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FACTS: A buy-bust operation was conducted wherein accused was caught selling
illegal drugs. The accused argued that there was there was lack of inventory, and the
marking of the items was not done in his presence, a representative of media, the
Department of Justice and an elected official. Regional Trial Court affirmed his
conviction and ruled that substantial compliance with the legal requirements on the
handling of the seized item is sufficient. Such procedural lapse is not fatal and will not
render the items seized inadmissible in evidence. What is of utmost importance is the
preservation of the integrity and evidentiary value of the seized items, as the same
would be utilized in the determination of the guilt or innocence of the accused. CA also
affirmed in toto.

ISSUE: Whether or not CA erred in finding him guilty beyond reasonable doubt of the
violations of Section 5 and Section 11 of RA No. 9165.

RULING: We have usually presumed the regularity of performance of their official duties
in favor of the members of buy-bust teams enforcing our laws against the illegal sale of
dangerous drugs. Such presumption is based on three fundamental reasons, namely:
First, innocence, and not wrongdoing, is to be presumed; Second, an official oath will
not be violated; and, Third, a republican form of government cannot survive long unless
a limit is placed upon controversies and certain trust and confidence reposed in each
governmental department or agent by every other such department or agent, at least to
the extent of such presumption. But the presumption is rebuttable by affirmative
evidence of irregularity or of any failure to perform a duty. Judicial Reliance on the
presumption despite any hint of irregularity in the procedured undertaken by the agents
of the law will thus be fundamentally unsound because such hint is itself affirmative
proof of irregularity.




RULING: Factual findings of administrative bodies charged with their specific field of
expertise, are afforded great weight by the courts, and in the absence of substantial
showing that such findings were made from an erroneous estimation of the evidence
presented, they are conclusive, and in the governmental structure, should not be


FACTS: On January 26, 2004, Ogawa filed a complaint for sum of money, damages,
breach of good human relation and unjust enrichment before the RTC against
Menigishi, alleging that the latter borrowed from her the amounts of P15,000.00,
P100,000.00 and P8,000.00, in September 2000, August 2001, and March 2003,
respectively. Unable to pay, respondent offered to sell her building and its
improvements in Sorsogon City to petitioner for a consideration of P1,500,000.00 with
the agreement that her outstanding loans with petitioner be deducted from the purchase
price and the balance payable in installments. As partial payment for the properties,
petitioner remitted the following amounts to respondent: (a) P150,000.00 through the
account of her friendEmma Fulleros on October 23, 2003; and (b) P250,772.90 by way
of bank remittance to respondent's Equitable-PCI Bank Account on December 8,2003.
Having paid huge amounts and in order to protect her proprietary rights, petitioner then
demanded for the execution of the corresponding deedof sale, but respondent backed
out from the deal and reneged on her obligations. The RTC ruled in favor of Ogawa. It
disregarded the receipt presented by respondent as proof of petitioner's purported
indebtedness of 1,000,000.00 Yen. However, the CA gave probative value to the receipt
for 1,000,000.00 Yen and held it sufficient to establish petitioner's indebtedness to
respondent, considering the purported admission of the former's counsel as well as
petitioner's own failure to specifically deny the same under oath as provided for under
Section 8, Rule 8 of the Rules of Court. Consequently, it granted respondent's
counterclaim of 1,000,000.00 Yen. Finally, having found both parties at fault, the CA
deleted the awards of damages.

ISSUE: Whether or not the disputed receipt sufficiently established respondent's

counterclaim that petitioner owed her 1,000,000.00 Yen.

A receipt is defined as a written and signed acknowledgment that money or good was
delivered or received. Exhibit 1, upon which respondent relies to support her
counterclaim, sufficiently satisfies this definition. However, while indubitably containing
the signatures of both parties, a plain reading of the contents of Exhibit 1 negates any
inference as to the nature of the transaction for which the 1,000,000 Yen was received
and who between the parties is the obligor and the obligee. What is apparent is a mere
written and signed acknowledgment that money was received. There are no terms and
conditions found therein from which a right or obligation may be established. Hence, it
cannot be considered an actionable document upon which an action or defense may be
founded. It is settled that the burden of proof lies with the party who asserts his/her
right. In a counterclaim, the burden of proving the existence of the claim lies with the
defendant, by the quantum of evidence required by law, which in this case is
preponderance of evidence.


FACTS: Court of Appeals affirmed the lower court’s decision of declaring respondent
municipality (now city) as having the right to expropriate petitioner’s property for the
construction of an access road. Petitioner argues that there was no valid and definite
offer made before a complaint for eminent domain was filed as the law requires (Art. 35,
Rules and Regulations Implementing the Local Government Code). Respondent
contends that a letter to purchase was offered to the previous owners and the same
was not accepted.

ISSUE: Whether or not the absence of competent evidence that, indeed, the
municipality made a definite and valid offer is compliance with Section 19 of R.A. No.

RULING: Neither is the declaration in one of the whereas clauses of the ordinance that
the property owners were already notified by the municipality of the intent to purchase
the same for public use as a municipal road, a substantial compliance with the
requirement of a valid and definite offer under Section 19 of R.A. No. 7160. Presumably,
the Sangguniang Bayan relied on the erroneous premise that the letter of Engr. Reyes
reached the co-owners of the property. In the absence of competent evidence that,
indeed, the respondent made a definite and valid offer to all the co-owners of the
property, aside from the letter of Engr. Reyes, the declaration in the ordinance is not a
compliance with Section 19 of R.A. No. 7160.


Trade and Industry (DTI)

FACTS: The signing of the Japan-Philippines Economic Partnership Agreement

(JPEPA) at the sidelines of the Asia-Europe Summit in Helsinki in September 2006 was
hailed by both Japanese Prime Minister Junichiro Koizumi and Philippine President
Gloria Macapagal Arroyo as a “milestone in the continuing cooperation and
collaboration, setting a new chapter of strategic partnership for mutual opportunity and
growth (for both countries).” JPEPA which has been referred to as a ‘mega treaty’ is a
comprehensive plan for opening up of markets in goods and services as well as
removing barriers and restrictions on investments. It is a deal that encompasses even
our commitments to the WTO.
The complexity of JPEPA became all the more evident at the Senate hearing conducted
by the Committee on Trade and Commerce last November 2006. The committee,
chaired by Senator Mar Roxas, heard differing views and perspectives on JPEPA. On
one hand the committee heard Government’s rosy projections on the economic benefits
of JPEPA and on the other hand the views of environmental and trade activists who
raised there very serious concerns about the country being turned into Japan’s toxic
waste basket. The discussion in the Senate showed that JPEPA is not just an issue
concerning trade and economic relations with Japan but one that touches on broader
national development concerns.

ISSUE: Whether or not the documents and information being requested in relation to
the JPEPA exempted from the general rules on transparency and full public disclosure
such that the Philippine government is justified in denying access thereto.

RULING: In asserting that the balance in this instance tilts in favor of disclosing the
JPEPA documents, the dissent contents that the Executive has failed to show how
disclosing them after the conclusion of negotiations would impair the performance of its
functions. The contention, with due respect, misplaces the anus probandi. While, in
keeping with the general presumption of transparency, the burder is initially on the
Executive to provide precise and certain reasons for upholding its claim of privilege,
once the Executive is able to show that the documents being sought are covered by a
recognized privilege, the burder shifts to the party seeking information to overcome the
privilege by a strong showing of need.


FACTS: An appeal interposed by accused Servando Saturno and other accused from
the Decision of the RTC of San Jose City, Nueva Ecija for the crime of Multiple Murder.
They contended that prosecution witness Lucila Valdez, wife of the deceased Delfin
Gregorio, was not able to positively identify all the accused. They claim an alibi, that is,
it was physically impossible for them to be at the locus criminis at the time theincident

ISSUE: Whether or not Trial court was correct eventhough the prosecution's failure to
prove their guilt beyond resonable doubt.

In the case at bar, the prosecution was able to establish the fact of the killing; however,
it failed to prove that appellants perpetrated the crime. Where the prosecution has failed
to discharge the onus probandi for a pronouncement of guilt beyond reasonable doubt,
the constitutional presumption of innocence in favor of the accused will result in
acquittal. Equipoise Rule provides that where the evidence in a criminal case is evenly
balanced, the constitutional presumption of innocence tilts the scale in favor of the


FACTS: Larry Erguiza was charged with one count of rape. The victim’s father, testified
that the family of Erguiza went to their house after the case was filed, and initially
offered P50,000 and later P150,000. Albina, the mother of Erguiza admitted that she did
talk with the parents of the victim, but according to her, it was the spouses who asked
for P1M, later reduced to P250,000, to settle the case and that she made a counter-
offer of P5,000.00.

ISSUE: Whether or not can the offer of compromise given by the mother of the accused
be used as evidence of his guilt.

The alleged offer of the parents of appellant to settle the case cannot be used against
appellant as evidence of his guilt. Appellant testified that he did not ask his parents to
settle the case. Moreover, appellant was not present when the offer to settle was
allegedly made.

An offer of compromise from an an unauthorized person cannot amount to an admission

of the party himself. Although the Court has held in some cases that an attempt of the
parents of the accused to settle the case is an implied admission of guilt, we believe
that the better rule is that for a compromise to amount to an implied admission of guilt,
the accused should have been present or at least authorized the proposed compromise.
Moreover, it has been held that where the accused was not present at the time the offer
for monetary consideration was made, such offer of compromise would not save the day
for the prosecution.