CASE DIGEST : HEIRS OF SPOUSES SILVESTRE MANZANO AND GERTRUDES D. MANZANO, REPRESENTED BY CONRADO D. MANZANO AS ATTORNEY-IN-FACT AND ALSO IN HIS PERSONAL CAPACITY VS. KINSONIC PHILIPPINES, INC., G.R. No. 214087. February 27, 2023 GAERLAN

FACTS : The parties entered into a Contract to Sell on July 19, 1993 involving a 35,426-square-meter parcel of land in Bulacan for ₱23,026,900.00. Respondent Kinsonic Philippines, Inc. paid ₱8,000,000.00 and spent ₱700,000.00 to convert the property from agricultural to industrial use. When respondent later tendered the remaining balance, petitioners refused to accept payment, claiming that the contract had already been automatically rescinded due to respondent's failure to pay within the 60-day period provided in the agreement. Respondent consequently filed an action for specific performance or, alternatively, for the refund of its payments and reimbursement of its expenses.

During the proceedings, respondent successfully obtained a summary judgment from the Court of Appeals ordering petitioners to execute the deed of sale upon full payment of the purchase price or, alternatively, to refund the ₱8,000,000.00 already paid and reimburse the ₱700,000.00 conversion expenses with legal interest. The Supreme Court later denied petitioners' challenge to the summary judgment, rendering it final and executory. Upon remand, the RTC awarded respondent ₱200,000.00 as attorney's fees and ₱50,000.00 as exemplary damages.

On appeal, petitioners argued for the first time that the case should have included the administrator of the estates of the original owners as an indispensable party, that the sale violated Article 130 of the Family Code due to the lack of liquidation of the conjugal partnership, and that summary judgment was improper. The Court of Appeals rejected these arguments, holding that they were raised too late and that the earlier summary judgment had already become final and immutable. It likewise ruled that no administrator had been appointed and that the indispensable parties were only those who executed the Contract to Sell. However, the CA deleted the award of exemplary damages, finding that no compensatory damages had been awarded to justify such relief.

The case involved Article 130 of Executive Order No. 209 (Family Code of the Philippines), which governs the liquidation of the conjugal partnership before the disposition of conjugal property. Petitioners invoked this provision to challenge the validity of the sale, but the Court held that the issue could no longer be entertained because it was raised only on appeal and the prior judgment upholding the Contract to Sell had already attained finality under the doctrine of immutability of judgments.

ISSUE : 1) WON administrator of the estates/conjugal partnership of the Spouses Manzano is an indispensable party to the proceedings relative to respondent's Complaint before the trial court

HELD : The Supreme Court denied the petition and affirmed the Court of Appeals, holding that the administrator of the estates or conjugal partnership of the deceased spouses was not an indispensable party to the action for specific performance and sum of money. The Court explained that no probate or intestate proceedings had been instituted and no administrator had been appointed. Hence, there was no existing administrator whose absence could divest the courts of jurisdiction. At most, a future administrator would only be a necessary party because his interest in the property is separable from the contractual rights and obligations of the parties to the Contract to Sell.

The Court likewise ruled that petitioners could no longer question the validity of the Contract to Sell, the alleged lack of liquidation of the conjugal partnership, or the propriety of the summary judgment because these issues were raised only on appeal and after the earlier summary judgment had already become final and executory. The Court found no evidence on record showing that the Contract to Sell was patently void or that the courts lacked jurisdiction. Moreover, petitioners failed to substantiate their allegations with the necessary documents and merely attempted to introduce new theories after judgment had become final.

The Court further held that, even assuming there were defects in the sale, petitioners were barred by estoppel and the doctrine of clean hands. Having actively participated in the execution of the Contract to Sell, accepted substantial payments from respondent, and allowed respondent to incur expenses for the property's conversion, petitioners could not later repudiate the transaction to evade their contractual obligations. Accordingly, the Court affirmed the CA's decision sustaining the award of attorney's fees while deleting exemplary damages.

Although the Court acknowledged that Article 130 of the Family Code (Executive Order No. 209) requires the liquidation of the conjugal partnership before any disposition of conjugal property and that unauthorized sales of estate property may be void under Rule 89 of the Rules of Court, it held that these provisions did not warrant relief in this case. Petitioners failed to timely invoke these issues before the trial court and did not prove facts showing the patent nullity of the Contract to Sell. The Court instead applied the rules on indispensable and necessary parties under Sections 7 and 8, Rule 3 of the Rules of Court, as well as the doctrines of immutability of judgments and estoppel, in denying the petition.

CASE DIGEST : RODRIGO CONCHE Y OBILO v. PEOPLE GR No. 253312, Mar 01, 2023 GAERLAN

FACTS : Rodrigo O. Conche was convicted by the Regional Trial Court for violating Section 5, Article II of Republic Act No. 9165, and his conviction was affirmed by the Court of Appeals (CA), which sentenced him to life imprisonment and a fine of ₱500,000.00. Although his counsel, the Gutierrez and Trinidad Law Office, received a copy of the CA decision, it failed to file a motion for reconsideration or an appeal to the Supreme Court, causing the decision to become final and executory. Conche and his wife later discovered that, despite assurances from their counsel that an appeal had been filed, no such pleading was ever submitted.

Seeking relief, Conche obtained assistance from the BNG Humanitarian Outreach Volunteer Paralegal Services, which confirmed with the CA that no appeal had been filed. He subsequently sought help from the Office of the Chief Justice, the Integrated Bar of the Philippines, and eventually the Public Attorney's Office (PAO), which entered its appearance and filed a Motion to Recall Entry of Judgment and Notice of Appeal. The PAO argued that Conche's former counsel was guilty of gross negligence and misrepresentation, warranting an exception to the rule that a client is bound by the negligence of counsel.

The Office of the Solicitor General opposed the motion, insisting that Conche was likewise responsible for monitoring his case. The CA denied the motion, finding no compelling reason to relax the rule that the negligence of counsel binds the client, and likewise denied Conche's motion for reconsideration. Conche thereafter elevated the matter to the Supreme Court through a Petition for Review on Certiorari.

ISSUE : WON CA is correct

HELD : The Supreme Court granted Conche's petition, holding that his constitutional right to due process was violated due to the gross negligence and misrepresentations of his counsel, Atty. Evelyn Gutierrez. Although the general rule is that the negligence of counsel binds the client and that final judgments are immutable, the Court ruled that this case falls under the recognized exceptions because counsel's failure to file the promised appeal deprived Conche of his right to appeal and effectively denied him liberty. The Court found that Atty. Gutierrez repeatedly assured Conche, his wife, and BNG Humanitarian Outreach Volunteer Paralegal Services that an appeal had already been filed, when in fact no appeal or motion for reconsideration was ever submitted, causing the conviction to become final and executory.

The Court further held that Conche was not guilty of contributory negligence. As a detained prisoner, he reasonably relied on his retained counsel and, upon learning of the Entry of Judgment, immediately sought assistance from the Office of the Chief Justice, the Integrated Bar of the Philippines, the Public Attorney's Office, and BNG to revive his appeal. The delay in filing the motion to recall the Entry of Judgment was attributed to the administrative processing of these agencies rather than to Conche. The Court also observed that there appeared to be substantial issues regarding compliance with the chain of custody requirements under the law, warranting a review of the merits of his appeal. Consequently, the Court recalled the Entry of Judgment, directed the Court of Appeals to give due course to Conche's appeal, and referred Atty. Gutierrez to the Integrated Bar of the Philippines for investigation.

The case stemmed from Conche's conviction for violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). In resolving the petition, the Court emphasized the constitutional right of an accused under Section 14(2), Article III of the 1987 Constitution to be heard through effective counsel. It likewise cited Canons 17 and 18 of the Code of Professional Responsibility, stressing that lawyers must competently, diligently, and faithfully protect their clients' interests, and that gross negligence resulting in the loss of a client's right to appeal constitutes a denial of due process.

CASE DIGEST : HEIRS OF RAISA DIMAO v. NATIONAL GRID CORPORATION OF PHILIPPINES GR No. 254020, Mar 01, 2023 GAERLAN

 FACTS : The case arose from an expropriation complaint filed by the respondent to acquire 11,460 square meters of Lot No. 104 in Baloi, Lanao del Norte for the maintenance of the Baloi-Agus 2 138kV Transmission Line (BATL), which had been constructed by the National Power Corporation (NPC) in 1978. Pursuant to Republic Act No. 9136 (Electric Power Industry Reform Act of 2001), the transmission functions of the NPC were transferred to the National Transmission Corporation (TRANSCO), whose management, operation, and maintenance were later assumed by the respondent. To facilitate the maintenance of the transmission lines, the respondent initiated expropriation proceedings in 2014, deposited the amount equivalent to 100% of the Bureau of Internal Revenue (BIR) zonal value as required for the issuance of a writ of possession, and was subsequently placed in possession of the property. The petitioners, however, sought substantially higher just compensation, including accrued interest and rentals. After the parties failed to reach an amicable settlement, the Regional Trial Court (RTC), assisted by commissioners pursuant to the Rules of Court governing expropriation proceedings, granted the complaint and awarded just compensation amounting to ₱49,622,050.00, directing the respondent to pay the deficiency after deducting its initial deposit.

On appeal, the Court of Appeals (CA) affirmed the respondent's authority to expropriate the property but modified the RTC's ruling by deleting the additional award of ₱47,865,650.00 as just compensation. The CA held that because the property originated from a free patent, it was subject to the 60-meter legal easement of right-of-way in favor of the government under Section 112 of Commonwealth Act No. 141 (Public Land Act). Under this provision, the owner of the affected property is generally entitled only to compensation for the value of improvements situated within the easement. The CA further observed that the transmission lines had already been constructed in 1978, whereas the petitioners' predecessor-in-interest acquired title to the property only in 2012. Consequently, the petitioners could not claim actual loss arising from the existence of the transmission line because the easement had long been established before they acquired ownership. Moreover, the appellate court found no competent evidence showing the existence or value of improvements on the property at the time of the original taking in 1978, as the evidence presented referred only to improvements introduced during the filing of the expropriation case. For these reasons, the CA sustained the expropriation but deleted the RTC's award of additional just compensation.

ISSUE : WON petitioners are entitled to just compensation and correspondingly, the reckoning point for its computation.

HELD : The Supreme Court denied the petition and upheld the Court of Appeals' ruling that the petitioners were not entitled to just compensation for the portion of their property traversed by the Baloi-Agus 2 138kV Transmission Line (BATL). The Court first affirmed the respondent's authority to expropriate property, holding that while the power of eminent domain is an inherent attribute of State sovereignty, Congress may validly delegate its exercise to government agencies and quasi-public entities. Pursuant to Republic Act No. 9511, which granted the respondent its legislative franchise, the respondent was expressly authorized under Section 4 to exercise the power of eminent domain whenever reasonably necessary for the construction, expansion, operation, and maintenance of the national transmission system, subject to the constitutional and statutory requirements governing expropriation, including the payment of just compensation. This authority complements the respondent's functions under Republic Act No. 9136 (Electric Power Industry Reform Act of 2001), which transferred the transmission functions of the National Power Corporation (NPC) to the National Transmission Corporation (TRANSCO) and eventually to the respondent. Since the parties did not dispute the necessity of the expropriation or the public purpose it served, the only issue before the Court was whether the petitioners were entitled to just compensation.

The Court ruled that the reckoning point for determining just compensation was the date of the actual taking in 1978, when the NPC entered the property and constructed the transmission lines, and not the filing of the expropriation complaint in 2014. Citing Republic v. Vda. de Castellvi, National Transmission Corporation v. Oroville Development Corporation, National Power Corporation v. Vda. de Capin, National Power Corporation v. Manalastas, and Republic v. Heirs of Borbon, the Court reiterated that "taking" occurs when the government permanently enters private property under lawful authority for public use and substantially deprives the owner of its beneficial enjoyment. Applying these principles, the Court found that the BATL had occupied the property continuously since 1978, thereby constituting the actual taking contemplated under the law. Consequently, just compensation, if any, should be determined based on the property's condition and ownership at that time. The Court emphasized that just compensation is measured by the owner's loss rather than the government's gain, and therefore only the owner at the time of the taking is entitled to compensation.

The Court held that the petitioners were not entitled to just compensation because they and their predecessor-in-interest acquired ownership of the property only in 2012, or thirty-four years after the transmission line had already been constructed. At the time of the taking in 1978, ownership of the land remained with the government, as the petitioners' predecessor acquired the property only through a free patent issued decades later. The Court explained that an application for a free patent constitutes recognition that the land is public land, citing Yabut v. Alcantara, and that mere possession, even for several decades, does not automatically convert public land into private property. Moreover, the petitioners failed to prove ownership or lawful possession prior to 1978 and never questioned the NPC's occupation of the property or sought compensation through inverse condemnation, circumstances that further weakened their claim. The Court also stressed that the petitioners purchased or acquired the property with full knowledge that the transmission line had long existed, meaning they suffered no compensable injury from its installation.

The Court further ruled that the property remained subject to the 60-meter statutory right-of-way easement under Section 112 of Commonwealth Act No. 141 (Public Land Act), as amended by Presidential Decree No. 635, because it originated from a homestead or free patent. Since the transmission corridor occupied only 30 meters, it fell squarely within the statutory easement, under which the landowner may recover only damages for existing improvements and not the value of the land itself. The Court rejected the petitioners' argument that Republic Act No. 8974 and Republic Act No. 10752 (The Right-of-Way Act) had impliedly repealed Section 112, emphasizing that repeals by implication are disfavored and that Section 4 of R.A. No. 10752 expressly recognizes the continued applicability of Section 112 of C.A. No. 141 to lands acquired through free patents. The Court likewise found no factual basis for awarding damages for improvements because the records contained no competent evidence that improvements existed at the time of the taking in 1978. Instead, the evidence showed that most trees were planted only a few years before the filing of the complaint, indicating an attempt to increase the value of the claim.

Finally, the Court held that the ₱1,756,400.00 previously deposited by the respondent, representing 100% of the property's BIR zonal value, was mistakenly paid under the erroneous belief that the petitioners were legally entitled to just compensation. Applying the doctrine of solutio indebiti under Article 2154 of the Civil Code, which requires the return of money or property unduly delivered through mistake when the recipient has no legal right thereto, the Court ordered the petitioners to return the entire amount to the respondent. Accordingly, while the Court affirmed the respondent's authority to expropriate the property for public use, it held that the petitioners had no legal entitlement to compensation because they were not the owners at the time of the taking, the property remained subject to the statutory easement under Commonwealth Act No. 141, and no compensable improvements existing in 1978 had been proven. Consequently, the petition was denied, the Court of Appeals' decision was affirmed with modification, and the petitioners were ordered to refund the amount previously deposited by the respondent.

CASE DIGEST : CORAZON C. REYES v. OFFICE OF DEPUTY OMBUDSMAN FOR LUZON GR No. 230704, Mar 15, 2023 GAERLAN

FACTS : The Office of the Ombudsman filed criminal and administrative complaints against the members of the Bids and Awards Committee (BAC) of the Municipality of Palauig, Zambales, including petitioner Corazon C. Reyes, based on the findings of a COA post-audit of the municipality's 2006 procurement of office supplies. The COA found that the municipality procured supplies worth ₱804,678.00 through shopping/canvassing, allegedly without an Annual Procurement Plan (APP), using a procurement method not authorized by law, and favoring Tabing Daan Mart, whose owner was petitioner's sister. The Ombudsman alleged that the BAC violated Section 3(e) and (i) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) and committed administrative offenses, asserting that Tabing Daan Mart should have been disqualified under Section 47 of the Implementing Rules and Regulations (IRR) of R.A. No. 9184 (Government Procurement Reform Act) because of its relationship with a BAC member.

The BAC members denied the allegations, claiming that the municipality had an approved Annual Procurement Plan (APP) authorizing shopping as an alternative procurement method and that Tabing Daan Mart was selected because it offered the lowest and most advantageous prices, benefiting the government. They further argued that the disclosure of relationship under Section 47 of the IRR of R.A. No. 9184 applies only to competitive bidding and not to shopping. Nevertheless, the Ombudsman found probable cause to indict the BAC members for violating Section 3(e) of R.A. No. 3019, holding that they acted with manifest partiality and evident bad faith by awarding the contracts to a supplier owned by the petitioner's sister despite the prohibition against relatives within the third civil degree participating in procurement. However, it dismissed the charge under Section 3(i) of R.A. No. 3019 for lack of evidence that respondents had any financial interest in or personally benefited from the transactions. Petitioner's motion for reconsideration was subsequently denied.

ISSUE : WON Ombudsman gravely abused its discretion in finding probable cause against petitioner for violation of Section 3(e) of R.A. No. 3019

HELD : The Supreme Court granted the petition and held that the Office of the Ombudsman committed grave abuse of discretion in finding probable cause against the petitioner for violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). While the Court reiterated that the Ombudsman enjoys broad discretion in determining probable cause pursuant to the 1987 Constitution and Republic Act No. 6770 (The Ombudsman Act of 1989), such discretion remains subject to judicial review through a petition for certiorari when exercised in a capricious or arbitrary manner amounting to grave abuse of discretion. Upon review, the Court found that the Ombudsman erred in concluding that the petitioner and the other members of the Bids and Awards Committee (BAC) violated Section 47 of the Implementing Rules and Regulations (IRR) of Republic Act No. 9184 (Government Procurement Reform Act) by failing to require the supplier to disclose its relationship with a BAC member. The Court clarified that although Section 47 of the IRR was already in force in 2006, its disclosure requirement applies only to procurements conducted through competitive public bidding and not to Shopping, which is an authorized alternative mode of procurement under Sections 48 and 52 of R.A. No. 9184. After examining the provisions of the law and its 2003 IRR, the Court found no legal basis requiring bidders in Shopping procurements to submit a sworn affidavit disclosing relationships with BAC members. It emphasized that Shopping is governed by its own statutory requirements, including procurement within an approved Annual Procurement Plan (APP) under Section 7 of R.A. No. 9184, prior approval of the Head of the Procuring Entity, observance of procurement thresholds, obtaining at least three price quotations from qualified suppliers, compliance with posting requirements under Sections 21 and 54 of the IRR, and the prohibition against splitting contracts. The records showed that the Municipality substantially complied with these requirements by having an approved APP, obtaining the mayor's approval, canvassing fifteen suppliers, and selecting the supplier offering the lowest and most advantageous price. Although the BAC admittedly failed to comply with the posting requirements under Section 54.2 of the IRR, the Court agreed with the Ombudsman that such lapse constituted, at most, an administrative infraction and did not establish criminal liability.

The Court further ruled that the essential elements of Section 3(e) of Republic Act No. 3019 were not established. Citing Sistoza v. Desierto, Sabaldan, Jr. v. Ombudsman, Duque v. Ombudsman, and Martel v. People, it reiterated that violations of procurement laws or procurement irregularities do not automatically constitute a violation of the Anti-Graft and Corrupt Practices Act. To sustain criminal liability, the prosecution must prove not only a breach of procurement rules but also that the public officer acted with manifest partiality, evident bad faith, or gross inexcusable negligence, and that such acts caused undue injury to the government or conferred unwarranted benefits, advantage, or preference upon a private party. The Court found these elements absent. It held that the BAC lawfully resorted to Shopping, complied with the applicable procurement requirements, obtained quotations from fifteen suppliers, and awarded the procurement to Tabing Daan Mart because it offered the lowest price, possessed sufficient inventory, and was willing to extend credit to the municipality. Since the disclosure requirement under Section 47 of the IRR of R.A. No. 9184 did not apply to Shopping, the supplier's familial relationship with the petitioner did not automatically disqualify it nor establish favoritism or bad faith. Accordingly, the Court found no evidence of manifest partiality, evident bad faith, gross negligence, undue injury to the government, or unwarranted benefit to the supplier. Consequently, the Ombudsman's finding of probable cause was declared tainted with grave abuse of discretion, and the criminal complaint for violation of Section 3(e) of Republic Act No. 3019 was dismissed for lack of probable cause.

CASE DIGEST : CHEVRON PHILIPPINES v. ALBERTO T. LOOYUKO GR No. 236525, Mar 29, 2023 GAERLAN

 FACTS : Chevron Philippines, Inc. (formerly Caltex Philippines, Inc.) filed a complaint for collection of sum of money and damages against Alberto Looyuko, Achilles Pacquing, and Julieta Go, alleging that from April to November 1997, Noah's Ark Sugar Refinery purchased petroleum products and refinery services on credit amounting to ₱7,381,510.70, covered by 105 invoices. Despite repeated demand letters, the obligation remained unpaid. Chevron claimed that Alberto, as proprietor of Noah's Ark Sugar Refinery, and Achilles and Julieta, as its officers, were liable for the unpaid account.

Alberto challenged the complaint, arguing that he had not been validly served with summons and denying liability. He asserted that Noah's Ark Sugar Refinery had ceased operations in 1997, that he never personally entered into the transactions, and that no contractual relationship existed between him and Chevron. Achilles and Julieta likewise denied liability, claiming they were neither officers nor employees of Noah's Ark Sugar Refinery and had no participation in the purchases.

The Regional Trial Court ruled in favor of Chevron, holding Alberto personally liable as the sole proprietor of Noah's Ark Sugar Refinery and ordering his estate to pay the principal obligation, accrued interest, attorney's fees, litigation expenses, and continuing interest at 24% per annum. The RTC, however, dismissed the complaint against Achilles and Julieta for lack of evidence.

On appeal, the Court of Appeals reversed the RTC's decision and dismissed Chevron's complaint, finding that Chevron failed to establish Alberto's liability for the transactions and that the evidence presented was insufficient to support the collection of the claimed obligation.

ISSUE : WON the CA is Correct

HELD : The Supreme Court granted Chevron Philippines, Inc.'s petition, reversing the Court of Appeals and reinstating the RTC decision with modifications. Although petitions under Rule 45 of the Rules of Court generally raise only questions of law, the Court held that the case fell within an exception because the RTC and CA reached conflicting factual findings. It also ruled that respondents' failure to include page references in their appellant's brief was merely a formal defect. On the merits, the Court found that while Chevron failed to present a written supply agreement, the 105 invoices, delivery records, witness testimonies, and surrounding circumstances sufficiently established the existence of repeated deliveries of bunker fuel to Noah's Ark Sugar Refinery. Applying Article 1318 of the Civil Code on the requisites of contracts, Articles 1403 and 1405 on the Statute of Frauds, and Rule 131 on burden of proof, the Court held that the repeated acceptance and receipt of the fuel removed the transactions from the Statute of Frauds and proved the existence of enforceable sales.

The Court further held that respondent Alberto Looyuko, who admitted being the registered sole proprietor of Noah's Ark Sugar Refinery, failed to specifically deny the genuineness and due execution of the invoices as required under Rule 8, Sections 8 and 10 of the Rules of Court. His general denials and failure to present evidence disputing the refinery employees' authority or the deliveries amounted to implied admissions, while his failure to object to the invoices' admission in evidence constituted a waiver of any challenge to their authenticity. Applying Articles 1910 and 1911 of the Civil Code on agency by estoppel, the Court ruled that Alberto was bound by the acts of the refinery employees whom he allowed to appear authorized to receive and acknowledge the deliveries. Accordingly, Chevron successfully proved respondents' liability for the unpaid petroleum products and services.

The Court, however, modified the monetary awards. Pursuant to Article 2212 of the Civil Code and BSP Circular No. 799, it imposed 12% interest per annum from August 21, 1998 until June 30, 2013, and 6% interest per annum from July 1, 2013 until full payment, with 6% legal interest on the total judgment from finality of the decision until full satisfaction. It likewise awarded 20% of the principal obligation as attorney's fees in accordance with the invoices' conditions of sale, replacing the RTC's earlier computation. Finally, the Court affirmed the dismissal of respondents Julieta and Achilles as defendants because their personal liability and authority to bind the sole proprietor were not sufficiently established.

CASE DIGEST : LAND BANK OF PHILIPPINES v. MARGARITO E. TAYKO G.R. No. 231546. March 29, 2023 GAERLAN

FACTS : The spouses Josefa Tayko Guingona and Mauro Tayko voluntarily offered 481.0932 hectares of agricultural land for coverage under the Comprehensive Agrarian Reform Program (CARP). After inspection, only 360.0932 hectares were placed under CARP. In 2003, LBP valued the property at ₱32.8 million, deposited the provisional compensation, and titles were transferred to the Republic. Dissatisfied with the valuation, the landowners sought the determination of just compensation before the DAR adjudication bodies, which fixed a higher valuation. On appeal, the RTC-SAC further increased the compensation to ₱143.77 million with legal interest, prompting LBP to elevate the case to the Court of Appeals.

The CA partly granted LBP's appeal, holding that just compensation must be based on the property's value at the time of taking, which occurred on December 18, 2003, when LBP deposited the provisional payment. Finding the records insufficient to determine the proper valuation of the sugar lands using the applicable 2003 production data, the CA remanded the case to the RTC-SAC for the reception of additional evidence and recomputation in accordance with DAR A.O. No. 5, Series of 1998 and Joint Memorandum Circular No. 15, Series of 1999. It affirmed the valuation of the corn lands and ordered the payment of legal interest on the unpaid balance of just compensation from the time of taking until full payment.

ISSUE : WON the CA is correct

HELD : The Supreme Court held that the valuation of the 60.0932-hectare corn land should be governed by Section 17 of R.A. No. 6657 and the valuation formula under DAR Administrative Order No. 5, Series of 1998, and not by the formula under P.D. No. 27, which the RARAD, DARAB, and CA erroneously applied. The Court emphasized that just compensation must be based on the property's value at the time of taking, which occurred on December 30, 2003, when the titles were transferred to the Republic. Since the records lacked sufficient evidence to determine the proper valuation using the applicable formula and the production data as of the time of taking, the Court remanded the case to the RTC-SAC for the reception of additional evidence and the recomputation of just compensation in accordance with R.A. No. 6657 and DAR A.O. No. 5, Series of 1998.

The Court further ruled that the landowners are entitled to legal interest on the unpaid balance of the just compensation because of the delay in payment. Interest shall be computed only on the difference between the final judicially determined compensation and the government's provisional deposit, at the rate of 12% per annum from December 30, 2003 until June 30, 2013, and 6% per annum from July 1, 2013 until the finality of the decision. Thereafter, the entire unpaid amount shall earn legal interest at 6% per annum until fully paid. Accordingly, the Court partially granted the petition, affirmed the CA's ruling with modifications, and remanded the case to the RTC-SAC for the proper determination of just compensation.

CASE DIGEST : DIVERSIFIED PLASTIC FILM SYSTEM, INC., VS. PHILIPPINE INVESTMENT ONE (SPV-AMC), INC., G.R. No. 236924. March 29, 2023 GAERLAN

FACTS : The case arose from Diversified's default on a ₱100 million loan secured by a Mortgage Trust Indenture (MTI), which was eventually assigned by DBP to PI-One after All Asia transferred its rights to DBP. When PI-One initiated the extrajudicial foreclosure of Diversified's mortgaged properties, Diversified questioned PI-One's authority to foreclose, claiming that it was not the valid trustee under the MTI. After the writ of preliminary injunction obtained by Diversified was dissolved with finality, PI-One filed a petition for its appointment as successor trustee under Section 7.08 of the MTI. The RTC granted the petition, and the CA affirmed, holding that the court had authority to appoint a successor trustee after the contractual period lapsed, and that PI-One, as assignee of the loan and the remaining creditor, succeeded to All Asia's rights under the MTI.

On appeal, Diversified argued that the RTC had no jurisdiction to appoint PI-One as trustee, that summons was improperly served, that PI-One was not qualified to act as trustee because it was not engaged in the trust business, and that no urgency justified the appointment. The CA rejected these arguments, ruling that Section 7.08 of the MTI expressly authorizes any lender to seek judicial appointment of a successor trustee when the parties fail to appoint one within the prescribed period, that Diversified voluntarily submitted to the RTC's jurisdiction by filing its Answer, and that under Section 13 of the Special Purpose Vehicle Act (R.A. No. 9182), PI-One validly acquired All Asia's rights and interests under the MTI through assignment, including the right to act as trustee.

ISSUE : WON the RTC does not have jurisdiction to appoint a trustee because under the MTI, the power to appoint a trustee is lodged in both Diversified and the majority of its lenders

HELD : The Supreme Court held that while the RTC had jurisdiction over the petition for appointment of a trustee, as the action is incapable of pecuniary estimation and Section 7.08 of the Mortgage Trust Indenture (MTI) expressly authorizes a lender to seek judicial appointment of a successor trustee, it failed to acquire jurisdiction over Diversified's person due to improper service of summons. Summons was served on Diversified's receiving officer instead of the corporate officers exclusively enumerated under Section 11, Rule 14 of the Rules of Court. The Court further ruled that Diversified did not voluntarily submit to the RTC's jurisdiction because its Answer Ad Cautelam and subsequent pleadings consistently and expressly challenged the RTC's jurisdiction through a special appearance, thereby rendering all proceedings before the RTC null and void.

The Court likewise ruled that the Deed of Assignment between DBP and PI-One was ineffective for failure to comply with the mandatory notice requirements and certification under Section 12 of the Special Purpose Vehicle Act (R.A. No. 9182). Even assuming a valid assignment, PI-One could not automatically assume the position of trustee because an assignee merely acquires the rights of its assignor and remains bound by the conditions of the MTI. Since the MTI requires that the trustee be an institution duly authorized to engage in the trust business, and PI-One admittedly lacked such qualification, it was disqualified from serving as trustee. Accordingly, the Court granted the petition, reversed the CA and RTC rulings, and dismissed PI-One's petition for appointment as trustee.

CASE DIGEST : SALVADOR M. SOLIS FOR HIMSELF AND ON BEHALF OF ESTATE OF SPS. RAMON M. SOLIS v. MARIVIC SOLIS-LAYNES GR No. 235099, Mar 29, 2023 GAERLAN

FACTS : The Spouses Solis owned an untitled five-hectare fishpond in Romblon covered by tax declarations in the name of Ramon M. Solis, Sr. After their deaths, one of their heirs, Salvador Solis, discovered that the tax declaration had been altered to reflect the name of his brother, Ramon M. Solis, Jr., allegedly due to a "typographical error." Upon Ramon Jr.'s death, the fishpond was included in his estate and later transferred to his heirs. Eventually, respondent Marivic Solis-Laynes secured a free patent and an Original Certificate of Title over the fishpond. Claiming that Marivic fraudulently obtained title to property belonging to the estate of their parents, petitioners filed an action for quieting of title, reconveyance, and declaration of nullity of the tax declaration, free patent, and title. Although Marivic was already residing in the United States, the RTC allowed service of summons by publication after summons sent to her Philippine address were returned unserved. Marivic failed to answer the complaint, was declared in default, and the RTC rendered judgment nullifying her title and ordering her to pay damages.

Marivic later filed a motion for new trial, arguing that she was denied due process because Salvador knew she had been residing in the United States for over 20 years but failed to properly serve summons at her foreign address as required by the RTC's own order. The RTC denied her motion, prompting her to appeal. The Court of Appeals reversed the RTC, holding that the action was quasi in rem and that, under Section 15, Rule 14 of the Rules of Court, service by publication alone was insufficient. Since Salvador failed to send a copy of the summons by registered mail to Marivic's last known address in the United States despite the RTC's directive, there was no valid service of summons. Consequently, the CA set aside the RTC's decision and dismissed the complaint for lack of valid jurisdiction over Marivic.

ISSUE : WON the CA erred when it set aside of the decision of the RTC

HELD : The Supreme Court partly granted the petition. It held that the extraterritorial service of summons on Marivic was defective because although summons was published, petitioners failed to send copies of the summons and complaint to her last known address in the United States, as expressly required by Section 15, Rule 14 of the Rules of Court and the RTC’s own order. However, the defect was cured when Marivic voluntarily appeared before the RTC by filing a Motion for New Trial seeking not only to question jurisdiction but also to set aside the default judgment and present evidence on the merits, thereby submitting herself to the court’s jurisdiction.

Nevertheless, the Court ruled that Marivic’s voluntary appearance cured only the jurisdictional defect and did not cure the denial of her right to be heard. Since she was improperly declared in default and deprived of the opportunity to present evidence, the RTC should have granted her Motion for New Trial. Thus, while affirming the CA’s nullification of the RTC’s default judgment, the Court modified the CA’s ruling by reinstating the complaint instead of dismissing it and remanded the case to the RTC for a full-blown trial to allow Marivic to file her responsive pleading and fully participate in the proceedings, in keeping with the requirements of due process and substantial justice.

CASE DIGEST : ATTY. ROGELIO B. DE GUZMAN VS. SPOUSES BARTOLOME AND SUSAN SANTOS G.R. No. 222957. March 29, 2023 GAERLAN

FACTS : Petitioner Rogelio B. De Guzman owned a house and lot in Taytay, Rizal, covered by TCT No. 5788. In November 2000, he entered into a Contract to Sell with respondents spouses Bartolome and Susan Santos for the purchase price of ₱1,500,000.00, payable through a ₱250,000.00 down payment and monthly installments of ₱15,000.00 with 9% annual interest on the unpaid balance. Upon payment of the down payment, the spouses Santos immediately took possession of the property. However, they failed to pay the monthly installments, vacated the property in February 2001, and subsequently filed a complaint for rescission of the contract, recovery of their down payment (less reasonable rental), and damages.

The RTC initially dismissed the complaint and ordered the spouses Santos to pay the remaining purchase price with interest. Thereafter, the spouses Santos discovered that De Guzman had already sold the subject property to a third party, Elizabeth Algoso, on August 17, 2005 while the case was still pending. On the basis of this newly discovered fact, they successfully moved for a new trial. The RTC set aside its earlier decision, declared the Contract to Sell rescinded, and ordered De Guzman to return the balance of the down payment amounting to ₱208,500.00 with legal interest. The RTC held that De Guzman acted in bad faith by disposing of the property under litigation without informing either the court or the opposing party, thereby rendering the enforcement of the contract impossible. The Court of Appeals affirmed the RTC, ruling that the unauthorized sale of the property during the pendency of the case constituted bad faith and justified the grant of a new trial in the interest of justice and equity.

ISSUE : WON the CA correctly affirmed the rescission of the Contract to Sell and WON De Guzman is liable to reimburse the spouses Santos their down payment

HELD : The Supreme Court granted the petition and reversed the rulings of the RTC and the Court of Appeals. It held that under a Contract to Sell, ownership remains with the seller until the buyer fully pays the purchase price. Since the spouses Santos admittedly failed to pay the agreed installments, the suspensive condition was never fulfilled, and De Guzman had no obligation to transfer ownership. Consequently, his subsequent sale of the property to a third party, although done in bad faith during the pendency of the case, was nevertheless valid and did not constitute a legal ground to rescind the Contract to Sell or require the return of the down payment. At most, the buyers could have sought damages.

The Court further ruled that both parties acted in bad faith. The spouses Santos deliberately defaulted on their payment obligations, abandoned the property, and then sought rescission, while De Guzman improperly sold the property during the litigation. Applying the doctrine of in pari delicto, the Court refused to grant relief to either party, leaving them where it found them. Moreover, pursuant to the express terms of the Contract to Sell, the spouses Santos' failure to pay the installments resulted in the automatic cancellation of the contract and forfeiture of all payments made, consistent with the principle that contracts have the force of law between the parties and must be complied with in good faith.

CASE DIGEST : F & DIR. ROGELIO F. ASIGNADO v. OFFICE OF OMBUDSMAN GR Nos. 225204-05, Mar 29, 2023 GAERLAN

FACTS : The petitioners, former officers and trustees of the Bureau of Fire Protection Mutual Aid & Beneficiary Association, Inc. (BFPMBAI), filed criminal and administrative complaints before the Office of the Ombudsman against Fire Chief Superintendent Carlito S. Romero, then Officer-in-Charge of the Bureau of Fire Protection (BFP). They alleged that under a 2006 Memorandum of Agreement, the BFP was obligated to deduct BFPMBAI members' contributions from their salaries and remit the same to the association. However, in February 2013, Romero ordered the temporary suspension of payroll deductions and the withholding of remittances after a dispute arose over the legitimacy of BFPMBAI's Board of Trustees following the contested June 30, 2012 elections. Petitioners claimed that despite repeated demands, Romero refused to release the remittances unless he and his allied candidates were recognized as the association's officers, causing BFPMBAI financial losses and disrupting its lending and insurance operations. They accused Romero of violating Sections 3(e) and 3(f) of the Anti-Graft and Corrupt Practices Act, committing grave coercion under the Revised Penal Code, and administratively committing grave misconduct, oppression, grave abuse of authority, and conduct prejudicial to the best interest of the service.

Romero denied the accusations, asserting that the BFPMBAI elections were unresolved because the Committee on Elections issued a status quo ante order after serious irregularities, including the casting of votes for thousands of absent members. To protect the association's funds and avoid releasing them to the wrong claimants, he suspended the remittances and later filed an interpleader case before the Regional Trial Court to determine the rightful Board of Trustees. He maintained that his actions were done in good faith, without malice, and that the withheld funds were eventually reverted to the Bureau of the Treasury. The Ombudsman dismissed both the criminal and administrative complaints, finding that Romero had valid legal grounds to withhold the remittances pending judicial resolution of the leadership dispute, that filing an interpleader was an appropriate remedy, and that there was no evidence of bad faith, personal benefit, or corrupt motive. Petitioners' motion for reconsideration was likewise denied, prompting them to file a petition for certiorari before the Supreme Court, where they argued that Romero should have challenged the election through an intra-corporate controversy rather than withholding the remittances and claimed that the Ombudsman gravely abused its discretion, even alleging bias on the part of the Deputy Ombudsman due to his prior professional relationship with Romero.

ISSUE : WON public respondent committed grave abuse of discretion in dismissing both the criminal and administrative charges filed against private respondent

HELD : The Supreme Court dismissed the petition and upheld the Ombudsman's dismissal of the criminal charges against Romero. It first ruled that it had no jurisdiction over the administrative aspect of the case because the proper remedy to question the Ombudsman's dismissal of administrative charges is a petition before the Court of Appeals. Thus, the Court limited its review to the criminal aspect, specifically whether the Ombudsman gravely abused its discretion in finding no probable cause for violations of Sections 3(e) and 3(f) of the Anti-Graft and Corrupt Practices Act and Article 286 of the Revised Penal Code. The Court emphasized that while Romero may have lacked clear authority to suspend the remittances and his handling of the funds may have been legally flawed, these acts alone did not establish manifest partiality, evident bad faith, gross inexcusable negligence, or corrupt motive, which are essential elements of the offenses charged. His actions were motivated by the unresolved dispute over the legitimate BFPMBAI Board of Trustees and his intent to protect the association's funds pending judicial resolution through an interpleader case. Moreover, there was no evidence that Romero personally benefited from the withheld remittances, as the funds were reverted to the Bureau of the Treasury.

The Court likewise found no probable cause for violations of Section 3(f) of R.A. No. 3019 and grave coercion under Article 286 of the Revised Penal Code. Petitioners failed to substantiate their allegations that Romero withheld the remittances to force them to recognize him and his allies as BFPMBAI officers or that he employed threats, intimidation, or coercion. Their claims were supported only by bare allegations without documentary or testimonial evidence. The Court also rejected petitioners' accusations of bias against the former Deputy Ombudsman, noting that there was no proof that he influenced the Ombudsman's resolutions. Finding no grave abuse of discretion in the Ombudsman's determination that probable cause was lacking, the Court affirmed the dismissal of the criminal charges and reiterated its policy of non-interference with the Ombudsman's prosecutorial discretion absent clear arbitrariness or capriciousness.

CASE DIGEST : XXX v. PEOPLE GR No. 255877, Mar 29, 2023 GAERLAN

FACTS : XXX was charged with violating Section 5(i) of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) for allegedly committing psychological violence and economic abuse against his wife, AAA. The Information alleged that from 2004 onwards, XXX abandoned AAA and deliberately denied her financial support, causing her substantial mental and emotional anguish. During trial, AAA testified that they married on October 14, 2002 and initially lived together until 2004, when XXX left the Philippines to work as a seafarer. Although he initially remitted part of his salary, he stopped sending financial support after a few months and ceased communicating with her after instructing her to live with his parents in Antique, which she refused. For the next 13 years, he neither contacted nor supported her financially. As a result, her sari-sari store failed, forcing her to work as a freelance massage therapist to support herself. Her sister, CCC, also testified that she saw XXX back in the Philippines in 2013, yet he made no effort to communicate with or support AAA.

For his defense, XXX admitted that he stopped sending financial support and never contacted AAA after 2004 but claimed that he was forced into marrying her. He explained that he discontinued the remittances because his parents were suffering from cancer and needed financial assistance, and that he was traumatized by their frequent marital disputes. Although he returned to the Philippines in 2007 and worked as a maritime instructor, he still did not provide support to AAA. The Regional Trial Court found him guilty beyond reasonable doubt of violating Section 5(i) of R.A. No. 9262 and sentenced him to imprisonment, imposed a fine of ₱100,000.00, and ordered him to undergo mandatory psychological counseling. On appeal, the Court of Appeals affirmed the conviction, holding that XXX's deliberate refusal to support and communicate with his wife constituted economic abuse and psychological violence under the law despite his personal justifications.

ISSUE : WON XXX is guilty beyond reasonable doubt for violation of Section 5(i) of R.A. No. 9262

HELD : The Supreme Court granted the petition and acquitted XXX, ruling that the prosecution failed to prove all the essential elements of Section 5(i) of R.A. No. 9262, as clarified in Acharon v. People. The Court emphasized that denial of financial support is mala in se, requiring proof not only that the accused willfully withheld financial support legally due, but also that he did so with the specific intent to cause the woman mental or emotional anguish. Mere failure or inability to provide support does not constitute a criminal offense under the law.

The Court found that while XXX admittedly stopped sending financial support, the evidence showed that he did so because his parents were seriously ill and he had to shoulder their medical expenses, not because he intended to inflict psychological violence on AAA. It also noted that AAA never demanded support or attempted to communicate with XXX despite learning that he had returned to the Philippines, and there was no showing that XXX knew she was in need of financial assistance. Moreover, AAA was capable of supporting herself, having operated a sari-sari store and later worked as a freelance massage therapist. Thus, the prosecution failed to establish the criminal intent required under Section 5(i), warranting XXX's acquittal.