CASE DIGEST : PEOPLE v. CECILLE AMARA GR No. 225960 GAERLAN

FACTS : The case involves accused-appellant Jose Centeno, who, along with several others, was charged with syndicated and large-scale illegal recruitment and multiple counts of estafa for fraudulently recruiting individuals for overseas employment without the required license. Centeno and his co-accused falsely represented that they had the authority to deploy workers abroad, collected substantial placement and processing fees from multiple applicants, and promised deployment on specific dates that never materialized. Despite assurances and collection of fees, the victims were neither deployed nor reimbursed. Witnesses testified that Centeno actively assisted in the recruitment process, providing instructions, facilitating payments, and assuring deployment schedules. A POEA officer confirmed that neither Centeno nor the manpower agency was licensed to recruit. Centeno claimed he was merely an employee and not involved in recruitment, but the court found sufficient evidence of his participation. The RTC convicted him of two counts of syndicated illegal recruitment and three counts of estafa, imposing life imprisonment for the illegal recruitment charges and imprisonment plus restitution for estafa. On appeal, the Court of Appeals affirmed the conviction, modifying only the fines and one penalty. The courts upheld the findings that Centeno, through deceitful representations, defrauded applicants by accepting fees without authority or intention to deploy them, establishing his guilt beyond reasonable doubt.

ISSUE : WON the CA is correct in affirming the RTC's decision

HELD : The Supreme Court affirmed the conviction of Jose Centeno for syndicated illegal recruitment in large scale, constituting economic sabotage, and for multiple counts of estafa, modifying only the penalties for estafa based on Republic Act No. 10951. The Court held that Frontline Manpower Resources & Placement Company had no license to recruit workers, and Centeno, along with others, engaged in recruitment and placement by falsely representing their authority to deploy workers abroad, collecting placement fees, and promising employment which never materialized. These acts satisfied the elements of syndicated and large-scale illegal recruitment as they involved at least three complainants and were committed by a group acting in conspiracy. The same acts also established estafa by deceit because Centeno induced complainants to part with their money through fraudulent misrepresentations, causing them financial damage. For illegal recruitment constituting economic sabotage, the Court maintained the penalty of life imprisonment and fines of ₱500,000. For estafa, the Court applied the amended penalty ranges under RA 10951, reducing the prison terms to an indeterminate penalty of four months of arresto mayor as minimum to one year and eight months of prision correccional as maximum for each count, and ordered payment of actual damages equivalent to placement fees, with legal interest at 12% per annum from February 11, 2008 to June 30, 2013, and 6% per annum from July 1, 2013 until finality, and thereafter 6% until fully paid. The appeal was dismissed for lack of merit, and the modified penalties were imposed accordingly.

CASE DIGEST : SUBIC BAY METROPOLITAN AUTHORITY VS. SUBIC BAY MARINE EXPLORATORIUM, INC. G.R. No. 237591 GAERLAN

 FACTS : SBMA, established under R.A. 7227 to develop the Subic Bay Freeport Zone as a self-sustaining economic center without government subsidy, provides essential municipal services such as security, fire protection, street cleaning, and lighting costing around ₱388 million annually. To recover these expenses, it imposed the Common User Service Area (CUSA) Fee on locators after conducting public hearings, publishing notices, and issuing Board Resolutions to implement the fee, supported later by Administrative Order No. 31 from the Office of the President. Subic Bay Marine Exploratorium, Inc. (SBMEI), a locator, challenged the CUSA fee’s legality, leading the RTC to annul the resolutions and permanently enjoin SBMA from collecting the fee. When SBMA attempted to appeal, its Notice of Appeal was filed one day late due to internal handling delays, and both the RTC and CA denied the appeal for being out of time, strictly applying procedural rules. SBMA argued excusable negligence and insisted on its authority to impose the fee based on law, lease terms, and due process compliance, eventually elevating the matter to the Supreme Court through a petition for review on certiorari.

ISSUE : WON the SBMA's appeal may be given due course

HELD : SBMA admitted that its notice of appeal was filed one day late due to honest mistake and excusable negligence involving a newly hired clerk and the handling lawyer’s good faith belief on the date of receipt. It emphasized that it had no participatory negligence and urged that its right to appeal should not be prejudiced by its counsel’s error. SBMA argued that strict procedural rules must yield to substantial justice, especially since the case involves significant public interest and large financial implications for SBMA, the national government, and local government units. It also highlighted inconsistent court rulings, as other locators like Philip Morris and Subic Techno Park were ordered to pay the CUSA fee, making it unfair if SBMEI alone were exempt. In contrast, SBMEI insisted that the appeal was correctly denied for being filed beyond the reglementary period, stressing that negligence does not excuse non-compliance, and that the RTC decision had become final and immutable. The Supreme Court ruled in favor of SBMA, holding that while appeal is a statutory privilege requiring compliance with rules, procedural rules must sometimes yield to substantial justice, equity, and the merits of the case. The Court noted that the one-day delay was due to excusable negligence, and denying the appeal would cause grave injustice by depriving SBMA and the government of substantial funds needed for municipal services, especially since SBMEI continued to benefit from those services without paying. It also cited prior jurisprudence allowing late appeals based on compelling reasons and emphasized that preventing SBMA from pursuing its appeal would result in unfair advantage to SBMEI. Recognizing the public interest and financial implications, the Court granted the petition, reversed the lower courts’ rulings, and directed the RTC to give due course to SBMA’s appeal and elevate the records for review on the merits.

CASE DIGEST : MCCONNELL DOWELL PHILS. v. ARCHIMEDES B. BERNAL GR No. 224685 GAERLAN

 FACTS : Archimedes Bernal, initially hired as an Estimator and later promoted as Manager of Business Development by McConnell Dowell Philippines, consistently received salary increases, bonuses, and commendations for securing major projects, including the Pililia Wind Farm Project. Despite his accomplishments, he became aware of negative perceptions from company directors in 2011, prompting him to seek performance evaluation, which was ignored. In 2012, he filed a grievance due to rude and antagonistic treatment from his superior, Colin Jenner. Around the same time, the company faced significant financial decline and implemented streamlining measures, abolishing several positions, including Bernal’s role, allegedly due to redundancy. Though offered alternative roles, Bernal declined, and he was terminated in June 2012, immediately stripped of company access despite a one-month notice period. Bernal filed a complaint for illegal dismissal. The Labor Arbiter ruled in his favor, declaring his dismissal illegal for lack of a bona fide redundancy program and awarding reinstatement, backwages, and attorney’s fees. On appeal, the NLRC reversed the decision, ruling the termination valid due to authorized redundancy, citing financial decline and organizational restructuring. Bernal’s motion for reconsideration was denied, leading him to elevate the case to the Court of Appeals via petition for certiorari. The CA reinstated the Labor Arbiter’s ruling with modifications, declaring Bernal illegally dismissed, deleting reinstatement due to strained relations but awarding moral and exemplary damages due to bad faith, and holding McConnell Dowell and Jenner jointly liable. The CA found that the employer failed to prove good faith, validity of redundancy, or application of fair criteria and noted oppressive treatment, including immediate revocation of Bernal’s access and failure to evaluate his performance despite his achievements.

ISSUE : WON Bernal's separation from MacDow was due to a valid redundancy program

HELD :  The Supreme Court ruled that although redundancy is a valid authorized cause for termination under Article 298 of the Labor Code, employers bear the burden of proving the existence of a legitimate redundancy program using substantial evidence, including proof of good faith and fair criteria in selecting affected employees. In this case, while MacDow complied with the procedural requirements of notice and payment of separation pay, it failed to substantiate the validity of its redundancy program, presenting only financial statements and organizational charts, which merely showed financial losses and positional restructuring but did not demonstrate the criteria or methods used to determine redundancy. Allegations of poor performance and transfer of functions were unsubstantiated and contradicted by evidence of Bernal's commendable performance. The Court affirmed that Bernal was illegally dismissed due to lack of substantial evidence proving a bona fide redundancy program. However, moral and exemplary damages were deleted because there was no proof of bad faith or arbitrary, malicious actions in carrying out the termination. Since reinstatement was no longer possible due to strained relations and nonexistence of the position, the Court ordered payment of separation pay in lieu of reinstatement, equivalent to one month salary for every year of service until finality of the decision, less the separation already received in 2012, along with full backwages.

CASE DIGEST : VICENTE A. BERNARDO v. MARCIAL O. DIMAYA GR No. 195584 GAERLAN

 FACTS : Virex Enterprises, a service center for air-conditioning installations, assigned a team led by Marcial Dimaya, with two helpers, to perform a job in July 2007. During the job, they used a drain pipe not listed in their material request form and received an undeclared additional ₱300 from the client, which they divided among themselves without issuing an official receipt or recording the transaction in the service report. Afterward, some excess materials like copper tubes and wires were unreturned. The employer investigated and fined the team double the value of the missing items, to be deducted from their salaries. According to the employer, Dimaya refused to pay and subsequently stopped reporting for work. Dimaya denied abandonment, claiming that he believed the ₱300 was a tip, and that he was effectively dismissed when Mr. Bernardo told him “Huwag ka muna magpakita, mainit ang dugo ko sayo!” and later, “Tapos na tayo!” Prompting him to file an illegal dismissal complaint. The Labor Arbiter ruled in favor of Dimaya, declaring illegal dismissal due to lack of due process, noting that no memorandum or directive was issued requiring him to explain or return to work. The LA awarded backwages (until he refused reinstatement), separation pay, unpaid salaries, 13th month pay, holiday pay, SIL pay, and attorney’s fees, but denied overtime as he was a field personnel. The NLRC dismissed the employer’s appeal for failure to attach a certificate of non-forum shopping, and denied reconsideration. The CA affirmed, holding that the NLRC did not commit grave abuse of discretion and that factual issues could not be revisited via certiorari. Before the Supreme Court, the employers argued there was no dismissal, only Dimaya’s refusal to comply with penalties and eventual abandonment, insisting that the remarks were not dismissal but expressions of displeasure. They also contested the monetary awards, particularly holiday pay and SIL pay, given the LA’s finding that Dimaya was a field personnel, and sought recomputation of ECOLA, attorney's fees, and 13th month pay. The core issues revolve around illegal dismissal, abandonment, procedural lapses in appeal, and entitlement to monetary benefits.

ISSUE : WON the circumstances in the present case warrant a relaxation in the application of the rules of procedure.

HELD : The Supreme Court partly granted the petition, recognizing that while procedural lapses occurred, substantial justice required a factual review. Virex Enterprises failed to attach a certificate of non-forum shopping, which is required to perfect an NLRC appeal, but the Court allowed liberal application of the rules due to the substantive issues involved. Upon review, the Court held that while Dimaya committed misconduct for failing to account for missing materials, refusing to comply with company policy, and blaming his team members, his actions constituted willful disobedience warranting dismissal for just cause under Article 297 of the Labor Code. However, his dismissal was procedurally defective as he was not given the required twin notices or hearing; thus, the Court awarded him ₱30,000 nominal damages under Agabon v. NLRC. Dimaya did not abandon his job, as the employer presented no evidence showing a clear intent to sever employment, nor was he asked to return to work. The Court affirmed that Dimaya was not a field personnel since his work hours could be reasonably monitored; therefore, he was entitled to holiday pay and service incentive leave. The awards of backwages, separation pay, and attorney’s fees were deleted since dismissal was based on just cause. Petitioners were ordered to pay only unpaid monetary benefits and nominal damages, with legal interest from finality until full payment.

CASE DIGEST : PEOPLE v. RUFINO PABLO PALABRICA III GR Nos. 250590-91 GAERLAN

 FACTS : Accused-appellant Rufino Pablo Palabrica III, then Municipal Mayor of Dingle, Iloilo, faced two separate charges for violating Section 3(h) of R.A. No. 3019 before the Sandiganbayan, arising from alleged acts committed on or around January 7, 2014. In Criminal Case No. SB-16-CRM-1080, he was accused of entering into a lease contract for a market stall in Dingle Public Market, effectively signing as both lessor (the Municipality of Dingle) and lessee (himself, as owner of his medical clinic and Farmacia Francisca), thus taking advantage of his official position. In SB-16-CRM-1081, he was charged with granting a business permit to Farmacia Francisca, in which he had direct financial interest, while exercising his authority as mayor. These complaints stemmed from a prior complaint filed with the Ombudsman, which, after investigation, found probable cause to indict him, leading to the filing of Informations before the Sandiganbayan in November 2016, and the issuance of a Hold Departure Order and warrant of arrest (later recalled upon posting of bail). Palabrica filed motions to quash the Informations, arguing lack of legal basis and violation of due process, but these were denied by the Sandiganbayan. During trial, the prosecution presented documentary and testimonial evidence from municipal officials and the complainant, establishing that Palabrica executed the lease contract and approved the business permit for his clinic and pharmacy, which had been occupying the stalls since 1996. Witnesses corroborated deficiencies in the business permit application, including lack of zoning clearance and certificate of occupancy, though Palabrica argued he acted in good faith under municipal ordinances and resolutions granting him authority to lease the stalls. The defense also presented evidence highlighting the continuity of prior lease agreements and his ministerial role in issuing permits, as well as his provision of free medical services. On July 19, 2019, the Sandiganbayan Special Sixth Division convicted Palabrica in both cases, sentencing him to six years and one month to eight years in prison per the Indeterminate Sentence Law and imposing perpetual disqualification from public office. Justice Sarah Jane T. Fernandez dissented regarding SB-16-CRM-1081, contending that issuing a business permit is an exercise of delegated police power, not a “transaction” involving monetary consideration under Section 3(h) of R.A. No. 3019. A subsequent motion for reconsideration filed by Palabrica was denied on November 15, 2019, with the dissent on SB-16-CRM-1081 maintained by Justice Fernandez and joined by Justice Michael Frederick Musngi.

ISSUE : WON the sandiganbayan erred

HELD : The Court’s ruling in this case carefully applies the law under Section 3(h) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act), emphasizing the essential elements for criminal liability: (1) that the accused is a public officer, (2) that he has a direct or indirect financial or pecuniary interest in a business, contract, or transaction, and (3) that he intervenes or participates in that interest in his official capacity. In SB-16-CRM-1080, although the accused-appellant was a public officer and had a pecuniary interest in the market stall lease (as lessee of his clinic and pharmacy), the Court found no evidence of actual intervention in the approval of the lease: his signing was authorized by Sangguniang Bayan Resolution No. 2012-32 and followed standard renewal procedures, without showing undue influence, special treatment, or alteration of terms, making his act insufficient to constitute “intervention” under the law. In SB-16-CRM-1081, while the accused-appellant did issue a business permit to his own pharmacy, the Court ruled that the issuance of a business permit does not constitute a “business, contract, or transaction” because it does not involve monetary consideration or profit; it is merely an authorization to engage in business. The Court relied on principles of statutory construction, including the plain meaning of “business,” “contract,” and “transaction,” and the doctrine of strict construction of penal laws, which requires doubts to be resolved in favor of the accused. Consequently, because the prosecution failed to prove all elements under Section 3(h) in both cases, the accused-appellant was acquitted, and his bail bond and hold departure order were canceled. The ruling underscores that mere signing or ministerial acts by a public officer, without evidence of corrupt intervention or pecuniary manipulation, cannot support a conviction under the Anti-Graft law.

CASE DIGEST : SPOUSES SERGIO D. DOMASIAN AND NENITA F. DOMASIAN VS. MANUEL T. DEMDAM G.R. No. 212349 GAERLAN

FACTS : The Supreme Court is asked to review the Court of Appeals’ (CA) August 31, 2012 Decision and April 22, 2014 Resolution in CA-G.R. CV No. 93727, involving spouses Sergio and Nenita Domasian (petitioners) and Manuel T. Demdam (respondent). The dispute arose from a P75,000 loan obtained by the petitioners in 1995, with 8% monthly interest due by June 30, 1996, which remained unpaid. The respondent filed a collection suit in 2001 before the RTC of Pasay City for P75,000 principal plus P414,000 accrued interest. Summons were not personally served as petitioners had moved to Naga City, and they did not receive the RTC’s default declaration or the 2003 judgment awarding the total amount, damages, and attorney’s fees. In 2006, the petitioners sought relief from judgment, arguing defective service and lack of jurisdiction, claiming the principal loan amount fell under the MeTC’s jurisdiction. The RTC granted their petition in 2008, setting aside the 2003 order for lack of jurisdiction. The respondent appealed to the CA, which in 2012 reinstated the 2003 RTC judgment, ruling that the total amount claimed, P489,000 (principal plus interest), was determinative of jurisdiction, not the principal alone, and thus the RTC had proper jurisdiction. The petitioners’ motion for reconsideration was denied in 2014. In their Supreme Court petition, the petitioners challenged the CA’s jurisdictional ruling, contending that the appeal raised only questions of law, that interest should not be included in determining jurisdiction, and that the RTC lacked jurisdiction over the claim, while the respondent maintained that the debt remained unpaid and the CA correctly ruled the RTC had jurisdiction over the full P489,000 claim.

ISSUE : WON CA erred in not finding that the respondent's appeal by Notice of Appeal is the wrong mode of appeal as the three issues raised therein are all questions of law

HELD : The Supreme Court denies the petition filed by spouses Sergio and Nenita Domasian, affirming the Court of Appeals’ August 31, 2012 Decision and April 22, 2014 Resolution, as well as the RTC’s January 14, 2003 Order, with modifications. While the Court agreed that the CA erred in taking cognizance of the respondent’s appeal—since it raised purely questions of law, which under Section 2, Rule 41 of the Rules of Court should have been dismissed—it upheld the CA’s ruling that the RTC had jurisdiction over the respondent’s claim. The total claim of P489,000, comprising the P75,000 principal and P414,000 monetary interest agreed upon by the parties, exceeds the jurisdictional threshold of P200,000 under BP 129 and R.A. 7691; the interest forms a primary and inseparable component of the obligation and cannot be excluded from jurisdictional computation. However, the Court found the agreed 8% monthly interest unconscionable and reduced it to the legal rate of 12% per annum, to run from the date of extrajudicial demand on June 30, 1996. Interest on the principal accrues legal interest at 12% per annum from judicial demand on August 1, 2001 until June 30, 2013, then at 6% per annum thereafter. The Court also removed the award of moral and exemplary damages, finding no fraud or bad faith on the part of the petitioners. All other aspects of the RTC and CA rulings remain valid.

CASE DIGEST : COCA-COLA FEMSA PHILIPPINES v. COCA-COLA FEMSA PHILS GR No. 238633 GAERLAN

 FACTS : The present petition for review on certiorari challenges the November 22, 2017 Decision and March 26, 2018 Resolution of the Court of Appeals in CA-G.R. SP No. 07723-MIN, which dismissed Coca-Cola FEMSA Philippines, Inc.’s (CCPI) petition for certiorari questioning the August 18, 2016 Order of Circuit Mediator-Arbiter Erwin C. Angeles granting the petition for certification election filed by the Union representing CCPI’s regular supervisory and coordinator employees in its Misamis Oriental plant. CCPI argued that the employees in the bargaining unit were managerial and thus ineligible to organize, but the Mediator-Arbiter and the CA found that based on their job descriptions and reporting lines, the employees were supervisory, not managerial, as they only executed ready-made policies and merely recommended managerial actions. The CA upheld that the employer has no standing to oppose a certification election and dismissed CCPI’s petition, noting that the reorganization of the plant positions in March 2017 did not alter the employees’ supervisory status. CCPI’s motion for reconsideration was denied, confirming the Union as the sole and exclusive bargaining agent.

ISSUE : WON MA and the CA erred in ruling that the employees in the bargaining unit represented by the Union are supervisory employees;  2) WON the CA erred when it refused to rule that the petition for certification election had been rendered moot and academic by the reorganization of the Misamis Oriental plant's manufacturing unit.

HELD : The Supreme Court denied Coca-Cola FEMSA Philippines, Inc.’s (CCPI) petition for review on certiorari, affirming the November 22, 2017 Decision and March 26, 2018 Resolution of the Court of Appeals in CA-G.R. SP No. 07723-MIN. The Court found CCPI guilty of forum shopping for failing to disclose the pendency of CA-G.R. SP No. 152835, which also challenged the certification of the Union as the sole and exclusive bargaining agent, and for seeking repetitive relief on substantially the same issues. Moreover, the Court reiterated that under Article 271 of the Labor Code, an employer is a mere bystander in certification election proceedings and lacks standing to oppose the Union’s petition. The Court further held that CCPI’s March 2017 reorganization did not affect the supervisory character of the positions in the bargaining unit, as the changes were largely nominal or consolidatory without altering reporting lines or the employees’ functions. Consequently, the Union’s certification remained valid, and the petition was denied, upholding the findings of both the Mediator-Arbiter and the Court of Appeals.