SUGAR REGULATORY ADMINISTRATION vs ENCARNACION B. TORMON, ET AL.

FACTS:

ISSUE:

RULING: Factual findings of administrative bodies charged with their specific field of
expertise, are afforded great weight by the courts, and in the absence of substantial showing
that such findings were made from an erroneous estimation of the evidence presented, they
are conclusive, and in the governmental structure, should not be disturbed.

ROSENA FONTELAR OGAWA vs. ELIZABETH GACHE MENIGISHI

FACTS: On January 26, 2004, Ogawa filed a complaint for sum of money, damages, breach
of good human relation and unjust enrichment before the RTC against Menigishi, alleging that
the latter borrowed from her the amounts of P15,000.00, P100,000.00 and P8,000.00, in
September 2000, August 2001, and March 2003, respectively. Unable to pay, respondent
offered to sell her building and its improvements in Sorsogon City to petitioner for a
consideration of P1,500,000.00 with the agreement that her outstanding loans with petitioner
be deducted from the purchase price and the balance payable in installments. As partial
payment for the properties, petitioner remitted the following amounts to respondent: (a)
P150,000.00 through the account of her friendEmma Fulleros on October 23, 2003; and (b)
P250,772.90 by way of bank remittance to respondent's Equitable-PCI Bank Account on
December 8,2003. Having paid huge amounts and in order to protect her proprietary rights,
petitioner then demanded for the execution of the corresponding deedof sale, but respondent
backed out from the deal and reneged on her obligations. The RTC ruled in favor of Ogawa. It
disregarded the receipt presented by respondent as proof of petitioner's purported
indebtedness of 1,000,000.00 Yen. However, the CA gave probative value to the receipt for
1,000,000.00 Yen and held it sufficient to establish petitioner's indebtedness to respondent,
considering the purported admission of the former's counsel as well as petitioner's own failure
to specifically deny the same under oath as provided for under Section 8, Rule 8 of the Rules
of Court. Consequently, it granted respondent's counterclaim of 1,000,000.00 Yen. Finally,
having found both parties at fault, the CA deleted the awards of damages.

ISSUE: Whether or not the disputed receipt sufficiently established respondent's counterclaim
that petitioner owed her 1,000,000.00 Yen.

RULING: No.
A receipt is defined as a written and signed acknowledgment that money or good was
delivered or received. Exhibit 1, upon which respondent relies to support her counterclaim,
sufficiently satisfies this definition. However, while indubitably containing the signatures of
both parties, a plain reading of the contents of Exhibit 1 negates any inference as to the
nature of the transaction for which the 1,000,000 Yen was received and who between the
parties is the obligor and the obligee. What is apparent is a mere written and signed
acknowledgment that money was received. There are no terms and conditions found therein
from which a right or obligation may be established. Hence, it cannot be considered an
actionable document upon which an action or defense may be founded. It is settled that the
burden of proof lies with the party who asserts his/her right. In a counterclaim, the burden of
proving the existence of the claim lies with the defendant, by the quantum of evidence
required by law, which in this case is preponderance of evidence.

JESUS IS LORD CHRISTIAN FOUNDATION vs. MUNICIPALITY OF PASIG

FACTS: Court of Appeals affirmed the lower court’s decision of declaring respondent
municipality (now city) as having the right to expropriate petitioner’s property for the
construction of an access road. Petitioner argues that there was no valid and definite offer
made before a complaint for eminent domain was filed as the law requires (Art. 35, Rules and
Regulations Implementing the Local Government Code). Respondent contends that a letter to
purchase was offered to the previous owners and the same was not accepted.

ISSUE: Whether or not the absence of competent evidence that, indeed, the municipality
made a definite and valid offer is compliance with Section 19 of R.A. No. 7160.

RULING: Neither is the declaration in one of the whereas clauses of the ordinance that the
property owners were already notified by the municipality of the intent to purchase the same
for public use as a municipal road, a substantial compliance with the requirement of a valid
and definite offer under Section 19 of R.A. No. 7160. Presumably, the Sangguniang Bayan
relied on the erroneous premise that the letter of Engr. Reyes reached the co-owners of the
property. In the absence of competent evidence that, indeed, the respondent made a definite
and valid offer to all the co-owners of the property, aside from the letter of Engr. Reyes, the
declaration in the ordinance is not a compliance with Section 19 of R.A. No. 7160.

AKBAYAN CITIZENS ACTION PARTY vs. THOMAS G. AQUINO of Department of Trade

and Industry (DTI)

FACTS: The signing of the Japan-Philippines Economic Partnership Agreement (JPEPA) at

the sidelines of the Asia-Europe Summit in Helsinki in September 2006 was hailed by both
Japanese Prime Minister Junichiro Koizumi and Philippine President Gloria Macapagal Arroyo
as a “milestone in the continuing cooperation and collaboration, setting a new chapter of
strategic partnership for mutual opportunity and growth (for both countries).” JPEPA which
has been referred to as a ‘mega treaty’ is a comprehensive plan for opening up of markets in
goods and services as well as removing barriers and restrictions on investments. It is a deal
that encompasses even our commitments to the WTO.
The complexity of JPEPA became all the more evident at the Senate hearing conducted by
the Committee on Trade and Commerce last November 2006. The committee, chaired by
Senator Mar Roxas, heard differing views and perspectives on JPEPA. On one hand the
committee heard Government’s rosy projections on the economic benefits of JPEPA and on
the other hand the views of environmental and trade activists who raised there very serious
concerns about the country being turned into Japan’s toxic waste basket. The discussion in
the Senate showed that JPEPA is not just an issue concerning trade and economic relations
with Japan but one that touches on broader national development concerns.

ISSUE: Whether or not the documents and information being requested in relation to the
JPEPA exempted from the general rules on transparency and full public disclosure such that
the Philippine government is justified in denying access thereto.

RULING: In asserting that the balance in this instance tilts in favor of disclosing the JPEPA
documents, the dissent contents that the Executive has failed to show how disclosing them
after the conclusion of negotiations would impair the performance of its functions. The
contention, with due respect, misplaces the anus probandi. While, in keeping with the general
presumption of transparency, the burder is initially on the Executive to provide precise and
certain reasons for upholding its claim of privilege, once the Executive is able to show that the
documents being sought are covered by a recognized privilege, the burder shifts to the party
seeking information to overcome the privilege by a strong showing of need.

PEOPLE OF THE PHILIPPINES vs. SERVANDO SATURNO, ET AL.

FACTS: An appeal interposed by accused Servando Saturno and other accused from the
Decision of the RTC of San Jose City, Nueva Ecija for the crime of Multiple Murder. They
contented that prosecution witness Lucila Valdez, wife of the deceased Delfin Gregorio, was
not able to positively identify all the accused. They claim an alibi, that is, it was physically
impossible for them to be at the locus criminis at the time theincident occurred.

ISSUE: Whether or not Trial court was correct eventhough the prosecution's failure to prove
their guilt beyond resonable doubt.
RULING: NO.
In the case at bar, the prosecution was able to establish the fact of the killing; however, it
failed to prove that appellants perpetrated the crime. Where the prosecution has failed to
discharge the onus probandi for a pronouncement of guilt beyond reasonable doubt, the
constitutional presumption of innocence in favor of the accused will result in acquittal.
Equipoise Rule provides that where the evidence in a criminal case is evenly balanced, the
constitutional presumption of innocence tilts the scale in favor of the accused.

PEOPLE OF THE PHILIPPINES vs. LARRY ERGUIZA

FACTS: Larry Erguiza was charged with one count of rape. The victim’s father, testified that
the family of Erguiza went to their house after the case was filed, and initially offered P50,000
and later P150,000. Albina, the mother of Erguiza admitted that she did talk with the parents
of the victim, but according to her, it was the spouses who asked for P1M, later reduced to
P250,000, to settle the case and that she made a counter-offer of P5,000.00.

ISSUE: Whether or not can the offer of compromise given by the mother of the accused be
used as evidence of his guilt.

RULING: NO.
The alleged offer of the parents of appellant to settle the case cannot be used against
appellant as evidence of his guilt. Appellant testified that he did not ask his parents to settle
the case. Moreover, appellant was not present when the offer to settle was allegedly made.

An offer of compromise from an an unauthorized person cannot amount to an admission of

the party himself. Although the Court has held in some cases that an attempt of the parents of
the accused to settle the case is an implied admission of guilt, we believe that the better rule
is that for a compromise to amount to an implied admission of guilt, the accused should have
been present or at least authorized the proposed compromise. Moreover, it has been held
that where the accused was not present at the time the offer for monetary consideration was
made, such offer of compromise would not save the day for the prosecution.