Eugenio v Drilon

Facts:
On May 10, 1972, private respondent purchased on installment basis from petitioner and his co-
owner/developer Fermin Salazar, two lots in the E & S Delta Village in Quezon City. Acting on
complaints for non-development docketed as NHA Cases Nos. 2619 and 2620 filed by the Delta Village
Homeowners’ Association, Inc., the National Housing Authority (NHA) rendered a resolution on January
17, 1979 inter alia ordering petitioner to cease and desist from making further sales of lots in said village
or in any project owned by him. Private respondent filed with the Office of Appeals, Adjudication and
Legal Affairs (OAALA) of the Human Settlements Regulatory Commission (HSRC), a complaint (Case
No. 80-589) against petitioner and spouses Rodolfo and Adelina Relevo alleging that, in view of the
above NHA resolution, he suspended payment of his amortization, but that petitioner resold one of the
two lots to the said spouses Relevo, in whose favor title to the said property was registered. Private
respondent further alleged that he suspended his payments because of petitioner’s failure to develop the
village. On October 11, 1983, the OAALA rendered a decision upholding the right of petitioner to cancel
the contract with private respondent and dismissed private respondent’s complaint. The Commission
Proper of the HSRC reversed the OAALA and, applying P.D. 957
Issue:
Whether or not the HSRC committed an error in reversing the decision of OAALA with the basis of P.D.
957
Ruling:
The petition is dismissed and deemed P.D. 957 to apply retrospectively
The court used the basis of the intent of the law, as called from its preamble and from the situation,
circumstances and conditions it sought to remedy, must be enforced. On this point, a leading authority on
statutory construction stressed. The court decided to construe P.D 957 by looking into the true intent of
the legislature. The legislative intent must have been to remedy the alarming situation by having P.D. 957
operate retrospectively even upon contracts already in existence at the time of its enactment.

Tanada v Tuvera
Facts:
The petitioner filed a petition for mandamus against multiple Presidential Decrees, Letter of Instructions,
General Orders, Executive Orders, Letter of Implementation, and Administrative Orders for violating Sec.
6 of Art. IV of the 1973 Constitution and Art. 2 of the Civil Code where it states that laws to be valid and
enforceable must be published in the Official Gazette or otherwise effectively promulgated. Petitioner
filed the petition for mandamus to compel the respondents to publish the said laws to make it effective.
Petitioner contends that the “Unless it is otherwise provided” relates to the date of the effectivity and not
to the choice to publish said Presidential Issuances.
Issue:
Whether or not the aforementioned Presidential Issuances should be published before gaining its effectivy
Ruling:
The court deemed that the presidential issuances of general application, which have not been published,
shall have no force and effect. In the spirit of transparency, the court affirmed the argument of the
petitioner that the “Unless it is otherwise provided” relates to the date of the effectivity rather than the
publication of the said law because a person should be able to know what the law prohibits him to do.
Antonio v Miranda
Facts:

The parties in this case were rival candidates for the Punong Barangay of Barangay Ilaya, Las Piñas City,
Metro Manila. After the board of canvassers proclaimed protestee-appellant Rustico Antonio, protestant-
appellee Vicente T. Miranda, Jr. filed an election protest docketed as Election Protest Case No. 97-
0017 against Antonio before the Metropolitan Trial Court of Las Piñas City. The court then ruled Vicente
Miranda as the duly elected Barangay Chairman of Barangay Ilaya, Las Piñas City, Metro Manila.
Antonio filed a Notice of Appeal with the trial court on 27 March 1998 or nine (9) days after receipt
thereof. Meanwhile, Miranda moved to execute the trial court's decision. Antonio then received a notice
from the Commission on Elections saying that he failed to perfect his appeal within the five (5) days
period prescribed for perfecting his appeal, as he filed his Notice of Appeal only on March 27, 1998 or
nine (9) days after receipt of the decision sought to be appealed.The Period aforestated is jurisdictional
and failure of the protestee to perfect his appeal within the said period deprives the Commission of its
appellate jurisdiction. Antonio asserts that Section 9 of Republic Act 6679 and Section 252 of the
Omnibus Election Code providing for a ten-day period to appeal prevails over the provisions of the
COMELEC Rules of Procedure. Petitioner submits that the dispositive portion in the Flores case only
declared unconstitutional that portion of Section 9 of Republic Act 6679 providing for appeal to the
Regional Trial Court but not the ten (10) day period of appeal.

Issue:

Whether or not COMELEC committed a grave abuse of discretion for affirming the decision of the MTC
and dismissing the petition for review of Antonio on the basis that he did not file his petition for review
on time.

Ruling:

The petition is dismissed for lack of merit.

On the previous case of Flores v COMELEC, the court deemed Sec. 9 of R.A. 6679 to be unconstitutional
as a whole. COMELEC did not commit a grave abuse of discretion amounting to lack or excess of
jurisdiction for sticking to the Sec. 252 of the Omnibus Election code. When the court deemed Sec. 9 of
R.A. 6679, even though the previous case of Flores v COMELEC had a problem with the venue of where
the petitioner filed the petition for review, the court removed the whole body of the section including the
dates for it is reliant to the part of the venue and the date cannot stand on its own.

People v Yabut
Facts:
The appellant, Yabut, was charged in the Court of First Instance of Manila with the crime of murder. On
the 1st of August 1932, the appellant, Antonio Yabut, who was currently serving a prison sentence in
Bilibid Prison, killed Sabas Aseo, another person serving a prison sentence, by hitting him at the back of
the head with a wooden club. Yabut was already convicted twice of the crime of homicide and once of
serious physical injuries. Yabut pleaded not guilty on the basis that it was not him who attacked Aseo, but
was Villafuente who struck down Aseo.
Issue:
Whether or not the lower court made an error in applying art. 160 of the Revised Penal Code
Ruling:
The petition is sustained
The appellant places much stress upon the word "another" appearing in the English translation of the
headnote of article 160 and would have us accept his deduction from the headnote that article 160 is
applicable only when the new crime which is committed by a person already serving sentence is different
from the crime for which he is serving sentence. While we do not concede that the appellant is warranted
in drawing the deduction mentioned from the English translation of the caption of article 160, it is clear
that no such deduction could be drawn from the caption. The language is plain and unambiguous. There is
not the slightest intimation in the text of article 160 that said article applies only in cases where the new
offense is different in character from the former offense for which the defendant is serving the penalty.

Flores v Comelec .
Facts:
On March 28, 1989, petitioner Roque Flores won the Sangguniang Barangay elections by receiving the
most number of votes for the position of Kagawad as per Sec. 5 of RA 6679, making him the Punong
Banrangay of Tayum, Abra. However, Nobelito Rapisora filed a petition to contest the election of the
petitioner in the Municipal Circuit Trial Court of Tayum for having 2 stray votes that could have made
him the winner of the election. The MCTC then granted the petition of Rapisora, proclaiming him as the
Punong Barangay. Flores then filed a petition for review to the Commission on Elections but was then
dismissed for they did not have jurisdiction over the decision of the MCTC as per Sec. 9 of RA 6679.
Issue:
Whether or not the decision of COMELEC to dismiss the petition for review and acknowledge the
decision of the MCTC valid
Rulling:
COMELEC using the Sec. 9 of RA 6679 for dismissing the petition for review of the Barangay Tayum,
Abra is invalid. Article IX-C, Sec. 2(2) of the Constitution states that the Commission on Elections shall
“Exercise exclusive original jurisdiction over all contests relating to the elections, returns and
qualifications of all elective regional, provincial, and city officials, and appellate jurisdiction over all
contests involving elective municipal officials decided by trial courts of general jurisdiction, or
involving elective barangay officials decided by trial courts of limited jurisdiction.” The MCTC being a
court that have limited jurisdiction, brings the duties for the review of the election to the COMELEC. Sec.
9 of RA 6679 is then deemed Uncostitutional.

Mecano v Commission on Audit

Facts:
Antonio A. Mecano, through a petition for certiorari, seeks to nullify the decision of the Commission
on Audit embodied in its 7th Indorsement, dated January 16, 1992, denying his claim for
reimbursement under Section 699 of the Revised Administrative Code (RAC), as amended, in the
total amount of P40,831.00.

Tolentino v Secretary of Finance

Facts:

The petitioners filed a motion for reconsideration for the dismissal of the petition to declare R.A.
No. 7716 or the Expanded Value-Added Tax Law as unconstitutional. Petitioners contends that
they enforced Power of the Senate to propose amendments to revenue bills. Some of the petitioners
(Tolentino, Kilosbayan, Inc., Philippine Airlines (PAL), Roco, and Chamber of Real Estate and
Builders Association (CREBA)) reiterate previous claims made by them that R.A. No. 7716 did not
"originate exclusively" in the House of Representatives as required by Art. VI, §24 of the
Constitution. Petitioners admit that H. No. 11197 was filed in the House of Representatives where it
passed three readings and that afterward it was sent to the Senate where after first reading it was
referred to the Senate Ways and Means Committee, they complain that the Senate did not pass it on
second and third readings.