Lazatin v Desierto five other legitimate siblings of the respondent and offspring of the

Stare Decisis deceased and the surviving wife, executed a deed of sale to the parcel
Facts: of land to which the respondent is duly a legal heir of without her
The complaint alleged that there were irregularities in the use by then consent, to herein petitioners at that price of P120,000. Respondent
Congressman Lazatin of his Countrywide Development Fund (CDF). filed a complaint to annul the sale with damages against the
He signed vouchers and supporting papers pertinent to the petitioners, and prays that her right of the land be exercised by
disbursement as Disbursing Officer; and he received, as claimant, redeeming the price of the land from the petitioners. RTC Branch 55
eighteen (18) checks amounting to ₱4,868,277.08. Petitioner was ruled in favor of the respondent and ordered The Register of Deeds
discovered to have (14) counts each of Malversation of Public Funds of the Province of Negros Occidental to cancel the title issued to the
and violation of Section 3 (e) of R.A. No. 3019. Said Resolution was petitioner and in lieu thereof issue a new transfer certificate of title
approved by the Ombudsman; hence, twenty-eight (28) Informations in the name of Tobias Selga consisting of an area of 37, 778 sq.m and
were filed before the Sandiganbayan. Subsequently, the OSP another new transfer certificate of title in the name of Sony Entierro
submitted to the Ombudsman its Resolution recommending the Brar consisting of an area 1,799 sq. m. upon submission of an
dismissal of the cases against petitioners for lack or insufficiency of approved subdivision plan and for the petitioners to account to
evidence. OLA recommended that the OSP Resolution be disapproved respondent her share in the produce of the land from the date of the
and the OSP be directed to proceed with the trial of the cases against first sale of the land to the petitioners up to the time that
petitioners in the Sandiganbayan. Petitioners assert that the OSP and respondent’s possession of her share of the land is restored to her.
the Ombudsman are independent and that the latter cannot compel Respondent was dissatisfied, and filed an appeal, but retracted it,
the former to continue their criminal proceeding. This was rejected fifteen days passed, and the decision of RTC Branch 55 was finalized.
by the courts, as the issue was already settled, in the records of the She then filed another complaint when the petitioners denied to give
Commissioners in the drafting of the powers of the Ombudsman and her the 10/11 share of the property in RTC Branch 56. This was
in People v Acop: It is indubitable then that Congress has the power reaffirmed, and when elevated to the CA, it reversed the decision of
to place the Office of the Special Prosecutor under the Office of the the RTC.
Ombudsman. In the same vein, Congress may remove some of the
powers granted to the Tanodbayan by P.D. No. 1630 and transfer Issue:
them to the Ombudsman; or grant the Office of the Special W/N the subsequent complain for legal redemption with damages is
Prosecutor such other powers and functions and duties as Congress barred by res judicata
may deem fit and wise. This Congress did through the passage of R.A.
No. 6770. The OSP is "merely a component of the Office of the Held:
Ombudsman and may only act under the supervision and control, and Yes. Res judicata means "a matter adjudged; a thing judicially acted
upon authority of the Ombudsman" and ruled that under R.A. No. upon or decided; a thing or matter settled by judgment”. The
6770, the power to preventively suspend is lodged only with the elements of res judicata are (1) the judgment bring sought to bar the
Ombudsman and Deputy Ombudsman. new action must be final; (2) the decision must have been rendered
by a court having jurisdiction over the subject matter and the parties;
Issue: (3) the disposition of the case must be based on a judgment or order
W/N the principle stare decisis be applied in this case on the merits; and (4) there must be identity of parties, subject matter
and causes of action as between the prior and the subsequent actions.
Held: Res judicata has two concepts. The first is bar by prior judgment under
Yes. The doctrine of stare decisis et non quieta movere (to adhere to Rule 39, Section 47(b), and the second is conclusiveness of judgment
precedents and not to unsettle things which are established) is under Rule 39, Section 47(c).
embodied in Article 8 of the Civil Code of the Philippines which
provides, thus: Judicial decisions applying or interpreting the laws or ALU v CA
the Constitution shall form a part of the legal system of the Philippines. Laches
The doctrine of stare decisis is based on the principle that once a Facts:
question of law has been examined and decided, it should be deemed The Roman Catholic Archbishop of Palo, Leyte (RCAP) is a corporation
settled and closed to further argument. The doctrine has assumed which sold to Societas Verbum Dei (SVD) or the Society of the Divine
such value in our judicial system that the Court has ruled that Word the subject 13 parcels of land on October 1958. The condition
abandonment thereof must be based only on strong and compelling attached to the deed of sale was that the parcels of land would be
reasons. used for education purposes for the development and maintenance
of St. Paul’s College, and that the lans shall be turned over to the
Under Sections 12 and 13, Article XI of the 1987 Constitution and RA ownership and possession of the RCAP in case there is or are
6770 (The Ombudsman Act of 1989), the Ombudsman has the power circumstances which will be beyond the control of the contracting
to investigate and prosecute any act or omission of a public officer or parties forcing the abandonment of educational and religious work of
employee when such act or omission appears to be illegal, unjust, the SVD with no hope for its resumption in the foreseeable future.
improper or inefficient. It has been the consistent ruling of the Court RCAP filed a cadastral case before the RTC Branch 8 praying an order
not to interfere with the Ombudsman's exercise of his investigatory directing the Registry of Deeds of Tacloban City to register the
and prosecutory powers. This is to ensure that his Office is insulated October 1958 Deed of Sale and annotate on the corresponding SVD
from any outside pressure and improper influence. titles the conditions, restrictions, and a reversionary interest of the
RCAP stipulated in the deed. On May 1995, Divine World University
Selga v Brar Tacloban (DWUT), as one of the existing schools on the parcels of
Res Judicata lands sold, issued notices to petitioners’ members advising them of
Facts: the decision of the DWUT Board of Trustees to close the university
Father of the respondent, Francisco, died and left behind an estate a starting academic year 1995-1996 and to consider themselves
parcel of land in Negros Occidental with an area of 39,577 sq. m. to dismissed. RTC then dismissed the cadastral case and also denied its
which Basilia, Francisco’s wife and mother of respondent, along with motion for reconsideration. While it concurred with the RCAP’s
arguments with regards to the jurisdiction of the RTC and the
relationship between the Union, in the previous labor case, and the Held:
RCAP, the trial court still denied the motion on the ground of laches, Yes. MEGAN is already estopped from assailing the authority of Atty.
noting that it took the RCAP 37 years after the execution of the deed Sabig. They contend that Atty. Sabig had actively participated in the
of sale before taking judicial action to assert his rights. Upon appeal proceedings before the RTC and had even filed a number of motions
however, the CA ruled that the RCAP was not barred by laches from asking for affirmative relief. They also point out that Jose Concha
asserting his legal right to cause the annotation of the pertinent (Concha), who was a member of the Board of Directors of MEGAN,
paragraphs of the deed of sale on the TCTs covering the subject accompanied Atty. Sabig during the hearing. Lastly, EPCIB and NFSC
properties. It ratiocinated that despite the lapse of 37 years, the contend that all the motions, pleadings and court orders were sent to
annotation would not be inequitable or prejudicial to any party since the office of MEGAN; yet, despite the same, MEGAN never repudiated
the SVD, under whose name the TCTs of the subject properties were the authority of Atty. Sabig. The doctrine of estoppel is based upon
issued, did not interpose any objection to the annotation. the grounds of public policy, fair dealing, good faith and justice, and
its purpose is to forbid one to speak against his own act,
Issue: representations, or commitments to the injury of one to whom they
W/N the ground of dismissal by virtue of laches is accepted were directed and who reasonably relied thereon. The rule is that the
active participation of the party against whom the action was brought,
Held: coupled with his failure to object to the jurisdiction of the court or
No. Laches means "the failure or neglect, for an unreasonable and administrative body where the action is pending, is tantamount to an
unexplained length of time, to do that which—by the exercise of due invocation of that jurisdiction and a willingness to abide by the
diligence—could or should have been done earlier." Verily, laches resolution of the case and will bar said party from later on impugning
serves to deprive a party guilty of it of any judicial remedies. Its the court or body’s jurisdiction. Based on the preceding discussion,
elements are: (1) conduct on the part of the defendant, or of one this Court holds that MEGAN’s challenge to Atty. Sabig’s authority and
under whom the defendant claims, giving rise to the situation which the RTC’s jurisdiction was a mere afterthought after having received
the complaint seeks a remedy; (2) delay in asserting the an unfavorable decision from the RTC. Certainly, it would be unjust
complainant’s rights, the complainant having had knowledge or and inequitable to the other parties if this Court were to grant such a
notice of the defendant’s conduct as having been afforded an belated jurisdictional challenge.
opportunity to institute a suit; (3) lack of knowledge or notice on the
part of the defendant that the complainant would assert the right in
which the defendant bases the suit; and (4) injury or prejudice to the
defendant in the event relief is accorded to the complainant, or the
suit is not held barred. As the CA aptly observed, no prejudice can
result from the annotation pleaded by the RCAP since the SVD, the
property purchaser in the October 1958 transaction, did not oppose
the annotation of the conditions, restrictions, and a reversionary right
of the RCAP over the subject properties.

Megan Sugar Corp v RTC

Estoppel
Facts:
Respondent New Frontier Sugar Corporation (NFSC) obtained a loan
with co-respondent Equitable CPI Bank (ECPIB) and was secured by a
real estate mortgage over NFSC’s land and a chattel mortgage over
NFSC’s sugar mill. Because of NFSC’s continued indebtedness to ECPIB,
the former entered into a contract with Central Iloilo Milling
Corporation (CIMCO) where the latter will take over the management
and operation of the NFSC sugar factories for three years. NFSC failed
to pay its debt to ECPIB which forced the latter to foreclose the land
where CIMCO is situated. CIMCO then filed a complaint in the RTC and
impleaded ECPIB, thus the foreclosure was desisted. CIMCO entered
into a contract with petitioner MEGAN wherein the petitioner would
assume CIMCO’s rights, interests and obligations over the property.
Then, Passi Sugar claimed that it had entered into a contract to sell
with ECPIB after the latter foreclosed NFSC’s land and sugar mill prior
to the decision of the RTC. After several proceedings with regards to
the delivery of rentals, shares, and deposits, the RTC riled that
MEGAN, is ordered to deposit in escrow the sugar quedans
representing the miller’s share to the Court every Friday of the week.
MEGAN then moved for petition for certiorari, stating that RTC erred
when it determined that MEGAN was subrogated to the obligations
of CIMICO and; second, that the RTC had no jurisdiction over MEGAN.

Issue:
W/N MEGAN is estopped from assailing the jurisdiction of the RTC in
hearing the petition as it had already participated in the former
proceedings