Molave Motor Sales, Inc. v.

Laron and Geminiano

FACTS

Petitioner is a corporation engaged in the sale and repair of motor vehicles in Dagupan City.
Private respondent in the case below, was, or is, the sales manager of Petitioner. Alleging that the
respondent was a former employee, Petitioner had sued him for payment of accounts pleaded as
that during his incumbency as such the defendant caused and without authority from the plaintiff
incurred accounts with the remaining balances in the total sum of P 33,890.38 excluding interests,
arising from the purchases of vehicles and parts, repair jobs of his personal cars and cash advances,
faithful reproductions of the Vehicle Invoice, Debit Memos, Deed of Absolute Sale, Repair
Orders, Charge Invoices, Vouchers , Promissory Notes, Acknowledgement Letter and
Statement of Account. In his Answer, The Respondent denied. He further alleged in a counterclaim
that he should still be considered an employee of Petitioner inasmuch as there has been no
application for clearance in regards to his separation.

ISSUE

W/N the Civil Code is the governing statute in the instant case.

HELD

Yes, the Civil Code is the governing statute. It is obvious from the complaint that the
plaintiffs have not alleged any unfair labor practice. There is a simple action for damages for
tortuous acts allegedly committed by the defendants. Such being the case, the governing statute is the
Civil Code and not the Labor Code. It results that the orders under review are based on a wrong premise.
In the case below, Petitioner had sued for monies loaned to respondent, the cost of repair jobs
made on his personal cars, and for the purchase price of vehicles and parts sold to him. Those accounts
have no relevance to the Labor Code. The cause of action was one under the civil laws, and it does not
breach any provision of the Labor Code or the contract of employment of respondent. Hence, the civil
courts, not the Labor Arbiters and the NLRC, should have jurisdiction.
 Modesta Borcena vs.INTERMEDIATE APPELLATE COURT
G.R. No. 70099 January 7, 1987

FACTS

On July 6, 1981, the petitioners engaged the legal services of respondent Gil P. de Guzman with
the condition that they will give a total of 25% of their claim as for the attorney’s fee. On this same date,
respondent de Guzman filed a complaint for damages against the Metropolitan Waterworks and
Sewerage System. On June 18, 1982, Atty. de Guzman filed a motion for preliminary attachment praying
that an order be issued attaching properties of the defendants amounting to P710, 000.00 plus 20%
thereof representing attorney's fees, or a total of P852, 000.00. The motion was granted upon plaintiffs'
posting a bond of P852, 000.00 issued by a bonding company acceptable to the court.

  
 ISSUE

W/N the amount which the respondent Court of Appeals and the trial court ordered to be paid
to their former lawyer, as his compensation is reasonable?

RULING

No, even the petitioners executed a contract stating the condition that they  agreed to give 25%
of their claim to their lawyer the higher court see nothing in the case appears complicated and no extra
ordinary skill was needed for Atty. de Guzman to accomplish what he had done in the case before he
was terminated. A court can disregard a contract regarding legal services rendered by a lawyer when it is
proven that the amount is unjustifiable and unreasonable.

A contract is a binding of minds, agreeing in the terms & conditions stated within the contract
but the implementation of it always applies only when there is no party that would benefit in the
expense of others. The court can decide the validity or nullity of a contract.
 PHILIPPINE NATIONAL BANK v. PRES. JUDGE BENITO C. SE
GR No. 119231, 1996-04-18
FACTS

In accordance with Act No. 2137, the Warehouse Receipts Law, Noah's Ark Sugar Refinery issued on
several dates warehouse receipts covering sugar deposited by St. Therese Merchandising and by RNS
Merchandising.

Subsequently, Warehouse Receipts Nos. 18080 and 18081 were negotiated and endorsed to Luis T.
Ramos; and Receipts Nos. 18086, 18087 and 18062 were negotiated and endorsed to Cresencia K.
Zoleta. Ramos and Zoleta then used the quedans as security for two loan agreements - one for P15.6
million and the other for P23.5 million - obtained by them from the Philippine National Bank. The
aforementioned quedans were endorsed by them to the Philippine National Bank.

Luis T. Ramos and Cresencia K. Zoleta failed to pay their loans upon maturity on January 9, 1990.
Consequently, on March 16, 1990, the Philippine National Bank wrote to Noah's Ark Sugar Refinery
demanding delivery of the sugar stocks covered by the quedans endorsed to it by Zoleta and Ramos.
Noah's Ark Sugar Refinery refused to comply with the demand alleging ownership thereof the Philippine
National Bank filed with the Regional Trial Court of Manila a verified complaint for "Specific Performance
with Damages and Application for Writ of Attachment”.

Private respondents thereupon filed before the trial court an Omnibus Motion seeking among others
the deferment of the proceedings until private respondents are heard on their claim for
warehouseman's lien.

ISSUE

Can the warehouseman enforce his warehouseman's lien before delivering the sugar stocks as ordered

RULING

Petitioner's submission is on a technicality, that is, that private respondents have lost their right to
recover warehouseman's lien on the sugar stocks covered by the five (5) Warehouse Receipts for the
reason that they failed to set up said claim in their Answer before the trial court private respondents
maintain that they could not have claimed the right to a warehouseman' s lien in their Answer to the
complaint before the trial court as it would have been inconsistent with their stand that they claim
ownership of the stocks covered by the quedans since the checks issued for payment thereof were
dishonored. If they were still the owners, it would have been absurd for them to ask payment for
storage fees and preservation expenses.

Accordingly, petitioner PNB is legally bound to stand by the express terms and conditions on the face of
the Warehouse Receipts as to the payment of storage fees.

Considering that petitioner does not deny the existence, validity and genuineness of the Warehouse
Receipts on which it anchors its claim for payment against private respondents, it cannot disclaim
liability for the payment of the storage fees stipulated therein. As contracts, the receipts must be
respected by authority of Article 1159 of the Civil Code.

While the PNB is entitled to the stocks of sugar as the endorsee of the quedans, delivery to it shall be
affected only upon payment of the storage fees.
 SALVADOR L. BUDLONG VS. HONORABLE AQUILES T. APALISOK
G.R. No. L-60151 June 24, 1983

FACTS
                The petitioner filed information before the respondent court charging private respondent with
the crime of serious physical injuries through reckless imprudence. During the scheduled arraignment,
on February 4, 1982, the accused pleaded guilty to the crime charged. Immediately after the plea the
respondent judge rendered judgment in open court and sentenced the accused to suffer thirty (30) days
of imprisonment and to pay the costs. No civil liability was imposed. At this same hearing, the accused
manifested his intention to avail of the provisions of Presidential Decree No. 968, the Probation Law, as
amended. Acting on the manifestation, the respondent court gave the counsel of the accused five (5)
days within which to file the petition for probation. On February 5, 1982, the petitioner filed an Ex-Parte
Motion to Set Case for Hearing for the reception of evidence to prove the civil liability of the accused.
On February 11, 1982, the respondent court issued an order denying the aforesaid motion. On February
18, 1982, the petitioner filed a motion for reconsideration of the February 11, 1982 order. On February
19, 1982, the respondent court issued an order denying the aforesaid motion for reconsideration. The
Acting Third Assistant City Fiscal decided to file this petition. On April 14, 1982, the issued a resolution.
The petition is meritorious.

ISSUE
Whether the Respondent Court has Committed has committed grave abuse on rendering judgment
convicting the respondent without adjudication of Civil Liability?

RULING
          
  The extinction and survival of civil liability are governed by Chapter Three, Title Five, and Book One of
the Revised Penal. If under Article 113 of the Revised Penal Code, the obligation to satisfy civil liability
continues notwithstanding service of sentence or non-service due to amnesty and pardon commutation
of sentence, or any other reason we fail to see what led the respondent judge to rule that an application
for probation should have an opposite effect insofar as determination of civil liability is concerned. It
could not have been delay because the motion was filed on the day after the judgment of conviction
was rendered in open court right after the plea of guilty and the manifestation that the accused was
applying for probation.
 PADILLA v CA
G.R. No. L-39999 May 31, 1984

FACTS

The information states that on February 8, 1964 at around 9AM, the accused prevented Antonio
Vergara and his family to close their stall located at the Public Market, Building No. 3, Jose Panganiban,
Camarines Norte, and by subsequently forcibly opening the door of said stall and thereafter brutally
demolishing and destroying said stall and the furniture therein by axes and other massive instruments,
and carrying away the goods, wares and merchandise. Roy Padilla, being the incumbent municipal
mayor and the rest of the accused being policemen except Ricardo Celestino who is a civilian, all of Jose
Panganiban, Camarines Norte, and that it was committed with evident premeditation. Roy Padilla,
Filomeno Galdonez, Ismael Gonzalgo and Jose Parley Bedenia guilty beyond reasonable doubt of the
crime of grave coercion. The CA acquitted the petitioners but ordered them to pay solidarily the amount
of 9,000. Hence, the petition.

ISSUE

W/N the respondent court committed a reversible error in requiring the petitioners to pay civil
indemnity to the complainants after acquitting them from the criminal charge.

HELD

No, the Court of Appeals is correct. To require a separate civil action simply because the
accused was acquitted would mean needless clogging of court dockets and unnecessary duplication of
litigation with all its attendant loss of time, effort, and money on the part of all concerned.

Article 29 of the Civil Code, earlier cited that "when the accused in a criminal prosecution is
acquitted on the ground that his guilt has not been proved beyond reasonable doubt, a civil action for
damages for the same act or omission may be instituted."
What Article 29 merely emphasizes that a civil action for damages is not precluded by an acquittal for
the same criminal act or omission.
 People v Castaneda
G.R. No. L-46306 February 27, 1979
FACTS

Benjamin Manaloto was charged with the crime of Falsification of Public Document. The
complaint was filed by his wife, Victoria Manaloto.

That on or about the 19th day of May, 1975, in the Municipality of San Fernando, province of
Pampanga, Philippines, Benjamin falsified in a deed of sale the house and lot belonging to the conjugal
partnership in favor of Ponciano Lacsamana, making it appear that his spouse gave her marital consent
to said sale.

At the trial, the prosecution called the wife to the witness stand but the defense moved to
disqualify her as a witness, invoking Sec. 20, Rule 130. The prosecution stated that it is a "criminal case
for a crime committed by one against the other." Notwithstanding such opposition, respondent Judge
granted the motion, disqualifying Victoria.

ISSUE
W/N the criminal case for Falsification of Public Document may be considered as a criminal case
for a crime committed by a husband against his wife and, therefore, an exception to the rule on marital
disqualification.

HELD

No. The case is an exception to the marital disqualification rule. WHEN AN OFFENSE DIRECTLY
ATTACKS, OR DIRECTLY AND VITALLY IMPAIRS, THE CONJUGAL RELATION, IT COMES WITHIN THE
EXCEPTION to the statute that one shall not be a witness against the other except in a criminal
prosecution for a crime committed (by) one against the other.
 People v Jalandoni
G.R. No. L-57555 August 28, 1984

FACTS

Teresa Jalandoni was accused of estafa. The information alleged that she issued several checks drawn
against the Rizal Commercial Banking Corporation in favor of the Bank of the Philippine Islands (BPI);
that the checks were dishonored for lack of funds, a fact which was known by the accused; and that as a
result thereof the BPI suffered damage in the amount of P1, 391, 780.00. Subsequently, BPI filed the
aforesaid Motion to Modify Judgment. BPI invoked a Court of Appeals decision People vs. De Castillo,
where the court acquitted the appellant who was accused of malversation of public funds on the ground
of reasonable doubt but nonetheless ordered her to pay the amount of her civil liability. Accordingly, BPI
prayed that in the interest of justice and to avoid multiplicity of suits, a second paragraph be added to
our judgment.

ISSUE

Whether or not Jalandoni was denied due process by not affording to her a separate hearing.

HELD

  There appear to be no sound reasons to require a separate civil action to still be filed considering that
the facts to be proved in the civil case have already been established in the criminal proceedings where
the accused was acquitted. Due process has been accorded the accused. He was, in fact, exonerated of
the criminal charge. The constitutional presumption of innocence called for more vigilant efforts on the
part of prosecuting attorneys and defense counsel, a keener awareness by all witnesses of the serious
implications of perjury, and a more studied consideration by the judge of the entire records and of
applicable statutes and precedents. To require a separate civil action simply because the accused was
acquitted would mean needless clogging of court dockets and unnecessary duplication of litigation with
all its attendant loss of time, effort, and money on the part of all concerned.

Jalandoni’s claim that “the amount of the civil liability, if any, is unsettled and requires necessarily the
introduction of proof (Rollo, p. 161) is utterly devoid of merit. As shown above the appellant has
formally admitted that BPI suffered damage in the amount of P1,391,780.00. For her now to assert that
the civil liability, if any, is unsettled is an insult to the dignity of this Court. We cannot allow a party to
state a fact only to disown it afterwards because of convenience.
 People of the Philippines v. Mariano Entes
G.R. No. L-50632 February 24, 1981

FACTS

Rosa filed a verified complaint for rape against her father, Mariano Entes. When Mariano
waived his right to the second stage of a preliminary investigation, the case was elevated to the Court of
First lnstance of Palawan for trial on the merits.

In the course of the trial, and at the time when complainant Rosa was about to wind up her
testimony, Ruben Entes, the eldest son of the accused talked to his sister and convinced her to forgive
their father, assuring her that the accused will leave them "complainant and her brothers and sisters
and the island of Cuyo. Both Rosa and her aunt then signed separate affidavits wherein it was stated
that they are forgiving the accused. The court ruled Mariano guilty of the crime of rape beyond
reasonable doubt. He was sentenced to the extreme penalty of death by electrocution for offense
having been committed with the use of a deadly weapon, and with the attendance of two
other aggravating circumstances of night time and relationship and was indemnify for the amount of
12,000. The penalty imposed being that of death was then brought to the Supreme Court for review.

ISSUE

W/N the lower court erred in not considering the affidavits of desistance of the complainant and

RULING

No. While it is true that under Art. 344 of the Revised Penal Code it is stipulated in part that "the
offenses of seduction, abduction, rape or acts of lasciviousness, shall not be prosecuted except upon a
complaint filed by the offended party or her parents, grandparents, or guardian, nor, in any case, if the
offenders has been expressly pardoned by the above named persons, as the case may be," the pardon,
to justify the dismissal of the complaint should have been made prior to the institution of the criminal
action.