Erectors, Inc.

, vs The Honorable National Labor Relations Commission and Danilo

Cris
G.R. No. 71177, February 29, 1988
Nature:
PETITION FOR APPEAL ON THE DECISION OF THE NLRC
Ponente:
SARMIENTO, J.
Facts:
The private respondent, Danilo Cris, a contract worker in Saudi Arabia, filed the case
with the Philippine Overseas Employment Administration (POEA) on February 27, 1984 for
the illegal termination of his contract of employment with the petitioner, Erectors, Inc. The
POEA, on September 27, 1984 ruled in favor of the private respondent and ordered the
petitioners to pay the former for damages. The decision of the POEA was received by the
petitioner on October 25, 1984.
On November 9, 1984, the petitioner filed a motion for reconsideration with the
respondent National Labor Relations Commission (NLRC). The appeal was dismissed by "for
having been filed out of time."
Thus, the petitioner, through counsel, alleged that the respondent NLRC committed
grave abuse of discretion in dismissing the case and affirmed that the appeal was
seasonably filed explaining that they have 10 working days to file their appeal citing Rule
XXIV Sec 1 and Rule XXV, Sec 2 of the1984 POEA Rules and Regulations.
Issue:
Whether or not the motion for reconsideration filed by the petitioner to the NLRC was filed
out of time?

Held:
YES. PETITION DISMISSED

Ratio Decidendi:
The Supreme Court ruled that the cited POEA rules (Rule XXIV and Rule XXV) do not
exist. The pertinent rule for this case is found in Book VII, Rule 5 of the 1984 POEA that the
aggrieved party may file for an appeal within 10 calendar days from receipt of the decision.
The Supreme Court also admonished the counsels of the petitioners for citing a
nonexistent rule with the warning that repetition of the same offense will be dealt more
severely.

De Roy vs Court of Appeals

No. L-80718, January 29, 1988
157 SCRA 757
SPECIAL CIVIL ACTION for Certiorari to review the resolutions of the

Nature:
Court of Appeals
Ponente:
CORTES, J.
Facts:

The firewall of a burned out building owned by petitioners collapsed and destroyed
the tailoring shop occupied by the family of private respondents, resulting in injuries and the
death of Marissa Bernal. The Regional Trial Court found petitioners guilty of gross negligence
and awarding damages to private respondents.
On appeal, the decision of the trial court was affirmed by the Court of Appeals on
August 17 1987, a copy of which was received by petitioners on August 25, 1987. On
September 9, 1987, the last day of the fifteen day period to file an appeal, petitioners filed a
motion for extension of time to file a motion for reconsideration, which was denied by the
appellate court on September 30, 1987 using the rule laid down in Habaluyas Enterprises,
Inc. v. Japzon. Petitioners filed their motion for reconsideration on September 24, 1987
stating that the rule enunciated in the Habaluyas case should not be made to apply to the
case at bar owing to the non-publication of the Habaluyas decision in the Official Gazette,
but this was again denied in the Resolution of October 27, 1987.
Issue:
1. Whether or not the 15 day period for filing a motion for reconsideration can be
extended?
2. Whether or not decisions of the Supreme Court should be published in the Official
Gazette before it becomes binding and effective?
Held:
1. NO. PETITION DENIED
2. NO. PETITION DENIED
Ratio Decidendi:
The Supreme Court finds that the Court of Appeals correctly applied the rule laid
down in Habaluyas Enterprises, Inc. v. Japzon stating that the fifteen day period for filing a
motion for reconsideration cannot be extended. Petitioners cannot seek refuge in the
ignorance of their counsel regarding said rule for their failure to file a motion for
reconsideration within the given period.
Also, there is no law requiring the publication of Supreme Court decisions in the
Official Gazette before they can be binding and as a condition to their becoming effective.

Nature:
Mandamus.
Ponente:

Province of Batangas vs Romulo

G.R. No. 152774, May 27, 2004
429 SCRA 736
SPECIAL CIVIL ACTION in the Supreme Court. Certiorari, Prohibition and
CALLEJO, SR., J.

Facts:
On December 7, 1998, then President Joseph Estrada issued Executive Order (E.O.)
No. 48 entitled ESTABLISHING A PROGRAM FOR DEVOLUTION ADJUSTMENT AND
EQUALIZATION. The Oversight Committee (referred to as the Devolution Committee in E.O.
No. 48) has been tasked to formulate and issue the appropriate rules and regulations
necessary for its effective implementation governing the equitable allocation and
distribution of said fund to the LGUs.
The Province of Batangas, represented by Governor Hermilando I. Mandanas, filed the
petition, to declare as unconstitutional and void certain provisions in the General
Appropriations Acts (GAA) of 1999, 2000 and 2001, insofar as they uniformly earmarked for
each corresponding year the amount of five billion pesos of the Internal Revenue Allotment
(IRA) for the Local Government Service Equalization Fund (LGSEF) and imposed conditions
for the release thereof, violate Section 6 Article X of Constitution and Section 18 and 286 of
Local Government Code of 1991 that mandates that the just share of the LGUs shall be
automatically released to them.
Issue:
1. Whether or not the petitioners has locus standi in the instant petition?
2. Whether or not the petition involves factual questions that are properly cognizable by
the lower courts?
3. Whether or not the present issue has been rendered moot or academic?
4. Whether or not the assailed provisions in the General Appropriations Act of 1999,
2000 and 2001 and the OCD Resolutions are unconstitutional?
Held:
1.
2.
3.
4.

YES. PETITION GRANTED

YES. PETITION GRANTED
YES. PETITION GRANTED
NO. PETITION GRANTED

Ratio Decidendi:
The Supreme Court holds that the petitioner has the locus standi to maintain the
present suit since it pertains to the LGUs share in the national taxes. Moreover, the
transcendental importance of the case, as it necessarily involves the application of the
constitutional principle on local autonomy, cannot be gainsaid. The nature of the present

controversy warrants the relaxation by this Court of procedural rules in order to resolve the
case.
Despite the fact that the assailed provisions have already been released and that a
new GAA is now operating. This Court has deemed it necessary to make a definitive ruling
on the matter in order to prevent its recurrence in future appropriations laws and that the
principles enunciated herein would serve to guide the bench, bar and public. Thus, the court
ruled that the assailed provisions contravene Section 6, Article X of the Constitution,
mandating the automatic release to the LGUs of their share in the national taxes.

Nature:
Ponente:

Engracia Obejera and Mercedes Intak vs Iga Sy

C.A. No. 34, April 29, 1946
76 SCRA 581
APPEAL from a judgment of the Court of First Instance of Batangas
JARANILLA, J.

Facts:

On December 13, 1941, plaintiffs and defendant sought refuge in the house of Leon
Villena, on account of the Japanese invasion of the Philippines. News having spread that the
Japanese were committing barbarous acts, plaintiffs and defendant decided to hide their
things and valuables in a dugout belonging to Villena.
On February 18, 1942, it was discovered that their money and things had been lost.
The defendant reported the loss of her valuables causing the arrest and investigation of
Villena, two others and the plaintiff Engracio Obejera, who were released shortly after,
except Engracio Obejera who was released only on April 19, 1912 after he, with his wife, had
consented to execute a transfer agreement with the defendant which was annulled by the
Court of First Instance in Batangas on the ground of force and intimidation.

Issue:
1. Whether or not the deed of transfer certificate executed by both parties is valid?
2. Whether or not Obejera is civilly liable to the assets that were lost by Sy?
Held:
1. NO. Decision AFFIRMED
2. NO. Decision AFFIRMED
Ratio Decidendi:
The Supreme Court ruled that the alleged deposit cannot be believed and is contrary
to the ordinary course of nature and the ordinary habits of life. Even if it was considered, any
obligation or liability arising therefrom was extinguished upon the loss. The evidence of
record shows that the plaintiffs were not in any way responsible for the loss of the
defendant's money and jewelry. It necessarily follows that the deed of transfer whereby the
plaintiffs promised to transfer their property cannot be held liable, is null and void for lack of
cause or consideration and lack of free consent.

Nature:
Ponente:

Chi Ming Tsoi vs Court of Appeals and Gina Lao Tsoi

G.R. No. 119190. January 16, 1997
266 SCRA 324
PETITION for review on certiorari of a decision of the Court of Appeals
TORRES, JR., J.

Facts:
On May 22, 1988, Gina Lao married Chi Ming Tsoi. Since their marriage until their
separation on March 15, 1989, there marriage was never consummated. Gina filed a petition
to annul their marriage on the ground of psychological incapacity with the Regional Trial
Court (RTC) in Quezon City. The RTC granted the annulment, which the Court of Appeals
affirmed.
Issue:
Whether or not the failure of the husband to consummate the marriage with his wife from
the time of the marriage until their separation constitute psychological incapacity under
Article 36 of the Family Code?
Held:
YES. Decision affirmed.
Ratio Decidendi:
The Supreme Court ruled that one of the essential marital obligations under the
Family Code is to procreate children based on the universal principle that procreation of
children through sexual cooperation is the basic end of marriage. Constant nonfulfillment of
this obligation will destroy the integrity of the marriage.
In the present case, the senseless and protracted refusal of the parties to fulfill the
above marital obligation is equivalent to psychological incapacity.

Nature:
Ponente:

Leouel Santos vs Court of Appeals and Julia Santos

G.R. No. 119190. January 16, 1997
266 SCRA 324
PETITION for review on certiorari of a decision of the Court of Appeals
VITUG, J.

Facts:

On September 20 1986 in the Municipal Trial Court of Iloilo City, Leouel Santos
(Petitioner) married Julia Santos (Respondent). On May 18, 1988, Julia left for the United
States to work as a Nurse despite Leouels pleas to dissuade her. Seven months after her
departure Julia called up Leouel for the first time and she promised to return home upon the
expiration of her contract. She never did.
In 1991, Leouel filed with the Regional Trial Court (RTC) of Negros Oriental a
complaint for voiding the marriage under Article 36 of the Family Code. The RTC dismissed
the complaint, and on appeal, the Court of Appeals affirmed the dismissal.
Issue:
Whether or not the failure of Julia to return home, or at the very least to communicate with
Leouel for more than five years constitute psychological incapacity under Article 36 of the
Family Code?
Held:
NO. Petition denied.
Ratio Decidendi:
The Supreme Court ruled that Psychological incapacity should refer to no less than
mental, not physical, incapacity that causes a party to be truly unable to understand the
basic marital covenants that concurrently must be assumed and discharged by the parties to
the marriage as expressed by Article 68 of the Family Code, these include their mutual
obligations to live together, observe love, respect and fidelity, and render help and support.
The intention of the law has been made to confine the meaning of psychological
incapacity to the most serious cases of personality disorders that demonstrate an utter

insensitivity or inability to give meaning and significance to the marriage. The psychological
condition must exist at the time of the marriage is celebrated.

Edward Te vs Rowena Yu-Te, Republic of the Philippines (oppositor)

G.R. No. 161793. February 13, 2009
579 SCRA 193
Nature:
PETITION for review on certiorari of a decision of the Court of Appeals
Ponente:
NACHURA, J.
Facts:
On January 1996, Edward Ngo Te met Rowena Yu. After developing a certain level of
closeness, in March 1996, both of them decided to elope despite Edwards initial refusal. On
April 23, 1996, Edward Ngo Te and Rowena Yu got married. After the marriage, they lived in
the house of latters uncle where Edward was treated like a Prisoner. Edward managed to
escape from the house and went back home to his family. In June 1996, Edward tried
convincing Rowena to live with him in his parents house but she refused. After that, they
decided to part ways.
Edward filed for annulment on January 18, 2000 in the Regional Trial Court of Quezon
City on the basis of Rowenas psychological incapacity. On July 30, 2001 the RTC declared
the marriage of the parties null and void on the grounds that both parties were
psychologically incapacitated. Subsequently, The Republic [represented by the Office of the
Solicitor-General (OSG)] filed its notice of appeal to the Court of Appeals and the trial courts
ruling was reversed for failure to prove the psychological incapacity of the respondent.
Petitioner filed for a motion for reconsideration but it was denied.
Issue:
Whether or not both parties are psychologically incapacitated to comply with the marital
obligations of marriage as stated under Article 36 of the Family Code?
Held:
YES. Petition Granted.
Ratio Decidendi:

The Supreme Court ruled that the psychological evaluation conducted produced the
findings that both parties are afflicted with personality disorders. Dependent Personality
disorder for the petitioner, and narcissistic and antisocial personality disorder for the
respondent. Due to the seriousness of the diagnosis and the gravity of the disorders
considered, the Court ruled that the marriage of the parties is null and void on ground of
both parties psychological incapacity.
Indeed, both parties who are afflicted with these personality orders cannot assume
the essential marital obligations of living together, observing love, respect, and fidelity and
rendering help and support under Article 68 of the Family Code..