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CIVIL LAW

Persons and Family Relations

HING v. CHOACHUY G.R. No. 179736|26 June 2013


Persons and Personality
DOCTRINE: An individual's right to privacy under Article 26 (1) of the Civil Code should not be confined
to his house or residence as it may extend to places where he has the right to exclude the public or deny
them access.

• An individual's right to privacy under Article 26 (1) of the Civil Code should not be confined to his
house or residence as it may extend to places where he has the right to exclude the public or deny them
access. The phrase "prying into the privacy of another's residence," therefore, covers places, locations,
or even situations which an individual considers as private. And as long as his right is recognized by
society, other individuals may not infringe on his right to privacy. The CA, therefore, erred in limiting the
application of Article 26 (1) of the Civil Code only to residences. • The reasonableness of a person's
expectation of privacy depends on a two-part test: (1) whether, by his conduct, the individual has
exhibited an expectation of privacy; and (2) this expectation is one that society recognizes as
reasonable.

JULIANO-LLAVE v. REPUBLIC G.R. No. 169766 |30 March 2011


Marriage
DOCTRINE: The law in effect at the time of marriage shall be applied in determining the validity of
marriage.

• Under the Civil Code, only one marriage can exist at any given time and divorce is not recognized
except during the effectivity of R.A. 394 (An Act Authorizing for a Period of Twenty Years Divorce Among
Moslems Residing in Non-Christian Provinces), however, this was not availed of by the parties.

While the Family Code is silent with respect to the proper party who can file a complaint for nullity of
marriage prior to A.M. No. 02-11-10-SC, it has been held that in a void marriage, in which no marriage
has taken place and cannot be the source of rights, any interested party may attack the marriage
directly or collaterally without prescription, and which may be filed even beyond the lifetime of the
contracting parties.

KALAW v. FERNANDEZ G.R. No. 166357 | 19 September 2011


Marriage
DOCTRINE: • It is the plaintiff that has the burden of proving the existence of facts that would establish
psychological incapacity. • Sexual infidelity per se is a ground for legal separation, the same does not
necessarily constitute psychological incapacity.

The burden of proving psychological incapacity is on the plaintiff who must prove that the incapacitated
party, based on his or her actions or behavior, suffers a serious or psychological disorder that completely
disables him or her from understanding and discharging the essential obligations of the marital state.
• The psychological problem must be grave, must have existed at the time of marriage, and must be
incurable.
MATUDAN v. REPUBLIC OF THE PHILIPPINES G.R. No. 203284 | 14 November 2016
Marriage
DOCTRINE: Psychological Incapacity must be characterized by gravity, juridical antecedence and
incurability

Psychological Incapacity must be characterized by


(a) gravity,
(b) juridical antecedence and
(c) incurability.
• The incapacity must be grave or serious such that the party would be incapable of carrying out the
ordinary duties required in marriage; it must be rooted in the history of the party antedating the
marriage although the overt manifestations may emerge only after the marriage; and it must be
incurable or even if it were otherwise, the cure would be beyond the means of the party involved.

TITAN CONSTRUCTION CORPORATION v. DAVID G.R. No. 169548| 15 March 2010


Property Relations of the Spouses
DOCTRINE: Article 124 of the Family Code requires that any disposition or encumbrance of conjugal
property must have the written consent of the other spouse, otherwise, such disposition is void.

Absence any proof that it is not part of the conjugal property, it must be deemed to be part of it.

FRANCISCO LIM v. EQUITABLE PCI BANK G.R. No. 183918 | 15 January 2014
Property Relations of the Spouses
DOCTRINE: The presumption in Article 160 that “all property of the marriage is presumed to belong to
the conjugal partnership” applies to property acquired during the lifetime of the husband and wife.
When the property is registered in the name of a spouse only and there is no showing as to when the
property was acquired by said spouse, this is an indication that the property belongs exclusively to said
spouse.

The presumption that a property registered to one spouse is part of the conjugal property applies only
to properties acquired during marriage

PERLA v. BARING G.R. No. 172471 | 12 November 2012


Paternity and Filiation
DOCTRINE:
• A certificate of live birth purportedly identifying the putative father is not competent evidence of
paternity when there is no showing that the putative father had a hand in the preparation of said
certificate.
• To prove open and continuous possession of the status of an illegitimate child, there must be evidence
of the manifestation of the permanent intention of the supposed father to consider the child as his, by
continuous and clear manifestations of parental affection and care, which cannot be attributed to pure
charity.
A certificate of live birth purportedly identifying the putative father is not competent evidence of
paternity when there is no showing that the putative father had a hand in the preparation of said
certificate.
• To prove open and continuous possession of the status of an illegitimate child, there must be evidence
of the manifestation of the permanent intention of the supposed father to consider the child as his, by
continuous and clear manifestations of parental affection and care, which cannot be attributed to pure
charity.

RODOLFO S. AGUILAR v. EDNA G. SIASAT G.R. No. 200169 | 28 January 2015


Paternity and Filiation
DOCTRINE: The filiation of illegitimate children can be established by an admission of legitimate filiation
in a public document and signed by the parent concerned.

The filiation of illegitimate children is, like legitimate children, under Art. 172 of the Family Code,
established by
(1) The record of birth appearing in the civil register or a final judgment; or
(2) An admission of legitimate filiation in a public document or a private handwritten instrument and
signed by the parent concerned.

REPUBLIC OF THE PHILIPPINES v. SARENOGON G.R. No. 199194 | 10 February 2016


Absence
DOCTRINE: Under Art. 41 of the Family Code, “well-founded” belief must be established by honest-to
goodness efforts to ascertain whether the absent spouse is still alive or is already dead.

In a petition for a declaration of presumptive death under Article 41 of the Family Code, the claim must
be based on a “well-founded belief” that the spouse is dead.

Property

PUDADERA v. MAGALLANES G.R. No. 170073 | 18 October 2010


Ownership
DOCTRINE: In case of a double sale of immovables, ownership shall belong to
(1) the first registrant in good faith;
(2) then, the first possessor in good faith; and
(3) finally, the buyer who in good faith presents the oldest title.

Art 1544 NCC, in case of a double sale of immovables, ownership shall belong to:
(1) The first registrant in good faith
(2) The first possessor in good faith
(3) The buyer who in good faith presents the oldest title
• The law requires that the second buyer must have acquired and registered the immovable property in
good faith. In order for the second buyer to displace the first buyer, the following must be shown:
(1) the second buyer must show that he acted in good faith (i.e., in ignorance of the first sale and of the
first buyer’s rights) from the time of acquisition until title is transferred to him by registration or failing
registration, by delivery of possession; and
(2) the second buyer must show continuing good faith and innocence or lack of knowledge of the first
sale until his contract ripens into full ownership through prior registration as provided by law.

COMMUNITIES CAGAYAN v. NANOL G.R. No. 176791 | 14 November 2012


Ownership
DOCTRINE: In case of a builder in good faith, the seller (the owner of the land) has two options under
Article 448:
(1) He may appropriate the improvements for himself after reimbursing the buyer (the builder in good
faith) the necessary and useful; or
(2) He may sell the land to the buyer, unless its value is considerably more than that of the
improvements, in which case, the buyer shall pay reasonable rent.

The presumption remains that the respondents are builders in good faith.
• Article 448 of the Civil Code applies when the builder believes that he is the owner of the land or that
by some title he has the right to build thereon, or that, at least, he has a claim of title thereto.

GUYAMIN v. FLORES G.R. No. 202189 | April 25, 2017


Ownership
DOCTRINE: Occupants by mere tolerance must vacate upon the demand of the registered owner.

CHUNG JR. V MANDRAGON G.R. No. 179754 | 21 November 2012


Ownership
DOCTRINE:
• In a case for quieting of title, the plaintiff must show that he has a legal or at least an equitable title
over the real property in dispute, and that some deed or proceeding beclouds its validity or efficacy.

• In a case for quieting of title are fairly simple, the plaintiff need to prove only two things, namely:
(1) The plaintiff or complainant has a legal or an equitable title to or interest in the real property subject
of the action; and
(2) That the deed, claim, encumbrance or proceeding claimed to be casting a cloud on his title must be
shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy.
• Stated differently, the plaintiff must show that he has a legal or at least an equitable title over the real
property in dispute, and that some deed or proceeding beclouds its validity or efficacy.

REPUBLIC v. AFP RSBS G.R. No. 180463 | 16 January 2013


Ownership
DOCTRINE: The failure of a party to avail of the proper remedy to acquire or perfect one’s title to land
cannot justify a resort to other remedies which are otherwise improper and do not provide for the full
opportunity to prove his title, but instead require him to concede it before availment.

MANANQUIL v. MOICO G.R. No. 180076 | 21 November 2012


Quieting of Title to or Interest in and Removal or Prevention of Cloud over Title or Interest in Real
Property
DOCTRINE: In order that an action for quieting of title may prosper, it is essential that the plaintiff must
have legal or equitable title to, or interest in, the property which is the subject-matter of the action.

An action for quieting of title is essentially a common law remedy grounded on equity. The competent
court is tasked to determine the respective rights of the complainant and other claimants, not only to
place things in their proper place, to make the one who has no rights to said immovable respect and not
disturb the other, but also for the benefit of both, so that he who has the right would see every cloud of
doubt over the property dissipated, and he could afterwards without fear introduce the improvements
he may desire, to use, and even to abuse the property as he deems best. But for an action to quiet title
to prosper, two indispensable requisites must concur, namely:
(1) The plaintiff or complainant has a legal or an equitable title to or interest in the real property subject
of the action;
(2) The deed, claim, encumbrance, or proceeding claimed to be casting cloud on his title must be shown
to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy.

GIL MACALINO, JR., et. al. v. ARTEMIO PIS-AN G.R. No. 204056 | 1 June 2016
Quieting of Title to or Interest in and Removal or Prevention of Cloud over Title or Interest in Real
Property
DOCTRINE: In cases of quieting of title, it is essential that the plaintiff has a legal or equitable title or
interest in the subject property.

In order that an action for quieting of title may prosper, it is essential that the plaintiff must have legal
or equitable title to, or interest in, the property that is the subject matter of the action.

MODESTO PALALI v. JULIET AWISAN G.R. No. 158385 | 12 February 2010


Quieting of Title to or Interest in and Removal or Prevention of Cloud over Title or Interest in Real
Property
DOCTRINE: One claiming to be in open, continuous, exclusive, notorious possession of a land in the
concept of an owner must be able to prove his claim through substantial evidence.

OLEGARIO v. MARI G.R. No. 147951 | 14 December 2009


Possession
DOCTRINE: Possession, to constitute the foundation of acquisitive prescription, must be possession
under a claim of title or must be adverse

DELA CRUZ v. CAPCO G.R. No. 176055 | 17 March 2014


Possession
DOCTRINE: The only issue in an ejectment case is the physical possession of real property — possession
de facto and not possession de jure.

The only issue in an ejectment case is the physical possession of real property — possession de facto
and not possession de jure but where the parties to an ejectment case raise the issue of ownership, the
courts may pass upon that issue to determine who between the parties has the better right to possess
the property.”
REPUBLIC v. CORTEZ G.R. No. 201405. | 24 August 2015
Possession
DOCTRINE: Possession, no matter how long, cannot produce any legal effect if the property cannot be
lawfully possessed in the first place.

Only things and rights which are susceptible of being appropriated may be the object of possession and
thus, property of the public dominion, common things and things specifically prohibited by law cannot
be appropriated and hence, cannot be possessed.

To prove that a land is alienable, the existence of a positive act of the government, such as presidential
proclamation or an executive order; an administrative action; investigation reports of Bureau of Lands
investigators; and a legislative act or a statute declaring the land as alienable and disposable must be
established.

• Hence, it must be considered as still inalienable public domain. Being such, it cannot be appropriated
and therefore not a proper subject of possession under Article 530 of the Civil Code. Possession, even if
the same be in the concept of an owner or no matter how long, cannot produce any legal effect since
the property cannot be lawfully possessed in the first place.

SIY v. TOMLIN G.R. No. 205998 | 24 April 2017


Possession
DOCTRINE: In a complaint for replevin, the claimant must convincingly show that he is either the owner
or clearly entitled to the possession of the object sought to be recovered.

In a complaint for replevin, the claimant must convincingly show that he is either the owner or clearly
entitled to the possession of the object sought to be recovered.

REGALADO v. DE LA PENA G.R. No. 202448 | 13 December 2017


Possession
DOCTRINE: In an action to recover possession of property, the assessed value of the subject property is
jurisdictional.

However, jurisdiction is conferred by law, it cannot be presumed nor implied. In the absence of any
allegation as to the assessed value of the subject properties, it cannot be determined which court has
exclusive jurisdiction over the complaint.
• MeTC, MTC, or MCTC has exclusive original jurisdiction over civil actions involving title to or possession
of real property, or any interest therein where the assessed value does not exceed Php 20,000 (or Php
50,000 in Metro Manila). If it exceeds such value, RTC has jurisdiction.

DE GUZMAN v. FILINVEST DEVELOPMENT CORPORATION G.R. No. 191710 | 14 January 2015


Easements
DOCTRINE: The need of the dominant estate is the one which governs the determination of the width of
the easement of right of way. The grant of the easement should not be excessive that would be
prejudicial to the dominant estate.
Under Art. 651 of the Civil Code, the width of the easement of right of way shall be that which is
sufficient for the needs of the dominant estate and may accordingly be changed from time to time.

ANDRES. v. STA. LUCIA DEV’T CO. G.R. No. 201405. | 24 August 2015
Easements
DOCTRINE: An easement of right-of-way may be demanded by the owner of an immovable or by any
person who by virtue of a real right may cultivate or use the same.

Under Article 649 of the Civil Code, an easement of right-of-way may be demanded by the owner of an
immovable or by any person who by virtue of a real right may cultivate or use the same.

NAGA CENTRUM, INC. v. ORZALES G.R. No. 203576 | 14 September 2016


Easements
DOCTRINE: The owner of a landlocked property has a right to demand a right-of-way through
neighboring estates provided that it is least prejudicial to the servient estate and shortest to the
highway.

To be entitled to an easement of right of way, the following requisites should be met:


(1) The estate is surrounded by other immovable and is without adequate outlet to public highway
(2) Payment of proper indemnity
(3) Isolation of the immovable is not due to its owner’s acts
(4) Right-of-way claimed is at a point least prejudicial to the servient estate

HIPOLITO, JR. v. CINCO G.R. No. 174143 | 28 November 2011


Nuisance
DOCTRINE: The mere fact that the building is considered as a nuisance under the Civil Code does not
deprive the Building Official the authority to order its condemnation and demolition.

PHILIPPINE NATIONAL BANK v. JUMAMOY G.R. No. 168164 | 3 August 2011


Prescription
DOCTRINE: The 10-year prescriptive period for an action for reconveyance based on an implied trust
applies when the plaintiff or the person enforcing the trust is not in possession of the property.

An action for reconveyance based on implied trust prescribes in 10 years as it is an obligation created by
law, to be counted from the date of issuance of the Torrens title over the property.
• This rule, however, applies only when the plaintiff or the person enforcing the trust is not in
possession of the property.
• If property is acquired through mistake or fraud, the person obtaining it is, by force of law, considered
a trustee of an implied trust for the benefit of the person from whom the property comes.

ANDRES. v. STA. LUCIA DEV’T CO. G.R. No. 201405. | 24 August 2015
Prescription
DOCTRINE: If the mode of acquisition is prescription, it must first be shown that the land has already
been converted to private ownership prior to the requisite acquisitive prescriptive period.
• Prescription is one of the modes of acquiring ownership under the Civil Code.
• However, only lands of the public domain subsequently classified or declared as no longer intended for
public use or for the development of national wealth, or removed from the sphere of public dominion
and are considered converted into patrimonial lands or lands of private ownership, may be alienated or
disposed through any of the modes of acquiring ownership under the Civil Code.
• And if the mode of acquisition is prescription, whether ordinary or extraordinary, it must first be
shown that the land has already been converted to private ownership prior to the requisite acquisitive
prescriptive period.

Obligation and Contracts

METROBANK v. ROSALES G.R. No. 183204| 13 January 2014


Sources of Obligations
DOCTRINE: Obligations arise from law, contracts, quasi-contracts, delicts and quasi-delicts

“Hold Out” clause applies only if there is a valid and existing obligation arising from any of the sources of
obligations enumerated in Article 1157 of the Civil Code, to wit: law, contracts, quasicontracts, delict
and quasi-delict.

MANLAR RICE MILL, INC. v. DEYTO G.R. No. 191189 | 29 January 2014
Kinds of Obligations
DOCTRINE: There is a solidary liability only when the obligation expressly so states, when the law so
provides or when the nature of the obligation so requires.

well-entrenched is the rule that solidary obligations cannot be lightly inferred. There is a solidary
liability only when the obligation expressly so states, when the law so provides or when the nature of
the obligation so requires
• A contract affects only the parties to it, and cannot be enforced by or against a person who is not a
party thereto. In the present case

GOLDLOOP v. GSIS G.R. No. 171076 | 1 August 2012


Kinds of Obligations
DOCTRINE: Parties may validly stipulate the unilateral rescission of a contract.

Parties may validly stipulate the unilateral rescission of a contract. Pursuant to Article 1191 of the Civil
Code, mutual restitution is required.

CONTINENTAL CEMENT CORPORATION v. ASEA BROWN BOVERI G.R. No. 171660 | 17 October 2011
Kinds of Obligations
DOCTRINE: The penalty clause takes the place of indemnity for damages and the payment of interests in
case of non-compliance with the obligation, unless there is a stipulation to the contrary.

Under Art. 1226 of the Civil Code, the penalty clause takes the place of indemnity for damages and the
payment of interests in case of non-compliance with the obligation, unless there is a stipulation to the
contrary.
SPOUSES BONROSTRO v. SPOUSES LUNA G.R. No. 172346 | 24 July 2013
Kinds of Obligations and Extinguishment of Obligations
DOCTRINE: Tender of payment takes effect only if accompanied by actual payment or followed by
consignation.

In a contract to sell, payment of the price is a positive suspension condition, the failure of which is not a
breach of contract warranting rescission under Article 1911 of the Civil Code but rather just an event
that prevents the supposed seller from being bound to convey title to the supposed buyer.

To have the effect of payment and the consequent extinguishment of the obligation to pay, the law
requires the companion acts of tender of payment and consignation.
• Tender of payment is the manifestation by the debtor of a desire to comply with or pay an obligation.
If refused without just cause, the tender of payment will discharge the debtor of the obligation to pay
but only after a valid consignation of the sum due shall have been made with the proper court.
• Consignation is the deposit of the proper amount with a judicial authority in accordance with rules
prescribed by law, after the tender of payment has been refused or because of circumstances which
render direct payment to the creditor impossible or inadvisable.

LAO v. SPECIAL PLANS, INC. G.R. No. 164791| 29 June 2010


Extinguishment of Obligations
DOCTRINE: Compensation takes place only if both obligations are liquidated and demandable.

Compensation can take place only when both debts are liquidated and demandable.
• The Civil Code provides that compensation shall take place when the following requisites are present:
(1) Each one of the obligors be bound principally and that he be at the same time a principal creditor of
the other;
(2) Both debts consist in a sum of money, or if the things due are consumable, they be of the same kind,
and also of the same quality if the latter has been stated;
(3) The two debts are due:
(4) The debts are liquidated and demandable;
(5) Over neither of them be any retention or controversy, commenced by third parties and
communicated in due time to the debtor.
• A claim is considered liquidated when the amount and time of payment is fixed.

LUZON DEVELOPMENT BANK v. ENRIQUEZ G.R. Nos. 168646 and 168666 | 12 January 2011
Extinguishment of Obligations
DOCTRINE: The dation in payment extinguishes the obligation to the extent of the value of the thing
delivered, either as agreed upon by the parties or as may be proved, unless the parties by agreement,
express or implied, or by their silence, consider the thing as equivalent to the obligation, in which case
the obligation is totally extinguished.

As a rule, the dation in payment extinguishes the obligation to the extent of the value of the thing
delivered, either as agreed upon by the parties or as may be proved, unless the parties by agreement,
express or implied, or by their silence, consider the thing as equivalent to the obligation, in which case
the obligation is totally extinguished. • It is the intention of the parties in the dation in payment which
determines whether the property subject of the dation will be considered as the full equivalent of the
debt and will therefore serve as full satisfaction of the said debt.

MONTEMAYOR v. MILLORA G.R. No. 168251 | 27 July 2011


Extinguishment of Obligations
DOCTRINE: A debt is considered liquidated, not only when it is expressed in definite figures which do not
require verification, but also when the determination of the exact amount depends only on a simple
arithmetical operation.

A debt is considered liquidated, not only when it is expressed in definite figures which do not require
verification, but also when the determination of the exact amount depends only on a simple
arithmetical operation.

• For legal compensation to take place, the requirements set forth in Arts. 1278 and 1279 of the Civil
Code must be present. It must be established that both parties have monetary obligations to each other,
that both obligations are already due, that they be liquated and demandable, and that no third parties
must be involved. • In the instant case,

CACAYORIN v. AFPMBAI G.R. No. 171298 | 15 April 2013


Extinguishment of Obligations
DOCTRINE: Article 1256 of the Civil Code authorizes consignation alone, without need of prior tender of
payment, when the creditor is unknown or when two or more persons claim the same right to collect.

Article 1256 of the Civil Code authorizes consignation alone, without need of prior tender of payment,
when the creditor is unknown or when two or more persons claim the same right to collect.
Consignation is necessarily judicial, as the Civil Code itself provides that consignation shall be made by
depositing the thing or things due at the disposal of judicial authority. While tender of payment can be
made in venues other than courts, consignation must be made only before the courts.

ROSETE v. BRIONES G.R. No. 176121 | 22 September 2014


Extinguishment of Obligations
DOCTRINE: Whoever pays for another may demand from the debtor what he has paid, except that if he
paid without the knowledge or against the will of the debtor, he can recover only insofar as the payment
has been beneficial to the debtor.

PSHS-CAGAYAN v. PIRRA CONSTRUCTION ENTERPRISES G.R. No. 204423 | 14 September 2016


Extinguishment of Obligations
DOCTRINE: if the obligation is substantially performed in good faith, the obligor, may recover as if it had
strictly and completely fulfilled its obligation, less damages suffered by the obligee.

It is provided under Article 1234 of the Civil Code that if the obligation is substantially performed in good
faith, the obligor, may recover as if it had strictly and completely fulfilled its obligation, less damages
suffered by the obligee.
SPOUSES CASTRO v. TAN G.R. No. 168940 | 24 November 2009
Essential Requisites of a Contract
DOCTRINE: The contracting parties may establish such stipulations, clauses, terms and conditions as
they may deem convenient, provided they are not contrary to law, morals, good customs, public order
or public policy.

Article 1306 of the Civil Code allows the contracting parties to establish such stipulations, clauses, terms
and conditions as they may deem convenient, provided they are not contrary to law, morals, good
customs, public order or public policy.
• While parties to a loan agreement have wide latitude to stipulate on any interest rate in view of
Central Bank Circular No. 905, which suspended the Usury Law ceiling on interest, it is worth stressing
that interest rates whenever unconscionable may still be declared illegal.

HEIRS OF MARIO PACRES v. HEIRS OF CECILIA YGOÑA G.R. No. 174719 | 5 May 2010
Essential Requisites of a Contract
DOCTRINE: Only parties to a contract can maintain an action to enforce the obligations arising under
said contract.

Under Article 1311 of the Civil Code, contracts take effect only between the parties, their assigns and
heirs (subject to exceptions not applicable here). Thus, only a party to the contract can maintain an
action to enforce the obligations arising under said contract.

Article 1311 of the Civil Code which provides that if a contract should contain some stipulation in favor
of a third person, he may demand its fulfillment. This refers to stipulations pour autrui or stipulation for
the benefit of third parties.

TOLEDO v. HYDEN G.R. No. 172139 | 8 December 2010


Essential Requisites of a Contract
DOCTRINE: A threat to enforce one’s claim through competent authority, if the claim is just or legal,
does not vitiate consent.

Article 1335 of the Civil Code provides that “a threat to enforce one’s claim through competent
authority, if the claim is just or legal, does not vitiate consent.”

SWIFT FOODS, INC. v. SPOUSES MATEO G.R. No. 170486 | 12 September 2011
Essential Requisites of a Contract
DOCTRINE: A contract is the law between the parties and those who are guilty of negligence in the
performance of their obligations are liable for damages.

MOVERTRADE CORP. v. COA and DPWH G.R. No. 204835 | 22 September 2015
Essential Requisites of a Contract
DOCTRINE: It is a basic principle in law that contracts have the force of law between the parties and
should be complied with in good faith.

Contracts have the force of law between the parties and should be complied with in good faith.
• A breach occurs where the contractor inexcusably fails to perform substantially in accordance with the
terms of the contract.

MANZANILLA v. WATERFIELDS G.R. No. 177484 | 18 July 2014


Interpretation of Contracts
DOCTRINE: Even without proper admission, the contemporaneous and subsequent acts of the parties
reveal their intention to amend the Original Contract of Lease.

Article 1371 of the Civil Code provides that, “In order to judge the intention of the contracting parties,
their contemporaneous and subsequent acts shall be principally considered.”

SONLEY v. ANCHOR SAVINGS BANK G.R. No. 205623 | 10 August 2016


Rescissible Contracts
DOCTRINE: The party aggrieved by the breach of a compromise agreement may, if he chooses, bring the
suit contemplated or involved in his original demand as if there had never been any compromise
agreement, and without bringing an action for rescission thereof.

Article 2041 of the Civil Code denotes that the party aggrieved by the breach of a compromise
agreement may, if he chooses, bring the suit contemplated or involved in his original demand, as if there
had never been any compromise agreement, without bringing an action for rescission thereof. He need
not seek a judicial declaration of rescission, for he may regard the compromise agreement already
rescinded.
• Under Article 2041 of the Civil Code, “if one of the parties fails or refuses to abide by the compromise,
the other party may either enforce the compromise or regard it as rescinded and insist upon his original
demand.”

CAMPOS v. PASTRANA G.R. No. 175994| 8 December 2009


Void and Inexistent Contracts
DOCTRINE: Contracts which are absolutely simulated or fictitious are inexistent and void from the
beginning.

Pursuant to Article 1410 of the Civil Code, an action or defense for the declaration of the inexistence of a
contract is imprescriptible.

An action to rescind is founded upon and presupposes the existence of a contract. A contract which is
null and void is no contract at all and hence, could not be the subject of rescission.

Sales

TUAZON v. DEL ROSARIO-SUAREZ G.R. No. 168325 | 8 December 2010


Nature and Form of Contract
DOCTRINE: An option contract is a contract by which the owner of property agrees with another person
that he shall have the right to buy his property at a fixed price within a certain time.
An option contract is entirely different and distinct from a right of first refusal in that in the former, the
option granted to the offeree is for a fixed period and at a determined price; Lacking these two essential
requisites, what is involved is only a right of first refusal.

LUZON DEVELOPMENT BANK v. ENRIQUEZ G.R. Nos. 168646 and 168666 | 12 January 2011
Nature and Form of Contract
DOCTRINE: Contract to Sell does not transfer ownership until there is full payment of the consideration.

The Contract to Sell did not transfer ownership over Lot 4 to Enriquez because a contract to sell is one
where the prospective seller reserves the transfer of title to the prospective buyer until the happening
of an event, such as full payment of the purchase price. It does not, by itself, transfer ownership to the
buyer.

DUARTE v. DURAN G.R. No. 173038 | 14 September 2011


Nature and Form of Contracts
DOCTRINE: A contract of sale is perfected the moment the parties agree upon the object of the sale, the
price, and the terms of payment. Once perfected, the parties are bound by it whether the contract is
verbal or in writing because no form is required.

A contract of sale is perfected the moment the parties agree upon the object of the sale, the price, and
the terms of payment.
• Once perfected, the parties are bound by it whether the contract is verbal or in writing because no
form is required. • Contrary to the view

REPUBLIC v. HEIRS OF SPS. BAUTISTA G.R. No. 181218| 30 January 2013


Nature and Form of Contract
DOCTRINE: The market value of a piece of property is the price that may be agreed upon by parties
willing but not compelled to enter into a sale. A seller in dire need of funds will accept less, and a buyer
desperate to acquire naturally agrees to pay more than what the property is truly worth.

DIEGO v. DIEGO G.R. No. 179965 | 20 February 2013


Nature and Form of Contract
DOCTRINE: An agreement which stipulates that the seller shall execute a deed of sale only upon or after
full payment of the purchase price is a contract to sell, not a contract of sale.

Stipulation to execute a deed of absolute sale upon full payment of the purchase price, is a unique and
distinguishing characteristic of a contract to sell.

ROBERN DEVELOPMENT v. PEOPLE’S LANDLESS ASSOCIATION G.R. No. 173622| 11 March 2013
Nature and Form of Contract
DOCTRINE: When there is merely an offer by one party without acceptance of the other, there is no
contract.
A contract of sale is perfected at the moment there is a meeting of minds upon the thing which is the
object of the contract and upon the price. Thus, for a contract of sale to be valid, all of the following
essential elements must concur:
a) consent or meeting of the minds;
b) determinate subject matter; and
c) price certain in money or its equivalent.

TUMIBAY v. LOPEZ G.R. No. 171692 | 16 June 2013


Nature and Form of Contract
DOCTRINE: In a contract to sell, the seller retains ownership of the property until the buyer has paid the
price in full. A buyer who covertly usurps the seller's ownership of the property prior to the full payment
of the price is in breach of the contract and the seller is entitled to rescission because the breach is
substantial and fundamental as it defeats the very object of the parties in entering into the contract to
sell.

LOCSIN v. MEKENI FOOD CORP. G.R. No. 192105| 9 December 2013


Nature and Form of Contracts
DOCTRINE: Express stipulation is needed to consider payment installments as rentals.

FIRST OPTIMA REALTY CORPORATION v. SECURITRON SECURITY SERVICES, INC. G.R. No. 199648 | 28
January 2015
Nature and Form of Contract
DOCTRINE: The payment of earnest money before the property owner agrees to sell his property cannot
bind the owner to the obligations of a seller.

As contemplated under Art. 1482 of the Civil Code, “there must first be a perfected contract of sale
before we can speak of earnest money.”
• The prior payment of earnest money even before the property owner can agree to sell his property is
irregular, and cannot be used to bind the owner to the obligations of a seller under a perfected contract
of sale, because it prevents the owner from freely giving his consent to the transaction. This constitutes
a palpable transgression of the property owner’s rights of ownership over his property.

DOMINGO v. MANZANO G.R. No. 201883 | 16 November 2016


Nature and Form of Contract
DOCTRINE: Non-fulfillment of the condition of full payment renders the contract to sell ineffective and
without force and effect.

Art. 1544 of the civil code does not apply. Since failure to pay the price in full in a contract to sell renders
the same ineffective, and without force and effect, then there is no sale to speak of.

SIY v. TOMLIN G.R. No. 205998 | 24 April 2017


Nature and Form of Contract
DOCTRINE: A sale made by the agent binds the principal to such sale.
MOLDEX REALTY v. SABERON G.R. No. 176289 | 8 April 2013
Capacity to Buy or Sell
DOCTRINE: The lack of a license to sell or the failure on the part of a subdivision developer to register
the contract to sell or deed of conveyance with the Register of Deeds does not result to the nullification
or invalidation of the contract to sell it entered into with a buyer.

BIGNAY EX-INN v. UNION BANK G.R. No. 171598 & 171590 |12 February 2014
Capacity to Buy or Sell
DOCTRINE: The sale of conjugal property without the consent of the wife is void.

TAINA MANIGQUE-STONE v. CATTLEYA LAND, INC. G.R. No. 195975 | 5 September 2016
Capacity to Buy or Sell
DOCTRINE: The rules on double sales only applies when the sales involved are valid.

In order for the rules on double sales to apply, the sales involved must be valid.

PUDADERA v. MAGALLANES G.R. No. 170073 | 18 October 2010


Obligations of the Vendor
DOCTRINE: One who buys a property with knowledge of facts which should put him upon inquiry or
investigation as to a possible defect in the title of the seller acts in bad faith.

ASIAN CONSTRUCTION and DEVELOPMENT CORPORATION v. CAPASCO G.R. No. 167942 | 29 June 2010
Obligations of the Vendee
DOCTRINE: Copies of delivery receipts, where there is sufficient uncontroverted evidence showing loss
of the originals despite the diligence exerted to find the same, are admissible.

Copies of delivery receipts, where there is sufficient uncontroverted evidence showing loss of the
originals despite the diligence exerted to find the same, are admissible.

UNION BANK OF THE PHILIPPINES v. PHILIPPINE RABBIT BUS LINES, INC. G.R. No. 205951 | 4 July 2016
Breach of Contract
DOCTRINE: The nonpayment of the purchase price renders the contract to sell ineffective not breach of
contract.

• It was incorrect to require a demand to pay prior to filing of the ejectment case, as this is not one of
the requisites in an ejectment case based on the petitioner’s contract to sell with respondent.
• The full payment of the purchase price in a contract to sell is a positive suspensive condition whose
nonfulfillment is not a breach of contract, but merely an event that prevents the seller from conveying
title to the purchase.

Lease

JOSE YUKI, JR. v. WELLINGTON CO G.R. No. 178527 | 27 November 2009


Rights and Obligations of Lessor and Lessee
DOCTRINE: The right of first refusal is available to lessees only if there is a stipulation thereto in the
contract of lease or where there is a law granting such right to them.

Agency

BUCTON v. RURAL BANK OF EL SALVADOR G.R. No. 179625 | 24 February 2014


Nature Form and Kinds of Agency
DOCTRINE: For the principal to be bound by a deed executed by an agent, the deed must be signed by
the agent for and in behalf of his principal.

Credit Transaction

SPOUSES PALADA v. SOLIDBANK CORPORATION G.R. No. 172227| 29 June 2011


Loan and Mortgage
DOCTRINE: A mortgagor is allowed to take a second or subsequent mortgage on a property already
mortgaged, subject to the prior rights of the previous mortgages.

Under Art. 1934 of the Civil Code, a contract of loan is perfected upon delivery of the object of the
contract. In this case

As a rule, a mortgagor is allowed to take a second or subsequent mortgage on a property already


mortgaged, subject to the prior rights of the previous mortgages.

ESTORES v. SUPANGAN G.R. No. 175139 | 18 April 2018


Loan
DOCTRINE: Absent any stipulation, the applicable rate of interest shall be 12% per annum when the
obligation arises out of a loan or a forbearance of money, goods or credits.

The general rule is that the applicable rate of interest shall be computed in accordance with the
stipulation of the parties. Absent any stipulation, the applicable rate of interest shall be 12% per annum
when the obligation arises out of a loan or a forbearance of money, goods or credits. In other cases, it
shall be six percent (6%).

Forbearance of money, goods or credits refers to arrangements other than loan agreements, where a
person acquiesces to the temporary use of his money, goods or credits pending happening of certain
events or fulfillment of certain conditions.

SUN LIFE OF CANADA v. TAN KIT G.R. No. 183272 | 15 October 2014
Loan
DOCTRINE: Monetary interest refers to the compensation set by the parties for the use or forbearance
of money while compensatory interest refers to the penalty or indemnity for damages imposed by law
or by the courts.
LIM v. DBP G.R. No. 177050 | 1 July 2013
Loan
DOCTRINE: Art. 1956 of the NCC provides that penalties and interest rates should be expressly stipulated
in writing.

DELA PAZ v. L&J DEVELOPMENT COMPANY G.R. No. 183360 | 8 September 2014
Loan
DOCTRINE: No interest shall be due unless it has been expressly stipulated in writing.

The lack of a written stipulation to pay interest on the loaned amount disallows a creditor from charging
monetary interest. Under Article 1956 of the Civil Code, no interest shall be due unless it has been
expressly stipulated in writing.
• Jurisprudence on the matter also holds that for interest to be due and payable, two conditions must
concur:
a) express stipulation for the payment of interest; and
b) the agreement to pay interest is reduced in writing. • Here

SILOS v. PNB G.R. No. 181045 | 2 July 2014


Loan
DOCTRINE: Any modification in the contract, such as the interest rates, must be made with the consent
of the contracting parties.

• It is basic that there can be no contract in the true sense in the absence of the element of agreement,
or of mutual assent of the parties. If this assent is wanting on the part of the one who contracts, his act
has no more efficacy than if it had been done under duress or by a person of unsound mind.
• Similarly, contract changes must be made with the consent of the contracting parties. The minds of all
the parties must meet as to the proposed modification, especially when it affects an important aspect of
the agreement. In the case of loan contracts, it cannot be gainsaid that the rate of interest is always a
vital component, for it can make or break a capital venture. Thus, any change must be mutually agreed
upon, otherwise, it is bereft of any binding effect.

METROBANK v ROSALES G.R. No. 183204| 13 January 2014


Deposit
DOCTRINE: It is not enough that the complaint was filed for a “Hold out” order to be issued, there must
be final judgment of conviction.

• The "Hold Out" clause applies only if there is a valid and existing obligation arising from any of the
sources of obligation enumerated in Article 1157 of the Civil Code, to wit: law, contracts, quasicontracts,
delict, and quasi-delict.

LANDBANK v. ONATE G.R. No. 192371 | 15 January 2014


Deposit
DOCTRINE: The unwarranted withholding of the money which rightfully pertains to another, amounts to
forbearance of money which can be considered as an involuntary loan.
Where the demand is established with reasonable certainty, the interest shall begin to run from the
time the claim is made judicially or extrajudicially (Art. 1169, Civil Code) but when such certainty cannot
be so reasonably established at the time the demand is made, the interest shall begin to run only from
the date the judgment of the court is made.

MANILA INSURANCE v. AMURAO G.R. No. 179628 | 16 January 2013


Guaranty And Suretyship
DOCTRINE: A surety's liability is joint and several, limited to the amount of the bond, and determined
strictly by the terms of contract of suretyship in relation to the principal contract between the obligor
and the obligee.

A contract of suretyship is defined as an agreement whereby a party, called the surety, guarantees the
performance by another party, called the principal or obligor, of an obligation or undertaking in favor of
a third party, called the obligee. It includes official recognizances, stipulations, bonds or undertakings
issued by any company by virtue of and under the provisions of Act No. 536, as amended by Act No.
2206. We have consistently held that a surety's liability is joint and several, limited to the amount of the
bond, and determined strictly by the terms of contract of suretyship in relation to the principal contract
between the obligor and the obligee. It bears stressing, however, that although the contract of
suretyship is secondary to the principal contract, the surety's liability to the obligee is nevertheless
direct, primary, and absolute.

SPS. EDRALIN v. PHILIPPINE VETERANS BANK G.R. No. 168523 | 9 March 2011
Mortgage
DOCTRINE: Once the title has been consolidated upon the purchaser, he becomes entitled to a writ of
possession and the trial court has the ministerial duty to issue such writ of possession.

the issuance of a writ of possession is ministerial once the purchaser has acquired absolute ownership.
During the period of redemption, the mortgagee is entitled to a writ of possession upon depositing the
approved bond. When the redemption period expires without the mortgagor exercising his right of
redemption, the mortgagor is deemed to have lost all interest over the foreclosed property, and the
purchaser acquires absolute ownership of the property.

With the consolidated title, the purchaser becomes entitled to a writ of possession and the trial court
has the ministerial duty to issue such writ of possession. Thus, the remedy of mandamus lies to compel
the performance of this ministerial duty.

The purchaser’s right for the issuance of a writ of possession is imprescriptible. The purchaser’s right to
request for the issuance of the writ of possession of the land never prescribes. The right to possess a
property merely follows the right of ownership, and it would be illogical to hold that a person having
ownership of a parcel of land Is barred from seeking possession thereof.

PHILIPPINE NATIONAL BANK v. JUMAMOY G.R. No. 169901 | 3 August 2011


Mortgage
DOCTRINE: The general rule that a mortgagee need not look beyond the title, does not apply to banks
and other financial institutions as greater care and due diligence is required of them.
A banking institution is expected to exercise due diligence before entering into a mortgage contract. The
general rule that a mortgagee need not look beyond the title does not apply to banks and other financial
institutions as greater care and due diligence is required of them.

ALANO v. PLANTER’S DEVELOPMENT BANK G.R. No. 171628|13 June 2011


Mortgage
DOCTRINE: The general rule that a mortgagee need not look beyond the title does not apply to banks
and other financial institutions as greater care and due diligence is required of them.

A banking institution is expected to exercise due diligence before entering into a mortgage contract. The
general rule that a mortgagee need not look beyond the title does not apply to banks and other financial
institutions as greater care and due diligence is required of them.
• Before approving a loan, the standard practice for banks and other financial institutions is to conduct
an ocular inspection of the property offered to be mortgaged and verify the genuineness of the title to
determine the real owner or owners thereof. Failure to do so makes them mortgagees in bad faith.

MAHINAY v. GAKO G.R. No. 165338 | 28 November 2011


Mortgage
DOCTRINE: An innocent mortgagee-for-value’s right or lien upon the land mortgaged must be respected
and protected

Sorensen claims that as an innocent mortgagee for value, she has the superior right to remain in custody
of the owner’s copy of the TCT. She insists that she merely relied on the four corners of said TCT which
at the time of the transaction did not contain any annotation of lis pendens.
• Such is not the case in the present controversy since

RUIZ v. DIMAILIG G.R. No. 204280 | 9 November 2016


Mortgage
DOCTRINE: Doctrine of Mortgagee in Good Faith can be invoked when the title of the property had
already been registered in the name of the impostor mortgaging the property.

A valid mortgage will not arise unless the mortgagor has a valid title or ownership over the mortgaged
property. By way of exception, a mortgagee can invoke that he or she derived title even if the
mortgagor's title on the property is defective, if he or she acted in good faith.
• For the Doctrine of Mortgagee in Good Faith to apply, the mortgagor, who is not the rightful owner,
must have succeeded in obtaining a Torrens title in his name thereafter in mortgaging the property.

IBM PHILIPPINES, INC. v. PRIME SYSTEMS PLUS, INC. G.R. No. 203192 | 15th August 2016
Loan
DOCTRINE: Interest rates must be agreed upon by the creditor and debtor through an express
stipulation in writing in order to be due and demandable.

Article 1956 states that interest rates should be expressly stipulated in writing in order to be due. Stated
differently, interest rates should be (1) expressly stipulated and (2) in writing in order for said rate to be
due and demandable. • In the present case
Succession

PASCO v. HEIRS OF DE GUZMAN G.R. No. 165554 | 26 July 2010


General Provisions of Succession
DOCTRINE: The heirs of a decedent have ownership over the property upon the death of the decedent,
however, distribution of the property is subject to the settlement of the estate’s liabilities.

ENDAYA v. VILLAOS G.R. No. 202426 | 27 January 2016


General Provisions of Succession
DOCTRINE: The rights of succession are transmitted from the moment of death of the decedent.

Under Article 777 of the Civil Code, the rights to the succession are transmitted from the moment of the
death of the decedent. Thus, petitioner and her coheirs should have been favored on the question of
possession, being heirs who succeeded the registered owner of the properties in dispute. Clearly,

In resolving the issue of possession in an ejectment case, the registered owner of the property is
preferred over the transferee under an unregistered deed of sale. While respondent has in his favor
deeds of sale over the eight parcels of land, these deeds were not registered

INING v. VEGA
G.R. No. 174727 | 12 August 2013
General Principles of Succession
DOCTRINE: One who is merely related by affinity to the decedent does not inherit from the latter and
cannot become a co-owner of the decedent’s property.

Under the Family Code, family relations, which is the primary basis for succession, exclude relations by
affinity. Thus, since none of the co-owners made a valid repudiation of the existing co-ownership

Land Titles and Deeds

VILBAR v. OPINION G.R. No. 176043 | 15 January 2014


Torrens System (General Principles)
DOCTRINE: Possession without registration will not confer indefeasible and incontrovertible title over a
parcel of land.

Registration is the operative act which gives validity to the transfer or creates a lien upon the land.

NICOLAS v. MARIANO G.R. No. 201070 | 1 August 2016


Torrens System (General Principles)
DOCTRINE: Torrens System only confirms ownership; It does not create ownership.

The principle nemo dat quod non habet certainly applies.


• Torrens system of land registration merely confirms ownership and does not create it. It cannot be
used to divest lawful owners of their title for the purpose of transferring it to another one who has not
acquired it by any of the modes allowed or recognized by law.
• Placing a parcel of land under the mantle of the Torrens system does not mean that ownership thereof
can no longer be disputed. Ownership is different from a certificate of title. The TCT is only the best
proof of ownership of a piece of land. Besides, the certificate cannot always be considered as conclusive
evidence of ownership.

URIETA v. ALFARO G.R. No. 164402 | 5 July 2010


Torrens System (General Principles)
DOCTRINE: The person who has a Torrens title over a land is entitled to possession thereof

A Torrens title is evidence of indefeasible title to property in favor of the person in whose name the title
appears. It is conclusive evidence with respect to the ownership of the land described therein. It is also
settled that the titleholder is entitled to all the attributes of ownership of the property, including
possession.

DELA MERCED v. GSIS G.R. No. 167140 | 23 November 2011


Torrens System (General Principles)
DOCTRINE: A transferee pendente lite of registered land, is bound by the outcome of the litigation,
whether it be for or against his transferor.

An order to cancel the transferor’s title may be enforced against his transferee, whose title is expressly
subject to the outcome of the litigation by the fact of the annotation of lis pendens. The title obtained
by the transferee pendente lite affords him no special protection; he cannot invoke the rights of a
purchaser in good faith and cannot acquire better rights than those of his predecessorin- interest.

JAKOSALEM v. BARANGAN G.R. No. 175025 | 15 February 2012


Torrens System (General Principles)
DOCTRINE: Prescription and laches does not apply to registered lands covered by the Torrens System.

Prescription and laches cannot apply to registered land covered by the Torrens system because under
the Property Registration Decree, no title to registered land in derogation to that of the registered
owner shall be acquired by prescription or adverse possession.

OLIVEROS v. SAN MIGUEL CORPORATION G.R. No. 173531 | 1 February 2012


Torrens System (General Principles)
DOCTRINE: The principle that the earlier title prevails over a subsequent one applies when there are two
apparently valid titles over a single property. Mere allegation of an earlier title will not suffice. Spurious
or non-existent titles may be subject to collateral attack because they do not enjoy indefeasibility.

The principle that the earlier title prevails over a subsequent one applies when there are two apparently
valid titles over a single property. The existence of the earlier valid title renders the subsequent title void
because a single property cannot be registered twice. A certificate is not conclusive evidence of title if it
is shown that the same land had already been registered and an earlier certificate for the same is in
existence." Clearly, a mere allegation of an earlier title will not suffice.
REPUBLIC v. HEIRS OF RAMOS G.R. No. 169481 | 22 February 2010
Torrens System (General Principles)
DOCTRINE: Section 2 of RA 26 enumerates the sources from which reconstitution of lost or destroyed
original certificates of title may be based: (1) Owner’s duplicate of the certificate of title; (2) Co-
owner’s, mortgagee’s, or lessee’s duplicate of the certificate of title; (3) Certified copy of tile; (4)
Authenticated copy of the decree of registration or patent; (5) A document, on file in the Registry of
Deed by which the property, the description of which is given in said document; and (6) Any other
document which, in the judgment of the court, is sufficient and proper basis for reconstitution the lost
or destroyed certificate of title.

RA 26 lays down the specific procedure for the reconstitution of lost or destroyed Torrens certificates of
title. It confers jurisdiction upon trial courts to hear and decide petitions for judicial reconstitution.

TRINIDAD v. PALAD G.R. No. 203397 | 9 December 2015


Torrens System (General Principles)
DOCTRINE: Title to property, evidenced by a certificate of title, is indefeasible and incontrovertible.
Those who hold such title of ownership is entitled to possession.

REPUBLIC v. PASICOLAN G.R. No. 198543 | 15 April 2015


Torrens System (General Principles)
DOCTRINE: Documentary evidence such as technical description and tax declarations are not sufficient
evidence to grant a Petition for Reconstitution under Section 2(f) of R.A. No. 26.

Sec. 2 of R.A. No. 26 enumerates the sources from which reconstitution of lost or destroyed OCTs may
be based, namely:
(a) The owner’s duplicate of the certificate of title;
(b) The co-owner’s, mortgagee’s, or lessee’s duplicate of the certificate of title;
(c) A certified copy of the certificate of title, previously issued by the register of deeds or by a legal
custodian thereof;
(d) An authenticated copy of the decree of registration or patent, as the case may be, pursuant to which
the original certificate of title was issued;
(e) A document, on file in the registry of deeds by which the property, the description of which is given
in said document, is mortgaged, leased or encumbered, or an authenticated copy of said document
showing that its original had been registered; and
(f) Any other document which, in the judgment of the court, is sufficient and proper basis for
reconstituting the lost or destroyed certificate of title.

PALOMATA v. COLMENARES G.R. No. 174251 | 15 Dec 2010


Torrens System (General Principles)
DOCTRINE: The surveys of the Bureau of Lands carry with it when presumption of regular performance
of official duty only when there is nothing on record that would arouse suspicions of irregularity.

MAHILUM v. ILANO G.R. No. 197923 | 22 June 2015


Torrens System (General Principles)
DOCTRINE: The issue of good faith in the acquisition of property only becomes relevant if a disputed title
comes within the coverage and protection of the Torrens system.

RESIDENTS OF LOWER ATAB TEACHER’S VILLAGE v. STA. MONICA G.R. No. 198878 | 15 October 2014
Torrens System (General Principles)
DOCTRINE: : For an action to quiet title to prosper, two indispensable requisites must be present,
namely:
(1) The plaintiff or complainant has a legal or an equitable title to or interest in the real property subject
of the action; and
(2) The deed, claim, encumbrance, or proceeding claimed to be casting cloud on his title must be shown
to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy.

Legal title denotes registered ownership, while equitable title means beneficial ownership.

JULAO v. DE JESUS G.R. No. 176020 | 29 September 2014


Torrens System (General Principles)
DOCTRINE: In an action for recovery of possession, the assessed value of the property sought to be
recovered determines the court’s jurisdiction.

Court held that in an action for recovery of possession, the assessed value of the property sought to be
recovered determines the court’s jurisdiction.

REPUBLIC OF THE PHILIPPINES v. SPS. BENIGNO G.R. No. 205492 | 11 March 2015
Original Registration
DOCTRINE: Unless a public land is shown to have been reclassified as alienable and disposable, it
remains part of the inalienable public domain that cannot be subject for an application for registration
of title.

Applicants for registration of title under PD 1529 must prove:


(1) That the subject land forms part of the disposable and alienable lands of the public domain; and
(2) That they have been in open, continuous, exclusive and notorious possession and occupation of the
land under a bona fide claim of ownership since 12 June 1945 or earlier.

HEIRS OF GUIAMBANGAN V. MUNICIPALITY OF KALAMANSIG G.R. No. 204899 | 27 July 2016


Original Registration
DOCTRINE: Judicial record shall be reconstituted to the extent that the parties agree.

Under Act No. 3110, the judicial record shall be reconstituted to the extent that the parties agree;
thereafter, the court shall intervene and determine what proper action to take. It can reconstitute only
that part of the record which can stand on its own, and then continue proceedings upon such record so
reconstituted.
• As far as the trial court and parties are concerned, there is admittedly a Judgment rendered in favor of
petitioners in Civil Case No. 989; indeed, the trial court even cited the dispositive portion of said
Judgment in its December 2010 Order, and respondents did the same in their Memorandum before this
Court; that said judgment became final and executory; and that the trial court directed the issuance of a
writ of execution.

REPUBLIC v. DAYAOEN G.R. No. 200773 | 8 July 2015


Original Registration
DOCTRINES:
(1) The annotation in the survey plan that the land is alienable and disposable is not the kind of evidence
required by law as proof that said land forms part of the alienable and disposable land of the public
domain.
(2) An applicant for registration of title based on an executive proclamation cannot present the
proclamation itself as evidence of the alienable and disposable character of the land applied for.

BANGUIS-TAMBUYAT v. BALCOM-TAMBUYAT G.R. No. 202805 | 23 March 2015


Original Registration
DOCTRINE: Proceedings under Sec. 108 of PD 1529 contemplates corrections or insertions of mistakes
which are only clerical but not controversial issues.

Under Sec. 108 of PD 1529, the proceeding for the erasure, alteration, or amendment of a certificate of
title may be resorted to in seven instances including:
(1) when any error, omission or mistake was made in entering a certificate or any memorandum thereon
or on any duplicate certificate; and,
(2) when there is reasonable ground for the annulment or alteration of title.

Proceedings under Sec. 108 are “summary in nature, contemplating corrections or insertions of mistakes
which are only clerical but certainly not controversial issues.

JOSEPHINE WEE v. REPUBLIC OF THE PHILIPPINES G.R. No. 177384| 8 December 2009
Subsequent Registrations
DOCTRINE: In registering land, the applicant must prove his/her claim with incontrovertible evidence.

MAHINAY v. GAKO G.R. No. 165338 | 28 November 2011


Subsequent Registrations
DOCTRINE: The annotation of a notice of lis pendens at the back of the original copy of the certificate of
title on file with the Register of Deeds is sufficient to constitute constructive notice to purchasers or
other persons subsequently dealing with the same property, regardless of whether the said annotation
is also inscribed upon the owner’s copy.

Being in the nature of involuntary registration, the annotation of the notice of lis pendens on the
original copy of the TCT on file with the Registry of Deeds is sufficient to bind third parties.

GUNTALILIB v. DELA CRUZ G.R. No. 200042 | 7 July 2016


Dealings With Unregistered Lands
DOCTRINE: The reliefs sought in an action for quieting of title and annulment of title are the same.
Torts and Damages

PNB v. CHEAH CHEE CHONG G.R. No. 170865 | 18 April 2012


Definition and Elements of Torts
DOCTRINE:
• Proximate cause is ‘that cause, which, in natural and continuous sequence, unbroken by any efficient
intervening cause, produces the injury and without which the result would not have occurred.
• Contributory negligence is conduct on the part of the injured party, contributing as a legal cause to the
harm he has suffered, which falls below the standard to which he is required to conform for his own
protection.

Proximate cause is ‘that cause, which, in natural and continuous sequence, unbroken by any efficient
intervening cause, produces the injury and without which the result would not have occurred.
• To determine the proximate cause of a controversy, the question that needs to be asked is: If the
event did not happen, would the injury have resulted? If the answer is no, then the event is the
proximate cause.

Contributory negligence is conduct on the part of the injured party, contributing as a legal cause to the
harm he has suffered, which falls below the standard to which he is required to conform for his own
protection.”

MARSMAN & CO. v. LIGO G.R. No. 198643 | 19 August 2015


Definition and Elements of Torts
DOCTRINE: For a malicious prosecution suit to prosper:
(1) prosecution must have occurred, and the defendant either was the prosecutor or instigated its
commencement;
(2) the criminal action ended with an acquittal;
(3) in bringing the action, the prosecutor acted without probable cause; and
(4) the prosecution was impelled by legal malice.

GREENSTAR EXPRESS, INC. v. UNIVERSAL ROBINA CORP. G.R. No. 205090 | 17 October 2016
The Tortfeasor
DOCTRINE: When by evidence of the ownership of vehicle and employment were proved, the
presumption on negligence will be attached, as the registered owner of the vehicle and employer.

Under Article 2180 of the New Civil Code, employers shall be held primarily and solidarily liable for
damages caused by their employees acting within the scope of their assigned tasks. To hold the
employer liable under this provision, it must be shown that an employer-employee relationship exists,
and that the employee was acting within the scope of his assigned task when the act complained of was
committed.

ORIX METRO LEASING AND FINANCE CORPORATION v. MANGALINAO G.R. Nos. 174089 & 174266 | 25
January 2012
The Concepts and Doctrines of Res Ipsa Loquitur, Last Clear Chance, Proximate Cause, Damnum
Absque Injuria, Presumption of Negligence, Vicarious Liability
DOCTRINE: • The Emergency Rule is not applicable when the driver is also negligent
• The registered owner of a vehicle could be held liable for damages even though he is no longer the
actual owner of the vehicle

SUBIC BAY LEGEND RESORTS v. FERNANDEZ G.R. No. 193426 | 29 September 2014
Actual and Compensatory Damages
DOCTRINE: Attorney's fees may be recovered when the defendant acted in gross and evident bad faith
in refusing to satisfy the plaintiff's plainly valid, just and demandable claim, or in any other case where
the court deems it just and equitable that attorney's fees and expenses of litigation should be
recovered.

Under Article 2208 of the Civil Code, attorney's fees may be recovered when the defendant acted in
gross and evident bad faith in refusing to satisfy the plaintiff's plainly valid, just and demandable claim,
or in any other case where the court deems it just and equitable that attorney's fees and expenses of
litigation should be recovered.

MCKAY v. CASWELL G.R. No. 183872 | 17 November 2014


Actual and Compensatory Damages
DOCTRINE: To justify an award of actual damages, there must be competent proof of the actual amount
of loss, credence can be given only to claims which are duly supported by receipts.

CONTINENTAL CEMENT CORPORATION v. ASEA BROWN BOVERI G.R. No. 171660 | 17 October 2011
Actual and Compensatory Damages
DOCTRINE: Damages claimed must be the natural and probable consequences of the breach, which the
parties have foreseen or could have reasonably foreseen at the time the obligation was constituted.

REPUBLIC v. SPS. SALVADOR G.R. No. 205428 | June 7, 2017


Actual and Compensatory Damages
DOCTRINE: Consequential damages are only awarded if as a result of the expropriation, the remaining
property of the owner suffers from an impairment or decrease in value.

Consequential damages are only awarded if as a result of the expropriation, the remaining property of
the owner suffers from an impairment or decrease in value. In this case, no evidence was submitted to
prove such impairment.

PEOPLE OF THE PHILIPPINES v. MARCELINO CAGA Y FABRE G.R. No. 206878| 22 August 2016
Moral Damages
DOCTRINE: In rape cases, the victim is awarded civil indemnity, exemplary damages and moral damages.
MEYR ENTERPRISES v. CORDERO G.R. No. 197336 | 3 September 2014
Moral Damages
DOCTRINE: The recovery of moral damages for malicious prosecution is allowed under Article 2219 of
the Civil Code, while attorney’s fees and expenses of litigation may be adjudged in malicious prosecution
cases pursuant to Article 2208 of the same Code.

the recovery of moral damages for malicious prosecution is allowed under Article 2219 of the Civil Code,
while attorney’s fees and expenses of litigation may be adjudged in malicious prosecution cases
pursuant to Article 2208 of the same Code.
• Malicious prosecution has been defined as ‘an action for damages brought by one against whom a
criminal prosecution, civil suit, or other legal proceeding has been instituted maliciously and without
probable cause, after the termination of such prosecution, suit, or other proceeding in favor of the
defendant therein.’

ONE NETWORK RURAL BANK v. BARIC G.R. No. 193684 | 5 March 2014
Nominal Damages
DOCTRINE: A third party who did not commit a violation of the plaintiff’s rights may not be held liable
for nominal damages.

SWIFT FOODS, INC. v. SPOUSES MATEO G.R. No. 170486 | 12 September 2011
Actual and Compensatory Damages; Moral Damages; Nominal Damages
DOCTRINE: Where there has been a breach of contract but actual damages have not been established,
nominal damages may be awarded to vindicate the injured party’s rights.
• The person claiming moral damages must prove the existence of bad faith by clear and convincing
evidence for the law always presumes good faith.
• Bad faith is defined as a state of mind affirmatively operating with furtive design or with some motive
of self-interest or ill will or for ulterior purpose.

In situations where there has been a breach of contract but actual damages have not been established,
nominal damages may be awarded to vindicate the injured party’s rights.

ENGR. APOLINARIO DUEAS VS. ALICE GUCE-AFRICA G.R. No. 165679 | 5 October 2009
Temperate or Moderate Damages
DOCTRINE: Temperate or moderate damages may be recovered when some pecuniary loss has been
suffered but its amount cannot, from the nature of the case, be proved with certainty.

In the absence of competent proof on the amount of actual damages suffered, a party is entitled to
temperate damages.
• Temperate or moderate damages may be recovered when some pecuniary loss has been suffered but
its amount cannot, from the nature of the case, be proved with certainty. In the case at bar, there is no
doubt that respondent sustained damages due to the breach committed by the petitioner.

PEOPLE v. BERNARDINO PERALTA and MICHAEL AMBAS G.R. No. 208524 | 1 June 2016
Temperate or Moderate Damages
DOCTRINE: Temperate damages are recovered when the court finds some pecuniary loss has been
suffered but its amount cannot be proved with certainty.

Under Article 2224 of the Civil Code, temperate damages may be recovered when the court finds that
some pecuniary loss had been suffered but its amount, cannot, from the nature of the case, be proved
with certainty.

PEOPLE v. BEDUYA G.R. No. 175315 | 9 Aug 2010


Actual or Compensatory Damages; Temperate or Moderate Damages
DOCTRINE: In the absence of proof on the exact sum of actual damages, there was no basis for granting
the same.

In the absence of proof on the exact sum of actual damages, there was no basis for granting the same.
"Credence can be given only to claims which are duly supported by receipts."

ADRIAN WILSON INT'L v. TMX PHILIPPINES G.R. No. 162608 | 26 July 2010
Actual and Compensatory Damages; Temperate or Moderate Damages
DOCTRINE: One is entitled to an adequate compensation only for such pecuniary loss suffered by him as
he has duly proved.

Vouchers are not receipts. A receipt is a written and signed acknowledgment that money has been
received or goods have been delivered, while a voucher is documentary record of a business
transaction.

SEGURITAN v. PEOPLE OF THE PHILIPPINES G.R. No. 172896 | 19 April 2010


Actual and Compensatory Damages; Moral Damages; Temperate or Moderate Damages
DOCTRINE: When pecuniary loss has been suffered but the amount cannot, from the nature of the case,
be proven with certainty, temperate damages may be recovered.

Moral damages were correctly awarded to the heirs of the victim without need of proof other than the
fact that a crime was committed resulting in the death of the victim and that the accused was
responsible therefor.

In lieu of actual damages, the heirs of the victim can still be awarded temperate damages. When
pecuniary loss has been suffered but the amount cannot, from the nature of the case, be proven with
certainty, temperate damages may be recovered.

CHING v. BANTOLO G.R. No. 177086 | 5 December 2012


Actual and Compensatory Damages; Exemplary or Corrective Damages
DOCTRINE: It is essential that for damages to be awarded, a claimant must satisfactorily prove during
the trial that they have a factual basis, and that the defendant’s acts have a causal connection to them.

Article 2229 of the Civil Code provides that exemplary damages may be imposed by way of example or
correction for the public good, in addition to the moral, temperate, liquidated or compensatory
damages. They are, however, not recoverable as a matter of right. They are awarded only if the guilty
party acted in a wanton, fraudulent, reckless, oppressive or malevolent manner.

PEOPLE v. BUSTAMANTE G.R. No. 172357 | 19 March 2010


Moral Damages; Exemplary or Corrective Damages
DOCTRINE: Exemplary damages may be awarded in criminal cases when the crime was committed with
one or more aggravating circumstances.

CASTRO v. PALENZUELA G.R. No. 184698 | 21 January 2013


Moral Damages; Exemplary or Corrective Damages
DOCTRINE: A demand letter presented in evidence by a lessee to prove a lesser liability for unpaid
rentals than that awarded by the trial court constitutes an admission of liability to the extent of such
lesser amount.

Moral damages may be awarded when the breach of contract is attended with bad faith Exemplary
damages may also be awarded when a wrongful act is accompanied by bad faith or when the defendant
acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner and since the award of
exemplary damages is proper in this case, attorney's fees and costs of the suit may also be recovered, as
stipulated in the lease agreement.
• Bad faith "means breach of a known duty through some motive or interest or ill will." By refusing to
honor their solemn obligations under the lease, and instead unduly profiting from these violations,
petitioners are guilty of bad faith.

PEOPLE v. YANSON G.R. No. 179195 | 3 October 2011


Actual Damages; Moral Damages; Damages in Case of Death
DOCTRINE: When death occurs due to a crime, the following damages may be awarded:
(1) civil indemnity ex delicto for the death of the victim;
(2) actual or compensatory damages;
(3) moral damages;
(4) exemplary damages; and
(5) temperate damages.

• The court makes a distinction between civil indemnity and moral damages. Civil indemnity is granted
to the heirs of the victim without need of proof other than the commission of the crime; while moral
damages are awarded despite the absence of proof of mental and emotional suffering of the victim’s
heirs.
• The award of actual damages was correctly deleted by the CA as the victim’s mother failed to present
receipts to prove the civil liability of Yanson. The award of temperate damages in lieu thereof is likewise
correct.
• The award of attorney’s fees is likewise sustained as the same was not assailed.

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