Federation of Free Farmers vs CA

September 10, 1981

Facts: Four separate petitions of the respective parties concerned for the review of the decision of the Court of
Appeals in CA G.R. No. 47298-R, entitled Federation of Free Farmers, et al. vs. Victorias Milling Co., Inc., et al. of
August 12,1975.

The appellate court held that notwithstanding the provisions of Section 9, in relation to Section 1 of the Sugar Act of
1952, Republic Act 809, providing that of any increase in the share of the proceeds of milled sugarcane and
derivatives obtained by the planters from the centrals in any sugar milling district in the Philippines, 60% of said
increase shall correspond to and should be paid by the planters to their respective laborers, the laborers of the
planters affiliated to the Victorias Milling District who are members of or represented by the Federation of Free
Farmers, one of the petitioners, have not been fully paid their share thus provided by law, corresponding to crop
years 1955 to 1974, in spite of clear evidence in the record showing that the increase of 4% in the share of the
Planters, Victorias Milling District, corresponding to all the years since the enforcement of the aforementioned Act
had already been paid by petitioner Victorias Milling Co., Inc. to said planters. The Court of Appeals further found
that even the shares of the laborers corresponding to crop years 1952-1955, when by operation of the Act, the
increase was 10%, had not been paid. The appellate court rendered judgment holding the planters of the district and
Victorias Milling Co., Inc. jointly and severally liable to the said laborers for all said alleged unpaid amounts.

The four parties involved in the case were the FEDERATION, the PLANTERS (in behalf of all planters in the
Victorias district), two individual planters (Santos and Tirol), and Central (Victorias), and each of them filed
different assignment of errors on behalf of the ruling of the Court of Appeals.

Among these errors, the court had already resolved a number of these in relation to the case Asociacion de
Agricultores de Talisay-Silay, Inc. vs. Talisay-Silay Milling Co.

With regard to the case of the constitutionality of R.A. No. 809, it was held constitution as it was founded by the
legislation not only on police power but also on the social welfare mandates of the Constitution.

It was also stated in the ruling in Talisay-Silay that the prerequisite of absence of milling agreements for the
application of Sec.1 of the act does not refer exclusively to the expiration of the then existing contracts but even to
future failure of centrals and planters to enter into new contracts, and that in said new contracts, they could provide
for a ratio of sharing different from the stipulated in Sec. 1, provided that any increase of their share in the proceeds
of milling that the PLANTERS would get 60% thereof must be paid by them to their laborers.

Another issue resolved through the courts was the validity of the Amicable Settlement- Compromise Agreement
between Victorias and the Planters. It was present in such Agreement that the share of 60-40 between the company
and planters, respectively, were distributed and it was the planters who were to distribute the share of the laborers.

The question of how the laborers were compensated and the liability of the three groups to the laborers were now at
hand.

Issue/s:

Whether the CA is correct in holding that the LABORERS are entitled to the payment of 60% of the 4% increase
paid by VICTORIAS to the PLANTERS every crop year.
Whether VICTORIAS and the PLANTERS have a joint and several solidary liability on the amounts due to the
LABORERS.

Ruling:

In the first issue, the Supreme Court affirms the decision of the CA with regard to the payment of 60% of the 4%
increase to the LABORERS, every crop year, from 1955-56 to 1973-74, including the sum of P180,679.38 which
was a balance of the share unpaid to the Laborers (10% of their reserve actually intended for such laborers). This
was part of the 5 Million pesos due and paid to the laborers, according to the stipulation of the Amicable Settlement-
Compromise Agreement.

As for the second issue, the court states that R.A. 809, does not impose upon the centrals, whether expressly or
impliedly, any joint and several liability with the planters fro the share which the Act apportions for the laborers of
the planters, since it is the responsibility exclusively of the planters to pay their laborers after they have been given
by the central what is due them. The inherent nature of the obligation of the planters, that of paying their own
laborers, has never been from the inception of the sugar industry up to the present, solidary with the Centrals.

Manila Jockey Club v Games and Amusement Board 107 Phil 151

Facts:

 Republic Act No. 1502 increased the sweepstakes draw and races for PCSO from six to twelve, without
specifying the days on which they are to be run.
 To accommodate the additional races GAB resolved to reduce the number of Sundays assign to private
entities by six.
 Petitioner protested that the additional 6 races be held on the 12 Saturdays not reserved for any private
entity or particular charitable institution or any other day of the week besides Sunday, Saturday and legal
holiday

Issue:

 Does the petitioner have vested rights on the unreserved Sundays

 Whether or not the additional races must be inserted in club races

Held:

 The appellant has no vested right to the unreserved Sundays, the wordings of Sec 4 RA 309 as amended by
RA 983 are merely permissive since the GAB reserves the right to determine the holding of any event

 In the interpretation of a legal document, especially a statute, unlike in the interpretation of an ordinary
written document, it is not enough to obtain information to the intention or meaning of the author or
authors, but also to see whether the intention or meaning has been expressed in such a way as to give it
legal effect and validity. The purpose of the inquiry, is not only to know what the author meant by the
language he used, but also to see that the language used sufficiently expresses that meaning.
  The language of Republic Act No. 1502 in authorizing the increase, clearly speaks of regular sweepstakes
draws and races. If the intention were to authorize additional sweepstakes draws only in which could be
inserted in the club races, the law would not have included regular races; and since regular sweepstakes
races were specifically authorized, and it would be confusing, inconvenient, if not impossible to mix these
sweepstakes races with the regular club races all on the same day (and it has never been done before), the
conclusion seems inevitable that the additional sweepstakes draws and races were intended to be held on a
whole day, separate and apart from the club races.

Aisporna v. CA [GR L-39419, 12 April 1982 (113 SCRA 459)]

Facts: A Personal Accident Policy was issued by Perla Compania de Seguros, through its authorized agent Rodolfo
Aisporna, for a period of 12 months with the beneficiary designated as Ana M. Isidro. The insured died by violence
during lifetime of policy. Mapalad Aisporna participated actively with the aforementioned policy.

For reason unexplained, an information was filed against Mapalad Aisporna, Rodolfo’s wife, with the City Court of
Cabanatuan for violation of Section 189 of the Insurance Act, or acting as an agent in the soliciting insurance
without securing the certificate of authority from the office of the Insurance Commissioner. Mapalad contends that
being the wife of true agent, Rodolfo, she naturally helped him in his work, as clerk, and that policy was merely a
renewal and was issued because Isidro had called by telephone to renew, and at that time, her husband, Rodolfo, was
absent and so she left a note on top of her husband’s desk to renew. The trial court found Mapalad guilty. On appeal
the trial court’s decision was affirmed by the appellate court.

Issue: Whether Mapalad Aisporna is an insurance agent within the scope or intent of the Insurance Act

Held: Legislative intent must be ascertained from a consideration of the statute as a whole. The particular words,
clauses and phrases should not be studied as detached and isolated expressions, but the whole and every part of the
statute must be considered in fixing the meaning of any of its parts and in order to produce harmonious whole. In the
present case, the first paragraph of Section 189 prohibits a person from acting as agent, subagent or broker in the
solicitation or procurement of applications for insurance without first procuring a certificate of authority so to act
from the Insurance Commissioner; while the second paragraph defines who is an insurance agent within the intent of
the section; while the third paragraph prescribes the penalty to be imposed for its violation. The appellate court’s
ruling that the petitioner is prosecuted not under the second paragraph of Section 189 but under its first paragraph is
a reversible error, as the definition of insurance agent in paragraph 2 applies to the paragraph 1 and 2 of Section 189,
which is “any person who for compensation shall be an insurance agent within the intent of this section.” Without
proof of compensation, directly or indirectly, received from the insurance policy or contract, Mapalad Aisporna may
not be held to have violated Section 189 of the Insurance Act.

Chinabank v Ortega
GR. L-34964
Facts:
On December 17, 1968 Vicente Acaban filed a complaint in the court a quo against Bautista Logging Co., Inc., B &
B Forest Development Corporation and Marino Bautista for the collection of a sum of money. Upon motion of the
plaintiff, the court declared the defendants in default for not answering within the prescribe period. To satisfy the
judgment, the plaintiff sought for the garnishment of the bank deposits of the defendants with the China Banking
Corporation. Consequently, a notice of garnishment was issued by the deputy sheriff of the trial court and served on
the bank’s cashier. The bank cashier, replied in the negative. In the reply, he invited the attention of the sheriff to
RA 1405. The plaintiff then filed a motion to cite the cashier for contempt of court. The trial court, despite having
denied the motion, ordered that the cashier confirm whether or not the defendants have existing deposit in their
bank. The cashier moved to reconsider but was denied and, subsequently, he was ordered to comply with the order
of the court within 10 days, otherwise, he would be arrested. Hence this petition.
Issue:
Whether or not china bank may validly refuse to comply with a court process garnishing the bank deposit of the
debtor by invoking the provisions of RA 1405.
Held:

The prohibition against examination of or inquiry into a bank deposit under Republic Act 1405 does not preclude its
being garnished to insure satisfaction of a judgment. In the present case, there was no inquiry as to how much the
actual deposits are, the only inquiry that the court had was whether or not there are deposits of the then defendants in
China bank

Board of Administrators of the PVA v. Bautista

GR L-37867, 22 February 1982 (112 SRCA 59)First Division, Guerrero (p): 5 concurring

Facts:
Calixto Gasilao was a veteran in good standing during the last World War that took activeparticipation in the
liberation drive against the enemy, and due to his military service, he wasrendered disabled. The Philippine Veterans
Administration, formerly the Philippine Veterans Board,(now Philippine Veterans Affairs Office) is an agency of
the Government charged with theadministration of different laws giving various benefits in favor of veterans and
their orphans/orwidows and parents. On July 23, 1955, Gasilao filed a claim for disability pension under Section 9
of Republic Act 65, with the Philippine Veterans Board, alleging that he was suffering from PulmonaryTuberculosis
(PTB), which he incurred in line of duty. Due to Gasilao’s failure to complete hissupporting papers and submit
evidence to establish his service-connected illness, his claim wasdisapproved by the Board on 18 December 1955.
On 8 August 1968, Gasilao was able to complete hissupporting papers and, after due investigation and processing,
the Board of Administrators found outthat his disability was 100% thus he was awarded the full benefits of section 9
of Republic Act 65.Later on, Republic Act 5753 was approved on 22 June 1969, providing for an increase in the
basicpension and additional pension for the wife and each of the unmarried minor children. Gasilao’smonthly
pension was, however, increased only on 15 January 1971, and by 25% of the increasesprovided by law, due to the
fact that it was only on said date that funds were released for thepurpose, and the amount so released was only
sufficient to pay only 25% of the increase. On 15January 1972, more funds were released to implement fully
Republic Act 5753 and allow payment infull of the benefits thereunder from said date.In 1973, Gasilao filed an
action against the Board to recover the pension, which he claims he isentitled to, from July 1955, when he first filed
his application for pension, up to 1968 when his pensionwas finally approved. The Board contends, however, based
on Section 15 of Republic Act 65, thatsince the section impliedly requires that the application filed should first be
approved by the Board of Administrators before the claimant could receive his pension, therefore, an award of
pension benefitsshould commence from the date of approval of the application.

Issue:
Whether Gasilao is entitled to the pension from 1955 instead of from 1968.

Held:
As it is generally known, the purpose of Congress in granting veteran pensions is to compensatea class of men who
suffered in the service for the hardships they endured and the dangers theyencountered, and more particularly, those
who have become incapacitated for work owing to sickness,disease or injuries sustained while in line of duty. A
veteran pension law is, therefore, a governmentalexpression of gratitude to and recognition of those who rendered
service for the country, especiallyduring times of war or revolution, by extending to them regular monetary aid. For
this reason, it is thegeneral rule that a liberal construction is given to pension statutes in favor of those entitled
topension. Courts tend to favor the pensioner, but such constructional preference is to be consideredwith other
guides to interpretation, and a construction of pension laws must depend on its ownparticular language. In the
present case, Republic Act 65 is a veteran pension law which must beaccorded a liberal construction and
interpretation in order to favor those entitled to rights, privileges,and benefits granted thereunder, among which are
the right to resume old positions in government,educational benefits, the privilege to take promotion examinations, a
life pension for the incapacited,pension for widow and children, and hospitalization and medical benefits. Upholding
the Board that the
pension awards are made effective only upon approval of the application, this would be dependentupon the
discretion of the Board which had been abused in this case through inaction extending for 12years. Such stand,
therefore does not appear to be, or simply is not, in consonance with the spirit andintent of the law. Gasilao’s claim
was sustained.The Supreme Court modified the judgment of the court a quo, ordering the Board of Administrators
of the Philippine Veterans Administration (now the Philippine Veterans Affairs Office) to make Gasilao’spension
effective 18 December 1955 at the rate of P50.00 per month plus P10.00 per month for eachof his then unmarried
minor children below 18, and the former amount increased to P100.00 from 22June 1957 to 7 August 1968; and
declaring the differentials in pension to which said Gasilao, his wifeand his unmarried minor children below 18 are
entitled for the period from 22 June 1969 to 14January 1972 by virtue of Republic Act 5753 subject to the
availability of Government fundsappropriated for the purpose.

PERFERCTO FLORESCA VS PHILEX MINING CORPORATION

FACTS:

On June 28, 1967, some employees of Philex Mining Corporation died as a result of the cave-in that buried
them in the tunnels of the copper mine (Tuba, Benguet) during underground operations. Allegedly, Philex was in
violation of government rules and regulations for negligently and deliberately failing to take the required precautions
for the protection of the lives of its men working underground.
The Petitioners (Floresca et al) are the heirs of the deceased employees of Philex Mining Corporation.
Petitioners moved to claim their benefits pursuant to the Workmen’s Compensation Act before the
Workmen’s Compensation Commission. They also petitioned before the regular courts and sued Philex for
additional damages.
Philex invoked that they can no longer be sued because the petitioners have already claimed benefits under
the WCA.

ISSUE: Whether or not Floresca et al can claim benefits and at the same time sue.

HELD:

Under the law, Floresca et al could only do either one. If they filed for benefits under the WCA then they
will be prohibited from proceeding with a civil case before the regular courts. On the contrary, if they sued before
the civil courts then they would also be prohibited from claiming benefits under the WCA.
The SC however ruled that Floresca et al are excused from this deficiency due to ignorance of the fact. Had
they been aware of such then they may have not availed of such a remedy. The SC ruled that the dismissal of the
case in the lower court be reversed and case is remanded for further proceedings.
However, if in case the petitioners win in the lower court, whatever award may be granted, the amount
given to them under the WCA should be deducted. The SC emphasized that if they would go strictly by the book in
this case then the purpose of the law may be defeated. (Refer to excerpt below)

“WHEREFORE, THE TRIAL COURT’S ORDER OF DISMISSAL IS HEREBY REVERSED AND SET
ASIDE AND THE CASE IS REMANDED TO IT FOR FURTHER PROCEEDINGS. SHOULD A GREATER
AMOUNT OF DAMAGES BE DECREED IN FAVOR OF HEREIN PETITIONERS, THE PAYMENTS ALREADY
MADE TO THEM PURSUANT TO THE WORKMEN’S COMPENSATION ACT SHALL BE DEDUCTED. NO
COSTS.”

Justice Gutierrez dissenting

No civil suit should prosper after claiming benefits under the WCA. If employers are already liable to
pay benefits under the WCA they should not be compelled to bear the cost of damage suits or get insurance for that
purpose. Theexclusion provided by the WCA can only be properly removed by the legislature NOT the SC.
 Republic of the Philippines v. CA and Molina
G.R. No. 108763
February 13, 1997
Panganiban, J.

FACTS
Respondent Roridel Molina married Reynaldo Molina on April 14, 1985. After a year of marriage,
Reynaldo showed signs of “immaturity and irresponsibility” as a husband and a father exhibited by his preference to
spend time with friends, squandering money, dependence on his parents and dishonesty involving finances.
Inevitably, this resulted in quarrels and by March 1987, Roridel quit her job and moved in with her parents in
Baguio. Reynaldo left her and their child a few weeks thereafter.
On Aug. 16, 1990, Roridel filed a verified petition for declaration of nullity of marriage on the grounds of
psychological incapacity of the husband. The trial court declared the marriage void, which the CA affirmed in toto;
hence, the petition for certiorari.

ISSUE
Whether there is psychological incapacity
HELD
No. The case of Roridel and Reynaldo merely constituted incompatibility among the estranged spouses.
The law intended to confine the meaning of psychological incapacity only to the most serious cases of personality
disorders that must have existed at the time marriage is celebrated. Irreconcilable differences or conflicting
personalities are not incapacities that would hinder the fulfillment of the essential marital obligations of the parties.
The characteristics of gravity, judicial antecedence and incurability are not present in the case.
Due to the improper interpretations and applications arrived at by the lower courts on this particular issue,
the SC found it wise to construe the law and lay down guidelines in interpretation and application of Art. 36. Here,
the SC sought the help of two amici curiae – considered an external aid in statutory construction. The guidelines set
forth are thus: (1) the burden of proof belongs to the plaintiff; (2) the root cause of psychological incapacity must be
medically or clinically identified, alleged in the complaint, sufficiently proven by expert, and clearly explained in
the decision; (3) the incapacity must be proven to be existing at the time of the celebration of marriage; (4) the
incapacity must be medically or clinically permanent or incurable; (5) such illness must be grave enough to disable
fulfillment of essential marital obligations; (6) the essential marital obligation must be embraced by Articles 68 to 71
of the Family Code as regards husband and wife, and Articles 220 to 225 of the same code as regards parents and
their children; (7) interpretation made by the National Appellate Matrimonial Tribunal of the Catholic Church are to
be given great weight; and (8) the fiscal and the Solicitor-General must appear as counsel for the State.