Krystle Realty Development Corporation vs.

Alibin

733 SCRA 1

Facts:

Alibin owned an undivided one-half portion of Lot. 1680 situated in Tahao, Legazpi City, Albay and
registered in his name and that of Mariano Rodrigueza. Sometime in 1962, on the strength of a contract
to sell, notarized and a deed of sale purporting to convey the one-half portion of Alibin’s share was
conveyed to Caridad Rodrigueza.

Alibin now claims that he has not sold his shares to Caridad nor received any consideration for the
alleged transfer, and that the signature on the deed was not his.

The parties agreed to submit to a handwriting expert of the NBI to determine the genuiness of Alibin’s
signature on the deed of sale which yielded a match to Alibin’s signature. The court dismissed the case.

On appeal, the decision was reversed and the court held that the anomalies surrounding the sale to
Krystle Realty was attended with bad faith.

Issue:

WON the findings of the handwriting expert bind the findings of the court.

Held:

The opinion of a handwriting expert, therefore, does not mandatorily bind the court, the expert’s
function being to place before the court data upon which it can form its own opinion. —As correctly
pointed out by the CA, the authenticity of a signature is a matter that is not so highly technical as to
preclude a judge from examining the signature himself and ruling upon the question of whether the
signature on a document is forged or not. The opinion of a handwriting expert, therefore, does not
mandatorily bind the court, the expert’s function being to place before the court data upon which it can
form its own opinion.
Bigler vs. People

785 SCRA 479

Facts:

Petitioner Bigler was charged with the crime of Libel before the RTC for allegedly maligning his former
spouse Barreto, through a letter sent to her lawyer purportedly containing various malicious and
defamatory imputations against her.

During trial, petitioner’s counsel filed a withdrawal of appearance and requested all notices be
forwarded to the petitioner’s address or to his new counsel, who shall enter an appearance in due time.

The RTC rendered a decision finding the petitioner guilty beyond reasonable doubt of the crime of Libel.
Aggrieved, petitioner moved for reconsideration but was denied in an Order. A warrant was set for his
arrest, petitioner filed an Urgent Omnibus Motion to reopen the criminal proceedings and to allow him
to file a notice of appeal, claiming that he never received notice of the promulgation nor was present
during the promulgation.

Issue:

WON the court was correct in judgement of conviction of the petitioner

Held:

Yes, under the doctrine of finality of judgment or immutability of judgment, a decision that has acquired
finality becomes immutable and unalterable, and may no longer be modified in any respect, even if the
modification is meant to correct erroneous conclusions of fact and law, and whether it be made by the
court that rendered it or by the Highest Court of the land. Any act which violates this principle must
immediately be struck down. Nonetheless, the immutability of final judgments is not a hard and fast rule
as the Court has the power and prerogative to relax the same in order to serve the demands of
substantial justice considering: (a) matters of life, liberty, honor, or property; (b) the existence of special
or compelling circumstances; (c) the merits of the case; (d) a cause not entirely attributable to the fault
or negligence of the party favored by the suspension of the rules; (e) the lack of any showing that the
review sought is merely frivolous and dilatory; and (f) that the other party will not be unjustly prejudiced
thereby.
Atilano II vs. Asaali

680 SCRA 345

Facts:

An order against the petitioners to pay their obligations to ZACI was laid before by the RTC. Petitioners
filed a petition for review on certiorari before the appellate court, imputing for grave abuse of discretion
upon the RTC for failing to reconsider the proceedings should be conducted when a third person
allegedly indebted to a judgement debtor denies said debt.

The CA dismissed their petition outright for several failures and deficiency of payment of corresponding
docket fees.

Issue:

WON payment of docket fees are dispensable

Held:

Payment of the full amount of docket fees is an indispensable step to the perfection of an appeal, and
the Court acquires jurisdiction over any case only upon such payment. Corollary to this, the Court has
consistently held that procedural rules are not to be disregarded simply because their non-observance
may result in prejudice to a party’s substantive rights.
People vs. Hallarte

720 SCRA 5882

Facts:

The criminal case was filed against the accused for the rape of AAA, a minor, and sexual assault against
BBB, also a minor which transpired in the house of the accused in Barangay Pasong Tamo, Quezon City.

The private complainants were brought to the Talipapa Police Station, where they gave their respective
sworn statements against the accused-appellant.

The RTC after trial of merits convicted the appellant as charged.

Issue:

WON the testimonies of the witnesses herein should be given full weight and respect

Held:

Testimonies of child-victims are normally given full weight and credit, since when a girl, particularly if
she is a minor, says that she has been raped, she says in effect all that is necessary to show that rape has
in fact been committed. When the offended party is of tender age and immature, courts are inclined to
give credit to her account of what transpired, considering not only her relative vulnerability but also the
shame to which she would be exposed if the matter to which she testified is not true. Youth and
immaturity are generally badges of truth and sincerity. A young girl’s revelation that she had been
raped, coupled with her voluntary submission to medical examination and willingness to undergo public
trial where she could be compelled to give out the details of an assault on her dignity, cannot be so
easily dismissed as mere concoction.
People vs. Dionaldo

731 SCRA 68

Facts:

Edwin Navarro was kidnapped from the Health is Wealth Gym. Dionaldo et al., demanded ransom for
the release of Edwin. The payment for ransom and the rescue operations failed, and Edwin was later
found dead.

The accused was convicted for the crime of kidnapping with serious illegal detention. The court gave
credence to the positive and straightforward testimonies of the prosecution witnesses which clearly
established that it was the accused-appellants who forcibly dragged a bloodied Edwin into a car and,
consequently, deprived him of his liberty. In light thereof, it rejected accused-appellants’ respective
alibis and claims of torture.

Issue:

WON the accused is guilty of the crime Kidnapping and Serious Illegal Detention

Held:

Well-settled is the rule that the question of credibility of witnesses is primarily for the trial court to
determine. Its assessment of the credibility of a witness is entitled to great weight, and it is conclusive
and binding unless shown to be tainted with arbitrariness or unless, through oversight, some fact or
circumstance of weight and influence has not been considered. Absent any showing that the trial judge
overlooked, misunderstood, or misapplied some facts or circumstances of weight which would affect the
result of the case, or that the judge acted arbitrarily, his assessment of the credibility of witnesses
deserves high respect by the appellate court.
Tiu vs. Dizon

793 SCRA 595

Facts:

Tiu was found guilty beyond reasonable doubt for violations of R.A. 6425 and was sentenced to suffer
the penalty of reclusion perpetua, the decision became final and executory on July 29, 2004.

On March 24, 2009 the BPP issued a Resolution no. 022-3-09 recommending the grant of executive
clemancy to petitioner, acting on it, then PGMA granted the “conditional pardon without parole
conditions”, no papers were issued in petitioner’s favor. That despite requests from the Legal Affairs
Office of the President, but the requests were denied by the Executive Secretary of the LAOP. Dizon
confirmed that the papers were not yet signed by PGMA.

PNoy signed into law R.A. 10592, which would substantially increase the Good Conduct Time Allowance
of qualified inmates. Tiu now contends that he has served his sentence, thus a Petition for Habeas
Corpus was filed seeking his immediate release from prison.

Issue:

WON a Writ of Habeas Corpus should be issued in favor of petitioner

Held:

Well-settled is the rule that the writ will not issue where the person in whose behalf the writ is sought is
in the custody of an officer under process issued by a court or judge with jurisdiction or by virtue of a
judgment or order of a court of record. The writ is denied if the petitioner fails to show facts that he is
entitled thereto ex merito justicias.

In this case, petitioner is serving sentence by virtue of a final judgment convicting him of the offense of
selling and delivering prohibited drugs defined and penalized under Section 15, Article III of RA 6425, as
amended by RA 7659. He failed to show, however, that his further incarceration is no longer lawful and
that he is entitled to relief under a writ of habeas corpus.
Heirs of the Late Sps. Maglasang vs. Manila Banking Corporation

706 SCRA 235

Facts:

The Spouses Flaviano and Salud Maglasang obtained a credit line from respondent Manila Banking
Corporation in the amount of P350,000.00, secured by a real estate mortgage over several properties.
The spouses availed of the credit line by securing loans in the amounts of P209,790.50 and P139,805.83.

Flaviano died intestate, leaving behind his widow and surviving children, among which Edgar was
appointed as their attorney-in-fact.

The probate court issued a notice to the creditors for filing money claims against the estate. The
surviving heirs of the decedent executed an extra-judicial partition of the properties. The loans owed by
the estate remained unsatisfied. The probate court expressly recognized the right of the respondent
bank under the mortgage and loan.

The bank opted to foreclose the properties and won as highest bidder during the public auction. MBC
filed a suit to recover the deficiency of the loan against the estate of the deceased.

Issue:

WON respondent bank may claim the deficiency of the loan

Held:

No, claims against deceased persons should be filed during the settlement proceedings of their estate.
Such proceedings are primarily governed by special rules found under Rules 73 to 90 of the Rules,
although rules governing ordinary actions may, as far as practicable, apply suppletorily.

A creditor holding a claim against the deceased secured by a mortgage or other collateral security, may
abandon the security and prosecute his claim in the manner provided in this rule, and share in the
general distribution of the assets of the estate; or he may foreclose his mortgage or realize upon his
security, by action in court, making the executor or administrator a party defendant, and if there is a
judgment for a deficiency, after the sale of the mortgaged premises, or the property pledged, in the
foreclosure or other proceeding to realize upon the security, he may claim his deficiency judgment in
the manner provided in the preceding section; or he may rely upon his mortgage or other security alone,
and foreclose the same at any time within the period of the statute of limitations, and in that event he
shall not be admitted as a creditor, and shall receive no share in the distribution of the other assets of
the estate; but nothing herein contained shall prohibit the executor or administrator from redeeming
the property mortgaged or pledged, by paying the debt for which it is held as security, under the
direction of the court, if the court shall adjudged it to be for the best interest of the estate that such
redemption shall be made.

Case law states that absent such qualifying or restrictive words to indicate the exclusivity of the agreed
forum, the stipulated place should only be as an additional, not a limiting venue. As a consequence, the
stipulated venue and that provided under Act No. 3135 can be applied alternatively. In particular,
Section 2 of Act No. 3135 allows the foreclosure sale to be done within the province where the property
to be sold is situated, viz.: SEC. 2. Said sale cannot be made legally outside of the province which the
property sold is situated; and in case the place within said province in which the sale is to be made is
subject to stipulation, such sale shall be made in said place or in the municipal building of the
municipality in which the property or part thereof is situated.
Almojuela vs. Republic

801 SCRA 399

Facts:

Petitioner Felipe “Almojuela” has been using his surname for almost 60 years. Upon request for a copy
of his NSO Birth Certificate, he discovered that he was registered as “Felipe Condeno”. Thus he filed a
Petition for Correction of Entry in his NSO Birth Certificate before the RTC.

Petitioner herein was borned on February 25, 1950 in Pandan, Catanduanes, he is the acknowledged
child of former Governor Jorge V. Almojuela and Francisca B. Condeno, both deceased. He had been
using “Almojuela” for all his documentations. The RTC order that the entry in the Civil Registrar of
Pandan, Catanduanes be first corrected before the correction of the NSO records be had.

The Republic of the Philippines, through the office of the OSG moved for reconsideration citing the lack
of jurisdiction due to defects in publication and procedure held by petitioner.

Issue:

WON the court has jurisdiction

Held:

No, failure for the petitioner to implead the corresponding parties involved is fatal to his petition.

Rule 108 of the Rules of Court provides the procedure for the correction of substantial changes in the
civil registry through an appropriate adversary proceeding. An adversary proceeding is defined as one
“having opposing parties; contested, as distinguished from an ex parte application, one of which the
party seeking relief has given legal warning to the other party, and afforded the latter an opportunity to
contest it.”