Tuesday, May 29, 2018

[CASE DIGEST] Martinez v. Martinez (G.R. No. 445)

March 31, 1902 | G.R. No. 445

Pedro Martinez Ilustre, plaintiff and appellant
Francisco Martinez, defendant and appellee

FACTS:

Pedro Martinez Ilustre filed for an appeal before the SC after the CFI dismissed his petition to declare his father, Francisco Martinez, a prodigal. Pedro claimed that due to his father's advanced age, he no longer had control of his mental faculties and that he was squandering his wealth by giving it away to his second wife.

ISSUE:

Whether or not Francisco Martinez is a prodigal.

Friday, May 25, 2018

[FULL CASE] CRISOSTOMO SUCALDITO and the HEIRS OF FELISA DE GUZMAN v. THE HON. JUAN MONTEJO, PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF DAVAO DEL SUR, BRANCH XX, BLAS B. LABAD and PACIENCIA L. LABAD (G.R. No. 75080)

February 6, 1991

Ponente: Padilla, J.

Petitioners Crisostomo Sucaldito and Felisa de Guzman, spouses, were grantees, by way of free patent, of two (2) parcels of public agricultural land identified as Lot No. 1, F-20-9368 with an area of 162,309 square meters and Lot No. 2, F-20-9368 with an area of 15,166 square meters. Both lots are situated in Barrio Ponpong, Municipality of Sta. Maria (formerly Malalag), Province of Davao del Sur (formerly Davao). An Original Certificate of Title, No. P-18659, covering the two (2) lots was issued in favor of said petitioners.

On 14 March 1972, in the City of Davao, petitioner Crisostomo Sucaldito and his spouse Felisa de Guzman (herein represented by her heirs) sold to the private respondents Blas Labad and Paciencia Labad the above-mentioned lots together with their improvements for the amount of P65,000.00, as evidenced by a Deed of Absolute Sale.

After the sale, respondents took possession of the lots. They fenced the area, planted trees thereon, harrowed the soil, and cultivated the lands.

On 20 June 1975, petitioners wrote the respondents informing the latter that they desired to repurchase the lots and that they had the necessary amount representing the repurchase price. A reply from respondents within five (5) days from their receipt of the letter was requested by petitioners, for otherwise, they would be constrained to file a court action for reconveyance.

Respondents sent a reply dated 2 July 1975. The reply letter, however, was not received by petitioners. Thus, on 10 July 1975, petitioner-spouses brought an action for reconveyance before the RTC of Davao del Sur, docketed as Civil Case No. 952 entitled "Crisostomo Sucaldito and Felisa de Guzman v. Blas Labad and Paciencia Labad" seeking the repurchase and reconveyance of the two (2) above-mentioned parcels of land.

On 1 October 1976, the trial court rendered a decision in favor of petitioners and against the respondents. Petitioners were declared to have the right to repurchase the two (2) parcels of land within thirty (30) days from the date the decision becomes final, provided that the petitioners paid to the respondents the amount of P73,103.79.

Tuesday, May 22, 2018

[CASE DIGEST] CALTEX REFINERY EMPLOYEES ASSOCIATION (CREA) v. HON. JOSE S. BRILLANTES, in his capacity as Acting Secretary of the Department of Labor and Employment, and CALTEX (PHILIPPINES) (G.R. No. 123782)

September 16, 1997

Ponente: Panganiban, J.


FACTS

Prior to the expiration of the then existing CBA between Caltex Refinery Employees Association (CREA) and Caltex Philippines, the two parties sat down to negotiate the terms and conditions of employment to be contained in a new CBA. The two did not meet eye to eye on certain items despite the holding of conciliation meetings by the NCMB, prompting CREA to declare a deadlock and file a notice of, and subsequently stage an actual, strike.

Given the economic significance of the industry to which CREA and Caltex are part of, then SOLE Jose Brillantes assumed jurisdiction over the entire labor dispute. Accordingly, he issued an order to resolve the bargaining deadlock on the following items: wage increase, union security clause, new retirement plan, grievance machinery and arbitration, and signing bonus.

Dissatisfied with the SOLE's order and convinced that he merely adopted Caltex's proposals, CREA filed the present special civil action for certiorari under Rule 65 imputing grave abuse and discretion on the part of the SOLE in resolving the five aforecited items.

RULING


Monday, May 14, 2018

[CASE DIGEST] PRISCILLA C. MIJARES, LORETTA ANN P. ROSALES, HILDA B. NARCISO, SR. MARIANI DIMARANAN, SFIC, and JOEL C. LAMANGAN in their behalf and on behalf of the Class Plaintiffs in Class Action No. MDL 840, United States District Court of Hawaii v. HON. SANTIAGO JAVIER RANADA, in his capacity as Presiding Judge of Branch 137, Regional Trial Court, Makati City, and the ESTATE OF FERDINAND E. MARCOS, through its court appointed legal representatives in Class Action MDL 840, United States District Court of Hawaii, namely: Imelda R. Marcos and Ferdinand Marcos, Jr. (G.R. NO. 139325)



Tinga, J.

FACTS

In 1991, a complaint was filed before the US District Court, District of Hawaii, against the estate of former Philippine President Ferdinand E. Marcos. The suit was filed by 10 prominent human rights victims on their own behalf and on behalf of a class of similarly situated individuals, particularly consisting of all current civilian citizens of the Philippines, their heirs and beneficiaries, who between 1972 and 1987 were tortured, summarily executed or had disappeared while in the custody of military or paramilitary groups. The US District Court certified the case as a class action and created three sub-classes of torture, summary execution and disappearance victims.

Trial ensued. Subsequently, a jury rendered an award of compensatory and exemplary damages in favor of the complainants. Thereafter, a final judgment was rendered, awarding the complainants a total of US$1,964,005,859.90. The judgment was affirmed by the US Court of Appeals. •    In 1997, Mijares, et al. filed a complaint before the Makati RTC for the enforcement of the foreign judgment. The Marcos Estate filed a motion to dismiss, raising, among others, the non-payment of the correct filing fees. The estate alleged that Mijares, et al. had only paid P410.00 as docket and filing fees, notwithstanding the fact that they sought to enforce a monetary amount of damages worth billions.  •    Judge Ranada of Makati RTC dismissed the complaint for the enforcement of the foreign judgment. Relying on Section 7(a) of Rule 141, Judge Ranada estimated the proper amount of filing fees to be around P472M, which obviously had not been paid. Hence, the instant petition.

RULING


Wednesday, May 9, 2018

[FULL CASE] ALBIENDA v. CA (G.R. No. L-61416)

March 18, 1985

Ponente: Escolin, J.

The issue posed for resolution in this petition for review of the decision of the then Court of Appeals is whether or not the description of a parcel of land in the petitioner's certificate of title may be corrected to conform with the technical description appearing in the "survey return" on file in the Bureau of Lands, notwithstanding the lapse of more than one (1) year since the issuance of said certificate of title.

Both the Court of First Instance of Agusan del Sur and the Court of Appeals held that such correction is proper. We reverse. Such holding is contrary to the settled principles aplicable to the Torrens System of land recording.

There is no dispute as to the facts. The spouses Ruben Sumampao and Angeles Sumampao, private respondents herein, were applicants for a free patent over a piece of the land designated as Lot No. 1548, Pls-67, situated in San Francisco, Agusan del Sur. Claiming that an 8-hectare portion thereof was erroneously included in the technical description of the certificate of title covering Lot 1550, the adjoining land belonging to petitioner Felda Albienda, respondents instituted in the then Court of First Instance of Agusan del Sur an action against Albienda for correction of the latter's certificate of title, TCT No. T-1718, and for recovery of possession of said portion of the land, with damages.

The complaint alleged inter alia that respondents acquired Lot 1548 under a deed of sale dated November 11, 1968 executed in their favor by Antonio Baldonase; that the latter previously purchased said land from Loida Baterbonia, who in turn had bought it from Galicano Ontua, the primitive owner thereof; that having acquired the land in 1968, respondents occupied and cultivated the same, and paid the taxes thereon; that sometime in 1973, petitioner Albienda, claiming ownership over the adjoining land designated as Lot No. 1550, took possession not only of said Lot 1550, but also usurped a portion of eight [8] hectares of Lot 1548 belonging to respondents; and that despite repeated demands, Albienda refused to vacate said portion and to restore possession thereof to respondents.

In her answer, petitioner averred that Lot 1550, containing an area of 196,848 square meters, originally belonged to Enesaria Goma, in whose name the same was registered under the Torrens System on July 23, 1958; that on July 14, 1959, Enesaria Goma sold the land to Gliceria Senerpida who possessed it continuously and peacefully until November 21, 1972, when petitioner acquired the same for value in good faith; that upon registration of the deed of sale executed in favor of petitioner, the latter was issued TCT No. T-1718 covering Lot 1550 with an area of 196,848 square meters, which is the same area stated in the certificates of title of petitioner's aforenamed predecessors-in-interest.

Wednesday, May 2, 2018

[CASE DIGEST] PONCE DE LEON v. REHABILITATION FINANCE CORP. (G.R. No. L-24571)

December 18, 1970

Ponente: Concepcion, C.J.

FACTS:

On October 8, 1951, Jose Ponce De Leon and Francisco Soriano took out a loan from the Rehabilitation Finance Corporation or RFC (now Development Bank of the Philippines) for P495,000.00. The loan was secured by a parcel of land owned by Soriano. A deed of mortgage was then executed in view of the loan. Soriano and Ponce de Leon also executed a promissory note in the amount of P495k, payable in monthly installments of P28,831.64.

Part of the P495k was used to pay off the previous encumbrances amounting to P135k on the property of Soriano. The rest were released to Ponce de Leon in various amounts from December 1951 to July 1952, still pursuant to the deed of mortgage.

The loan went unpaid and so RFC initiated a foreclosure proceeding on the mortgaged property. According to RFC, the monthly payments were supposed to be due in October 1952.

In his defense, Ponce de Leon insists that the amortizations never became due because allegedly, RFC did not complete the disbursement of the loan to him (allegedly, P19k was withheld). He also invokes that on the face of the promissory note it was written that the installments have “no fixed or determined dates of payment”. Hence, the monthly payments were never due therefore the foreclosure is void. He insists that the court should first determine the date of maturity of the loan.

RULING:

Whether or not Ponce de Leon is right. - NO.

During trial and based on the records, Ponce de Leon’s lawyer admitted that all the remainder of the loan was released to Ponce de Leon so he cannot invoke that not all of the P495k was released by RFC.

Anent the issue of the loan’s maturity date, under Secs. 13 and 14 of the Negotiable Instruments Law, when a  promissory note expresses “no time for payment,” it is deemed “payable on demand.” Therefore, when RFC demanded payment on October 24, 1952, the installments become due.