Case Title: People of the Philippines v.

Efren Agao y Añonuevo

G.R. No. 248049, October 04, 2022

Doctrine:
In rape cases involving penile penetration, the crime is consummated upon any
penetration, however slight, of the labia majora. Mere contact with the external genitalia is
insufficient.

Facts:
Efren Agao, the live-in partner of AAA's mother, was charged with two counts of
statutory rape. AAA testified that Agao molested her in 2010 (age 10) and 2012 (age 13),
penetrating her labia majora with his penis on both occasions, though not achieving full vaginal
penetration. The RTC and Court of Appeals convicted Agao of two counts of statutory rape,
sentencing him to reclusion perpetua and ordering him to pay damages.

Issues:
1. Is full penile penetration necessary for consummated rape?
2. Did the Court of Appeals correctly affirm the RTC's decision finding Agao guilty of
two counts of statutory rape?

Ruling: The Supreme Court affirmed that full penetration isn't required for consummated rape;
penetration of the labia majora suffices. The Court upheld the 2010 conviction for consummated
statutory rape due to the penetration of the labia majora. However, regarding the 2012 incident,
the Court modified the conviction to simple rape, as the evidence did not fully support a statutory
rape charge given AAA's age at the time.
Case Title: Bohol Wisdom School, Dr. Simplicio Yap Jr., and Raul H. Deloso v. Miraflor
Mabao
G.R. No. 252124, July 23, 2024

Doctrine:
Premarital sexual relations between consenting adults, resulting in pregnancy, do not
constitute immorality under secular legal standards and cannot justify dismissal or suspension
under labor law.

Facts:
Miraflor Mabao, a regular teacher at Bohol Wisdom School (BWS) since 2010, informed
the school of her pregnancy in September 2016. The school suspended her indefinitely without
pay, citing immorality. Mabao married her boyfriend shortly after. Despite receiving multiple
return-to-work notices, Mabao refused to return, stating her intention to leave BWS and had
already filed a complaint with the NLRC. The Labor Arbiter ruled in Mabao's favor, finding
constructive dismissal. The NLRC reversed this, but the Court of Appeals affirmed the illegality
of the suspension, ordering BWS to pay compensation.

Issue:
Was the suspension of Miraflor Mabao for premarital pregnancy valid under labor law?

Ruling:
Illegal Suspension: The Supreme Court declared Mabao's suspension illegal. The Court
held that the school's definition of "immorality" was based on religious, not secular, standards.
Mabao's consensual premarital relationship and intention to marry did not constitute immorality
under the law.
Abandonment of Employment: Despite the illegal suspension, the Court found that
Mabao subsequently abandoned her employment. Her refusal to return to work, coupled with her
explicit statement of intent to leave BWS, demonstrated a clear severance of the employment
relationship.
Case Title:Berteni Cataluña Causing v. People of the Philippines, et al.
G.R. No. 258524, October 11, 2023

Case Doctrine:
Cyber libel, as defined under the Cybercrime Prevention Act (RA 10175), is not a distinct
offense but a mode of committing traditional libel under the Revised Penal Code (RPC).
Therefore, the one-year prescriptive period for libel under Article 90 of the RPC applies to cyber
libel. This period begins from the date the offended party, authorities, or their agents discover the
offense. Prescription is an affirmative defense requiring evidentiary proof and cannot be solely
inferred from the information's allegations.

Facts of the Case:

Berteni Cataluña Causing, a former lawyer and journalist, published allegedly libelous
statements about Representative Ferdinand L. Hernandez on his Facebook page on February 4
and April 29, 2019. These posts accused Hernandez of misappropriating public funds. On May
10, 2021, Hernandez filed a complaint, resulting in two cyber libel charges against Causing.
Causing's motion to quash the informations, based on the argument that the offenses had
prescribed, was denied by the Regional Trial Court, which incorrectly applied a twelve-year
prescriptive period.

Issues:
Does cyber libel constitute a separate offense under RA 10175 with a different
prescriptive period, or is it simply a form of libel under the RPC subject to the one-year
prescriptive period?

Ruling:
The Supreme Court held that cyber libel is not a novel offense but a method of
committing the crime of libel under the RPC, as detailed in Section 4(c)(4) of RA 10175.
Consequently, the applicable prescriptive period is one year, as stipulated in Article 90 of the
RPC, commencing from the date of discovery of the offense. The Court overruled its prior
decision in Tolentino v. People, which incorrectly applied a fifteen-year prescriptive period.
Crucially, the Court reiterated that prescription is an affirmative defense requiring the accused to
present evidence, not merely relying on the information's contents. Because Causing failed to
provide such evidence, the issue of prescription must be addressed during the trial
Case Title: Angelito Ridon y Guevarra v. People of the Philippines
G.R. No. 252396, December 6, 2023

Case Doctrine:
A warrantless search is unlawful unless it immediately follows a lawful arrest. A minor
traffic infraction, particularly one not resulting in imprisonment, does not justify a warrantless
arrest or the subsequent search. Evidence obtained through such an illegal search is inadmissible
in court.

Facts of the Case:

In 2013, Angelito Ridon, while operating a motorcycle in Makati City, violated a one-
way street regulation. Instead of stopping when signaled by police, Ridon attempted to evade
them. After a pursuit, Ridon fell from his motorcycle. As he reached toward his waist, police
officers, along with a Bantay Bayan volunteer, apprehended him and conducted a pat-down
search. This search revealed an unregistered revolver loaded with ammunition. Ridon was
subsequently arrested and charged under Republic Act No. 10591 (Comprehensive Firearms and
Ammunition Regulation Act). The Regional Trial Court (RTC) and the Court of Appeals (CA)
both upheld the conviction, deeming the warrantless search valid as incidental to a lawful arrest
for the traffic violation.

Issues:
Was the warrantless search and seizure of Ridon's firearm and ammunition lawful,
making the seized evidence admissible in court?

Ruling:
The Supreme Court overturned the RTC and CA decisions, declaring the warrantless
search and seizure invalid. The Court highlighted that Rule 126, Section 13 of the Rules of Court
permits warrantless searches only when incidental to a lawful arrest. Ridon's traffic offense did
not justify an arrest, but at most, the confiscation of his driver's license. Therefore, no lawful
arrest preceded the search. The Court also rejected the applicability of the "stop-and-frisk"
doctrine due to the absence of sufficient reasonable suspicion to warrant the intrusion. The
illegally obtained firearm and ammunition were deemed inadmissible. Lacking other evidence,
the Court acquitted Ridon.
Case Title: Argelyn M. Labargan v. People of the Philippines
G.R. No. 246824, December 6, 2023

Case Doctrine:
Statements criticizing public officials regarding their official conduct do not constitute
oral defamation unless the prosecution demonstrates actual malice. This principle protects free
speech and acknowledges the public's right to scrutinize government officials.

Facts of the Case:

On February 21, 2013, during a barangay conciliation proceeding in Muntay,
Kolambugan, Lanao del Norte, the complainant alleged that Argelyn M. Labargan publicly
insulted Barangay Kagawad Aileen R. Macabangon, calling her "dull," "ignorant," and biased.
These remarks were purportedly made within earshot of others as Macabangon passed
Labargan's residence near a public road. Labargan denied making the statements, claiming her
dispute was with a different individual. The Municipal Circuit Trial Court convicted Labargan of
grave oral defamation (dismissing a concurrent light threats charge). The Regional Trial Court
and Court of Appeals affirmed this conviction. Labargan appealed to the Supreme Court.

Issues:
Was Argelyn M. Labargan proven guilty beyond a reasonable doubt of grave oral
defamation?

Ruling:
The Supreme Court, in its December 6, 2023 decision, acquitted Argelyn M. Labargan.
The Court reiterated that criticism of public officials related to their official duties is not
defamatory unless uttered with actual malice. The prosecution failed to establish that Labargan's
statements were made with knowledge of their falsity or reckless disregard for the truth. The
Court highlighted the importance of free speech and the need for public accountability of
officials. The lower court decisions were reversed, and Labargan was acquitted.
Case Title: XXX v. People of the Philippines
G.R. No. 252739, April 16, 2024

Case Doctrine:
Marital infidelity constitutes psychological violence under Section 5(i) of Republic Act
No. 9262 (Anti-Violence Against Women and Their Children Act). The act of infidelity itself,
due to its inherent capacity to inflict emotional distress, is sufficient to establish the requisite
intent, regardless of the perpetrator's specific intention. The law's focus is on the victim's
suffering, not the offender's motive.

Facts of the Case:

Petitioner XXX was charged with violating Section 5(i) of R.A. No. 9262 for inflicting
psychological violence on his wife, AAA, through an extramarital affair. AAA discovered
XXX's affair with YYY, which resulted in a child. This discovery caused AAA significant
emotional distress. XXX admitted to the affair but claimed it was a single incident and denied
intending to harm AAA.

Issues:
Does marital infidelity, without proof of specific intent to cause harm, constitute
psychological violence under Section 5(i) of R.A. No. 9262?

Ruling:
The Supreme Court upheld XXX's conviction. The Court ruled that marital infidelity
inherently causes mental and emotional anguish, fulfilling the definition of psychological
violence. Specific intent to cause harm is unnecessary; the natural consequences of the act are
sufficient to establish liability. The law prioritizes the victim's experience of suffering. The
prosecution's evidence, including XXX's admission and AAA's testimony, sufficiently
demonstrated the psychological harm resulting from the infidelity.
Case Title: Amadea Angela K. Aquino vs. Rodolfo C. Aquino and Abdulah C. Aquino
G.R. No. 208912, December 7, 2021

Case Doctrine:
Article 992 of the Civil Code does not bar illegitimate children from inheriting from their
grandparents by right of representation. The Court rejected the traditional "iron curtain"
interpretation of Article 992, finding it inconsistent with principles of equality and the child's
best interests. Inheritance through representation is permitted for illegitimate children from direct
ascendants (grandparents), but not necessarily from collateral relatives.

Facts of the Case:

Miguel T. Aquino died intestate on July 5, 1999, leaving behind assets. He was survived
by his second wife, Enerie B. Aquino, and his sons (Rodolfo, Abdulah, and the heirs of
Wilfredo) from his first marriage to Amadea C. Aquino. Another son, Arturo, predeceased
Miguel, dying on January 10, 1978. Amadea Angela K. Aquino (Angela), claiming to be Arturo's
only child (born October 9, 1978, after Arturo's death), petitioned for inclusion in the estate
distribution. Angela's parents were unmarried but had no legal impediment to marry and
intended to do so before Arturo's death. The Regional Trial Court (RTC) initially granted
Angela's petition, but the Court of Appeals reversed, citing insufficient proof of filiation and
Article 992's prohibition.

Issue:
Can an illegitimate child inherit from their grandparent by right of representation, despite
Article 992 of the Civil Code?

Ruling:
The Supreme Court ruled in Angela's favor. The Court reinterpreted Article 992, holding
that the "iron curtain" rule does not apply to inheritance by representation from direct ascendants.
Article 982, allowing inheritance by representation for "grandchildren and other descendants,"
does not distinguish between legitimate and illegitimate descendants. Therefore, an illegitimate
child can inherit from their grandparent by representing their deceased parent. This applies only
to direct ascendants, not collateral relatives. The Court also clarified that Angela's claim of
filiation was not automatically invalidated by her birth after Arturo's death, remanding the case
to the RTC to definitively determine Angela's filiation.
Case Title: People of the Philippines v. Jerry Sapla y Guerrero a.k.a. Eric Salibad y
Mallari
G.R. No. 244045, June 16, 2020

Case Doctrine:
A warrantless search and seizure based solely on an unverified anonymous tip is
unconstitutional. Such a tip does not establish probable cause, rendering any seized evidence
inadmissible under the exclusionary rule. This decision reinforces the protection against
unreasonable searches and seizures guaranteed by Article III, Section 2 of the 1987 Constitution.

Facts of the Case:

On January 10, 2014, Tabuk City, Kalinga police received an anonymous tip about an
individual transporting marijuana on a passenger jeepney. Using the description provided, police
officers established a checkpoint and apprehended Jerry Sapla, who matched the description.
Sapla admitted ownership of a blue sack containing four bricks of marijuana after being
questioned. He was arrested and charged with violating Section 5, Article II of Republic Act No.
9165 (illegal transportation of dangerous drugs).

Issue:
Was the warrantless search and seizure of Sapla's marijuana, based solely on an
unverified anonymous tip, valid and constitutional?

Ruling:
The Supreme Court declared the warrantless search and seizure unconstitutional. An
unverified anonymous tip does not constitute probable cause. The seized marijuana was
inadmissible as evidence. Without the corpus delicti, the prosecution's case failed, resulting in
Sapla's acquittal.
Case Title: Erwin Alvero y Tresvalles v. People of the Philippines
G.R. No. 260214, April 17, 2023

Case Doctrine:
A trial court may approve a plea bargain in drug cases even if the prosecution objects,
provided the proposal adheres to the Supreme Court's Plea Bargaining Framework in Drugs
Cases. Prosecutorial objections based solely on internal executive policies conflicting with the
judicial framework do not prevent court approval of the plea bargain.

Facts of the Case:

In 2016, Erwin Alvero y Tresvalles and a co-accused were charged under Section 5,
Article II of Republic Act No. 9165 (illegal sale of 0.1459 grams of methamphetamine
hydrochloride). Alvero initially pleaded not guilty. During the trial, citing Estipona v. Lobrigo,
Alvero proposed a plea bargain to plead guilty to a lesser offense under Section 12, Article II of
R.A. No. 9165 (possession of drug paraphernalia). The prosecution objected, referencing
Department of Justice (DOJ) Department Circular No. 027, which disallowed such plea bargains
in cases involving conspiracy or specific drug quantities. The Regional Trial Court (RTC)
approved the plea bargain, leading to Alvero's conviction for the lesser offense. The Court of
Appeals (CA) reversed the RTC's decision, stating that prosecutorial consent is mandatory for a
valid plea bargain.

Issue(s):
Did the RTC gravely abuse its discretion by allowing Alvero's plea bargain despite the
prosecution's objection?

Ruling:
The Supreme Court found no grave abuse of discretion by the RTC. While the
prosecution has discretion over who to prosecute and what charges to file, the judiciary retains
authority to approve plea bargains consistent with its established frameworks. Objections based
solely on internal executive policies cannot override judicial rules. However, the Court remanded
the case to the RTC to determine whether Alvero is a recidivist, habitual delinquent, or if strong
evidence of guilt exists, in line with People v. Montierro guidelines.
Case Title: Diocese of Bacolod v. Commission on Elections
G.R. No. 205728, January 21, 2015

Case Doctrine:
Private individuals and entities, such as the Diocese of Bacolod, enjoy freedom of
expression protection under the Constitution. Their expressions are not considered election
propaganda subject to COMELEC regulation unless created in conjunction with, or funded by, a
candidate or political party.

Facts of the Case:

In February 2013, the Diocese of Bacolod displayed two large tarpaulins at the San
Sebastian Cathedral. One opposed the Reproductive Health Law (Republic Act No. 10354),
stating "IBASURA RH Law." The other, "Conscience Vote," categorized candidates for the May
2013 elections as "Team Buhay" (against the RH Law) or "Team Patay" (in favor), based on
their voting records. COMELEC, citing Resolution No. 9615 (limiting campaign material size),
ordered the tarpaulins' removal, claiming they were oversized election propaganda. The Diocese
argued that the tarpaulins expressed religious and moral beliefs, not election propaganda, and
were thus protected under freedom of expression.

Main Issue:
Does COMELEC have the authority to regulate expressions by private citizens or entities
during elections, especially when such expressions are not coordinated with any candidate or
political party?

Ruling:
The Supreme Court sided with the Diocese of Bacolod. The tarpaulins expressed the
Diocese's beliefs on a matter of public concern and did not constitute election propaganda
because they were not paid for or authorized by any candidate or political party. COMELEC's
order violated the Diocese's constitutional right to freedom of expression.
Case Title: Richard Ricalde v. People of the Philippines
G.R. No. 211002, January 21, 2015

Case Doctrine:
In rape cases under Article 266-A(2) of the Revised Penal Code (sexual assault), the
slightest penetration of the anal orifice constitutes consummation of the crime. The victim's
credible testimony alone can establish guilt beyond a reasonable doubt, even without physical
evidence.

Facts of the Case:

Richard Ricalde was charged with raping a male minor (XXX) through anal sexual
assault. The alleged assault occurred while Ricalde was staying overnight at XXX's home. XXX
testified that Ricalde inserted his penis into his anus. Ricalde denied the accusation, stating he
slept on a sofa while XXX slept on the floor. He pointed to the lack of physical injuries or
spermatozoa in the medico-legal examination and inconsistencies in XXX's testimony.

Issue:
Did the prosecution prove beyond a reasonable doubt that Richard Ricalde committed
rape through sexual assault under Article 266-A(2) of the Revised Penal Code?

Ruling:
The Supreme Court affirmed Ricalde's conviction. XXX's testimony was deemed clear,
categorical, and credible, detailing the anal penetration. The absence of physical evidence
(injuries or spermatozoa) did not negate the rape, as the slightest penetration suffices, and such
acts may not always cause physical trauma. The Court modified the penalty to an indeterminate
sentence of six (6) years and one (1) day of prision mayor as minimum, to twelve (12) years and
one (1) day of reclusion temporal as maximum.
Case Title: Bishop Shinji Amari of Abiko Baptist Church, et al. v. Ricardo R. Villaflor Jr.
G.R. No. 224521, February 17, 2020

Case Doctrine:
Church membership matters and the appointment or dismissal of religious personnel are
ecclesiastical issues beyond the jurisdiction of civil courts. These internal religious affairs are
protected by the constitutional guarantee of religious freedom.

Facts of the Case:

Ricardo R. Villaflor Jr., a Filipino missionary affiliated with the Abiko Baptist Church
(ABC) in Japan and the Missionary Baptist Institute & Seminary (MBIS) in the Philippines,
received a letter on November 24, 2011, notifying him of his removal as an ABC missionary and
the cancellation of his American Baptist Association (ABA) missionary appointment. Villaflor
sued ABC and MBIS for illegal dismissal and damages, claiming his removal lacked due process
and that he was owed compensation.

Issue:
Is Villaflor's removal as a missionary and church member an ecclesiastical matter outside
the jurisdiction of civil courts?

Ruling:
The Supreme Court held that the issue is an ecclesiastical matter concerning the church's
internal decisions regarding membership and missionary appointments. Civil courts lack
jurisdiction to intervene in such matters. The constitutional guarantee of religious freedom
protects the autonomy of religious organizations in managing their internal affairs. Villaflor's
complaint for illegal dismissal was dismissed for lack of jurisdiction.
Case Title: Linconn Uy Ong v. Senate of the Philippines; Michael Yang Hong Ming v.
Senate Committee on Accountability of Public Officers and Investigations
G.R. Nos. 257401 & 257916, March 28, 2023

Case Doctrine:
The Senate's inherent powers of contempt and arrest in aid of legislation must be
exercised consistent with constitutional due process rights. Individuals must be afforded due
process before being held in contempt and arrested.

Facts of the Case:

In 2021, the Senate Blue Ribbon Committee investigated the DOH's COVID-19
pandemic-related expenditures, focusing on contracts awarded to Pharmally Pharmaceutical
Corporation. Linconn Uy Ong (Pharmally director and supply chain manager) and Michael Yang
(former presidential economic advisor linked to Pharmally) were summoned to testify. Both
initially failed to appear but testified on September 10, 2021. The Committee deemed their
testimonies false and evasive, citing them for contempt and issuing arrest orders. Ong was
detained at the Senate; a lookout bulletin was issued for Yang.

Issue:
Did the Senate Blue Ribbon Committee gravely abuse its discretion by citing Ong and
Yang for contempt and ordering their arrest without due process?

Ruling:
The Supreme Court ruled that while the Senate can conduct inquiries and exercise
contempt powers, it must do so within constitutional limits. The Committee failed to provide
Ong and Yang with an opportunity to be heard before citing them for contempt and ordering
their arrest, violating their due process rights. The contempt and arrest orders were declared
invalid.
Case Title: Pedro J. Amarille v. People of the Philippines
G.R. No. 256022, August 7, 2023

Case Doctrine/s:
1. Intent to Gain (Animus Furandi) in Theft: Conviction for theft requires proof beyond
a reasonable doubt of the accused's intent to gain; a genuine belief of ownership negates
this intent.
2. Solutio Indebiti: Even without criminal liability, unjust enrichment necessitates
restitution of the benefit received.
3. Equal Protection Clause: Laws disproportionately penalizing specific groups, such as
small-scale coconut farmers, may violate the equal protection guarantee.

Facts of the Case:

On November 4, 2011, Pedro J. Amarille directed Daniel Albaran to harvest 200
coconuts from a Maribojoc, Bohol plantation, claiming ownership through his grandfather,
Eufemio Amarille. Albaran, aware the land was managed by Hospicio Almonte for the Jabines
family, initially hesitated but complied. Amarille processed the coconuts into copra and sold
them. Noel M. Jabines (son of Macario Jabines) reported the incident. During a barangay
settlement on November 9, 2011, Amarille admitted to the harvesting but asserted his belief in
rightful ownership. An agreement for Amarille to cease harvesting and deposit the copra was not
fulfilled.

Issues:
1. Was Pedro J. Amarille guilty of qualified theft beyond a reasonable doubt?
2. Does an honest belief of ownership negate the intent to gain required for theft?
3. Is classifying coconut theft as qualified theft constitutionally valid under the equal
protection clause?

Ruling:
The Supreme Court acquitted Amarille of qualified theft, finding insufficient proof of
intent to gain beyond a reasonable doubt. Amarille's honest belief in his ownership, supported by
a tax declaration and long-term cultivation, was acknowledged. However, Amarille was held
civilly liable under solutio indebiti, ordered to pay the heirs of Macario Jabines the copra sale
proceeds with interest. Justice Leonen's concurring opinion questioned the constitutionality of
classifying coconut theft as qualified theft, suggesting potential disproportionate impact on
small-scale farmers and a violation of the equal protection clause.
Case Title: Salvador Yapyuco y Enriquez, et al. v. Sandiganbayan and People of the
Philippines
G.R. Nos. 120744-46, June 25, 2012

Case Doctrine:
1. Mistake of Fact: This defense exonerates only when the mistake is made without fault or
negligence, and the accused acted under a genuine, honest, and reasonable belief in a fact
that, if true, would justify the act.
2. Justifying Circumstance – Fulfillment of Duty (Article 11(5), RPC): This applies only
when the act is in the lawful performance of duty, using necessary and reasonable means.
Excessive force or lack of verification negates this defense.
3. Standard of Reasonableness: Reasonableness is judged not by hindsight but by whether
a prudent person would have acted similarly under the circumstances.

Facts of the Case:

On April 5, 1988, in Barangay Quebiawan, San Fernando, Pampanga, police officers and
barangay officials ambushed a jeepney carrying barrio fiesta attendees. The accused (INP,
barangay captains, CHDF members) claimed they responded to reports of NPA rebels. After the
jeepney allegedly failed to stop when flagged down, they opened fire, killing Leodevince Licup
and injuring Noel Villanueva. The accused argued they believed the passengers were rebels and
that force was necessary.

Issue(s):
1. Did the accused act in the lawful performance of their duties under Article 11(5) of the
Revised Penal Code?
2. Does the defense of mistake of fact apply?
3. Did the prosecution prove the accused's guilt beyond a reasonable doubt for homicide and
attempted homicide?

Ruling:
The Supreme Court affirmed the Sandiganbayan's guilty verdict for homicide (Licup's death)
and attempted homicide (Villanueva's injuries). The Court found:

1. Lawful Performance of Duty: The accused failed to prove lethal force was necessary.
The lack of warning shots and targeted gunfire indicated excessive force.
2. Mistake of Fact: This defense was inapplicable. The accused lacked an honest and
reasonable belief that the passengers were armed rebels; their actions stemmed from
negligence and lack of verification.
3. Guilt Beyond Reasonable Doubt: Compelling evidence (ballistic reports, witness
testimonies) showed the accused deliberately fired without just cause. The bullet patterns
and shooter positions indicated a coordinated attack, establishing guilt beyond a
reasonable doubt.