#1: Philippine Deposit Insurance Corp. vs.

Gidwani

Facts:

Manu Gidwani is charged with estafa and money laundering for using 86 individuals as dummies to
increase his protected deposit.

The rural banks owned by the Legacy Group of Companies were ordered closed and placed under
the receivership of the Philippine Deposit Insurance Corporation (PDIC).

Manu, together with his wife and the 86 individuals, claimed to be the owners of 471 deposit
accounts with the Legacy Banks and filed claims with PDIC.

The face value of the checks issued to the individuals were credited to a single account owned by
Manu in Rizal Commercial Banking Corporation (RCBC).

Issue:

Whether or not the Court of Appeals erred in taking cognizance of Manu Gidwani's petition for
certiorari under Rule 65.

Whether or not the Caparas Resolution became final and executory as to Manu Gidwani for failure
to file a motion for reconsideration.

Ruling:

The Court ruled in favor of PDIC and found probable cause to charge Manu Gidwani for estafa
through falsification under Art. 315 (2) (a) in relation to Arts. 172 (1) and 171 (4) of the Revised Penal
Code.

The Court reversed the decision of the Court of Appeals and reinstated the resolution of the
Department of Justice (DOJ) finding probable cause.

The Court held that the filing of a motion for reconsideration is not a mere formality but an
opportunity for the DOJ to correct errors in its findings and conclusions.

The Court also found that there is probable cause to charge Manu Gidwani based on the allegations
and evidence presented during the preliminary investigation.

Ratio:

The general rule is that courts are precluded from disturbing the findings of public prosecutors and the DOJ on the existence or non-
existence of probable cause, unless such findings are tainted with grave abuse of discretion.

The exception to this rule is when there is a grave abuse of discretion amounting to lack or excess of jurisdiction, in which case the courts
have the power to review the prosecutor's determination of probable cause.

In this case, the Court found that the DOJ Secretary did not commit grave abuse of discretion in reversing the earlier resolutions and
finding probable cause based on the evidence presented.

The Court emphasized that the filing of a motion for reconsideration is not a futile exercise and that the DOJ Secretary has the power and
discretion to make his own assessment of the evidence.

The Court further explained that the elements of estafa under Art. 315 (2) (a) of the Revised Penal Code are present in this case, and that
the allegations and evidence presented during the preliminary investigation are sufficient to establish probable cause.
#2: Republic of the Philippines vs. Asuncion

Facts:

The case involved Alexander Dionisio, a member of the PNP who shot and killed T/Sgt. Romeo
Sadang while responding to a complaint in Novaliches, Quezon City.

Dionisio was charged with homicide and the case was docketed as Criminal Case No. Q-91-23224 in
the RTC of Quezon City.

The respondent Judge questioned the jurisdiction of the RTC and dismissed the case, ordering it to
be refiled with the Sandiganbayan.

Issue:

Whether the term "regular courts" in Section 46 of Republic Act No. 6975 includes the
Sandiganbayan.

Ruling:

The term "regular courts" in Section 46 includes the Sandiganbayan.

The Sandiganbayan is considered a regular court within the framework of the judicial department.

Ratio:

Regular courts are those within the judicial department of the government, such as the Supreme
Court, Court of Appeals, Sandiganbayan, and Regional Trial Courts.

The Sandiganbayan, being a regular court with special jurisdiction over offenses committed by public
officials, is considered a regular court within the framework of the judicial department.

For the Sandiganbayan to have jurisdiction over a case, the offense must be committed by a public
officer or employee in relation to their office.

This requirement must be alleged in the information for the Sandiganbayan to have exclusive
original jurisdiction.

Application to the Case:

In the specific case of Dionisio, the information did not allege that the offense of homicide was
committed in relation to his office.

Therefore, the RTC had jurisdiction over the case.

However, the RTC was directed to conduct a preliminary hearing to determine if the offense was
committed in relation to Dionisio's office.

If it was, the case should be transferred to the Sandiganbayan.

If not, the RTC should proceed with the trial and render judgment.

Additional Points:

Any officer conducting a preliminary investigation of an offense committed by a public officer or

If the crime was not committed in relation to the office, the information should be filed with the
proper court.

The Sandiganbayan is a regular court with jurisdiction over criminal cases involving members of the
PNP, provided that the offense was committed in relation to their office.
#3: Carreon vs. Aguillon

Facts:

Petitioner Edgar T. Carreon filed a petition for annulment of judgment.

The case originated from a complaint for breach of contract, damages, and attorney's fees filed by
respondent Mario Aguillon against Carreon and his wife before the Regional Trial Court (RTC) of
Davao City.

The RTC declared the defendants in default and rendered a decision in favor of Aguillon.

A writ of execution was issued, and the defendants' property was levied and sold at a public auction.

The highest bidder was respondent Betty P. Lopez, who obtained a new title in her name.

Carreon later discovered the proceedings that transpired without their knowledge and participation.

Issue:

Whether the Court of Appeals (CA) correctly treated Carreon's motion for reconsideration as a
second motion for reconsideration and dismissed the annulment petition based on its finding that
the RTC acquired jurisdiction over the defendants.

Ruling:

The Supreme Court ruled in favor of Carreon.

The CA erred in treating Carreon's motion for reconsideration as a second motion for
reconsideration.

The motion was technically a first motion for reconsideration of the CA's ruling on the merits of the
annulment petition.

Therefore, the prohibition on filing a second motion for reconsideration did not apply.

The annulment petition had prima facie merit based on Carreon's argument of defective service of
summons.

The CA's dismissal of the annulment petition based on the presumption of regularity in the
performance of official duties was not justified.

The Supreme Court directed the CA to give due course to the annulment petition, issue the
necessary summons, and conduct a trial on its merits in accordance with the rules on annulment of
judgment.

Ratio:

The CA erred in treating Carreon's motion for reconsideration as a second motion for reconsideration because it was
technically a first motion for reconsideration of the CA's ruling on the merits of the annulment petition.

The prohibition on filing a second motion for reconsideration did not apply in this case.

The annulment petition had prima facie merit based on Carreon's argument of defective service of summons.

The CA's dismissal of the annulment petition based on the presumption of regularity in the performance of official duties
was not justified.

The Supreme Court directed the CA to proceed with the case, issue the necessary summons, and conduct a trial on its
merits in accordance with the rules on annulment of judgment.
#4: Madarang vs. Spouses Morales

Facts:

Petitioners, Juliet Vitug Madarang and Romeo Bartolome, represented by their attorneys-in-fact
Rodolfo and Ruby Bartolome, filed a petition for relief from judgment.

The trial court ordered the petitioners to pay the Spouses Morales P500,000.00 plus interest for a
loan that was not fully paid.

The petition for relief from judgment was filed beyond the 60-day period from notice of the
judgment and the 6-month period from the entry of judgment.

The petition for relief from judgment was dismissed outright.

The petitioners then filed a petition for certiorari with the Court of Appeals.

The petition for certiorari was denied for failure to file a motion for reconsideration of the order
denying the petition for relief from judgment.

The petitioners argued that they did not need to file a motion for reconsideration because the issues
raised in the petition for relief were pure questions of law.

The Court of Appeals found that the questions raised were not purely legal and dismissed the
petition for certiorari.

The Supreme Court affirmed the decision of the Court of Appeals.

Issue:

Whether the petition for relief from judgment was filed within the prescribed period.

Whether a motion for reconsideration was necessary before filing a petition for certiorari.

Ruling:

The petition for relief from judgment was filed out of time.

A motion for reconsideration was necessary before filing a petition for certiorari.

Ratio:

The petition for relief from judgment was filed beyond the 60-day period from notice of the
judgment and the 6-month period from the entry of judgment. Therefore, it was dismissed outright.

The failure of the petitioners' former counsel to file a timely notice of appeal was not excusable
negligence.

The Court agreed with the Court of Appeals that a motion for reconsideration was necessary before
filing a petition for certiorari.

The issues raised in the petition for relief were not purely legal, as they involved questions of fact.
Therefore, a motion for reconsideration should have been filed before resorting to a petition for
certiorari.

The Supreme Court denied the petition for review on certiorari and affirmed the resolutions of the
Court of Appeals.
#5: Johansen vs. Office of the Civil Registrar General

Facts:

Marietta Pangilinan Johansen, a Filipino citizen, seeks recognition of her foreign divorce in the
Philippines.

Marietta married Knul Johansen, a Norwegian national, in Norway in 2015.

They lived together in Norway until 2017 when they separated and Knul obtained a divorce decree
against Marietta under the Norwegian Marriage Act.

Marietta filed a petition for recognition of the foreign divorce decree in the Regional Trial Court
(RTC) of Malolos City, Bulacan.

She asked the court to order the Office of the Civil Registrar General (OCRG) and/or Department of
Foreign Affairs (DFA) to annotate the divorce decree on the Report of Marriage.

The RTC declared the petition sufficient in form and substance and ordered Marietta to furnish a
copy of the petition to the relevant authorities.

However, the RTC later dismissed the case for lack of jurisdiction.

Issue:

Whether the RTC erred in ruling that the venue under Rule 108 of the Civil Registry Law is
jurisdictional.

Ruling:

The Supreme Court denied the petition and affirmed the decision of the [Link] Court held that the
venue stated in Rule 108 of the Civil Registry Law is jurisdictional.

Rule 108 pertains to a special proceeding, and the specific provisions, particularly on venue, must be
observed to vest the court with jurisdiction. Marietta failed to comply with the requirements of Rule
108 as she filed the case in the RTC of Malolos City, Bulacan, instead of the RTC where the
corresponding civil registry is located (either Pasay City or Quezon City).

The local civil registrar of Pasay (in case the Report of Marriage is with the DFA) was not
[Link], the RTC of Malolos City, Bulacan had no authority to order the correction of
Marietta's civil status.

The dismissal of the case was without prejudice to the refiling of the petition in the proper court,
with full compliance with the specific requirements of Rule 108.

Ratio:

The venue stated in Rule 108 of the Civil Registry Law is jurisdictional.

Rule 108 pertains to a special proceeding, and the specific provisions, particularly on venue, must be
observed to vest the court with jurisdiction.

The petitioner failed to comply with the requirements of Rule 108 as she filed the case in the wrong
RTC and failed to implead the local civil registrar.

The dismissal of the case was without prejudice to the refiling of the petition in the proper court,
with full compliance with the specific requirements of Rule 108.
#6: Baterina vs. Musngi

Facts:

Salacnib F. Baterina filed a Petition for Certiorari and Prohibition to nullify the Resolutions of the
Sandiganbayan, Second Division.

The Resolutions denied Baterina's Request for Inhibition in a case involving the misuse of Priority
Development Assistance Fund (PDAF).

The case stemmed from PDAF cases filed against Mario L. Relampagos and other accused, including
Baterina, for the alleged misuse of PDAF funds.

The National Bureau of Investigation (NBI) filed a complaint against Baterina for charges involving
the misuse of his PDAF allotment for 2007.

The Office of the Ombudsman also filed a complaint against Baterina for the same PDAF allotment
and additional PDAF funds.

The Sandiganbayan issued a Joint Resolution finding probable cause to indict Baterina and other
accused for violation of Section 3 (e) of the Anti-Graft and Corrupt Practices Act and Malversation.
Baterina filed a Motion for Reconsideration, which was denied.

Informations were filed with the Sandiganbayan, and Baterina filed an Omnibus Motion seeking to
quash the Informations.

The Sandiganbayan denied the Omnibus Motion, and Baterina filed a motion for reconsideration,
which was also denied. Baterina then filed a Request for Inhibition, alleging bias, partiality, and
prejudice on the part of the Sandiganbayan justices. The Sandiganbayan denied the Request, and
Baterina filed a motion for reconsideration, which was also denied.

Issue:

Whether the Sandiganbayan justices acted with bias and grave abuse of discretion in denying
Baterina's Request for Inhibition.

Ruling:

The Supreme Court dismissed the petition, affirming the Resolutions of the Sandiganbayan. The
Court found that Baterina failed to substantiate his allegations of bias and prejudice on the part of
the Sandiganbayan justices.

The Court explained that the Sandiganbayan's inclusion of Baterina's name in a previous Resolution
was an inadvertent error, which was subsequently corrected.

The Court also noted that Baterina's Request for Inhibition was a voluntary act on the part of the
justices, and they had the discretion to decide whether to inhibit themselves from the case.

The Court further ruled that Baterina's allegations were based on conjectures and speculations, and
he failed to present strong and compelling evidence of actual bias and partiality.

Therefore, the Court found no grave abuse of discretion on the part of the Sandiganbayan justices in
denying Baterina's Request for Inhibition.
#7: Highpoint Development Corp. vs. Republic

Facts:

Highpoint Development Corporation filed an application for original registration of title over a parcel
of land in Cebu.

The land is described as Lot 7217, Barangay Lataban, Municipality of Lilo-an, Province of Cebu, with
an area of 43,919 square meters.

The petitioner presented several documents and witnesses to establish their ownership and
possession of the land.

The Regional Trial Court (RTC) granted the application, finding that all the requisites for registration
were present and that the land was alienable and disposable.

The Republic of the Philippines filed a motion for reconsideration, arguing that the petitioner failed
to prove the land's alienable and disposable status and their possession of the land for the required
period. The RTC denied the motion, prompting the Republic to appeal to the Court of Appeals (CA).

Issue:

Whether the petitioner provided sufficient evidence of the land's alienability and disposable status.

Whether the petitioner established possession of the land for the required period.

Ruling:

The CA reversed the RTC decision, finding that the petitioner failed to provide the necessary
evidence of the land's alienability and disposable status.

The CA held that the petitioner cannot solely rely on the certification from the Community
Environment and Natural Resources Office (CENRO) and must also present a certified true copy of
the original classification approved by the Department of Environment and Natural Resources
(DENR) Secretary.

The CA also disagreed with the RTC's finding of sufficient possession based on tax declarations. The
Supreme Court affirmed the CA's decision, stating that the petitioner erred in relying on a previous
ruling that cannot be considered a precedent.

The Court emphasized the requirement of presenting the DENR Secretary's certification and the
positive act of the government declassifying the land as alienable and disposable. The Court held
that the CENRO certification presented by the petitioner was insufficient to prove the land's status.

The Court also stated that the approval of an application based on substantial compliance falls
within the court's sound discretion.

Ratio:

The petitioner failed to provide sufficient evidence of the land's alienability and disposable status, as
they did not present the certified true copy of the DENR Secretary's original classification.

The CENRO certification alone is not enough to prove the land's status.

The court's approval of an application based on substantial compliance is within their discretion.
#8: Heirs of Borres vs. Abela

Facts:

Dispute over ownership of a property between the heirs of Faustina Borres and Victoria Villareiz-
Radjaie.

Case brought before the Regional Trial Court in Roxas City, with Judge Julius L. Abela presiding.

Borres heirs challenged the court's decision to grant Villareiz-Radjaie's petition for relief and to
suspend their attorney, Atty. Alberto Villarruz, from the practice of law.

In 1929, Court of First Instance of Capiz adjudicated Lot No. 3376 in favor of Faustina, Segundina,
Felisa, Micaela, Maria, and Sixto Borres.

Faustina died before World War II, and her children, including Victoria Villareiz-Radjaie, claimed sole
ownership over the property.

Borres heirs asserted their rights as heirs of Faustina and sought to cancel the title held by Villareiz-
Radjaie.

Borres heirs filed a complaint for partition and accounting against Villareiz-Radjaie, docketed as Civil
Case No. V-6186.

Case initially presided over by Judge Jose O. Alovera, who retired before rendering a decision.

Borres heirs presented their evidence ex-parte, and Judge Alovera issued a decision in their favor.

Later discovered that Judge Alovera had retired before rendering the decision, making it void.

Judge Abela nullified the decision and ordered the restoration of the property to Villareiz-Radjaie.

Borres heirs filed a petition for relief, which Judge Abela granted, setting aside the previous decision.

Judge Abela also suspended Atty. Villarruz from the practice of law for deceit, malpractice, and/or
misconduct.

Issue:

Whether the petitions should be dismissed for violation of the principle of hierarchy of courts.

Whether Judge Abela committed grave abuse of discretion in granting the petition for relief and
setting aside the previous decision.

Whether Judge Abela committed grave abuse of discretion in suspending Atty. Villarruz from the
practice of law.

Ruling:

Petitions should have been filed before the Court of Appeals, but due to the peculiar circumstances
and the length of time the case had been pending, the Supreme Court decided to resolve the case.

Previous decision rendered by Judge Alovera was void as it was made after his retirement, therefore
it could not attain finality and the Borres heirs could not claim rights under it.

Judge Abela did not commit grave abuse of discretion in granting the petition for relief and
suspending Atty. Villarruz from the practice of law.
Disciplinary proceedings for the suspension of an attorney are not a civil action, and the complainant
or the person who called attention to the attorney's alleged misconduct is not a party with a private
interest in the outcome.

Borres heirs' claims lacked merit, and the suspension of Atty. Villarruz was justified under the rules.

Ratio:

Petitions should have been filed before the Court of Appeals, but due to the peculiar circumstances
and the length of time the case had been pending, the Supreme Court decided to resolve the case.

Previous decision rendered by Judge Alovera was void as it was made after his retirement, therefore
it could not attain finality and the Borres heirs could not claim rights under it.

Judge Abela did not commit grave abuse of discretion in granting the petition for relief and
suspending Atty. Villarruz from the practice of law.

Disciplinary proceedings for the suspension of an attorney are not a civil action, and the complainant
or the person who called attention to the attorney's alleged misconduct is not a party with a private
interest in the outcome.

Borres heirs' claims lacked merit, and the suspension of Atty. Villarruz was justified under the rules.
#9: Montehermoso vs. Batuto

[ G.R. No. 246553, December 02, 2020 ]

MARILYN B. MONTEHERMOSO, TANNY B. MONTEHERMOSO, EMMA [Link] OLIVEROS,

Facts:

A lawsuit was filed, seeking cancellation of the title, reconveyance, and monetary damages.
Respondents Romeo Batuto and Arnel Batuto claimed that their 44,410 square meter (44,410 sq.m.)
plot was mistakenly included in petitioners' Marilyn B. Montehermoso, Tanny B. Montehermoso,
Emma B. Montehermoso Oliveros, Eva B. Montehermoso Carig, and Salvar B. Montehermoso OCT
No. 5781. In Decision2 dated March 8, 2015, the Regional Trial Court (RTC) found merit in the
respondents' claim and ordered the property to be reconveyed to them. Petitioners then filed a slew
of court actions in an attempt to reverse the trial court's decision, including:Petitioners first
challenged the trial court's decision, which was overturned by the Court of Appeals on August 5,
2016. It became final and executory on September 9, 2016,3 and the corresponding writs of
execution and demolition4 were issued.

Second, about a year later, Petitioner Tanny Montehermoso filed an independent petition for relief
from judgment, which was denied by the Court of Appeals in Resolution5 dated September 27, 2017.
Petitioner Tanny's motion for reconsideration was also denied in Resolution6 dated April 24, 2018.

Third, petitioners filed a petition for review on certiorari with the Court, which denied it in a
Resolution dated August 6, 2018 for failing to demonstrate that the Court of Appeals committed
reversible error justifying the Court's exercise of discretionary appellate jurisdiction.

However, the petitioners did not stop there. They filed another petition for annulment of judgment
before the Court of Appeals, this time claiming that the trial court lacked jurisdiction over the case.
The Court of Appeals dismissed the petition in its assailed Resolution8 dated February 13, 2019.
Petitioners' motion for reconsideration was also denied in accordance with Resolution9 dated April
10, 2019.

Finally, Petitioners have returned to the Court under Rule 45, challenging the Court of Appeals'
denial of their petition for annulment of judgment.

Petitioners have never stopped attacking the trial court's Decision dated March 8, 2015 before
various fora and through various modes of review for over five (5) years. Despite the fact that the
contested decision had long since reached finality on September 9, 201610 and had already been
implemented,11 petitioners have stubbornly refused to respect the immutability of this judgment,
trifling and playing around with the judicial process over and over again.

Issue: Whether petitioners have stubbornly refused to respect the immutability of this judgment as
they keep trifling and playing around the judicial process over and overagain

Held:

Every litigation must come to an end, which is a fundamental principle in the legal system. Access to the courts is ensured.
But there has to be a limit. Once a litigant'srights have been adjudicated in a valid and final judgment of a competent court,
he should not be given free rein to try again. Following suits should not be brought against the prevailing party. For, if
endless litigations are encouraged, unscrupulous litigants will proliferate, harming the administration of [Link]
should also stop making a mockery of the judicial system by attempting to resurrect the trial court's long settled and
implemented decision. Any violation of this injunction will result in appropriate sanctions.