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.

CASE DIGEST : ROMUALDO J. BAWASANTA v. PEOPLE GR No. 219300 GAERLAN

 FACTS : These consolidated petitions for review challenge the Sandiganbayan’s April 20, 2015 Decision and July 20, 2015 Resolution convicting Romualdo J. Bawasanta, Rodolfo G. Valencia, and Alfonso V. Umali, Jr. for violations of Sections 3(e) and 3(g) of the Anti-Graft and Corrupt Practices Act in connection with a Credit Agreement between the Oriental Mindoro provincial government and Alfredo M. Atienza. Valencia, as Governor, Umali, as Provincial Administrator, and Bawasanta, as SP member, were found liable for unlawfully granting unwarranted benefits and privileges to Atienza, acting with manifest partiality and in bad faith. The Sandiganbayan emphasized that the Credit Agreement was grossly disadvantageous to the government, as it extended unsecured credit to a private party for non-public purposes and contrary to legal objections raised by the Provincial Treasurer and Auditor. Valencia authorized the loan and disbursement over their objections; Umali approved the disbursement without exercising discretionary powers or following Dalisay’s recommendations; and Bawasanta, as SP member, approved the appropriation without properly assessing its legality. The Court noted that the three officials acted in conspiracy, making them criminally liable as co-principals. Motions for reconsideration filed by Valencia, Umali, and Bawasanta were denied by the Sandiganbayan, leading to the present petitions for review, while Valencia was later granted leave to travel abroad.

ISSUE : SB erred in ruling that the Credit Agreement was manifestly and grossly disadvantageous to the government

HELD : These consolidated petitions for review challenge the Sandiganbayan’s April 20, 2015 Decision and July 20, 2015 Resolution convicting Romualdo J. Bawasanta, Rodolfo G. Valencia, and Alfonso V. Umali, Jr. for violations of Sections 3(e) and 3(g) of the Anti-Graft and Corrupt Practices Act in connection with a Credit Agreement between the Oriental Mindoro provincial government and Alfredo M. Atienza. Valencia, as Governor, Umali, as Provincial Administrator, and Bawasanta, as SP member, were found liable for unlawfully granting unwarranted benefits and privileges to Atienza, acting with manifest partiality and in bad faith. The Sandiganbayan emphasized that the Credit Agreement was grossly disadvantageous to the government, as it extended unsecured credit to a private party for non-public purposes and contrary to legal objections raised by the Provincial Treasurer and Auditor. Valencia authorized the loan and disbursement over their objections; Umali approved the disbursement without exercising discretionary powers or following Dalisay’s recommendations; and Bawasanta, as SP member, approved the appropriation without properly assessing its legality. The Court noted that the three officials acted in conspiracy, making them criminally liable as co-principals. Motions for reconsideration filed by Valencia, Umali, and Bawasanta were denied by the Sandiganbayan, leading to the present petitions for review, while Valencia was later granted leave to travel abroad.

The consolidated petitions challenge the Sandiganbayan’s April 20, 2015 Decision and July 20, 2015 Resolution convicting Romualdo J. Bawasanta, Rodolfo G. Valencia, and Alfonso V. Umali, Jr. for violating Sections 3(e) and 3(g) of the Anti-Graft and Corrupt Practices Act in connection with a Credit Agreement between the Oriental Mindoro provincial government and Alfredo M. Atienza. The Sandiganbayan held that the Credit Agreement was grossly disadvantageous to the government, as it extended unsecured credit to a private party for non-public purposes, contrary to legal objections from the Provincial Treasurer and Auditor. Valencia authorized the loan and disbursement despite these objections; Umali approved the disbursement without exercising his discretionary powers or following recommendations to withhold it; and Bawasanta, as SP member, approved the appropriation without assessing its legality. The court found the three acted in conspiracy, making them co-principals liable for the crime. Their motions for reconsideration were denied, prompting these petitions, while Valencia was later granted leave to travel abroad.

CASE DIGEST : BW SHIPPING PHILIPPINES v. MARIO H. ONG GR No. 202177 GAERLAN

 FACTS : The petition for review on certiorari is grounded on the contention that the Court of Appeals (CA) erred in affirming the National Labor Relations Commission’s (NLRC) rulings granting respondent permanent total disability benefits. The factual backdrop shows that respondent, a seafarer employed by petitioner BW Shipping Philippines, Inc., developed uncontrolled diabetes and hypertension while on duty, prompting repatriation and subsequent medical treatment. Despite company-designated physicians declaring him fit to resume sea duties, respondent’s own medical evaluation confirmed persistent illness, rendering him unable to return to work. The Labor Arbiter awarded permanent total disability benefits, which the NLRC affirmed, emphasizing that the illness was work-connected and occurred during the contract term. The CA upheld these findings, recognizing that respondent’s inability to perform his duties despite the fitness certification, combined with medical proof of work-related illness, entitled him to compensation. Petitioners’ claim that the CA gravely abused its discretion is unmeritorious, as the findings of the labor tribunals on the compensability of the respondent’s disability, being factual and supported by substantial evidence, are binding and cannot be overturned on certiorari absent a showing of grave abuse of discretion amounting to lack or excess of jurisdiction.

ISSUE : WON the CA is correct

HELD : The petition for review on certiorari is GRANTED. The Court holds that the respondent, Mario H. Ong, failed to establish entitlement to permanent total disability benefits, as his claims of diabetes mellitus and essential hypertension were not proven to be work-related or of such severity as to cause permanent incapacity under Section 20(B), paragraph 6, and Section 32-A of the 2000 POEA Standard Employment Contract (POEA-SEC). The Court emphasized that diabetes is generally a metabolic and familial condition not typically caused by occupational duties, while essential hypertension, though recognized as an occupational disease, must impair bodily functions to a degree constituting permanent disability—a showing absent in the present case. Respondent’s contention was further undermined by the credible medical findings of company-designated physicians who treated him immediately after repatriation and certified him fit to resume sea duties, supported by normal laboratory results. Respondent also failed to follow the POEA-SEC-mandated procedure to resolve conflicting medical assessments with a third mutually agreed-upon physician. Consequently, the Court found that the CA did not correctly determine the absence of grave abuse of discretion by the NLRC in granting the benefits, as the award was not supported by substantial evidence. The CA decision dated March 9, 2012, and its Resolution dated June 4, 2012, are REVERSED and SET ASIDE, and respondent’s complaint is DISMISSED.

CASE DIGEST : PEOPLE v. ERNESTO MONTILLA Y CARIAGA GR No. 198449 GAERLAN

 FACTS : The appeal challenges the Court of Appeals’ (CA) February 10, 2011 decision affirming the RTC of Cadiz City’s November 18, 2004 ruling convicting Ernesto Montilla y Cariaga of murder. Montilla and Dale Duay were charged for the August 20, 1999 killing of Ranie Lapidante, with Montilla claiming self-defense, testifying that the victim aggressively drew a “pugalite” and the fatal shot occurred during a struggle. The prosecution presented witnesses asserting that Montilla shot the victim on Duay’s instructions. The RTC found Montilla’s version implausible, noting lack of independent corroboration, and convicted him of murder with the aggravating circumstance of treachery, sentencing him to reclusion perpetua plus civil indemnity and moral damages. The CA affirmed this decision, adopting the RTC’s findings, and Montilla subsequently filed a Notice of Appeal to the Supreme Court, while the plaintiff-appellee indicated intent to uphold the CA’s factual findings, arguing that self-defense was unsupported and treachery properly applied.

ISSUE : WON the RTC is correct.

HELD : The appeal is denied. The accused-appellant’s claim of self-defense fails because he did not prove unlawful aggression by the victim, a necessary element to justify self-defense; his account was self-serving, uncorroborated, and contradicted by credible prosecution witnesses and the nature of the victim’s injuries. The trial court and the Court of Appeals correctly found that the killing was attended by treachery, as the victim was caught off-guard and defenseless when shot, making the crime murder under Article 248 of the RPC. The penalty of reclusion perpetua is thus affirmed, while the award of damages is modified: the accused-appellant is ordered to pay the heirs P75,000 each for civil indemnity, moral, and exemplary damages, plus P50,000 for temperate damages, with six percent annual interest from finality of the decision until full payment.

CASE DIGEST : MARY GRACE D. CORPUZ v. COA GR No. 253777 GAERLAN

 FACTS : The case involves a Petition for Certiorari filed on March 11, 2020 under Rules 64 and 65 of the Revised Rules of Court, seeking the reversal of COA Decision No. 2018-370 and Notice No. 2020-014, which affirmed COA-RO3 Decision No. 2015-04 disallowing payments to Atty. Teodoro G. Mendoza under a legal retainer contract with PhilRice. PhilRice, through its Executive Director Atty. Ronilo Beronio, executed the contract with Atty. Mendoza in 2009 without prior COA concurrence, which was only later issued in December 2009, directing reductions in fees. COA subsequently issued Notices of Disallowance totaling ₱209,765.00, holding several PhilRice officials—including petitioners Mary Grace Corpuz, Babylinda Reyes, Sophia Borja, Leo Javier, and Caesar Tado—liable for certifying and approving the payments. The petitioners appealed to COA-RO3 and the COA proper, both of which denied their appeals for failure to comply with the Legal Retainer Review and for lack of merit. The petitioners now seek relief before this Court, arguing that sustaining the disallowances would unjustly enrich the government, the contract and disbursements were fair and lawful, and the disbursements were made in good faith.

ISSUE : WON the Subject Contract, at the time of execution, was not entered into in accordance with the prevailing law, rules, and jurisprudence.

HELD : The Court ruled that while PhilRice officers sought the concurrence of the OGCC and COA, the Subject Contract with Atty. Mendoza was executed without prior approval, violating applicable laws and COA Circulars. Petitioners Corpuz, Borja, Javier, Tado, and Reyes were not involved in hiring Mendoza and are therefore absolved from liability under Notice of Disallowance No. 14-001-101-(09), along with Conyfel Jiao, Eulito Bautista, and Ruben Miranda. Atty. Beronio, as Executive Director, and Atty. Mendoza remain liable, with Mendoza entitled only to a reasonable retainer of ₱10,000/month and ₱1,000/appearance. For Notice of Disallowance No. 14-002-101-(2013), only Reyes and Tado remain liable for reimbursement of notarial commission fees, since such costs were not covered under the contract. The Court affirmed COA’s decisions with modification, leaving unresolved the potential liability of Beronio, Mendoza, Rasco, and the PhilRice Board members, and allowing COA to issue supplemental notices if warranted.

CASE DIGEST : J.R. NEREUS O. ACOSTA* v. PEOPLE GR Nos. 225154-57 GAERLAN

 FACTS : The petitioners, Nereus and Socorro Acosta, sought review of the Sandiganbayan’s March 28, 2016 Decision and June 14, 2016 Resolution convicting Socorro for violation of Section 3(h) of R.A. No. 3019 and both for violation of Section 3(e) of R.A. No. 3019, in connection with the release of P5,500,000.00 from Nereus’ Priority Development Assistance Fund (PDAF) to the Bukidnon Vegetable Producers Cooperative (BVPC). The Sandiganbayan found that both acted with manifest partiality and gross negligence, causing undue injury to the government and giving unwarranted benefits to BVPC, which was partly organized by Socorro and her relatives, and that Socorro, as Municipal Mayor, had prohibited financial interest in the transaction. The petitioners argued that the Sandiganbayan erred in excluding the BVPC Annual Report of December 2001, that the concurrence of the Sangguniang Bayan was unnecessary since the funds came from the national government, that they lacked the requisite elements of Sections 3(e) and 3(h) violations, and that Socorro no longer had financial interest in BVPC at the time. They also claimed that denial of their motion for new trial deprived them of presenting newly discovered evidence, including the Annual Report, which could rebut the prosecution’s witness, Engr. Pangan. The prosecution opposed, urging dismissal of the petition as devoid of merit.

ISSUE :  WON the Sandiganbayan erred when it anchored its factual conclusions with respect to the supposed existence of pecuniary interest in BVPC, on speculation, surmise, and conjectures

HELD : The Court held that Socorro O. Acosta cannot be convicted for violation of Section 3(h) of R.A. No. 3019 because she no longer had any pecuniary interest in BVPC when the P5,500,000.00 was released, and the prosecution failed to prove otherwise beyond reasonable doubt. Socorro’s prior involvement in organizing BVPC and her former position as Chairperson did not establish a continuing financial interest at the time of the disbursement, and her approval of the fund release did not constitute “actual intervention” under the law. Regarding Section 3(e), both Socorro and her son Nereus were acquitted because the disbursement of the P5,500,000.00 to BVPC was legally justified under the PDAF system, properly authorized by the DBM, and did not result in undue injury or confer unwarranted benefits, negating manifest partiality, bad faith, or gross negligence. Consequently, the Sandiganbayan’s decisions convicting them were reversed and set aside, and both petitioners were acquitted of the charges.

CASE DIGEST : LIMCOMA LABOR ORGANIZATION (LLO)-PLAC VS. LIMCOMA MULTI-PURPOSE COOP. (LIMCOMA) G.R. No. 239746 GAERLAN

FACTS : The case is a Petition for Review on Certiorari filed by Limcoma Labor Organization (LLO)-PLAC under Rule 45, challenging the Court of Appeals’ (CA) decision and resolution in CA-G.R. SP No. 139655. LLO-PLAC, as the sole and exclusive bargaining agent (SEBA) for rank-and-file employees of Limcoma Multi-Purpose Cooperative, contended that the 18% profit-sharing provision in the collective bargaining agreement (CBA) applied only to rank-and-file employees. After the implementation of a Voluntary Retire-Rehire Program in 2005, the first CBA was executed in 2006 and renewed in 2011, maintaining the 18% profit-sharing term. In 2014, during wage reopening negotiations, the union learned that supervisors and managerial employees were also granted 18% profit sharing under a separate agreement, prompting arbitration. The Voluntary Arbitrator (VA) ruled that profit sharing was due exclusively to rank-and-file employees. The CA, however, reversed the VA’s decision, holding that all regular employees, regardless of rank or position, were entitled to the 18% profit-sharing, with deductions for hospitalization, rice subsidy, and 13th month pay. Petitioner’s motion for reconsideration was denied, leading to the present petition, which focuses solely on profit-sharing coverage for 2011-2013, as subsequent CBA negotiations have rendered other issues academic.

ISSUE :  WON the CA committed serious error of judgement in ruling that supervisors, confidential and managerial employees are entitled to benefit from the provisions of the CBA of the rank and file employees

HELD : The Court granted the petition, ruling that the Court of Appeals erred in reversing the Voluntary Arbitrator’s (VA) decision regarding the profit-sharing provision in Section 2, Article VIII of the CBA. The CBA clearly covers only regular rank-and-file employees, and supervisory, confidential, and managerial employees are excluded under labor law from the collective bargaining unit, meaning they cannot share in the profit allocation secured by the union. The Court emphasized that while the employer may voluntarily grant similar benefits to non-rank-and-file employees through separate agreements like the K-VRR Program, such grants cannot be deducted from the 18% net surplus intended for rank-and-file employees under the CBA. The Court noted that the respondent’s argument that the profit-sharing had “ripened into practice” did not prevent correction, as there was an error in interpreting the CBA. Accordingly, the Court reinstated the VA’s decision, ordering the cooperative to provide the 18% profit share to all rank-and-file employees as agreed in the CBA, while any profit-sharing for K-VRR employees must come from separate allocation and not reduce the rank-and-file share. The CA’s August 9, 2017 Decision and May 16, 2018 Resolution were reversed and set aside.

CASE DIGEST : SAINT WEALTH LTD. v. BIR GR No. 252965 GAERLAN

FACTS : The consolidated petitions for certiorari and prohibition challenge Section 11(f) and (g) of the Bayanihan 2 Law, as well as related BIR and DOF issuances (RR No. 30-2020, RMC Nos. 64-2020, 102-2017, and 78-2018), seeking to annul them and enjoin their enforcement via TRO or preliminary injunction. These provisions imposed a five percent (5%) franchise tax on Philippine Offshore Gaming Operators (POGOs) and other taxes on non-gaming income. The petitioners, including Saint Wealth and the Marco Polo group of offshore POGO licensees, argued that the taxes violate constitutional principles, including due process, equal protection, territoriality, uniformity of taxation, and the prohibition against riders, as offshore POGOs earn income abroad and are differently situated from Philippine-based casinos. They also contended that RMCs issued by the BIR lack statutory basis.

Respondents (DOF and BIR) countered that the taxes are constitutional, based on existing laws and the PAGCOR Charter, which allows collection of a five percent franchise tax, and that the RMCs merely implement valid statutory provisions. They argued there is a reasonable classification between POGO licensees and other entities, the taxes comply with situs and uniformity principles, and the issuance of a TRO was unwarranted.

During the case’s pendency, R.A. No. 11590 was enacted, formally taxing all POGOs as entities “engaged in doing business in the Philippines,” imposing a five percent gaming tax on gross gaming revenues, a 25% income tax on non-gaming income within the Philippines for offshore POGOs, and zero-rated VAT on goods and services supplied to POGOs.

ISSUE : WON offshore-based POGO licensees are liable to pay a five percent (5%) franchise tax for income derived from their gaming operations; and 

(2) WON offshore-based POGO licensees are liable to pay income tax, VAT, and other applicable taxes for income derived from their non-gaming operations.

HELD : The Court found the Consolidated Petitions meritorious, declaring Section 11(f) and (g) of the Bayanihan 2 Law, along with RR No. 30-2020, RMC Nos. 64-2020, 102-2017, and 78-2018, unconstitutional and void for imposing taxes on offshore-based POGO licensees without statutory basis. Although R.A. No. 11590 later clarified the taxation of POGOs, including a 5% gaming tax and 25% income tax on Philippine-sourced income, it cannot be applied retroactively. The Court held that prior to Bayanihan 2, no law imposed franchise, income, or VAT taxes on POGOs, and the PAGCOR Charter’s 5% franchise tax applies only to casino licensees, not POGOs. RMC No. 102-2017 and related issuances were invalid for exceeding BIR authority and encroaching on Congress’s exclusive power to tax. Offshore-based POGOs were found not to engage in business in the Philippines, as their income-generating activities occur abroad, and taxation requires source within the Philippines. Section 11(f) and (g) were also ruled unconstitutional as riders, introducing new taxes unrelated to the law’s COVID-19 relief purpose, violating the “one subject, one title” constitutional rule. Consequently, all related tax impositions on offshore POGOs prior to R.A. No. 11590 are null and void.

CASE DIGEST : MALATE CONSTRUCTION DEVELOPMENT CORPORATION* AND GIOVANNI OLIVARES VS. EXTRAORDINARY REALTY AGENTS & BROKERS COOPERATIVE G.R. No. 243765 GAERLAN

 FACTS : The case involves Malate Construction Development Corporation (MCDC) and its president Giovanni Olivares, who sought to overturn the Court of Appeals’ affirmation of an RTC ruling ordering them to pay commissions and attorney’s fees to Extraordinary Realty Agents & Brokers Cooperative (ERABCO). In 2003, MCDC contracted ERABCO to promote and sell units in Mahogany Villas, agreeing to pay commissions based on sales milestones. When MCDC refused to pay in 2005–2006, ERABCO filed a complaint for P4,962,935.77 plus damages and attorney’s fees. The RTC found that ERABCO sold 202 units and was entitled to nine percent of the total sales, awarding P4,069,919.88 in unpaid commissions and P50,000 in attorney’s fees, with Olivares held solidarily liable. The CA affirmed the RTC, ruling that MCDC’s buy-back of some units and cancellation of the Marketing Agreement did not negate ERABCO’s right to earned commissions, and modified interest rates accordingly. The Supreme Court denied MCDC’s petition, confirming that contractual obligations must be honored and that corporate officers may be held liable for payments due under valid agreements.

ISSUE : WON MCDC is liable for broker's fees 
WON Olivares may be held solidarily liable with MCDC.

HELD : In this case, MCDC and Olivares challenged the CA’s affirmation of the RTC ruling ordering payment of commissions to ERABCO, arguing lack of evidence, improper burden shifting, and Olivares’ personal liability. ERABCO countered that it had fulfilled its obligations under the Marketing Agreement, and that MCDC had admitted the authenticity of relevant documents, allowing photocopies as evidence. The Court emphasized that factual findings are generally not revisited on certiorari unless clearly unsupported or based on speculation. It affirmed that the Marketing Agreement, which outlined ERABCO’s promotional and selling duties and the conditions for commission release, was clear and binding, and that ERABCO completed its obligations by facilitating sales of 202 units totaling over P140 million. MCDC’s argument that subsequent “buy-back” of units relieved it of payment obligations was rejected, as the sales were completed and proceeds released. However, the Court ruled that Olivares could not be held personally liable, since there was no clear evidence of bad faith, gross negligence, or conflict of interest. Consequently, the Court modified the CA decision by removing Olivares’ personal liability and ordered MCDC to pay ERABCO the remaining commission of P4,069,919.88 with legal interest as specified.

CASE DIGEST : PEOPLE v. XXX GR No. 254254 GAERLAN

 FACTS : The appeal resolves the conviction of the accused-appellant, XXX, who was found guilty by the Regional Trial Court (RTC) and affirmed by the Court of Appeals (CA) for two counts of Qualified Rape committed against his own minor daughter, AAA. The victim was between 13 and 15 years old during the alleged incidents. Specifically, XXX was convicted of Qualified Rape by Carnal Knowledge (for an incident in 2009 when the victim was 13) and Qualified Rape by Sexual Assault (for an incident in 2012 involving non-carnal acts). The RTC acquitted him of a third charge due to insufficient evidence. The courts found AAA's testimony credible and consistent, rejecting XXX's defense of denial and motive. A key legal point addressed by the CA was the duplicitous nature of the Information in the sexual assault case; however, the CA ruled that XXX waived his right to object to this defect because he failed to contest it before or during the trial. The CA affirmed the penalties of imprisonment for both convictions and modified the damages awarded in the Qualified Rape by Sexual Assault case, increasing the civil indemnity, moral damages, and exemplary damages from 30k to 100k each

ISSUE : WON XXX is guilty beyond reasonable doubt of (i) qualified rape by carnal knowledge in Criminal Case No. 158506; and (ii) qualified rape by sexual assault in Criminal Case No. 158508

HELD : The Supreme Court denied the appeal filed by the accused-appellant, XXX, thereby affirming his conviction for the sexual abuse of his minor daughter, AAA, but necessitated modifications to the designation and penalty for one of the crimes. In his appeal, XXX challenged his conviction for qualified rape by sexual assault, arguing that the Information was duplicitous and that the variance doctrine was improperly applied. The Court confirmed XXX's guilt beyond reasonable doubt for Qualified Rape through Sexual Intercourse (Criminal Case No. 158506), upholding the penalty of reclusion perpetua without eligibility for parole, plus P300,000.00 in damages, based on the established facts of carnal knowledge, the victim's minority, and his relationship as her father. For the second incident (Criminal Case No. 158508), the Court agreed with XXX that the Information, which charged both forced fellatio and sexual intercourse, was duplicitous; however, his failure to object before entering his plea constituted a waiver of this right, allowing the court to convict him of the offenses charged and proven during the trial.

The Court held that the correct crime for the second incident (forced fellatio and anal penetration when the victim was 15) was not Rape by Sexual Assault, but rather Lascivious Conduct under Section 5(b), Article III of R.A. No. 7610 (The Child Abuse Act), pursuant to controlling jurisprudence. Due to the relationship of the offender as the victim's father, which constitutes an aggravating circumstance, the Court imposed the maximum penalty of Reclusion Perpetua for Lascivious Conduct, along with specific damages: P75,000.00 each for civil indemnity, moral damages, and exemplary damages, plus a fine of P15,000.00. Finally, the Court dismissed XXX's arguments questioning the victim's credibility, reiterating that the victim's sole, credible testimony is sufficient to convict, and that the absence of a medical certificate or a delay in reporting the incident—especially when motivated by fear of the perpetrator—does not negate the commission of the crime, thereby confirming the factual findings of the lower courts against his defense of denial.