV, Benedicto Ernesto R. Bitonio, Jr., Ma. Teresita S. Tolentino, Rodolfo C. Cerezo, and Warren de GuzmanA court cannot throw out a graft case before trial just because the borrower fully paid the loans, since whether the loans were improperly favored must be decided after a full trial.
  59. 59G.R. 255981Xxx v. People of the PhilippinesA father who is sometimes late or short in sending support is not criminally liable under the anti-violence law for women and children unless he deliberately withholds support to cause emotional suffering.
  60. 60G.R. 253305Benito Chua, Substituted by His Wife, Edita Lim Ong Chua and His Children, Evelyn Chua Go, Bernard Ong, Eleonor Ong Ngu, and Eliza Ong Chua v. Republic of the Philippines, Represented by the Director of Lands Management BureauA buyer of titled land who sees many houses on it and knows the seller is not in possession cannot rely on a clean title alone, and if he does not investigate further he is a buyer in bad faith who loses the land.
  61. 61G.R. 263227People of the Philippines v. XxxA child who does not shout, run or avoid her father after being raped by him is not lying, because children react to abuse by someone close to them in ways that adults may find strange.
  62. 62G.R. 223810Michael John Robles v. People of the PhilippinesA motorcycle rider was acquitted of reckless imprudence because the physical evidence and the traffic investigator's report contradicted the prosecution's story, and lacking a license or registration did not prove he caused the crash.
  63. 63G.R. 249121Felix Nathaniel "Angel" Villanueva Manalo II v. People of the PhilippinesProsecutors may change a criminal charge, even to a more serious one, before the accused enters a plea, and a missing signature of the city prosecutor is only a minor defect.
  64. 64G.R. 200539Heirs of Kukungan Timbao, Represented by Musa Timbao, Halima Timbao Andang, Fatima Timbao Ismael, Omar Timbao, and Zubaina Timbao Atog v. Oscar D. EnojadoThe Court of Appeals should not have thrown out an appeal over a missing brief when the other side had admitted receiving it, but the heirs still lost because their claim over the land came too late and was not proven.
  65. 65G.R. 259181People of the Philippines v. Nhelmar Mendiola y Martin @ "Honda," Noel Mendiola y Ponce @ "Noel," and Glen Ramos y Akiatan @ "Glen,"The Court upheld the life sentences of three men caught selling about one kilogram of shabu in a buy-bust operation, because the police followed the required steps in handling the drugs, and it raised each fine to P1,000,000.00.
  66. 66G.R. 251463Grandspan Development Corporation v. Franklin Baker, Inc. and Advance Engineering CorporationA subcontractor who has an arbitration clause in its contract must take its claim for unpaid work, even against the project owner, to the Construction Industry Arbitration Commission (CIAC) and not to the regular courts.
  67. 67G.R. 251350Isabel Cojuangco-Suntay and Emilio Cojuangco-­suntay, Jr. v. Emilio a.m. Suntay III and Nenita TañedoA will cannot be allowed to cut out the heirs by hiding the probate case from them, and a court judgment obtained that way can be annulled for extrinsic fraud and denial of due process.
  68. 68G.R. 258486Mary Ann Carmen Ferrer,* in Her Capacity as Attorney-in-Fact of M.y. Intercontinental Trading Corporation and/or Tedwin T. Uy v. St. Mary'S Publishing and/or Jerry Vicente S. CatabijanA petition for declaratory relief, which asks a court to explain contract rights, cannot be used after the contract has already been broken.
  69. 69G.R. 255583Axel Tria y Cipriano v. People of the PhilippinesDemanding money from someone in exchange for deleting her nude photos posted online is robbery by intimidation, and doing it through online tools raises the penalty by one degree.
  70. 70G.R. 256851Spouses Marino Dagode and Julita Duero Dagode v. Elesito D. Tapao, Substituted by His Children Namely: Edsel L. Tapao, Emelyn* T. Simpeon, Elixer L. Tapao and Engelbert L. Tapao, Purita T. Anin, Marina T. Cantillas, Marites Tapao and Jesus D. TapaoA landowner who allowed relatives to stay on the land out of kindness can evict them through an unlawful detainer case once the owner withdraws that permission and they refuse to leave.
  71. 71A.C. 8367Estrella Peralta-Diasen v. Atty. Oscar P. PaguintoA lawyer who let his client's two cases be dismissed, kept her in the dark, and had two earlier suspensions was disbarred.
  72. 72A.C. 11863Evelyn M. Bratschi v. Atty. Robert y. PeneyraA lawyer who repeatedly skipped hearings in his client's criminal and civil cases, leading to her conviction and the loss of her land title, was disbarred.
  73. 73A.C. 13674Monette Manauis-Taggueg v. Atty. Vincenzo Nonato M. TagguegA married lawyer who abandoned his wife and child, lived with another woman and displayed the relationship publicly on social media was disbarred for gross immorality.