People vs. Fitzgerald Enrile vs.

Sandiganbayan
G.R. No. 149723 G.R. No. 213847
October 27, 2006 August 18, 2015
Austria-Martinez, J. Bersamin, J.

In both cases, the accused was charged with a crime with the penalty of reclusion perpetua and life imprisonment,
respectively. The Rules of Criminal Procedure provide that bail is a matter of discretion against one facing an
accusation for an offense punishable by death, reclusion perpetua or life imprisonment when the evidence of his
guilt is strong. Both were also of advanced age and raised such circumstance in their case. In People vs. Fitzgerald,
it was held that bail is not a sick pass for an ailing or aged detainee or prisoner needing medical care outside the
prison facility. A mere claim of illness is not a ground for bail. However, in Enrile vs. Sandiganbayan, the court
ruled that the Philippines has a national commitment to uphold the fundamental human rights as well as value the
worth and dignity of every person. The grant of bail is applicable not only to those charged in criminal proceedings
but also to extraditees upon showing: (1 ) that the detainee will not be a flight risk or a danger to the community;
and (2 ) that there exist special, humanitarian and compelling circumstances. The currently fragile state of Enrile’s
health presents a compelling justification for his admission to bail.
Pascual vs. Hon. Provincial Board of Nueva Ecija Carpio Morales v. Court of Appeals and Binay, Jr.
G.R. No. L-11959 G.R. Nos. 217126-27
October 31, 1959 November 10, 2015
Gutierrez David, J.: Perlas-Bernabe, J.:

Both cases involve an elective official elected for 2 successive terms who committed administrative offenses during
their first term. Both raise the condonation doctrine as a defense. In the case of Pascual v. Provincial Board,
petitioner was absolved of administrative liability for the reason that: (1) The penalty of removal may not be
extended beyond the term in which the public officer was elected for each term is separate and distinct; (2) An
elective official's re-election serves as a condonation of previous misconduct, thereby cutting the right to remove
him therefor and; (3) Courts may not deprive the electorate, who are assumed to have known the life and
character of candidates, of their right to elect officers. The doctrine was overturned in the case of Carpio Morales
vs. CA which ruled that public officers and employees must at all times be accountable to the people, serve them
with utmost responsibility, integrity, loyalty, and efficiency and act with patriotism and justice, and lead modest
lives. Election is not a mode of condoning an administrative offense, and there is no constitutional or statutory
basis in our jurisdiction to support the notion that an official elected for a different term is fully absolved of any
administrative liability arising from an offense done during a prior term.
Penera vs.COMELEC Penera vs.COMELEC
G.R. No. 181613 G.R. No. 181613
November 25, 2009 November 25, 2009
Chico-Nazario, J.: Carpio, J.:

Penera allegedly committed acts pertaining to premature campaigning, where he campaigned after the filing of
the certificate of candidacy but before the start of the campaign period. In September 2009 Decision, it was held
that a person, after filing his/her COC but prior to the start of the campaign period, can already commit premature
campaigning. However, only after said person officially becomes a candidate, at the beginning of the campaign
period, can acts give effect as premature campaigning and only then can his/her disqualification be sought for
premature campaigning. However in the November 2009 resolution, the court used Lanot v. COMELEC in ruling
that a person who files a certificate of candidacy is not a candidate until the start of the campaign period and
unlawful acts or omissions applicable to a candidate shall effect only upon the start of the aforesaid campaign
period. Congress elevated the Lanot doctrine into a statute by inserting it as the 2nd sentence of the 3rd paragraph
of the amended Section 15 of RA 8436 which cannot be annulled except when unconstitutional. The Decision
cannot reverse Lanot without repealing this 2nd sentence, because to reverse Lanot would mean repealing this 2nd
sentence. Hence, a candidate is liable for an election offense only for acts done during the campaign period, not
before.
Perfecto vs. Meer Nitafan vs. Commissioner of Internal Revenue
G.R. No. L-2348 G.R. No. 78780
February 27, 1950 July 23, 1987
Bengzon, J.: Melencio-Herrera, J.:

Both cases deal with the issue of taxability of the salaries of Justices of the Supreme Court and judges of the lower
court allegedly being unconstitutional since it constitutes a decrease in their salary. In Perfecto vs. Meer, citing the
case of Evans v Gore, it was held that Judges would be hapless guardians of the Constitution if they did not
perceive and block encroachments upon their prerogatives in whatever form. The undiminishable character of
judicial salaries is not a mere privilege of judges, but a limitation upon legislative or executive action imposed in
the public interest. However, in Nitafan v CIR, it was held that Sec. 10, Art. 8 of the 1987 Constitution set aside the
doctrine. The deliberations on the proposal of Sec. 10, Art. 8 clarified the issue: Commissioner Rigos’s proposal,
that the term “diminished” be changed to “decreased” and that the word “nor subjected to income tax” be
deleted, was accepted. Commissioner Bernas announced that by putting a period after “decreased”, it is with the
understanding that the salaries of justices are subject to tax. Thus, the Supreme Court accorded due respect to the
intent of the people in the spirit that all citizens should bear their aliquot part of the cost of maintaining the
government and should share the burden of general income taxation.
People vs. Macarandang People vs. Mapa
G.R. No. L-12088 December 23, 1959 G.R. No. L-22301 August 30, 1967
Paras, C. J.: Fernando, J.:

Both accused in these cases were convicted of illegal possession of firearms. Both were secret agents of their
respective provincial governors. In People vs. Macarandang, the Supreme Court acquitted the accused on the
ground that Section 879 of the Revised Administrative Code exempts peace officers from the requirements relating
to the issuance of license to possess firearms. The appointment of the accused as secret agent to the assist in the
maintenance of peace and order campaigns and detention of crimes, sufficiently put him within the category of a
"peace officer" equivalent even to a member of the municipal police. However, in People vs. Mapa, the Supreme
Court held that the was clear and no provision is made for a secret agent. As such he is not exempt.
The first and fundamental duty of courts is to apply the law. Construction and interpretation come only after it has
been demonstrated that application is impossible or inadequate without them.
Quinto v Morata Taboada v. Rosal
GR No. 31732 G.R. No. L-36033
February 19, 1930 November 5, 1982
JOHNSON, J.: GUTIERREZ, JR., J.

Both of the cases involved institution of probate proceedings involving testamentary dispositions. Oppositions to
the applications were made since both wills in failed to comply with the prescribed form of the attestation clause
stated by law. In Quinto v Morata, the Supreme Court held that the attestation clause must be made in strict
conformity with law and denied the probate ruling that where said clause fails to show on its face full compliance,
the defect constitutes sufficient ground for disallowance of the will. However, after the advent of the New Civil
Code in 1950, In Taboada v Rosal, the Supreme Court allowed the probate of the will of the late Dorotea Perez
declaring that the failure of the will’s attestation clause to state the number of pages used in writing the will would
have been a fatal defect were it not for the fact that it is discernible from the entire will that it is actually
composed of only 2 pages signed by the testatrix and her instrumental witnesses. The law is to be liberally
construed, the underlying and fundamental objective permeating the provisions on the law on wills in this project
consists in the liberalization of the manner of their execution with the end in view of giving the testator more
freedom in expressing his last wishes but with sufficient safeguards and restrictions to prevent the commission of
fraud and the exercise of undue and improper pressure and influence upon the testator.
People v Taño et. al. People v Amarela and Racho
G.R. No. L-11991 G.R. No. 225642-43
October 31, 1960 January 17, 2018
LABRADOR, J.: MARTIRES, J.:
Both cases involved the crime of rape where conviction was anchored on the sole testimony of their victim. In
People vs Taño, the Supreme Court convicted the accused of rape declaring that it is a well-known fact that
women, especially Filipinos, would not admit that they have been abused unless that abuse had actually
happened. This is due to their natural instinct to protect their honor. The aforesaid doctrine, more popularly
known as the Maria Clara Doctrine or Women’s Honor Doctrine, was later modified in the the case of People v
Amarela where the Supreme Court acquitted the accused on grounds of reasonable doubt regarding the testimony
of the victim. As stated by the Court, the opinion in Taño borders on the fallacy of non sequitor. And while the
factual setting back then would have been appropriate to say it is natural for a woman to be reluctant in disclosing
a sexual assault; today, it simply cannot be stuck to the Maria Clara stereotype of a demure and reserved Filipino
woman and should stay away from such mindset and accept the realities of a woman's dynamic role in society
today; she who has over the years transformed into a strong and confidently intelligent and beautiful person,
willing to fight for her rights.
Santiago vs. COMELEC Lambino vs. COMELEC
G.R. No. 127325 G.R. No. 174153
March 19, 1997 November 21, 2006
Davide, Jr., J

Both of the cases involve the inadequacy of R.A. 6735 as the implementing legislation to invoke the right of the
people to directly propose amendments to the Constitution through the system of initiative. In Santiago vs.
COMELEC, it was ruled that R.A. 6735 was inadequate since: (1) The statement and policy of the Act does not
suggest an initiative on amendments to the Constitution; (2) Unlike the other systems of initiative mentioned, the
Act does not provide for the contents of a petition for initiative on the Constitution; and (3) while the Act provides
subtitles for National Initiative and Referendum (Subtitle II) and for Local Initiative and Referendum (Subtitle III),
no subtitle is provided for initiative on the Constitution. The Court also declined to revisit Santiago in the October
2006 Decision of Lambino vs. COMELEC ruling that RA 6735 does not comply with the requirements of the
Constitution to implement the initiative clause on amendments to the Constitution. However, in a minute
resolution of Lambino vs. Comelec, the Supreme Court resolved the petitioner’s motion for reconsideration
holding that RA No. 6735 is adequate and complete for the purpose of proposing amendments to the Constitution
through people’s initiative by a vote of 10 members as per Certification of the En Banc’s Clerk of Court.
Tongko vs. MANULIFE Tongko vs. MANULIFE
G.R. NO. 167622 G.R. No. 167622
November 7, 2008 June 29, 2010
VELASCO, JR., J.: BRION, J.:

The decision and resolution involves the relationship between Tongko and Manulife. Tongko’s was allegedly
illegally dismissed so he filed an illegal dismissal complaint stating he was an employee. In the November 2008
Decision, the Court found that an employer-employee relationship existed since Manulife had control over Tongko
since: (1)Tongko undertook to comply with Manulife’s rules and regulations (2) The affidavits of Manulife’s
insurance agents and managers, who occupied similar positions as Tongko, showed that they performed
administrative duties; and (3) Tongko was tasked to recruit some agents in addition to his other administrative
functions. However in the June 2010 Resolution, the Court ruled that there was no employer employee
relationship, since by the parties’ agreement’s express terms, Tongko served as an insurance agent and not as an
employee. The mere presentation of codes or of rules and regulations, however, is not per se indicative of labor
law control. Neither do guidelines restrictive of the insurance agent’s conduct necessarily indicate
control. Guidelines indicative of labor law control must have the nature of dictating the means or methods to be
employed in attaining the result. There was insufficient evidence regarding the effects of Tongko’s additional roles
in Manulife’s sales operations on the contractual relationship between them.