7. Landbank vs CA, GR No.

118712, July 5, 1996

& DAR vs CA, GR No. 118745, July 5, 1996

Ratio:
When the law speaks in clear and categorical language,
there is no reason for interpretation or construction, but
only for application. Thus, recourse to any rule which
allows the opening of trust accounts as a mode of deposit
under Section 16(e) of RA 6657 goes beyond the scope of
the said provision and is therefore impermissible.

Facts:
 The case involves how the government pays “just
compensation” in expropriation proceedings.
 Petitioners filed their respective motions for
reconsideration contending mainly that, contrary to the
Court’s conclusion, the opening of trust accounts in
favor of the rejecting landowners is sufficient
compliance with the mandate of RA 6657.
 Sec. 16, RA 6657. Procedure for Acquisition of Private
Lands –
xxx xxx xxx
(e) Upon receipt by the landowner of the
corresponding payment or, in case of rejection or
no response from the landowner, upon deposit
with an accessible bank designated by the DAR of
the compensation in cash or in LBP bonds in
accordance with this Act, the DAR shall take
 immediate possession of the land and shall request .
. .”
 Moreover, it is argued that there is no legal basis
for allowing the withdrawal of the money
deposited in trust for the rejecting landowners
pending the determination of the final valuation of
their properties.

Issue:
Whether or not the opening of trust accounts is
sufficient compliance with the mandate of RA 6657.

Ruling:
No, the opening of trust accounts is not sufficient
compliance.

The provision is very clear and unambiguous,

foreclosing any doubt as to allow an expanded construction
that would include the opening of “trust accounts” within
the coverage of the term “deposit.” Accordingly, we must
adhere to the well-settled rule that when the law speaks in
clear and categorical language, there is no reason for
interpretation or construction, but only for application.
Thus, recourse to any rule which allows the opening of
trust accounts as a mode of deposit under Section 16(e) of
RA 6657 goes beyond the scope of the said provision and is
therefore impermissible.
Notes:
The rule-making power must be confined to details for
regulating the mode or proceedings to carry into effect the
law as it had been enacted, and it cannot be extended to
amend or expand the statutory requirements or to embrace
matters not covered by the statute. Any resulting
discrepancy between administrative regulations and
provisions of the law will always be resolved in favor of the
basic law.
8. South Pacific Sugar Corp. vs. CA
GR No. 180462, February 9, 2011

Facts:
 1999 – the government projected a shortage of some
500,000 metric tons of sugar due to the effects of El Nio
and La Nia phenomena.
 To fill the expected shortage and to ensure stable sugar
prices, then President Joseph Ejercito Estrada issued
Executive Order No. 87, Series of 1999, facilitating
sugar importation by the private sector.
 Section 2 of EO 87 created a Committee on Sugar
Conversion/Auction to determine procedures for sugar
importation as well as for collection and remittance of
conversion fee.
 Under Section 3 of EO 87, sugar conversion is by
auction and is subject to conversion fee to be remitted
by Sugar Regulatory Administration (SRA) to the
Bureau of Treasury.
 May 3, 1999 – the Committee on Sugar
Conversion/Auction issued the Bidding Rules providing
guidelines for sugar importation. Under the Bidding
Rules, the importer pays 25% of the conversion fee
within three working days from receipt of notice of the
bid award and the 75% balance upon arrival of the
imported sugar.
 The Bidding Rules also provide that if the importer fails
to make the importation or if the imported sugar fails to
 arrive on or before the set arrival date, 25% of the
conversion fee is forfeited in favor of the SRA, to wit:
“G. Forfeiture of Conversion Fee
G.1 In case of failure of the importer to make
the importation or for the imported sugar to arrive
in the Philippines on or before the Arrival Date,
the 25% of Conversion Fee Bid already paid shall be
forfeited in favor of the SRA. . .”
 Pursuant to the Bidding Rules, Sugar Mill paid 25% of
the conversion fee amounting to P14,340,000.00, while
Pacific Sugar paid 25% of the conversion fee
amounting to P28,599,000.00.
 As it turned out, Sugar Mill and Pacific Sugar (sugar
corporations) delivered only 10% of their sugar import
allocation, or a total of only 3,000 metric tons of sugar.
They requested the SRA to cancel the remaining
27,000 metric tons of sugar import allocation blaming
sharp decline in sugar prices. The sugar corporations
sought immediate reimbursement of the corresponding
25% of the conversion fee amounting
to P38,637,000.00.
 The SRA informed the sugar corporations that the
conversion fee would be forfeited pursuant to
paragraph G.1 of the Bidding Rules. The SRA also
notified the sugar corporations that the authority to
reconsider their request for reimbursement was vested
with the Committee on Sugar Conversion/Auction.

RTC:
  February 26, 2002 – the Sugar corporations filed a
complaint for breach of contract and damages in the
Regional Trial Court
 RTC held that paragraph G.1 of the Bidding Rules
contemplated delay in the arrival of imported sugar, not
cancellation of sugar importation. It concluded that the
forfeiture provision did not apply to the sugar
corporations which merely cancelled the sugar
importation.
 February 7, 2007 – Atty. Raul Labay, the deputized SRA
counsel, filed a notice of appeal.
 The sugar corporations moved to expunge the notice of
appeal on the ground that only the OSG, as the
principal counsel, can decide whether an appeal should
be made.
 The OSG pointed out that in its notice of appearance, it
authorized SRA counsel Atty. Labay to assist the OSG
in this case.
 RTC granted the motion to expunge the notice of
appeal. The OSG moved for reconsideration stressing
that the OSG ratified Atty. Labays filing of a notice of
appeal. The RTC denied the OSGs motion for
reconsideration. RTC granted the sugar corporations
motion for execution
CA:
 Aggrieved, the SRA filed in the Court of Appeals a
petition for certiorari under Rule 65 seeking to set aside
the RTCs orders
  The Court of Appeals held that the deputized SRA
counsel had authority to file a notice of appeal. The
appellate court thus directed the RTC to give due
course to the appeal that Atty. Labay timely filed.
 Dissatisfied with the decision of the Court of Appeals,
the sugar corporations filed in this Court a petition for
review on certiorari.

Issue:
Whether or not petitioners are entitled for
reimbursement of the paid conversion fee.
Ruling:
No, the petitioners are not entitled for the
reimbursement of the paid conversion fee.

Plainly and expressly, paragraph G.1 identifies two

situations which would bring about the forfeiture of 25% of
the conversion fee: (1) when the importer fails to make the
importation or (2) when the imported sugar fails to arrive in
the Philippines on or before the set arrival date.

Where the language of a rule is clear, it is the duty of

the court to enforce it according to the plain meaning of the
word. There is no occasion to resort to other means of
interpretation.
9. Cecilleville Realty and Service Corp. vs. CA
GR No. 120363, September 5, 1997

Summary:
The SC applied the law, RA 1199, as amended by RA
2263, according to its plain and obvious meaning, according
to its express terms. Verba Legis non est recedendum, or
from the word, only a tenant is granted to have a home lot
and the right to construct or maintain a house thereon.
It is a fundamental principle that once the policy or
purpose of the law has been ascertained, effect should be
given to it by the judiciary. This Court should not deviate
therefrom.
Facts:
 1976 – Sotero Pascual became a tenant of Jose A.
Resurrecion, president of Petitioner-corporation.
 When Sotero died, his wife Ana Pascual, succeeded
him in tenancy by operation of law. As such tenant,
she had a home lot and a house on the landholding.
 She was assisted in the cultivation of the land by her
son, private respondent Hermigildo Pascual, who also
occupies a portion of the landholding distinct from that
occupied by his mother.
 Petitioner sought to eject Respondent from the portion
occupied by his house but the latter, insisting that he is
entitled to occupancy since he is helping his mother in
the cultivation of the land, refused to vacate.
MTC:
  Petitioner instituted an ejectment suit against
Respondent before MTC.
 Finding no tenancy relationship between Petitioner
and Respondent, MTC ordered the latter to vacate the
land and pay attorney’s fees and the sum of PhP 500.00
monthly from the filing of the complaint.
RTC:
 RTC reversed the MTC and ordered that the case be
remanded to DARAB (Department of Agrarian Reform
Adjudication Board) for further adjudication.
 The court was of the opinion that Ana Pascual was
entitled to the help of her son in the cultivation,
consequently, her son cannot be simply ejected
without circumventing the law.
CA:
 The case was elevated to CA which affirmed RTC’s
decision on the basis of Sec. 5, RA 1199, as amended by
RA 2263, governing the relations of landlords and
tenants, which provides that
o A tenant is entitled to the aid and assistance of
immediate members of his family and other
persons who, though not tenants themselves,
are afforded the protection of law and security
of tenure accorded to the tenant.
 CA concluded that Respondent’s having a house on the
landholding is but an incident of tenancy.

Issue:
 Whether or not private respondent is entitled to
occupy the premises.

Ruling:
No, private respondent is not entitled to occupy the
premises.

As the Court sees it, the issue lies on the interpretation

of Section 22, paragraph 3, of Rep. Act No. 1199, as
amended by Rep. Act No. 2263. The pertinent section in
the provision is as follows:

“SEC. 22
 “x x x x x x x x x
 “(3) The tenant

shall have the right to demand for a home lot
suitable for dwelling . . . The tenant’s dwelling shall
not be removed from the lot already assigned to
him by the landholder . . . or unless the tenant is
ejected for cause, and only after the expiration of
forty-five days following such severance of
relationship or dismissal for cause.”

The law is unambiguous and clear. Consequently, it

must be applied according to its plain and obvious meaning,
according to its express terms. Verba legis non est
recedendum, or from the words of a statute there should be
no departure. As clearly provided, only a tenant is granted
the right to have a home lot and the right to construct or
maintain a house thereon.
 Here, private respondent does not dispute that he is not
petitioner’s tenant. In fact, he admits that he is a mere
member of Ana Pascual’s immediate farm household.
Under the law, therefore, we find private respondent not
entitled to a home lot. Neither is he entitled to construct a
house of his own or to continue maintaining the same
within the very small landholding of petitioner. To rule
otherwise is to make a mockery of the purpose of the
tenancy relations between a bona-fide tenant and the
landholder as envisioned by the very law.
10. Tabao vs Judge Espina
AM No. RTJ-96-1348, June 14, 1996

Ratio:
Respondent Judge should be sanctioned for digressing
from the regular course and procedure of rendering
judgment, which must be done only after both the
prosecution and the defense have rested their respective
cases; that a hearing is absolutely indispensable before a
judge can determine whether or not to grant bail; and that
the ruling in Simon did not alter, much less set aside the
State’s right to a hearing to oppose bail and neither did it
cure the defect of lack of a bail hearing in this case.

Facts:
 April 19, 1995 – when accused finished testifying as
the third counsel and last witness for the defense,
defense counsel, Atty. Lauro G. Noel made a
reservation to submit within 5 days documentary
evidence consisting of the accuseds alleged business
licenses and permits and the defenses formal offer of
exhibits, after which the defense would rest its case
 June 22, 1995 – Prosecution received a notice of
promulgation of judgment in said case. Prosecution
filed an urgent manifestation seeking to postpone
promulgation of judgment since the defense had not
submitted its documentary evidence, formal offer of
exhibits and rested its case. The prosecution also
 manifested its intention of adducing rebuttal evidence
to the documentary exhibits to be submitted.
 June 23, 1995 – Respondent nonetheless issued an
order reiterating the notice setting the date of
promulgation of judgment on June 27, 1995
 June 27, 1995 – Respondent promulgated a judgment
acquitting the accused
 July 4, 1995 – Petitioner, First Assistant City
Prosecutor for Tacloban City Leo C. Tabao, accused
Respondent, Judge Pedro S. Espina of RTC Br. 7,
Tacloban City, in a sworn complaint of:
A. Gross irregularity
B. Abuse of authority
C. Bias in favor of the accused
In handling and deciding Criminal Case No. 93-04-197,
PP vs Salvador Padernal, for violation of RA 6425
(Drug Pushing)
 July 21, 1995 – Regional State Prosecutor, Francisco Q.
Aurillo, Jr. manifested his desire to be a co-
complainant against Respondent, adding that he had
earlier assailed before the Court of Appeals an Order,
dated 22 April 1993, issued by respondent granting bail
to the accused in the same above-mentioned criminal
case without giving the prosecution a chance to
present evidence to oppose the grant of bail.
 The Court of Appeals in a decision dated 30 August
1994 annulled Respondent’s orders granting bail to the
accused and denying the prosecutions motion for
reconsideration of the order which granted bail.
  September 22, 1995, Respondent filed a comment on
the first complaint, arguing that:
1. He proceeded to decide the case without the
documentary evidence of the defense since such
documents were not submitted within the period
allowed
2. He is of the opinion that the documentary
evidence, consisting of business licenses and
permits, even if offered to show that accused is
gainfully employed, is immaterial to the innocence
or guilt of the accused
3. The official duty is presumed to have been
regularly performed unless the contrary is shown
4. His grant of bail to the accused in now allowed in
view of the ruling in People vs Simon
 February 6, 1996 - the Office of the Court
Administrator submitted to the Court a
recommendation to absolve respondent Judge Espina
from any administrative liability, based on the opinion
that respondents acts constitute an exercise of judicial
prerogative.

Issue:
Whether or not the respondent Judge is
administratively liable.

RULING:
Yes, the respondent Judge is administratively liable.
In People vs. Dacudao, the Court has stressed that a hearing
is absolutely indispensable before a judge can properly
determine whether the prosecution’s evidence is weak or
strong on the issue of whether or not to grant bail to an
accused charged with a heinous crime where the imposable
penalty is death, reclusion perpetua or life imprisonment.
Under the Rules of Court, a hearing for bail is mandatory to
afford the State its right to oppose the grant of bail.

In this case, hearing was not afforded to and the

prosecution is deprived of due process.
10-a. Galvez and Guy vs CA, GR No. 187919,
Asia United Bank vs. Guy, Leung, Guy, Galvez and Galvez,
GR No. 187979,
Guy, Leung and Galvez vs Asia United Bank, GR No.
188030, April 25, 2012

Summary:
In this case, the Court holds that AUB, being a
commercial bank, is not beyond the coverage of PD 1689.
The Court asserts that a bank is a corporation whose fund
comes from the general public and PD 1689 does not
distinguish the nature of the corporation. It requires,
rather, that the funds of such corporation should come
from the general public. This was highlighted by the third
“whereas clause” of the quoted law which states that the
same also applies to other “corporations/associations
operating on funds solicited from the general public.”
Facts:
 1999 – Radio Marine Network (Smartnet) Inc. (RMSI)
claiming to do business under the name Smartnet
Philippines and/or Smartnet Philippines, Inc. (SPI),
applied for an Omnibus Credit Line for various