ANDAYA, ARNIE D.

MODULE 1 CASE DIGEST EVIDENCE

Baguio Country Club Corp. v. National Labor Relations Commission

G.R. No. L-55624, [November 19, 1982], 204 PHIL 194-203)

FACTS:
On August 18, 1978, Baguio Country Club Corporation filed an application with the Ministry of
Labor in Baguio City to terminate the services of Jimmy Sajonas. The grounds for termination
included willful breach of trust, dishonesty, and other violations of club rules. Jimmy Sajonas
opposed the dismissal, claiming it was without justifiable grounds and violated his constitutional
right to security of tenure.

ISSUE:
Whether the evidence presented by the Baguio Country Club Corporation was sufficient to justify
the dismissal of Jimmy Sajonas.

RULING:
The labor arbiter and the National Labor Relations Commission (NLRC) initially ruled in favor of
Jimmy Sajonas, citing insufficiency of evidence to support the dismissal. However, the Supreme
Court reversed these decisions, stating that the evidence presented by the petitioner was not
properly considered by the labor arbiter and the NLRC. The court held that the summary
procedures used by the public respondents did not satisfy the requirements of justice and fair play.
Consequently, the Supreme Court granted the petition, set aside the decisions of the NLRC and the
labor arbiter, and ordered the Ministry of Labor and Employment to give the petitioner a clearance
to terminate the employment of Jimmy Sajonas.
***

Bustos v. Lucero
G.R. No. L-2068, [October 20, 1948], 81 PHIL 640-658

FACTS:
Dominador B. Bustos, the petitioner, was an accused in a criminal case. After being bound over
for trial by the Court of First Instance of Pampanga, Bustos filed a motion to remand the record of
the case to the justice of the peace court of Masantol. The purpose was to cross-examine the
complainant and her witnesses regarding their testimony, which led to the issuance of the arrest
warrant against him. The motion was denied, and Bustos sought relief from the Supreme Court.

ISSUE:
Whether the Court of First Instance of Pampanga erred in denying Bustos' motion to remand the
record to the justice of the peace court for cross-examination of the complainant and her witnesses.

RULING:
The Supreme Court dismissed the petition, ruling that the Court of First Instance did not act in
excess of its jurisdiction or abuse its discretion in denying the motion. The court held that the
justice of the peace did not err in refusing to grant the motion to return the record for the purpose
of cross-examination. The court emphasized that while section 11 of Rule 108 defines the bounds
of the defendant's right in the preliminary investigation, it does not restrict the authority of the
court to pursue actions reasonably calculated to bring out the truth.
***

Aldeguer v. Hoskyn
G.R. No. 1164, [September 17, 1903], 2 PHIL 500-503

FACTS:
Doña Petrona Inarda bought the land in question in 1855 from Don Pablo Garcia. Doña Petrona
lived on the land until her death in 1876, when Don Miguel Aldeguer, their grandfather, was
appointed guardian of Doña Petrona's four children, the present plaintiffs. In 1884, Don Manuel
Aldeguer sold the land to one Martinez, who sold it to the defendant, Henry Hoskyn, in 1887. The
court found that the declaration in the deed to Martinez was the only evidence that Don Manuel
had any title to the land.

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ISSUE:
Whether the judgment was supported by the findings of fact stated in the decision, particularly
regarding the existence of a contract of sale between Don Pablo and Doña Petrona based on parol
evidence.

RULING:
The Supreme Court denied the motion for a new trial and affirmed the judgment of the court below.
The court held that the parol evidence of the contract's existence was properly received after
preliminary proof of the written contract's record and its subsequent destruction. The court also
found that the recital in the deed to Martinez did not prove anything against the plaintiffs.
***

People v. Moner y Adam

G.R. No. 202206, [March 5, 2018]

FACTS:
Teng Moner y Adam was arrested on April 23, 2005, in Quezon City for the illegal sale of 3.91
grams of methylamphetamine hydrochloride. The arrest was conducted by the Las Piñas Police
Station Anti-Illegal Drugs Special Operation Task Force (SAIDSOTF) following a tip from an
arrested individual, Joel Taudil, who identified Moner as the source of the illegal drugs.

ISSUE:
Whether the evidence presented by the prosecution was sufficient to establish Moner's guilt beyond
reasonable doubt for the illegal sale of dangerous drugs.

RULING:
The Supreme Court dismissed the appeal for lack of merit and affirmed the decision of the Court
of Appeals, which upheld the conviction of Moner for violating Section 5, Article II (sale of
dangerous drugs) of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The
court found that the prosecution's evidence, including testimonies from police officers and the
chain of custody of the seized drugs, was sufficient to prove Moner's guilt beyond reasonable
doubt.
***

Commissioner of Internal Revenue v. Court of Appeals

298 SCRA 83 (1998) G.R. 124043

FACTS:
The Young Men's Christian Association of the Philippines, Inc. (YMCA), a non-stock, non-profit
institution, earned income from leasing a portion of its premises to small shop owners and
collecting parking fees. The Commissioner of Internal Revenue (CIR) issued an assessment against
YMCA for deficiency income tax, expanded withholding taxes, and withholding tax on wages.
YMCA protested the assessment, claiming tax exemption on the income derived from the lease of
its real property.

ISSUE:
Whether the income derived by YMCA from the rentals of its real property is subject to income
tax under the National Internal Revenue Code (NIRC) and the Constitution.

RULING:
The Supreme Court granted the petition, reversing the resolutions of the Court of Appeals and
reinstating its decision that the income derived by YMCA from the rentals of its real property is
subject to income tax. The court held that the income was not exempt from taxation as it was not
used directly for YMCA's charitable, religious, and educational purposes.
***

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ANDAYA, ARNIE D. MODULE 1 CASE DIGEST EVIDENCE

Villanueva v. Court of Appeals

294 SCRA 90 (1998) GR 127997

FACTS:
Almario Go Manuel filed a civil action for a sum of money against Felix Villanueva and his wife
Melchora Villanueva in 1991. The case involved a check dated June 30, 1991, in the amount of
P167,600.00 issued by Felix Villanueva, which was dishonored due to insufficiency of funds. The
trial court ruled in favor of Manuel, directing Felix to pay the amount of P167,600.00.

ISSUE:
Whether the Court of Appeals erred in affirming the trial court's decision, particularly regarding
the interest rate imposed on the amount due and the principal obligation of Felix Villanueva.

RULING:
The Supreme Court affirmed the decision of the Court of Appeals with a modification regarding
the rate of legal interest. The court ruled that the rate of legal interest to be paid is twelve percent
(12%) per annum from the time the complaint was filed until the finality of the decision. After the
decision becomes final and executory, the rate of twelve percent (12%) per annum shall be
additionally imposed on the total obligation until payment is satisfied.
***

Cruz v. People
303 SCRA 533 (1999) GR121422

FACTS:
Noel Cruz y Digma was arrested without a warrant on June 19, 1990, for illegal possession of a
.38 caliber revolver with six rounds of ammunition while waiting outside the Manila Pavilion Hotel
along U.N. Avenue, Manila. Assistant Prosecutor Tranquil P. Salvador, Jr. filed an information
against Cruz for violating Presidential Decree No. 1866. Cruz's parents filed a petition for habeas
corpus, but the trial court proceeded with the trial.

ISSUE:
Whether the trial court erred in admitting the prosecution's formal offer of evidence, denying
Cruz's demurrer to evidence, and denying his motion for reconsideration.

RULING:
The Supreme Court denied the petition and ordered the trial court to continue with the proceedings.
The court found that the trial court did not abuse its discretion in admitting the prosecution's
evidence and denying Cruz's motions.
***

Ferrer v. Carganillo
G.R. No. 170956, [May 12, 2010], 634 PHIL 557-593)

FACTS:
Felisa R. Ferrer filed four separate cases against Domingo Carganillo, Sergio Carganillo, Soledad
Agustin, and Marcelina Solis for ejectment and damages. The cases involved a 6,000-square meter
lot in Brgy. Legaspi, Tayug, Pangasinan, which was allegedly subleased without Felisa's consent.

ISSUE:
Whether the evidence presented by Felisa R. Ferrer was sufficient to establish her claim for
ejectment and damages against the respondents.

RULING:
The Supreme Court partially granted the petition. The court authorized the dispossession of
Domingo and Sergio Carganillo from the subject landholding. However, the complaints against
Soledad Agustin and Marcelina Solis were dismissed due to failure to establish their claims and
improper indication of the appealing party.
***

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People v. Caparas Jr. y Temporas

G.R. Nos. 121811-12, [May 14, 1998], 352 PHIL 686-699

FACTS:
Ramon Caparas, Jr. y Temporas and Jose Santos y Jordan were convicted by the Regional Trial
Court of Cabanatuan City for the crime of rape with homicide. The crime involved the rape and
murder of Maricris Fernandez, a 13-year-old girl, on January 1, 1994. The prosecution's case relied
heavily on circumstantial evidence, including the testimonies of two witnesses, Arnulfo Esmino
and Morimar Sandaan.

ISSUE:
Whether the circumstantial evidence presented by the prosecution was sufficient to establish the
guilt of Ramon Caparas, Jr. and Jose Santos y Jordan beyond reasonable doubt.

RULING:
The Supreme Court reversed the judgment of the Regional Trial Court and acquitted Ramon
Caparas, Jr. and Jose Santos y Jordan. The court found that the circumstantial evidence presented
was not sufficient to prove their guilt beyond reasonable doubt.
***

Guinea v. Vda. de Ramonal

G.R. No. L-38659, [February 20, 1975], 159 PHIL 426-431

FACTS:
The petitioners, represented by Betty Edmilao Vda. de Mercado as guardian-ad-litem, filed a case
against Matilde S. Vda. de Ramonal over Lot No. 2059 of the Cagayan de Oro cadastre. During
the trial, the petitioners presented eight witnesses, all testifying to the same point already covered
by the previous seven witnesses.

ISSUE:
The main issue was whether the testimony of the eighth witness was merely cumulative and not
corroborative, and whether the trial court was justified in disallowing this testimony.

RULING:
The Supreme Court dismissed the petition, ruling that the testimony of the eighth witness was
merely cumulative and not corroborative. The court found that the trial court was within its
prerogative to stop further testimony on the same point when the evidence was already sufficient.
The court also noted deficiencies and suppressions of facts in the petitioners' pleadings, as well as
their dilatory tactics, indicating that their petition was bereft of merit.
***

People v. Araneta
G.R. No. 137604, [July 3, 2000], 390 PHIL 306-317

FACTS:
Robert Araneta a.k.a. Gilbert Araneta, along with his co-accused Gerry Silva and Alexander
Gulane, was charged with the murder of Leo Latoja on December 21, 1995, in Navotas, Metro
Manila. The prosecution's case relied on testimonies from witnesses Estelita Latoja and Dr.
Cristina Preyra, who provided crucial evidence regarding the incident.

ISSUE:
Whether the evidence presented by the prosecution was sufficient to establish the guilt of Robert
Araneta beyond reasonable doubt for the crime of murder.

RULING:
The Supreme Court affirmed the decision of the trial court with modification. The court found
Robert Araneta guilty beyond reasonable doubt of the crime of homicide aggravated by abuse of
superior strength. He was sentenced to six years, four months, and ten days of prision mayor

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ANDAYA, ARNIE D. MODULE 1 CASE DIGEST EVIDENCE

minimum as minimum to eighteen years, two months, and twenty days of reclusion temporal
maximum as maximum.
***

H. D. Kneedler v. Paterno
G.R. No. L-1349, [December 29, 1949], 85 PHIL 183-192

FACTS:
H. D. Kneedler, in his capacity as liquidator of Kneedler Realty Co., filed a case against Simon
Paterno for the foreclosure of a mortgage on a parcel of land in Pasay (now Rizal City). Paterno
had purchased the land from Kneedler Realty Co. and mortgaged it to secure the balance of the
purchase price. The mortgage was duly annotated on the transfer certificate of title, which was
subsequently lost.

ISSUE:
Whether the trial court erred in exempting Paterno from paying interest during the years 1942 to
1944 and suspending the payment until the lifting of the moratorium, which was not pleaded and
invoked by Paterno.

RULING:
The Supreme Court affirmed the judgment of the trial court with costs against Paterno. The court
found two errors in favor of Paterno: (1) the exemption from paying interest during the years 1942
to 1944 without legal basis, and (2) the suspension of payment until the lifting of the moratorium,
which was not invoked by Paterno. However, since the plaintiff did not appeal from these errors,
the court was not justified in modifying the judgment in this respect.
***

Cometa v. Court of Appeals

G.R. No. 124062 (Resolution), [December 29, 1999], 378 PHIL 1187-1197

FACTS:
Reynaldo T. Cometa, in his capacity as President of State Investment House, Inc. (SIHI), accused
Reynaldo S. Guevarra of falsifying a public document, an Affidavit of Undertaking purportedly
signed by Cometa. SIHI and Cometa filed a criminal case against Guevarra, which was initially
dismissed by the Makati Provincial Fiscal office but later reinstated by the Department of Justice.
The case was eventually dismissed by the Regional Trial Court (RTC) for insufficient evidence.

ISSUE:
Whether the complaint against Cometa and SIHI for malicious prosecution stated a sufficient cause
of action.

RULING:
The Supreme Court granted the petitioners' motion for reconsideration and reversed the decision
of the Court of Appeals. The court dismissed the complaint against Cometa and SIHI for failure to
state a cause of action. The court found that the allegations in the complaint did not sufficiently
establish the elements of malicious prosecution, particularly the lack of probable cause and malice.
***

Grace Park International vs. Eastwest

G.R. No. 210606. July 27, 2016

FACTS:
Grace Park International Corporation and Woodlink Realty Corporation filed an Amended
Complaint for Injunction and Annulment of Foreclosure Sale against Eastwest Banking
Corporation, Allied Banking Corporation, and Security Banking Corporation. The complaint
alleged that the foreclosure proceedings were initiated without the written instructions from the
majority creditors, as required under the Mortgage Trust Indenture (MTI).

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ISSUE:
Whether the complaint against Grace Park International Corporation and Woodlink Realty
Corporation should be dismissed on the grounds of forum shopping and litis pendentia.

RULING:
The Supreme Court granted the petition and reversed the decision of the Court of Appeals. The
court reinstated Civil Case No. 543-M-2010 and remanded it to the Regional Trial Court of
Malolos City, Bulacan, Branch 15 for further proceedings.
***

Tantuico Jr. v. Republic of the Philippines

G.R. No. 89114, December 2, 1991

FACTS:
Francisco S. Tantuico, Jr. was included as a defendant in Civil Case No. 0035 before the
Sandiganbayan, which involved allegations of misappropriation and theft of public funds, plunder
of the nation's wealth, extortion, bribery, embezzlement, and other acts of corruption against
former President Ferdinand Marcos, Imelda Marcos, and Benjamin Romualdez. Tantuico filed a
motion for a bill of particulars, which was denied by the Sandiganbayan.

ISSUE:
Whether the Sandiganbayan acted with grave abuse of discretion in denying Tantuico's motion for
a bill of particulars and whether the respondents should be compelled to prepare and file a bill of
particulars.

RULING:
The Supreme Court granted the petition and annulled the resolutions of the Sandiganbayan dated
April 21, 1989, and May 29, 1989. The court ordered the respondents to prepare and file a bill of
particulars containing the facts prayed for by Tantuico within twenty days from notice. The court
also stated that if the respondents failed to submit the bill of particulars, the Sandiganbayan was
ordered to exclude Tantuico as a defendant in Civil Case No. 0035.
***

Blas v. Angeles-Hutalla
G.R. No. 155594, [September 27, 2004], 482 PHIL 485-508)

FACTS:
Rhodora G. Blas, a Filipino citizen, and Linda Angeles-Hutalla, a naturalized U.S. citizen, entered
into a contract for the sale of a residential lot in Mandaluyong, Metro Manila. Initially, they
executed an unnotarized deed of sale for PHP 250,000. Later, they executed a notarized deed of
sale for USD 40,000 and a Real Estate Purchase Contract and Receipt for Deposit (REPCRD).
Blas failed to make the required payments under the REPCRD, leading to a dispute.

ISSUE:
Whether Rhodora G. Blas could invoke Article 1592 of the New Civil Code to avoid rescission of
the contract despite failing to make the required payments and not consigning the amount due.

RULING:
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The
court ruled that Blas could not find refuge in Article 1592 of the New Civil Code because she failed
to tender the amount due and did not consign the same before the trial court. The court emphasized
that under Article 1256 of the New Civil Code, Blas would be released from liability only by
consigning the amount due after complying with the legal requirements.
***

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Trans-Pacific Industrial Supplies, Inc. v. Court of Appeals

G.R. No. 109172, [August 19, 1994]

FACTS:
Trans-Pacific Industrial Supplies, Inc. (Transpacific) filed a case against Associated Bank, alleging
that it had fully discharged its obligations and seeking specific performance and damages.
Transpacific had an unpaid balance of P492,100.00 representing interest, which it admitted. After
consulting with a lawyer, Transpacific opted to sue despite knowing that the interest claim could
not be recovered.

ISSUE:
Whether the award of attorney's fees in favor of Associated Bank was justified and whether
Transpacific's suit was unfounded.

RULING:
The Supreme Court denied the petition for lack of merit. The court found that Transpacific's claim
of full payment was not supported by the evidence, and its suit was an ill-advised attempt to
capitalize on the delivery of duplicates of promissory notes. The court affirmed the award of
attorney's fees under Article 2208 (4) and (11) of the Civil Code, finding the sum of P15,000.00
fair and equitable.
***

People v. Sood y Amatondin

G.R. No. 227394 , [June 6, 2018]

FACTS:
Norjana Sood y Amatondin was charged with violating Section 5, Article II of Republic Act No.
9165 (Comprehensive Dangerous Drugs Act of 2002) for allegedly selling five point eighty-five
(5.85) grams of Methylamphetamine Hydrochloride (Shabu) on January 28, 2009, in Quezon City.
The prosecution's case relied on testimonies from police officers and a confidential informant who
conducted a buy-bust operation.

ISSUE:
Whether the evidence presented by the prosecution was sufficient to establish the guilt of Norjana
Sood y Amatondin beyond reasonable doubt, particularly in light of procedural irregularities in the
handling of the seized drugs.

RULING:
The Supreme Court granted the appeal and acquitted Norjana Sood y Amatondin. The court found
that there were procedural irregularities in the inventory and photographing of the seized drugs,
and the testimonies of the police officers were conflicting. The court emphasized the importance
of complying with Section 21 of R.A. No. 9165, which requires the presence of certain witnesses
during the inventory and photographing of seized items. The court concluded that the integrity and
evidentiary value of the seized drugs were not properly preserved, leading to the acquittal of the
accused-appellant.
***

Stonehill v. Diokno
G.R. No. L-19550, (19 June 1967), 126 Phil 738-766

FACTS:
Harry S. Stonehill, Robert P. Brooks, John J. Brooks, and Karl Beck, along with their corporations,
were subjected to 42 search warrants issued by various judges upon the application of government
officers. These search warrants authorized the search of their offices, warehouses, and residences,
and the seizure of various documents, financial records, and other items. The warrants were issued
based on allegations of violations of Central Bank Laws, Tariff and Customs Laws, Internal
Revenue Code, and the Revised Penal Code.

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ISSUE:
Whether the search warrants were valid and whether the searches and seizures conducted were
constitutional.

RULING:
The Supreme Court held that the search warrants were null and void as they contravened the
Constitution and the Rules of Court. The court found that the warrants did not describe with
particularity the documents, books, and things to be seized, and that cash money, not mentioned in
the warrants, was actually seized. The court also noted that the warrants were issued to fish
evidence against the petitioners in deportation cases and that the searches and seizures were
conducted in an illegal manner. The court made the writ of preliminary injunction permanent,
ordering the return of the seized documents, papers, and cash money.
***

People v. Burgos y Tito

G.R. No. L-68955, (04 September 1986), 228 Phil 1-23

FACTS:
Ruben Burgos y Tito was charged with illegal possession of firearms in furtherance of subversion.
The case stemmed from an arrest made without a warrant based on information from an informant.
During the search, a homemade revolver and subversive documents were seized.

ISSUE:
Whether the evidence obtained through the warrantless arrest and search was admissible in court.

RULING:
The Supreme Court reversed the judgment of conviction and acquitted Ruben Burgos y Tito on
grounds of reasonable doubt. The court held that the search and seizure were conducted without a
valid warrant, violating the constitutional rights of the accused. Consequently, the evidence
obtained was excluded, and the accused was acquitted.
***

People v. Compacion y Surposa

G.R. No. 124442, (20 July 2001), 414 Phil 68-86

FACTS:
Armando S. Compacion, the Barangay Captain of Barangay Bagonbon, San Carlos City, Negros
Occidental, was charged with violating Section 9 of Republic Act No. 6425 (the Dangerous Drugs
Act of 1972) as amended by Republic Act No. 7659. The charge was for planting, cultivating, or
culture two full-grown Indian Hemp (marijuana) plants in his backyard.

ISSUE:
Whether the evidence obtained through the search and seizure was admissible in court, and
whether Armando S. Compacion was guilty beyond reasonable doubt of the crime charged.

RULING:
The Supreme Court reversed the decision of the Regional Trial Court and acquitted Armando S.
Compacion on grounds of reasonable doubt. The court found that the search and seizure were
conducted without a valid warrant, violating the constitutional rights of the accused. Consequently,
the evidence obtained was excluded, and the accused was acquitted.
***

Waterous Drug Corp. v. National Labor Relations Commission

G.R. No. 113271, [October 16, 1997], 345 PHIL 983-997

FACTS:
Antonia Melodia Catolico was employed as a pharmacist by Waterous Drug Corporation. She was
accused of various irregularities, including dispensing medicine to employees chargeable to their
accounts and negotiating with suppliers without consulting the Purchasing Department. The

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ANDAYA, ARNIE D. MODULE 1 CASE DIGEST EVIDENCE

company conducted an investigation and gathered evidence against her, which included
communications and documents.

ISSUE:
Whether the evidence obtained against Antonia Melodia Catolico was admissible in court, given
that it was allegedly obtained in violation of her constitutional rights of privacy of communication
and against unreasonable searches and seizures.

RULING:
The Supreme Court dismissed the petition and affirmed the decision and resolution of the National
Labor Relations Commission (NLRC), except for its reason for upholding the Labor Arbiter's
decision regarding the admissibility of evidence. The court set aside the NLRC's reason for
excluding the evidence, stating that the evidence was admissible and that the NLRC's decision was
affirmed on other grounds.
***

Pollo v. Constantino-David
G.R. No. 181881, [October 18, 2011], 675 PHIL 225-300

FACTS:
Briccio "Ricky" A. Pollo was a Supervising Personnel Specialist at the Civil Service Commission
(CSC) Regional Office No. IV and Officer-in-Charge of the Public Assistance and Liaison Division
(PALD). Following an anonymous letter-complaint, Chairperson Karina Constantino-David
formed a team to investigate and directed them to back up all files in the computers of the PALD
and Legal Divisions. The investigation revealed evidence of misconduct, leading to Pollo's
dismissal for dishonesty, grave misconduct, and other charges.

ISSUE:
Whether the evidence obtained from the search of Pollo's office computer was admissible in the
administrative case against him, given that it was allegedly obtained in violation of his
constitutional rights of privacy of communication and against unreasonable searches and seizures.

RULING:
The Supreme Court denied the petition for review on certiorari and affirmed the decision and
resolution of the Court of Appeals. The court ruled that the search of Pollo's computer was
reasonable and that the evidence obtained was admissible in the administrative case against him.
The court emphasized that the search was conducted in accordance with office practice and was
necessary to investigate the allegations of misconduct.
***

People v. Toledo
G.R. No. 28655 (August 6, 1928)

FACTS:
Eugenio Toledo was charged with the crime of homicide in connection with the death of Filomeno
Morales, who died during a bolo duel with Sisenando Holgado. The prosecution presented
witnesses who testified to Toledo's participation in the fight. The defense argued that Toledo was
not involved in the fight and only helped Holgado after the fight.

ISSUE:
Whether the evidence presented by the prosecution was sufficient to establish Toledo's guilt
beyond reasonable doubt, and whether the lower court erred in not admitting certain evidence
presented by the defense.

RULING:
The Supreme Court found that the evidence presented by the prosecution was sufficient to establish
Toledo's guilt beyond reasonable doubt. The court also ruled that the lower court did not err in not
admitting the affidavit of Sisenando Holgado (Exhibit 1) as evidence, as it was not properly

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authenticated. The court affirmed the judgment of the lower court, sentencing Toledo to
imprisonment for fourteen years, eight months, and one day.
***

Uniwide Sales Realty and Resources Corp. v. Titan-Ikeda Construction and Development
Corporation
G.R. No. 126619 (December 20, 2006)

FACTS:
Uniwide Sales Realty and Resources Corporation (Uniwide) entered into three construction
agreements with Titan-Ikeda Construction and Development Corporation (Titan) for various
projects. After the completion of the projects, Uniwide failed to pay Titan the full amount due,
leading to Titan filing a complaint for a sum of money. The case was initially suspended for
arbitration but was later re-filed with the Construction Industry Arbitration Commission (CIAC).

ISSUE:
Whether the evidence presented by Titan was sufficient to support its claims against Uniwide and
whether the decisions of the CIAC and the Court of Appeals were correct in awarding damages to
Titan.

RULING:
The Supreme Court denied the petition for review on certiorari and affirmed the decisions of the
CIAC and the Court of Appeals. The court found that the evidence presented by Titan was
sufficient to support its claims and that Uniwide failed to pay the full amount due for the completed
projects. The court also upheld the award of damages to Titan, including actual and exemplary
damages, as well as attorney's fees.
***

People v. Yatco
G.R. No. L-9181 (November 28, 1955)

FACTS:
Juan Consunji, Alfonso Panganiban, and an unidentified third person were charged with conspiring
to murder Jose Ramos. During the trial, the prosecution attempted to introduce extrajudicial
confessions made by Consunji and Panganiban. However, the defense objected, arguing that the
confessions were hearsay and inadmissible against Panganiban.

ISSUE:
Whether the extrajudicial confessions of Consunji and Panganiban could be admitted as evidence
against both defendants without prior proof of conspiracy.

RULING:
The Supreme Court found that the lower court committed a grave abuse of discretion by
completely excluding the prosecution's evidence on the alleged confessions. The court held that
the confessions could be admissible against Consunji himself, but not against Panganiban without
prior proof of conspiracy. The court emphasized that the prosecution must first establish conspiracy
through definite acts, conditions, and circumstances before introducing the confessions as evidence
against both defendants.
***

Gonzales v. Court of Appeals

G.R. No. L-37453 (May 25, 1979)

FACTS:
Rizalina Gabriel Gonzales filed a petition for review of the decision of the Court of Appeals, which
reversed the decision of the Court of First Instance of Rizal and allowed the probate of the last will
and testament of the deceased Isabel Gabriel. The will, which was typewritten in Tagalog,
designated Gonzales as the principal beneficiary and executrix. Lutgarda Santiago, another niece

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of the deceased, opposed the probate, arguing that the will was not executed and attested as
required by law.

ISSUE:
Whether the three attesting witnesses to the will were competent and credible, as required by
Article 820 of the Civil Code.

RULING:
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the
Court of Appeals. The court found that the evidence presented by the respondents was sufficient
to establish the competence and credibility of the attesting witnesses3. The court emphasized that
the attesting witnesses were competent and credible, and that the will was executed and attested as
required by law.
***

Bautista v. Sarmiento
G.R. No. L-45137 (September 23, 1985)

FACTS:
Fe J. Bautista and Milagros J. Corpus were charged with estafa for allegedly receiving jewelry
from Dr. Leticia C. Yap on consignment and failing to return the proceeds or the jewelry itself. The
prosecution presented Dr. Yap as its only witness. Bautista and Corpus filed a Motion to Dismiss,
arguing that the prosecution failed to prove their guilt beyond reasonable doubt.

ISSUE:
Whether the prosecution met its burden of proof and whether the evidence presented was sufficient
to establish the guilt of Bautista and Corpus beyond reasonable doubt.

RULING:
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the
Court of Appeals. The court found that the prosecution failed to establish the prior demand
necessary to prove misappropriation and that the evidence presented was not sufficient to meet the
burden of proof. As a result, the court upheld the denial of the Motion to Dismiss and allowed the
case to proceed.
***

People v. Dereco y Hayag

G.R. No. 243625 (December 2, 2020)

FACTS:
Jeffrey Dereco y Hayag was charged with the special complex crime of Robbery with Rape. On
August 26, 2009, while victim AAA was walking along Quirino Highway, Dereco and an
accomplice approached her. Dereco poked a knife at her while his accomplice took her belongings.
Dereco then dragged her to a vacant lot, where he sexually assaulted her.

ISSUE:
Whether the prosecution met its burden of proof to establish Dereco's guilt beyond reasonable
doubt for the crimes of robbery and rape.

RULING:
The Supreme Court affirmed the decision of the Court of Appeals, which upheld the conviction of
Jeffrey Dereco y Hayag. The court found that the prosecution successfully established Dereco's
guilt beyond reasonable doubt through the testimonies of the victim and other evidence presented
during the trial.
***

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People v. Solar y Dumbrique

G.R. No. 225595 (August 6, 2019)

FACTS:
Rolando Solar y Dumbrique was charged with the murder of Joseph Capinig y Mato. On March 9,
2008, Solar and his accomplice Mark Kenneth Solar allegedly attacked Capinig with a baseball
bat, causing fatal injuries. The prosecution presented the testimony of Ma. Theresa Capinig, the
victim's wife, who witnessed the attack, and the medical findings of Dr. Voltaire Nulud, who
conducted the postmortem examination.

ISSUE:
Whether the prosecution met its burden of proof to establish Solar's guilt beyond reasonable doubt
for the crime of murder, and whether the evidence presented was sufficient to support the
conviction.

RULING:
The Supreme Court affirmed the decision of the Court of Appeals, which upheld Solar's conviction
but downgraded the crime from murder to homicide due to insufficient allegations of the qualifying
circumstances in the Information. The court found that the prosecution's evidence, including the
eyewitness testimony and medical findings, was sufficient to establish Solar's guilt beyond
reasonable doubt.
***

Fortune Tobacco Corp. v. Commissioner of Internal Revenue

G.R. No. 192024 (July 1, 2015)

FACTS:
Fortune Tobacco Corporation filed a petition for review on certiorari under Rule 45 of the Rules
of Court, challenging the March 12, 2010 Decision of the Court of Tax Appeals En Banc (CTA En
Banc) and its April 26, 2010 Resolution in CTA EB Case No. 533. The case involved a claim for
refund of overpaid excise taxes for the period from June 1, 2004, to December 31, 2004.

ISSUE:
Whether the Court of Tax Appeals En Banc correctly applied the rules of evidence in affirming the
decision of the Former First Division of the Court of Tax Appeals (CTA Division) to grant Fortune
Tobacco Corporation's claim for refund of overpaid excise taxes.

RULING:
The Supreme Court denied the petition for review on certiorari and affirmed the decision of the
Court of Tax Appeals En Banc. The court found that the evidence presented by Fortune Tobacco
Corporation was sufficient to support its claim for refund of overpaid excise taxes. The court
emphasized the importance of a liberal construction of the rules of evidence to ensure that justice
is served and that taxpayers are not unjustly burdened with overpaid taxes.
***

Tayao v. Republic
G.R. No. 235682 (Notice), [January 22, 2018]

FACTS:
Diwa T. Tayao had been purchasing flour from BRW Import Distribution since 1997. To pay for
the flour delivered from January to May 2007, Tayao issued ten checks totaling P1,139,975.00.
These checks were dishonored by the banks due to insufficient funds or closed accounts. Despite
receiving a demand letter, Tayao failed to settle the amount.

Legal Proceedings: Beatriz White, BRW's proprietor, filed ten separate cases for violation of B.P.
22 against Tayao. Tayao pleaded "not guilty." The defense filed a demurrer, arguing that the
prosecution failed to overturn the presumption of innocence and that imprisonment for non-
payment of debt is unconstitutional. The MeTC granted the demurrer, finding no evidence that

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Tayao received notice of dishonor. The civil aspect of the case proceeded, and Tayao was held
liable for the face value of the checks. Tayao appealed to the RTC.

The RTC affirmed the MeTC's decision. It found that while Tayao issued the checks which were
dishonored, there was no proof she received notice of dishonor, essential to convict her under B.P.
22. However, on the civil aspect, the court ruled that Tayao failed to pay the checks' face value by
preponderance of evidence, amounting to P1,139,975.00.

The Court of Appeals (CA) ruled that the demand letter itself could be used as evidence to prove
civil liability, even if not sufficient for criminal liability. The CA explained that, unlike criminal
cases which require proof beyond a reasonable doubt, civil cases only need a preponderance of
evidence to prove notice.

ISSUE:
Whether the prosecution provided sufficient evidence (preponderance of evidence) to prove
Tayao's monetary obligation to BRW Import Distribution, despite the lack of proof beyond
reasonable doubt required for her criminal conviction under B.P. 22.

RULING:
The Supreme Court addressed the issue of whether the prosecution provided sufficient evidence
to establish Tayao's civil liability for the amount of the dishonored checks, despite her criminal
acquittal. The Court emphasized the distinction between the standards of proof required in criminal
cases (proof beyond reasonable doubt) and civil cases (preponderance of evidence).

The Supreme Court denied the petition and affirmed the decisions of the lower courts. The Court
highlighted that while Tayao was acquitted of the criminal charges due to the lack of proof beyond
reasonable doubt, this did not absolve her of civil liability. The Court ruled that the civil aspect of
the case required only a preponderance of evidence, which the prosecution successfully provided
to establish Tayao's monetary obligation to BRW. The Court found that the demand letter sent to
Tayao, even without the messenger's testimony, was sufficient to prove civil liability. The Court
also rejected Tayao's claim of double jeopardy, noting that it applies only to criminal proceedings
and not to civil cases.
***

Spouses Manalo v. Roldan-Confesor

G.R. No. 102358, November 19, 1992

FACTS:
Spouses Vicente and Gloria Manalo responded to a newspaper advertisement by Career Planners
Specialists International, Inc. (CPSI), seeking employment as a driver and tutor/baby sitter in Saudi
Arabia. After the interview and testing, they were hired with a monthly salary of US$350.00 each.
CPSI imposed a placement fee of P40,000.00, of which they paid P30,000.00 in cash and executed
a promissory note for the balance. However, CPSI did not issue a receipt for the placement fee.
Before their departure, Gloria discovered her position had been changed to domestic help, contrary
to her recruiter's assurance. After working for only 25 days, Gloria returned to Manila, followed
by Vicente due to unbearable working conditions. They sued CPSI for illegal exaction, false
advertisement, and other violations, demanding a refund and moral damages.

Legal Proceedings: The case was brought before the Philippines Overseas Employment
Administration (POEA), which initially suspended CPSI's license for illegal exaction. However,
on reconsideration, POEA reversed its decision, requiring clear and convincing evidence for such
suspension. The case was then appealed to the Supreme Court.

ISSUE:
Whether the POEA's requirement of clear and convincing evidence for the suspension of CPSI's
license was appropriate in this case.

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RULING:
The Supreme Court ruled that only substantial evidence was required to establish administrative
findings of fact, even if the determination may result in the suspension of a license. The Court
emphasized that requiring a higher degree of proof (clear and convincing evidence) was
unnecessary in this context. The Court reinstated the POEA's initial order suspending CPSI's
license for illegal exaction and ordered restitution to the Manalos.
***

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