David Reyes(Substituted by Victoria Fabella) vs Jose Lim

GR 134241 (August 11, 2003)

Facts: Petitioner David Reyes filed a complaint for annulment of contract and
damages against respondents. The complaint alleged that Reyes as seller and Lim as
buyer entered into a contract to sell a parcel of land located along F.B. Harrison
Street, Pasay City with a monthly rental of P35,000.
The complaint claimed that Reyes had informed Harrison Lumber to vacate the
Property before the end of January 1995. Reyes also informed Keng and Harrison
Lumber that if they failed to vacate by 8 March 1995, he would hold them liable for
the penalty of P400,000 a month as provided in the Contract to Sell. It was also
alleged that Lim connived with Harrison Lumber not to vacate the Property until the
P400,000 monthly penalty would have accumulated and equaled the unpaid
purchase price of P18,000,000.
Keng and Harrison Lumber denied that they connived with Lim to defraud Reyes, and
that Reyes approved their request for an extension of time to vacate the Property due
to their difficulty in finding a new location for their business. Harrison Lumber claimed
that it had already started transferring some of its merchandise to its new business
location in Malabon.
Lim filed his Answer stating that he was ready and willing to pay the balance of the
purchase price. Lim requested a meeting with Reyes through the latters daughter on
the signing of the Deed of Absolute Sale and the payment of the balance but Reyes
kept postponing their meeting. Reyes offered to return the P10 million down payment
to Lim because Reyes was having problems in removing the lessee from the Property.
Lim rejected Reyes offer and proceeded to verify the status of Reyes title to the
Property. Lim learned that Reyes had already sold the Property to Line One Foods
Corporation Lim denied conniving with Keng and Harrison Lumber to defraud
Reyes.Reyes filed a Motion for Leave to File Amended Complaint due to supervening
facts. These included the filing by Lim of a complaint for estafa against Reyes as well
as an action for specific performance and nullification of sale and title plus damages
before another trial court. The trial court granted the motion.
In his Amended Answer Lim prayed for the cancellation of the Contract to Sell and for
the issuance of a writ of preliminary attachment against Reyes. The trial court denied
the prayer for a writ of preliminary attachment.
Lim requested in open court that Reyes be ordered to deposit the P10 million down
payment with the cashier of the Regional Trial Court of Paraaque. The trial court
granted this motion.
Reyes filed a Motion to Set Aside the Order on the ground the Order practically
granted the reliefs Lim prayed for in his Amended Answer. The trial court denied
Reyes motion.
The trial court denied Reyes Motion for Reconsideration. In the same order, the trial
court directed Reyes to deposit the P10 million down payment with the Clerk of
Court.
Reyes filed a Petition for Certiorari with the Court of Appeals and prayed that the
orders of the trial court be set aside for having been issued with grave abuse of
discretion amounting to lack of jurisdiction. But the Court of Appeals dismissed the
petition for lack of merit.
Issue: Whether or not the equity jurisdiction is an applicable law on the matter?

Held: In this case, the Supreme Court held that if this was a case where there is
hiatus in the law and in the Rules of Court, the hiatus will result in unjust enrichment
to Reyes at the expense of Lim. Here the court exercised equity jurisdiction. The
exercise of equity jurisdiction in this case is to prevent unjust enrichment and to
ensure restitution so that substantial justice may be attained in cases where the
prescribed or customary forms of ordinary law are inadequate.In this case, it was just,
equitable and proper for the trial court to order the deposit of the P10 million down
payment. The decision of the Court of Appeals.was affirmed.
Francisco Tupas and Ignacio Tupas vs Court of Appeals
GR 89571 (February 6,1991)
Facts: The petitioners in this case received a copy of the Regional Trial Court decision
and then they filed their respective motions for reconsideration 14 days after. The
motion was denied, instead of filling the petition with the Court of Appeals within the
15 day reglementary period prescribed(which is supposed to be the day after receipt
of Court Order/Decision), the said petitioners filed their petition for reconsideration a
day before the period expires. The Court of Appeal denied the petitioners motion on
the grounds of tardiness.
Petitioners filed a motion for reconsideration with the Supreme Court alleging that
the latter should not be punished for the wrong doings of their counsel as they were
only laymen and not familiar with the inner workings and intricacies of the law.
Issues:
Held: The Supreme Court denied the motion with finality. The Court also found that
petitioners failed to show that their counsel was motivated by bad faith or misled by
the facts. There is no reason as to why the rule that bounds clients to their counsel,
even including counsels mistakes, should not apply.
Spouses Imbong vs Ochoa
G.R. Nos. 204819, 204934, 204957, 204988, 205003, 205043, 205138,
205478, 205491, 205720, 206355, 207111, 207172 & 207563 (April 8, 2014)
Facts: Nothing has polarized the nation more in recent years than the issues of
population growth control, abortion and contraception. As in every democratic
society, diametrically opposed views on the subjects and their perceived
consequences freely circulate in various media. From television debates2 to sticker
campaigns,3 from rallies by socio-political activists to mass gatherings organized by
members of the clergy4 - the clash between the seemingly antithetical ideologies of
the religious conservatives and progressive liberals has caused a deep division in
every level of the society. Despite calls to withhold support thereto, however,
Republic Act (R.A.) No. 10354, otherwise known as the Responsible Parenthood and
Reproductive Health Act of 2012 (RH Law), was enacted by Congress on December
21, 2012. The petitioners are one in praying that the entire RH Law be declared
unconstitutional. Petitioners herein argues that the government sponsored
contraception program, the very essence of the RH Law, violates the right to health
of women and the sanctity of life, which the State is mandated to protect and
promote.
Issue: Whether or not the Court may exercise its power of judicial review in this
case/controversy?

Held: The petitioners also claim that the RH Law violates the equal protection clause
under the Constitution as it discriminates against the poor because it makes them
the primary target of the government program that promotes contraceptive use.
They argue that, rather than promoting reproductive health among the poor, the RH
Law introduces contraceptives that would effectively reduce the number of the poor.
Their bases are the various provisions in the RH Law dealing with the poor, especially
those mentioned in the guiding principles and definition of terms of the law.
"According to a long line of decisions, equal protection simply requires that all
persons or things similarly situated should be treated alike, both as to rights
conferred and responsibilities imposed." It "requires public bodies and institutions to
treat similarly situated individuals in a similar manner." "The purpose of the equal
protection clause is to secure every person within a state's jurisdiction against
intentional and arbitrary discrimination, whether occasioned by the express terms of
a statue or by its improper execution through the state's duly constituted
authorities." "In other words, the concept of equal justice under the law requires the
state to govern impartially, and it may not draw distinctions between individuals
solely on differences that are irrelevant to a legitimate governmental objective."
The equal protection clause is aimed at all official state actions, not just those of the
legislature. Its inhibitions cover all the departments of the government including the
political and executive departments, and extend to all actions of a state denying
equal protection of the laws, through whatever agency or whatever guise is taken.
It, however, does not require the universal application of the laws to all persons or
things without distinction. What it simply requires is equality among equals as
determined according to a valid classification. Indeed, the equal protection clause
permits classification. Such classification, however, to be valid must pass the test of
reasonableness. The test has four requisites: (1) The classification rests on
substantial distinctions; (2) It is germane to the purpose of the law; (3) It is not
limited to existing conditions only; and (4) It applies equally to all members of the
same class.
"Superficial differences do not make for a valid classification."
For a classification to meet the requirements of constitutionality, it must include or
embrace all persons who naturally belong to the class. "The classification will be
regarded as invalid if all the members of the class are not similarly treated, both as to
rights conferred and obligations imposed. It is not necessary that the classification be
made with absolute symmetry, in the sense that the members of the class should
possess the same characteristics in equal degree. Substantial similarity will suffice;
and as long as this is achieved, all those covered by the classification are to be
treated equally. The mere fact that an individual belonging to a class differs from the
other members, as long as that class is substantially distinguishable from all others,
does not justify the non-application of the law to him."
The classification must not be based on existing circumstances only, or so
constituted as to preclude addition to the number included in the class. It must be of
such a nature as to embrace all those who may thereafter be in similar circumstances
and conditions. It must not leave out or "under include" those that should otherwise
fall into a certain classification.
Salvador Moll vs. Hon. Mamerto Buban
GR 136974 (August 27, 2002)

Facts: The trial court rendered a Decision on October 28, 1998 in People of the
Philippines vs. Salvador K. Moll and Ysmael Zepeda, finding petitioner Salvador K.
Moll, former Vice Mayor of Malinao, Albay, guilty of violating Section 3 (e) of Republic
Act No. 3019.
On November 3, 1998, petitioner, through counsel, filed a notice of appeal, stating
that he was appealing the decision to the Court of Appeals. Petitioner furnished a
copy of his notice of appeal to respondent Prosecutor Niceto Villamin. The trial court
gave due course to the appeal in an Order[5] dated November 4, 1998. However, on
November 12, 1998, the last day of the reglementary period to appeal, petitioner
filed a Manifestation/Motion withdrawing the notice of appeal dated November 3,
1998 and filing in its stead a second notice of appeal. This second notice of appeal
sought to bring the appeal to the Sandiganbayan. In its Order of November 12, 1998,
the trial court gave due course to petitioners Manifestation/Motion, set aside its
earlier Order, and ordered the entire record of the case forwarded to the
Sandiganbayan for proper disposition.
On November 19, 1998, the respondent prosecutor filed a Motion for Reconsideration
of the Order of November 12, 1998 and a Motion for Issuance of Mittimus[9] praying
that the Order of November 12, 1998 be set aside on three grounds. First, the
accused perfected his appeal upon filing the first notice of appeal, and therefore, the
respondent court, under Section 9, Rule 41 of the Rules of Court, lost jurisdiction over
the case. Second, the accused failed to serve a copy of his Manifestation/Motion and
second notice of appeal to the prosecution in violation of Section 3(a), Rule 122 and
Section 4, Rule 13 of the Rules of Court. Third, the Manifestation/Motion did not
contain a notice of hearing and proof of service to the prosecution. The prosecution
further prayed that the trial court declare the Decision of October 28, 1998 final
because of the withdrawal of the first notice of appeal. Alternatively, the prosecution
prayed that the record of the case be forwarded to the Court of Appeals in
accordance with the trial courts earlier Order of November 4, 1998.
On December 10, 1998, the trial court issued an Order[10] giving due course to the
prosecutions motion and reinstated its Order of November 4, 1998 giving due course
to the appeal to the Court of Appeals. Upon petitioners motion for reconsideration,
the trial court on January 5, 1999 affirmed[11] its Order of December 10, 1998.
On January 20, 1999, petitioner filed this petition for certiorari under Rule 65 of the
Rules of Court. Respondent prosecutor later filed his Comment, and the Office of the
Solicitor General filed a Manifestation and Motion in Lieu of Comment recommending
that petitioners second notice of appeal to the Sandiganbayan be given due course.
Issue: Whether or not the first notice of appeal is valid, rendering the second notice
of appeal unnecessary?
Held: The assailed Orders of the trial court direct petitioner, over his vigorous
objections, to bring his appeal to the Court of Appeals where the appeal is bound to
be dismissed outright for being filed in the wrong court. Petitioner asserts that the
trial court, in directing him to bring his appeal to the wrong court, acted with grave
abuse of discretion amounting to lack of jurisdiction. s for the other lapses in
procedure attributed by the prosecution to the petitioner, the same are not errors in
law because there is no requirement to set for hearing the approval of a notice of
appeal.

WHEREFORE, the petition is GRANTED. The trial courts Orders of December 10,
1998 and January 5, 1999 are SET ASIDE, and the Order of November 12, 1998 giving
due course to the petitioners appeal to the Sandiganbayan is REINSTATED.