FIRST DIVISION
CITATION
[ G.R. No. 198629. April 05, 2022 ]
NAME OF THE CASE
REPUBLIC OF THE PHILIPPINES, PETITIONER, VS. EFREN S. BUENAVENTURA, RESPONDENT.
PARTIES AND THEIR ROLES
DECISION
GAERLAN, J.:
PARTIES
Efren S. Buenaventura filed a petition for land registration for Lot No. 1788, Cad. 674 (the subject property).
FACTS
The case "Republic of the Philippines v. Buenaventura" involves a petition for the original registration of title over Lot
No. 1788, Cad. 674, located at P. Sandoval St., Burgos, Rodriguez, Rizal.
Efren S. Buenaventura filed the petition on January 11, 2008, before the Regional Trial Court (RTC) of San Mateo,
Rizal, Branch 77.
Buenaventura claimed ownership through a Deed of Absolute Sale dated August 4, 1993, from Lorenzo Habagat.
The Republic, represented by the Office of the Solicitor General (OSG), opposed the application, arguing that
Buenaventura failed to prove the land's alienable and disposable status and his possession and ownership of the
property.
The RTC ruled in favor of Buenaventura, granting his application for land registration.
The Republic appealed to the Court of Appeals (CA), which affirmed the RTC's decision.
The Republic then filed a petition for review on certiorari before the Supreme Court, challenging the CA's decision.
ISSUE
WHETHER OR NOT THAT THE SUBJECT LAND IS SUSCEPTIBLE OF REGISTRATION UNDER THE PROPERTY REGISTRATION
DECREE DESPITE ABSENCE OF INCONTROVERTIBLE PROOF THAT RESPONDENT IS ENTITLED TO A CONFIRMATION OF
TITLE.
RULING
YES. Both the RTC and the CA found that Buenaventura had sufficiently established his possession over the subject
property, and these findings are binding upon the Supreme Court. Republic Act No. 11573, effective September 1,
2021, amended this requirement, reducing the period of possession to at least twenty years immediately preceding
the filing of the application for confirmation of title. Land registration is governed by Section 14 of Presidential
Decree No. 1529, requiring proof of open, continuous, exclusive, and notorious possession and occupation of
alienable and disposable lands of the public domain under a bona fide claim of ownership since June 12, 1945, or
earlier.
FIRST DIVISION
CITATION
[ G.R. No. 225409, March 11, 2020 ]
TITLE
PHILIPPINE HEART CENTER PETITIONER, V. THE LOCAL GOVERNMENT OF QUEZON CITY, CITY MAYOR OF QUEZON CITY,
CITY TREASURER OF QUEZON CITY AND CITY ASSESSOR OF QUEZON CITY RESPONDENT.
PARTIES INVOLVED
PHC is a government instrumentality established to provide specialized treatment for heart and allied diseases.
FACTS
PHC was established in 1975 under Presidential Decree 673 (PD 673) as a specialty hospital providing cardiovascular
care, especially to the poor.
The national government initially provided the land, building, equipment, and facilities for the PHC.
In 2004, Quezon City issued final Notices of Delinquency for unpaid real property taxes amounting to
Php36,530,545.00 on these properties.
Following a 2006 memorandum from the Office of the Government Corporate Counsel (OGCC) citing the Supreme
Court's ruling in Manila International Airport Authority v. Court of Appeals (MIAA), PHC suspended the MOA,
asserting its tax-exempt status.
Quezon City issued final Notices of Tax Delinquency and a Warrant of Levy in 2011, leading to the auction and sale of
PHC's properties to the Quezon City Government.
PHC filed a petition for certiorari with the Court of Appeals, which was dismissed for being the wrong remedy.
PHC’s motion for reconsideration was denied, prompting the PHC to elevate the case to the Supreme Court.
ISSUE
WHETHER OR NOT Is the PHC exempt from paying real property taxes on its eleven (11) properties in Quezon City?
RULING
YES. Section 234(a) of RA 7160 exempts real property owned by the Republic from real property taxes except when
the beneficial use thereof has been granted, for consideration or otherwise, to a taxable person. Thus, the Court has
invariably held that a government instrumentality, though vested with corporate powers, are exempt from real
property tax but the exemption shall not extend to taxable private entities to whom the beneficial use of the
government instrumentality's properties has been vested.
[ G.R. No. 237813. March 05, 2019 ]
JAMES ARTHUR T. DUBONGCO, PROVINCIAL AGRARIAN REFORM PROGRAM OFFICER II OF DEPARTMENT OF
AGRARIAN REFORM PROVINCIAL OFFICE-CAVITE IN REPRESENTATION OF DARPO-CAVITE AND ALL ITS OFFICIALS
AND EMPLOYEES, PETITIONER, VS. COMMISSION ON AUDIT, RESPONDENT.
PARTIES INVOLVED
JAMES ARTHUR T. DABUNGCO the Provincial Agrarian Reform Program Officer II of DARPO-Cavite
FACTS
The case involves a petition to reverse the decision of the Commission on Audit (COA) regarding the illegal use of the
Comprehensive Agrarian Reform Program (CARP) Fund to finance the Collective Negotiation Agreement (CNA)
Incentive for employees of the Department of Agrarian Reform Provincial Office-Cavite.
The petitioner, James Arthur T. Dubongco, , filed a petition for certiorari to challenge the COA's decision.
The COA argued that it was merely enforcing the provisions of DBM Budget Circular No. 2006-1, which stated that
the CNA Incentive should be sourced solely from savings from released MOOE allotments.
ISSUE
WHETHER THE CARP FUND OR FUND 158 CAN BE A VALID SOURCE FOR THE GRANT OF CNA INCENTIVE TO RANK-AND-
FILE EMPLOYEES;
RULING
NO. From the foregoing provisions, it is unequivocal that the CARP Fund could not be legally used to finance the grant of
the CNA Incentive. Both A.O. No. 135 and DBM Budget Circular No. 2006-01 use the word "shall" when pertaining to the
funds to be used in the CNA Incentive, that is, savings from operating expenses. The word "shall" is imperative,
underscoring the mandatory character of the provisions.24
INTERNATIONAL HOTEL CORPORATION, Petitioner,
vs.
FRANCISCO B. JOAQUIN, JR. and RAFAEL SUAREZ, Respondents.
CITATION
G.R. No. 158361 April 10, 2013
PARTIES INVOLVED
nternational Hotel Corporation (IHC)
Francisco B. Joaquin, Jr. and Rafael Suarez
Joaquin and Suarez provided services to IHC in securing a foreign loan for the construction of a hotel.
FACTS
On February 1, 1969, Joaquin proposed to provide technical assistance to IHC for securing a foreign loan for hotel
construction, guaranteed by the Development Bank of the Philippines (DBP).
The IHC Board approved phases one to six on February 11, 1969, and allocated P2,000,000.00 for the project.
Joaquin requested P500,000.00 for his services on July 11, 1969, which the IHC stockholders approved, allowing
payment in shares due to IHC's financial situation.
Negotiations with various financiers were conducted, but when Barnes International failed to deliver the loan, DBP
canceled its guaranty on December 6, 1971.
IHC then agreed with Weston International Corporation, but DBP denied the guaranty application.
IHC canceled the shares issued to Joaquin and Suarez, leading them to file a complaint for specific performance,
annulment, damages, and injunction in the Regional Trial Court (RTC) of Manila on December 6, 1973.
ISSUE
WHETHER OR NOT THE COURT OF APPEALS IS CORRECT IN AWARDING COMPENSATION AND EVEN MODIFYING THE
PAYMENT TO HEREIN RESPONDENTS DESPITE NON-FULFILLMENT OF THEIR OBLIGATION TO HEREIN PETITIONER
RULING
NO. the CA rightly concluded that the full amount of ₱2,000,000.00 could not be awarded to respondents because such
amount was not allocated exclusively to compensate respondents, but was intended to be the estimated maximum to
fund the expenses in undertaking phase 6 of the scope of services. Its conclusion was unquestionably borne out by the
minutes of the February 11, 1969 meeting, viz:
EN BANC
G.R. No. 189600 June 29, 2010
MILAGROS E. AMORES, Petitioner,
vs.
HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and EMMANUEL JOEL J. VILLANUEVA, Respondents.
PARTIES INVOLVED
Milagros E. Amores against Emmanuel Joel J. Villanueva's assumption of office as a representative of the party-list
organization Citizens' Battle Against Corruption (CIBAC) in the House of Representatives.
FACTS
Milagros E. Amores (petitioner) filed a petition for certiorari against Emmanuel Joel J. Villanueva (private
respondent).
Amores challenged Villanueva's assumption of office as a representative of the Citizens' Battle Against Corruption
(CIBAC) party-list.
Allegations included:
Villanueva assumed office without a formal proclamation by the Commission on Elections (COMELEC).
He was disqualified due to being over the age limit for youth sector nominees.
He changed his sectoral affiliation within six months of the election, violating Section 15 of Republic Act (RA) No.
7941
ISSUE
Whether Amores’ petition was dismissible for having been filed beyond the 10-day reglementary period..
RULING
NO. The Supreme Court ruled that the HRET committed grave abuse of discretion in considering the petition
untimely. NBC Resolution No. 07-60 was not a formal proclamation of Villanueva himself per Section 13 of RA No.
7941, which requires that representatives be proclaimed based on the list submitted by their respective parties.
Since the exact date of Villanueva’s proclamation was not disclosed, the Court decided to overlook the technicality
and ruled on the merits.
G.R. No. 173615 October 16, 2009
PHILIPPINE NATIONAL BANK, Petitioner,
vs.
CAYETANO A. TEJANO, JR., Respondent.
PARTIES INVOLVED
Respondent Cayetano A. Tejano, Jr. and eight other employees of PNB in its branch in Cebu City were charged
with grave misconduct, gross neglect of duty, conduct prejudicial to the best interest of the service, and acts
violative of the Code of Conduct and Ethical Standards for Public Officials and Employees.
FACTS
Tejano served as Vice-President and Manager at PNB and faced allegations of grave misconduct and gross neglect of
duty.
The allegations pertained to fraudulent transactions with various corporate entities while PNB was still under
government ownership.
On February 24 and March 17, 1994, Tejano and eight other employees were charged administratively before the
PNB Management Hearing Committee.
The Committee found Tejano guilty of misappropriating funds and extending unwarranted credit, recommending
forced resignation without forfeiture of benefits.
Tejano then appealed to the Civil Service Commission (CSC) on September 21, 1995, and filed a Memorandum on
Appeal on October 19, 1995. While the case was pending, PNB was privatized on May 27, 1996. On April 14, 1998,
the CSC dismissed Tejano’s appeal for being filed out of time. Tejano sought reconsideration, which the CSC denied,
citing loss of jurisdiction due to PNB’s privatization in December 1998
ISSUE
Whether Section 6 of Executive Order No. 80, which privatized PNB, had retroactive applicability to administrative
cases pending with the CSC
RULING
NO. The Supreme Court emphasized that laws are generally prospective unless the law provides otherwise. E.O. No.
80 did not expressly state a retrospective application. As a result, Tejano’s appeal was to be resolved based on the
law prevailing at the time of filing, when PNB was still government-owned.