DR. ULPIANO P.

SARMIENTO III
Dean

ATTY. CARLO D. BUSMENTE

Vice Dean

ATTY. MARIA ELIZA CAMILLE B. YAMAMOTO-SANTOS

Prefect of Student Affairs

ATTY. ROBEN B. CADUGO JR.

Administrative Officer

ATTY. ROBEN B. CADUGO JR.

ATTY. PAULINO Q. UNGOS III
Advisers

SAMUEL JOSHUA CRUZ

Overall Chairperson

REX ROLAND REGIO DIAZMEAN KYLA SOTELO

Chairperson, Academics Chairperson, Recruitment & Membership

MAEIA MIKAELA MAYUGA BRYAN AREVALO

Chairperson, ALD Chairperson, Partnership & External
Relations
PIA MONICA DIMAGUILA
Chairperson, Bar Matters THERESE JEANNE BELARMINO
Chairperson, Operations & Logistics
ANDREA JOSES TAN
Chairperson, Communications ROSANNA NAIG
Chairperson, EDP

MIGERN ESTABILLO MA. LOLITA KIM PALENCIA

Chairperson, Secretariat
Chairperson, Bar Mentoring Program

MARIA LOURDES MENDOZA

Chairperson, Finance

1
 DR. ULPIANO P. SARMIENTO III
Dean

ATTY. CARLO D. BUSMENTE

Vice Dean

ATTY. MARIA ELIZA CAMILLE B. YAMAMOTO-SANTOS

Prefect of Student Affairs

ATTY. ROBEN B. CADUGO JR.

Administrative Officer

ATTY. ROBEN B. CADUGO JR.

ATTY. PAULINO Q. UNGOS III
Advisers

SAMUEL JOSHUA CRUZ

Overall Chairperson

REX ROLAND REGIO MARIA LOURDES MENDOZA

Chairperson, Academics Chairperson, Finance

MAEIA MIKHAELA MAYUGA DIAZMEAN KYLA SOTELO

Chairperson, Assessment, Learning & Chairperson, Recruitment & Membership
Development
BRYAN AREVALO
PIA MONICA DIMAGUILA Chairperson, Partnership & External
Chairperson, Bar Matters Relations

ANDREA JOSES TAN THERESE JEANNE BELARMINO

Chairperson, Communications Chairperson, Operations & Logistics

MIGERN COLE ESTABILLO ROSANNA NAIG

Chairperson, Secretariat Chairperson, EDP

MA. LOLITA KIM PALENCIA

Chairperson, Bar Mentoring Program
ZYRREL DAVE NAVELA JUSTINE VINCENT PASCUAL
MARK COLOCADO JOEL REMENTILLA
Deputy Chairpersons, Operations & Deputy Chairpersons, Academics
Logistics
GISELLE MARIE DIAZ
Deputy Chairperson, Communications
ANTONINA CONCEPCION
MIER DELA CRUZ JILL QUIMSON
Deputy Chairperson, Membership
MARIEL ARAGON
Deputy Chairpersons, ALD
ARAMAINE BALON
MICHAEL DOMINIQUE ISIDRO JASMINE JAGUNAP
Deputy Chairpersons, Finance
Deputy Chairperson, Bar Matters

ANGEL ROSE CINCO AARON FRANCISCO

MA. REGINA SANTIAGO RHIANA NAVARRO
AUBREY ANGELI TAN Deputy Chairpersons, Bar Mentoring
ZAMANTHA JOSH ALCAZAR Program
DOMSKI CANDOLITA
Deputy Chairpersons, EDP LAARMIE GOCE
ERIKA PACA
KATHERINE ANNE LABAYO Deputy Chairpersons, Secretariat
Deputy Chairperson, Ex Parte

HANZ CHRISTIAN MIRAFLOR

Commercial Law KIMBERLY JOY NAPARAN
Political Law
ISABELA SOFIA ELEAZAR
Legal Ethics ANTHONY JOHN RODRIGUEZ
Taxation Law
LANCE LIZOR PUNZALAN
Remedial Law
LOUISE ATHENA MONSERRAT
Civil Law
FELICE LEONAJOY HERNANDEZ
Criminal Law
ERYL AMRHEIN AGUSTIN
Labor Law
QUENNIE SERENO ENRIC ALCAIDE
Commercial Law Political Law

SOFIA REGINA YASAY ROSCH MANUEL

Legal Ethics Taxation Law

NALA ANOVER HILLARY SANTILLAN

Remedial Law Civil Law

JANNAH ODTUHAN BIANCA VELASCO

Criminal Law Labor Law

JABEZ CACAL
FRANCIA MARIE DIMACULANGAN
LEIGH ANNE DARLENE DISPO
RECEL DOMINGO
YUUMEI ESMA
APRILEENE GUEVARRA
KARMELA DOREEN SALVADOR
AUSTIN SANTUELE
AREANI FRANCINE SITON
ATHERINE KAYE VILLAFUERTE
This work is the intellectual property of the SAN BEDA COLLEGE ALABANG
SCHOOL OF LAW and SAN BEDA COLLEGE ALABANG CENTRALIZED BAR
OPERATIONS 2024. It is intended solely for the use of the individuals to
which it is addressed – the Bedan community.

Publication, reproduction, dissemination, and distribution, or copying of

the document without the prior consent of the SAN BEDA COLLEGE
ALABANG SCHOOL OF LAW CENTRALIZED BAR OPERATIONS ACADEMICS
COMMITTEE 2024 is strictly prohibited.

Material includes both cases penned by Justice Hernando and recent

landmark cases decided by the Supreme Court.

COPYRIGHT © 2024
SAN BEDA COLLEGE ALABANG SCHOOL OF LAW
SAN BEDA COLLEGE ALABANG SCHOOL OF LAW CENTRALIZED BAR
OPERATIONS 2024
ALL RIGHTS RESERVED BY THE AUTHORS

TABLE OF CONTENTS

HUMAN RELATIONS.................................................................................................................. 11
Unjust Enrichment (Civil Code,.............................................................................................. 11
Arts. 22-23 and 2142-2143)................................................................................................... 11
NATIONAL POWER CORPORATION vs. BENGUET ELECTRIC COOPERATIVE.. 11
PERSONS AND FAMILY RELATIONS....................................................................................... 12
Void Marriages; Effects and Remedies..................................................................................12
(Family Code, Arts. 35-44 and 50-54)................................................................................... 12
QUIOGUE, JR. vs. QUIOGUE................................................................................... 12
MUTYA-SUMILHIG vs. SUMILHIG............................................................................ 13
DEDICATORIA vs. DEDICATORIA............................................................................ 14
Property Relations Between Spouses................................................................................... 15
(Family Code, Arts. 74-81).....................................................................................................15
STRONG FORT WAREHOUSING CORP. vs. BANTA.............................................. 15
Marriage Settlements.............................................................................................................16
(Family Code, Arts. 75-81).....................................................................................................16
ALEXANDER vs. SPOUSES ESCALONA.................................................................16
PROPERTY, OWNERSHIP, AND ITS MODIFICATIONS............................................................17
Quieting of Title (Civil Code, Arts. 476-481).......................................................................... 17
SPOUSES VELARDE vs. HEIRS OF CANDARI....................................................... 17
DIFFERENT MODES OF ACQUIRING OWNERSHIP (Civil Code, Art. 712)........................... 18
Prescription (Civil Code, Arts. 1106-1155)............................................................................. 18
ALBA vs. AROLLADO................................................................................................18
LAND TITLES AND DEEDS....................................................................................................... 19
Regalian Doctrine (1987 Consti., Art. XII, Sec. 2)................................................................. 19
CENTRAL BAY RECLAMATION AND DEVELOPMENT CORP. vs. COMMISSION
ON AUDIT..................................................................................................................19
Registry of Property (Civil Code, Arts. 708-711).................................................................... 20
HEIRS OF BASTIDA vs. HEIRS OF FERNANDEZ................................................... 20
Original Registration................................................................................................................. 21
Innocent Purchaser for Value; Rights.................................................................................... 21
(P.D. No. 1529, Sec. 32)........................................................................................................ 21
JIMENEZ vs. JIMENEZ, JR....................................................................................... 21
WILLS AND SUCCESSION........................................................................................................ 22
Testamentary Succession......................................................................................................22
Allowance and Disallowance of Wills - Civil Code, Arts. 838-839....................................22
KUCSKAR vs. SEKITO.............................................................................................. 22
OBLIGATIONS AND CONTRACTS............................................................................................23
Obligations.............................................................................................................................23
Extinguishment of Obligations - Civil Code, Arts. 1231-1304.......................................... 23
MANILA CREDIT CORPORATION vs. VIROOMAL.................................................. 23
Contracts............................................................................................................................... 24
CHINGKOE vs. CHINGKOE...................................................................................... 24
QUIAMBAO vs. CHINA BANKING CORP..................................................................25
PRIVATIZATION AND MANAGEMENT OFFICE vs. NOCOM...................................26
Essential Requisites of Contract............................................................................................27
(Civil Code, Art. 1318)........................................................................................................... 27
THE COMMONER LENDING CORP. vs. SPOUSES VILLANUEVA......................... 27
Principles of Contracts...........................................................................................................28
(Civil Code, Arts. 1159 and 1305-1317).................................................................................28
Mutuality...........................................................................................................................28
THE COMMONER LENDING CORP. vs. SPOUSES VILLANUEVA......................... 28
HOME CREDIT MUTUAL BUILDING AND LOAN ASSOCIATION vs. PRUDENTE. 29
Real vs. Consensual Contracts; Forms, Reformation, and Interpretation............................. 30
(Civil Code, Arts. 1356-1379)................................................................................................ 30

9
 BANICO vs. STAGER................................................................................................ 30
PATENIA-KINATAC-AN vs. PATENIA-DECENA........................................................ 31
ALBA vs. AROLLADO................................................................................................32
INTEGRATED MICRO ELECTRONICS, INC. vs. STANDARD INSURANCE CO.,
INC.............................................................................................................................33
PHILIPPINE CHARITY SWEEPSTAKES OFFICE vs. MENDOZA............................34
Defective Contracts................................................................................................................... 35
Void - Civil Code, Arts. 1409-1422.........................................................................................35
CENTRAL BAY RECLAMATION AND DEVELOPMENT CORP. vs. COMMISSION
ON AUDIT..................................................................................................................35
CONTRACT OF SALE................................................................................................................ 36
Conventional Redemption..................................................................................................... 36
(Civil Code, Arts. 1601 and 1606-1618);............................................................................... 36
Legal Redemption (Civil Code, Arts. 1619-1623).................................................................. 36
RAMA vs. SPOUSES NOGRA.................................................................................. 36
BANK OF THE PHILIPPINE ISLANDS vs. LCL CAPITAL, INC.................................37
COMPROMISE AGREEMEN................................................................................................ 38
(Civil Code, Arts. 2028-2041)................................................................................................ 38
CITY GOVERNMENT OF TACLOBAN vs. COURT OF APPEALS........................... 38
ILOCOS NORTE ELECTRIC COOPERATIVE vs. ANDRES-RANJO....................... 39
QUASI-CONTRACTS..................................................................................................................40
(Civil Code, Arts. 2142-2143).................................................................................................... 40
Solutio Indebiti (Civil Code, Arts. 2154-2163)........................................................................40
DEPARTMENT OF AGRARIAN REFORM EMPLOYEES ASSOCIATION vs.
COMMISSION ON AUDIT......................................................................................... 40
NGALOB vs. COMMISSION ON AUDIT....................................................................41
HAGONOY WATER DISTRICT vs. COMMISSION ON AUDIT................................. 42

10
 HUMAN RELATIONS

Unjust Enrichment (Civil Code,

Arts. 22-23 and 2142-2143)

NATIONAL POWER CORPORATION vs. BENGUET

ELECTRIC COOPERATIVE
G.R. No. 218378 | June 14, 2021

FACTS
National Power Corporation (NAPOCOR) and Benguet Electric Cooperative
(BENECO) executed a Contract of Sale of Electricity and Transition Contract for
the supply of electricity. BENECO discovered that NAPOCOR had been using a
wrong Current Transformer Ratio in its metering system which resulted in
underbilling; as such, NAPOCOR insists that BENECO was unjustly enriched and
liable for the underbilling because it consumed the electricity but paid half the
price. The Court held that the BENECO is liable for the underbilling based on the
Contract, not the principle of unjust enrichment.

DOCTRINE
Unjust enrichment exists when a person unfairly retains a benefit, money, or
property against the fundamental principles of justice, equity, and good
conscience. The principle against unjust enrichment is embodied in Article 2244
of the Civil Code, which provides that a person who acquires or comes into
possession of something at the expense of another without just or legal ground
must return it. To be applicable, Article 22 requires that: (a) a person is benefited
without a valid basis or justification, and (b) such benefit is derived at another's
expense or damage.

11
 PERSONS AND FAMILY RELATIONS

Void Marriages; Effects and Remedies

(Family Code, Arts. 35-44 and 50-54)

QUIOGUE, JR. vs. QUIOGUE

G.R. No. 203992 | August 22, 2022

FACTS
Antonio Quiogue filed a Petition for Declaration of Nullity of Marriage on the
ground of psychological incapacity where he stated that his wife, Maribel
Quiogue, is psychologically incapacitated to comply with the basic marital
obligations. A witness for Antonio, Dr. Garcia, conducted a mental status
assessment and clinical psychiatric interviews with Antonio and Maribel and
recommended that the marriage between the parties be nullified. The RTC ruled
in favor of the nullification but the CA reversed the same and thereafter, the SC
reversed the decision of the CA leading to the nullification of the marriage.

DOCTRINE
While it is true that infidelity is a ground for legal separation, the same may also
be an indication of a psychological incapacity if, for the same reason, one is
completely unable to discharge the essential obligations of marriage. To be
considered as a form of psychological incapacity, infidelity must satisfy the
requirements of (1) gravity or severity, (2) antecedence, and (3) legal
incurability or persistence during the marriage.

12
 MUTYA-SUMILHIG vs. SUMILHIG
G.R. No. 230711 | August 22, 2022

FACTS
Carolyn Sumilhig filed a Petition for Declaration of Nullity of Marriage on the
ground of psychological incapacity of her husband, Joselito Sumilhig. The RTC
denied the petition as well as the CA stating that the psychiatric evaluations
presented were insufficient as the subject, Joselito, was not personally
evaluated. The SC granted the Petition as the presence of the party suffering
from psychological incapacity is not required for him to be evaluated as such.

DOCTRINE
In Tan-Andal, the Court states that the spouse of the person alleged to be
psychologically incapacitated may be interviewed by the psychologist since he
or she is in the best position to describe his or her spouse's inability to comply
with marital obligations. Notwithstanding, there is no legal and jurisprudential
requirement that the person to be declared psychologically incapacitated be
personally examined by a physician. What matters is that the totality of
evidence presented establishes the party's psychological condition. The
psychiatric evaluations of psychiatrists are reliable even when the subject was
not interviewed.

13
 DEDICATORIA vs. DEDICATORIA
G.R. No. 250618 | July 20, 2022

FACTS
Jennifer Dedicatoria filed a Petition for Declaration of Nullity of Marriage due
to Ferdinand's psychological incapacity, however, Ferdinand failed to file an
answer and the OSG entered its appearance for the Republic of the Philippines.
During trial, Jennifer presented Dr. Montefalcon, who diagnosed Ferdinand to be
suffering from Dependent Personality Disorder, rendering him incapacitated to
perform his marital obligations. The SC acknowledged Dr. Montefalcon’s
assessment and found no reason to discredit her testimony on this matter.

DOCTRINE
Psychological incapacity as a ground to consider a marriage void under Article
36 of the Family Code, is not a medical, but a legal concept. Application of rigid
medical parameters for its determination is, thus, ill-suited. Expert opinions
furnished by psychiatrists or psychologists on the psychological temperament
of parties are not indispensable. It is enough that the totality of clear and
convincing evidence proves that an enduring aspect of a spouse's personality,
existing at the time of the celebration of marriage, renders him or her incapable
of understanding or performing essential marital obligations.

14
 Property Relations Between Spouses
(Family Code, Arts. 74-81)

STRONG FORT WAREHOUSING CORP. vs. BANTA

G.R. No. 222369 & 222502 (Resolution) | November 16, 2020

FACTS
Antonio obtained loans which were secured by a Real Estate Mortgage covering
conjugal properties. Strong Fort argues that the subject deeds of mortgage
should remain valid with respect to the conjugal properties that belong to
Antonio. The SC ruled that the real estate mortgage with respect to the conjugal
properties covered by the mortgage that belong to Antonio is void since there is
no consent from his wife.

DOCTRINE
Any disposition or encumbrance of a conjugal property by one spouse must be
consented to, by the other; otherwise, it is void. Prior to the liquidation of the
conjugal partnership, the interest of each spouse in the conjugal assets is
inchoate, a mere expectancy, which constitutes neither a legal nor an equitable
estate, and does not ripen into a title until it appears that there are assets in the
community as a result of the liquidation and settlement. The interest of each
spouse is limited to the net remainder resulting from the liquidation of the
affairs of the partnership after its dissolution. Thus, the right of the husband or
wife to one-half of the conjugal assets does not vest until the dissolution and
liquidation of the conjugal partnership, or after dissolution of the marriage,
when it is finally determined that, after settlement of conjugal obligations, there
are net assets left which can be divided between the spouses or their respective
heirs.

15
 Marriage Settlements
(Family Code, Arts. 75-81)

ALEXANDER vs. SPOUSES ESCALONA

G.R. No. 256141 | July 19, 2022

FACTS
Spouses Jorge and Hilaria Escalona, who were married in 1960, acquired
unregistered parcels of land known as Lot Nos. 1 and 2 during their marriage. In
1998, Jorge waived his right over Lot No. 1 in favor of his illegitimate child,
Reygan Escalona, who relinquished his right over the said lot to Belinda
Alexander. In 2005, Reygan and Belinda entered into a Deed of Absolute Sale
covering both lots.

DOCTRINE
The Court holds that more than the date of the marriage of the spouses, the
applicable law must be reckoned on the date of the alienation or encumbrance
of the conjugal property made without the consent of the other spouse, to wit:

1. The alienation or encumbrance of the conjugal property, without the wife’s

consent, made BEFORE the effectivity of the Family Code, is not void but merely
voidable.

The applicable laws are Articles 166 and 173 of the Civil Code. The wife may file
an action for annulment of contract within 10 years from the transaction; and

2. The alienation or encumbrance of the conjugal property, without the authority

of the court or the written consent of the other spouse, made AFTER the
effectivity of the Family Code is void.

The applicable law is Article 124 of the Family Code without prejudice to vested
rights in the property acquired before August 3, 1988. Unless the transaction is
accepted by the non-consenting spouse or is authorized by the court, an action
for declaration of nullity of the contract may be filed before the continuing offer
on the part of the consenting spouse and the third person becomes ineffective.

16
 PROPERTY, OWNERSHIP, AND ITS
MODIFICATIONS

Quieting of Title (Civil Code, Arts. 476-481)

SPOUSES VELARDE vs. HEIRS OF CANDARI

G.R. No. 190057 | October 17, 2022

FACTS
Concepcion sold parcels of land to Isagani with the right to repurchase but the
former failed to redeem the same resulting in the transfer of ownership over the
properties to Isagani. After Isagani’s death, Concepcion began to appropriate a
part of the property as rental spaces prompting the heirs of Isagani to file an
action for quieting of title. The RTC ruled in favor of the heirs of Isagani while
the CA reversed the same resulting in a Petition for Review on Certiorari to the
SC where the same reinstated the judgment of the RTC.

DOCTRINE
Two indispensable requisites must concur for an action for quieting of title to
prosper, namely: (1) the plaintiff 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 their title must be shown to be in fact
invalid or inoperative despite its prima facie appearance of validity or legal
efficacy.

17
 DIFFERENT MODES OF ACQUIRING
OWNERSHIP (Civil Code, Art. 712)

Prescription (Civil Code, Arts. 1106-1155)

ALBA vs. AROLLADO

G.R. No. 237140 (Resolution) | October 5, 2020

FACTS
Arollado purchased petroleum products on credit and thereafter, issued three
(3) checks which were all dishonored. Alba filed an action for collection of a sum
of money; however, Arollado argues that prescription bars the action. The Court
ruled that Alba’s cause of action has prescribed in 6 years as the contract in
issue was a verbal rather than 10 years for written contracts. The reckoning
point of the prescriptive period shall accrue from the date the cause of action
arises.

DOCTRINE
The reckoning point of the prescriptive period shall accrue from the date the
cause of action arises. Furthermore, prescription of actions is only interrupted
when: (1) They are filed before the court; (2) When there is a written extrajudicial
demand by the creditors; or (3) When there is any written acknowledgement of
the debt by the debtor.

18
 LAND TITLES AND DEEDS

Regalian Doctrine (1987 Consti., Art. XII, Sec. 2)

CENTRAL BAY RECLAMATION AND DEVELOPMENT CORP.

vs. COMMISSION ON AUDIT
G.R. No. 252940 | April 5, 2022

FACTS
This case is rooted in a Joint Venture Agreement (JVA) entered into by the
Philippine Reclamation Authority (PRA) and Central Bay Reclamation and
Development Corporation (Central Bay). The said JVA having been declared by
the Supreme Court as null and void for violating the constitutional provisions on
the prohibition against private corporations from acquiring any kind of
alienable land of the public domain except through a lease, the Central Bay filed
a money claim against PRA before the Commission on Audit (COA). The parties
submitted a Compromise Agreement – which the COA disapproved - obliged
PRA to transfer the reclaimed land to Central Bay's qualified assignee.

DOCTRINE
Private corporations cannot own alienable lands of the public domain but may
lease them for a limited period. Section 3, Article XII of the 1987 Constitution
provides that private corporations "may not hold such alienable lands of the
public domain except by lease, for a period not exceeding twenty-five years,
renewable for not more than twenty-five years, and not to exceed one thousand
hectares in area."

19
 Registry of Property (Civil Code, Arts. 708-711)

HEIRS OF BASTIDA vs. HEIRS OF FERNANDEZ

G.R. No. 204420 (Resolution) | October 7, 2020

FACTS
The case involves a conflict of jurisdiction between the Department of Agrarian
Reform Adjudication Board (DARAB) and the Department of Agrarian Reform
Secretary over the cancellation of a Certificate of Land Award (CLOA). The heirs
(Heirs of Bastida) of Teofilo Bastida (Teofilo) sought to cancel the CLOA granted
to the heirs (Heirs of Fernandez) of Angel Fernandez (Angel).

DOCTRINE
At first glance, it would appear that jurisdiction over the cancellation of CLOA
recorded with the Registry of Deeds lies with the DARAB. However,
jurisprudence edifies that for the DARAB to have jurisdiction, the case must
relate to an agrarian dispute between landowners and tenants to whom a CLOA
had been issued.1

1
ADDITIONAL NOTES:

The heirs of Teofilo did not allege any tenancy, leasehold, or agrarian relations
with the heirs of Angel except for the fact that Lot No. 990 is an agricultural
land. In their complaint, the heirs of Teofilo focused on the erroneous grant of
the CLOA based on the grounds that Lot No. 990 was prematurely placed under
the CARP.

20
 Original Registration

Innocent Purchaser for Value; Rights

(P.D. No. 1529, Sec. 32)

JIMENEZ vs. JIMENEZ, JR.

G.R. No. 228011 | February 10, 2021

FACTS
Corona Jimenez (Corona) is the registered owner of a lot and had children.
During the settlement of Corona’s estate, the Jimenez siblings discovered a
deed of donation allegedly executed by Corona in favor of Damian on August
31, 2000 over the disputed property. Damian mortgaged the property to
Calubad and Keh for a loan.

DOCTRINE
The doctrine of "the mortgagee in good faith" is based on the rule that all
persons dealing with property covered by a Torrens Certificate of Title, as
buyers or mortgagees, are not required to go beyond what appears on the face
of the title. The public interest in upholding the indefeasibility of a certificate of
title, as evidence of the lawful ownership of the land or of any encumbrance
thereon, protects a buyer or mortgagee who, in good faith, relied upon what
appears on the face of the certificate of title.

21
 WILLS AND SUCCESSION

Testamentary Succession

Allowance and Disallowance of Wills - Civil Code, Arts. 838-839

KUCSKAR vs. SEKITO

G.R. No. 237449 | December 2, 2020

FACTS
Aida Bambao, a naturalized American citizen, executed a Last Will and
Testament in California where she nominated her cousin, Cosme Sekito, Jr., as a
special independent executor over her assets located in the Philippines. Aida
died a widow in her residence at Long Beach, California. Cosme filed a Petition
for the Allowance of Will/Appointment of Guardian Ad Litem before the RTC;
however, Linda Kucskar, the decedent's sister, and one of the heirs named in the
will, opposed the petition and claimed that she is the one defraying all of Elsa's
expenses.

DOCTRINE
A foreign will can have legal effects in the Philippines, but the party invoking the
application of a foreign law has the burden of proving the law. In the absence of
proper proof of the foreign law, the court applies Philippine laws in determining
the issues, particularly in the probate of a will, which must adhere to specific
formalities for validity. The court rejects the application of the substantial
compliance rule and highlights the significance of acknowledging the will before
a notary public, stating that estoppel is not applicable in probate proceedings
due to their public interest nature.

22
 OBLIGATIONS AND CONTRACTS

Obligations

Extinguishment of Obligations - Civil Code, Arts. 1231-1304

MANILA CREDIT CORPORATION vs. VIROOMAL

G.R. No. 258526 |January 11, 2023

FACTS
Spouses Viroomal obtained a loan under a promissory note from Manila Credit,
but eventually requested a loan restructuring due to difficulties in payment
resulting in an execution of a second promissory note representing the unpaid
balance from the first promissory note. When respondents failed to make timely
amortizations, petitioner demanded full payment of the outstanding obligation
which the respondents claimed that they have already paid a total of Php
1,175,638.12 and thus asked for recomputation but were ignored by petitioner.

DOCTRINE
When a principal obligation has been extinguished, an accessory contract
automatically terminates because accessory contracts cannot exist
independently of the principal.

23
 Contracts

CHINGKOE vs. CHINGKOE

G.R. No. 244076 | March 16, 2022

FACTS
Faustino allowed his brother, Felix, to occupy his property in 1990, and signed
the Deed of Absolute Sale to appease Felix without the intention to sell the
subject property. Felix claimed to have been in possession of the land since 1989
and that he purchased it from Faustino. Faustino refused to surrender the
Owner’s Duplicate of the Transfer Certificate of Title (TCT) which prompted Felix
filed to file a complaint for specific performance with damages to compel
Faustino to turn over the TCT and facilitate transfer pursuant to the Deed of
Sale.

DOCTRINE
Article 1345 of the Civil Code provides that simulation of a contract may be
absolute or relative. The former takes place when the parties do not intend to be
bound at all; the latter, when the parties conceal their true agreement.
Furthermore, Article 1346 of the same law states that an absolutely simulated or
fictitious contract is void. The main characteristic of an absolute simulation is
that the apparent contract is not really desired or intended to produce a legal
effect or alter the parties’ juridical situation.

24
 QUIAMBAO vs. CHINA BANKING CORP.
G.R. No. 238462 | May 12, 2021

FACTS
Elena Quiambao obtained a loan from China Banking Corporation for her
business, and executed a Real Estate Mortgage (REM) over a parcel of land to
secure the loan. The mortgage included a “blanket mortgage clause” stating
that the REM would secure the payment of obligations already incurred or which
may be subsequently incurred. China Banking Corporation filed for foreclosure
of the mortgage due to default on the loans as evidenced by promissory notes.
Elena avered that they signed the eight PNs in blank without understanding the
implications.

DOCTRINE
A contract of adhesion is a veritable trap for the weaker party whom the courts
are bound to protect from abuse and imposition. Hence, in case of doubt which
will cause a great imbalance of rights, the contract shall be construed strictly
against the party who prepared it.

25
PRIVATIZATION AND MANAGEMENT OFFICE vs. NOCOM
G.R. No. 250477 | November 9, 2020

FACTS
The Regional Trial Court approved a Compromise Agreement between the Asset
Privatization and Mariano Nocom where they ratified an amended Contract of
Lease. The Privatization Management Office, Asset Privatization’s successor,
argued that the contract of lease has already expired while Mariano insisted
that the contract is yet to expire and that he is still bound to exercise his right to
renew. The Supreme Court said that the Compromise Agreement explicitly
provided for a mere extension of the lease period and not a right to renew.

DOCTRINE
It is a cardinal rule in the interpretation of contracts that "if the terms of a
contract are clear and leave no doubt upon the intention of the contracting
parties, the literal meaning of its stipulations shall control." The process of
interpreting a contract requires the court to make a preliminary inquiry as to
whether the contract before it is ambiguous. A contract provision is ambiguous
if it is susceptible of two reasonable alternative interpretations. Where the
written terms of the contract are not ambiguous and can only be read one way,
the court will interpret the agreement as a matter of law.

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 Essential Requisites of Contract
(Civil Code, Art. 1318)

THE COMMONER LENDING CORP. vs. SPOUSES

VILLANUEVA
G.R. No. 235260 (Resolution) | August 27, 2020

FACTS
Spouses Villanueva borrowed money from TCLC and executed a real estate
mortgage to secure the obligation. When Spouses Villanueva failed to settle
their balance, TCLC foreclosed the mortgage and sold the property. The spouses
were seeking to annul the said sale, stating that the contract did not expressly
grant TCLC the power to sell.

DOCTRINE
It is basic that obligations arising from contracts have the force of law between
the parties and should be complied with in good faith. The stipulations are
binding between the contracting parties unless they are contrary to law, morals,
good customs, public order, or public policy.

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 Principles of Contracts
(Civil Code, Arts. 1159 and 1305-1317)

Mutuality

THE COMMONER LENDING CORP. vs. SPOUSES

VILLANUEVA
G.R. No. 235260 (Resolution) | August 27, 2020

FACTS
Spouses Villanueva borrowed money from TCLC. They executed a real estate
mortgage to secure the obligation, when they were not able to settle their
balance, TCLC foreclosed the mortgage and sold the property. The spouses were
seeking to annul the said sale, stating that the contract did not expressly grant
TCLC the power to sell.

DOCTRINE
The courts cannot supply material stipulations or read into the contract words
which it does not contain. It is only when the contract is vague and ambiguous
that the courts are permitted to interpret the agreement and determine the
intention of the parties.

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 HOME CREDIT MUTUAL BUILDING AND LOAN
ASSOCIATION vs. PRUDENTE
G.R. No. 200010 | August 27, 2020

FACTS
Rollette Prudente received her first service vehicle from her employer Home
Credit Mutual Building and Loan Association, and later on, bought the vehicle at
its depreciated value. Home Credit granted Rollette a second service vehicle but
required her to pay additional equity in excess of the limit of P660,000.00.
Rollette purchased this second vehicle from Home Credit at its depreciated
value. Rollette applied for a third service vehicle but was told by Home Credit to
pay equity exceeding P550,000.00 and to shoulder 40% of the acquisition cost.
Feeling aggrieved, Rollette filed a complaint against Home Credit for violating
Article 100 of the Labor Code, alleging the company diminished her benefits.

DOCTRINE
Under the principle of mutuality of contracts embodied in Article 1308 of the
Civil Code, the terms of a contract - both express and implied - cannot be
withdrawn except by mutual consent or agreement of the contracting parties.

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 Real vs. Consensual Contracts; Forms,
Reformation, and Interpretation
(Civil Code, Arts. 1356-1379)

BANICO vs. STAGER

G.R. No. 232825 | September 16, 2020

FACTS
Lydia Bernadette Stager owned a 6,100 square meter property in Boracay
which adjoins the sea and is generally flat at the center but has an elevated
northern rocky part. She sold an 800 sqm portion of the lot to Ulysses Rudi
Banico but he discovered that the land described in the deed of sale refers to
the elevated rocky portion and not the flat area which he bought and occupied.
The Court said that Banico may validly ask for the reformation of the deed of
sale on the ground of equity.

DOCTRINE
The lawyer's mistake in drafting the written instrument will not prevent its
reformation if the contemporaneous and subsequent acts of the parties show
that their true intention was not disclosed in the document.

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 PATENIA-KINATAC-AN vs. PATENIA-DECENA
G.R. No. 238325 | June 15, 2020

FACTS
Spouses Patenia owned a parcel of land to which their children, petitioners,
found out that the title had been cancelled by virtue of a deed of donation to
respondents. Petitioners allege that the donation is invalid due to a defective
notarial act. Court held that at that time, the operating law does not require the
parties to sign the notarial register.

DOCTRINE
Unlike ordinary contracts which are perfected by the concurrence of the
requisites of consent, object, and cause, solemn contracts like donations of
immovable property are valid only when they comply with legal formalities.
Absent the solemnity requirements for validity, the mere intention of the parties
and concurrence to the agreement will not give rise to a contract.

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 ALBA vs. AROLLADO
G.R. No. 237140 (Resolution) | October 5, 2020

FACTS
Arollado purchased petroleum products on credit and thereafter, issued three
(3) checks which were all dishonored. Alba filed an action for collection of a sum
of money; however, Arollado argues that prescription bars the action. The Court
ruled that Alba’s cause of action has prescribed in 6 years as the contract in
issue was a verbal rather than 10 years for written contracts. The reckoning
point of the prescriptive period shall accrue from the date the cause of action
arises.

DOCTRINE
To be a written contract, all its terms must be in writing, and, a contract partly in
writing and partly oral is, in legal effect, an oral contract. A "writing" for the
payment of money used in an action, within the meaning of the ten-year statute
of limitations, is one which contains either an express promise to pay or
language from which a promise to pay arises by fair implication. It is sufficient
if the words import a promise or an agreement or if this can be inferred from
the terms employed.

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INTEGRATED MICRO ELECTRONICS, INC. vs. STANDARD
INSURANCE CO., INC.
G.R. No. 210302 | August 27, 2020

FACTS
Micro Electronics claims its fire insurance against Standard Insurance due to a
fire breaking out at its building causing damage to its production equipment
and machineries, however, Standard Insurance rejected the claim on the ground
that the loss was an excluded peril. Moreover, Standard insurance insists that
the action has prescribed as according to their contract, the complaint shall be
filed 12 months from notice of rejection. The Court ruled in favor of Standard
Insurance, and held that the 12-month period starts from the first rejection of
the insurance claim and not the rejection of the reconsideration.

DOCTRINE
Contracts of insurance must be construed according to the sense and meaning
of the terms which the parties themselves have used. If the provisions are clear
and unambiguous, they must be taken and understood in their plain, ordinary
and popular sense.

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 PHILIPPINE CHARITY SWEEPSTAKES OFFICE vs.
MENDOZA
G.R. No. 257849 | March 13, 2023

FACTS
Mendoza alleged that one of the “lucky pick” number combinations he had bet
on for the Lotto 6/42 jackpot prize won. Unfortunately, the winning ticket was
damaged. The sweepstakes office informed Mendoza that the price had been
damaged and could not be validated. Mendoza reiterated that the fact that the
Committee on Games and the sweepstakes office differed in their interpretation
of the PCSO Rules renders it ambiguous. The Court ruled in favor of Mendoza.

DOCTRINE
A contract provision is ambiguous if it is susceptible to two reasonable
alternative interpretations. Where the written terms of the contract are not
ambiguous and can only be read one way, the court will interpret the contract
as a matter of law. If the contract is determined to be ambiguous, then the
interpretation of the contract is left to the court, to resolve the ambiguity in the
light of the intrinsic evidence.

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 Defective Contracts

Void - Civil Code, Arts. 1409-1422

CENTRAL BAY RECLAMATION AND DEVELOPMENT CORP.

vs. COMMISSION ON AUDIT
G.R. No. 252940 | April 5, 2022

FACTS
This case is rooted in a Joint Venture Agreement (JVA) entered into by the
Philippine Reclamation Authority (PRA) and Central Bay Reclamation and
Development Corporation (Central Bay). The said JVA having been declared by
the Supreme Court as null and void for violating the constitutional provisions on
the prohibition against private corporations from acquiring any kind of
alienable land of the public domain except through a lease, the Central Bay filed
a money claim against PRA before the Commission on Audit (COA). The parties
submitted a Compromise Agreement – which the COA disapproved - obliged
PRA to transfer the reclaimed land to Central Bay's qualified assignee.

DOCTRINE
Contracts or acts executed against the provisions of mandatory or prohibitory
laws shall be void, except when the law itself authorizes their validity.

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 CONTRACT OF SALE

Conventional Redemption
(Civil Code, Arts. 1601 and 1606-1618);
Legal Redemption (Civil Code, Arts. 1619-1623)

RAMA vs. SPOUSES NOGRA

G.R. No. 219556 | September 14, 2021

FACTS
Ricardo Rama sold his one-fourth undivided share of a lot registered under the
Heirs of Felix Rama, payable in installments to respondents Spouses Nogra.
Upon full payment, Spouses Nogra executed a Deed of Absolute Sale dealted
July 13, 2001. Heirs of Felix Rama claimed that they had no knowledge of the
sale.

DOCTRINE
The explicit requirement of written notice may only be dispensed with upon a
showing that the co-owners already had sufficient knowledge of the sale and
they were guilty of laches in the exercise of their redemption right. Absent these
factors, the strict letter of the law must apply — the written notice from the
seller remains to be an indispensable requirement to commence the running of
the 30-day redemption period.

36
 BANK OF THE PHILIPPINE ISLANDS vs. LCL CAPITAL,
INC.
G.R. Nos. 243396 & 243409 | September 14, 2021

FACTS
LCL Capital, Inc (LCL) obtained a loan from Far East Bank & Trust Co. (FEBTC) in
the amount of P3,000,000.00 subject to 17% interest per annum. As security, LCL
executed a deed of Real Estate Mortgage over its two condominium units. BPI
merged with FEBTC and absorbed FEBTC’s interest and penalties. BPI applied
for extrajudicial foreclosure of the real estate mortgage before the Office of the
Clerk of Court and Ex-officio sheriff of the RTC of Pasig.

DOCTRINE
Following Section 78 of RA No. 337, as further amended by PD 1828, the
effective law at the time the contract of loan and the deed of real estate
mortgage were executed in 1997, the redemption price must consist of the
following: (1) the principal obligation or the amount due under the mortgage
deed; (2) interest at the rate specified in the mortgage; (3) expenses of
foreclosure, i.e., Judicial Commission, Publication Fee, and Sheriff's Fee; and (4)
other expenses as a result of the custody of the property less the income
received.

37
 COMPROMISE AGREEMEN
(Civil Code, Arts. 2028-2041)

CITY GOVERNMENT OF TACLOBAN vs. COURT OF

APPEALS
G.R. No. 221554 | February 3, 2021

FACTS
The City Government of Tacloban filed a complaint for eminent domain over a
portion of the lot of the private respondents. They entered into a compromise
agreement, with consent of both parties and ratified by the Sangguniang
Panlungsod, and such was approved by the RTC and the parties were directed
to comply with its terms and conditions. The Sangguniang Panlungsod later
issued a resolution seeking to rescind/repeal and declare such former
ratification as null and void.

DOCTRINE
A compromise agreement is in the nature of both a contract and a judgment on
the merits. As a contract, the compromise agreement can only be avoided on
grounds of illegality, lack of consent, fraud or duress. It is settled that a
compromise agreement, once stamped with judicial imprimatur, becomes more
than a mere contract and acquires the force and effect of a judgment that is
immediately final and executory.

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 ILOCOS NORTE ELECTRIC COOPERATIVE vs.
ANDRES-RANJO
G.R. No. 200544 | August 17, 2022

FACTS
Delfino Andres bought from Felipa Segundo a land owned by the Segundos; the
same land was also bought in good faith by INEC from Conception Segundo
who is the widow of one of the Segundos. When Delfino died, he was substituted
by his son, Neil, who entered into a compromise agreement (approved by the
RTC) with INEC, alleging he was the only survivor of Delfino. Two years later, the
legally adopted children of Delfino sought the annulment of the compromise
agreement with the CA which was granted on the ground that the agreement
was obtained through extrinsic fraud.

DOCTRINE
Both judicial and extrajudicial compromise agreements constitute the contract
between the parties. To be valid, it must comply with the following requisites of
contracts: (a) consent of the parties; (b) object certain, and (c) cause of the
obligation. A compromise agreement must also be based on real claims and be
actually agreed upon in good faith. Finally, it must not be contrary to law, public
order, public policy, morals or good customs to constitute the law between the
parties.

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 QUASI-CONTRACTS
(Civil Code, Arts. 2142-2143)

Solutio Indebiti (Civil Code, Arts. 2154-2163)

DEPARTMENT OF AGRARIAN REFORM EMPLOYEES

ASSOCIATION vs. COMMISSION ON AUDIT
G.R. No. 217285 | November 10, 2020

FACTS
DAR Secretary Rene Villa and the petitioner Department of Agrarian Reform
Employees Association (DAREA) executed a Collective Negotiation Agreement
(CNA). The DAR Regional Office No. 02 (DAR-R02) released incentives to its
officials and employees from 2008 to 2009. The Commission on Audit (COA)
disallowed these disbursements, stating that the incentives were illegally
charged against the Comprehensive Agrarian Reform Program (CARP) Fund in
violation of the Presidential Decree No. 1445 (PD 1445), stating that trust funds
shall be available available and may be spent only for the specific purpose for
which the trust was created or the funds received.2

DOCTRINE
The receipt of public funds without valid basis or justification is already an
undue benefit that gives rise to the obligation to return. This obligation is
founded by the civil law principles of solutio indebiti and unjust enrichment. The
recipients' good faith or bad faith is immaterial in the determination of their
liability. By way of exception, however, the recipients do not incur liability to
refund when they can prove their entitlement to what they received as a matter
of fact and law because in such a situation, there is no undue payment and the
government incurs no loss. The essence of solutio indebiti and unjust enrichment
is thereby negated.

2
ADDITIONAL NOTES:
The recipients do not incur liability to refund when they can prove their
entitlement to what they received as a matter of fact and law because in such a
situation, there is no undue payment and the government incurs no loss.

40
 NGALOB vs. COMMISSION ON AUDIT
G.R. No. 238882 | January 5, 2021

FACTS
The Cordillera-Administrative Region (CAR) - Regional Development Council
(RDC) Executive Committee (ExCom) authorized the grant of incentives and
quarterly releases to compensate RDC-CAR officials and secretariat’s “extra
work” in implementing the RDC-CAR Work Program on Development and
Autonomy. Another RDC ExCom resolution was issued providing for a year-end
incentive to its officers and secretariat, in lieu of honoraria. The Commission on
Audit disallowed the grant of said allowances for lack of factual basis.

DOCTRINE
Mere receipt of public funds without valid basis or justification, regardless of
good faith or bad faith, is already an undue benefit that gives rise to the
obligation to return what was unduly received. This is grounded upon civil law
principles of solutio indebiti and unjust enrichment. 3

3
ADDITIONAL NOTES:
According to the Supreme Court, no badge of good faith can be appreciated in
favor of the approving and certifying officers considering the blatant disregard
of the rules and laws that they invoked and relied upon. The palpable disregard
of the laws amounts to gross negligence which betrays the presumption of good
faith.

41
 HAGONOY WATER DISTRICT vs. COMMISSION ON
AUDIT
G.R. No. 247228 | March 2, 2021

FACTS
Hagonoy Water District released resolutions granting an anniversary bonus and
rice allowance to its officials and employees. Respondent COA issued a Notice
of Disallowance (ND) which disallowed the disbursements of petitioner stating
that it is in violation of the President’s memorandum limiting the payment of
anniversary bonuses and COA resolution limiting the grant of additional
allowances to incumbents. The COA sustained the validity of the ND but ruled
that the passive recipients should not be required to refund the amount of the
disallowed benefits that they received in good faith.

DOCTRINE
To emphasize, mere receipt of public funds without valid basis or justification,
regardless of good faith or bad faith, is already an undue benefit that gives rise
to the obligation to return what was unduly received in accordance with the
principles of solutio indebiti and unjust enrichment. Indeed, one's participation
in the disallowed transaction is a determinant of the extent of liability. Thus,
while the officers' good faith is determinative of their liability, such state of
mind is immaterial to the recipients' obligation because mere receipt of
disallowed funds results in unduly benefitting from the government, giving rise
to the obligation to refund.

42