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CORAZON ISON V.

PEOPLE
June 8, 2016

FACTS:
 Ison persuaded Atty. Hermengildo Ramos and Edward Barroga to buy 2 parcels
of fishpond after showing them the Laguna Lake Development Authority permits
and receipts.
 After executing the Contract to Sell, Ramos and Barroga paid P100,000 in cash
as partial payment for the P800,000 price. The two took possession of the
fishponds, and made Ison’s caretaker as their caretaker.
 After paying an additional P50,000, Ramos and Barroga received a call from one
Ligaya Tupaz who told them that Col. Pedro Vergara was the real owner of the
fishponds.
 In a meeting between Ramos, Barroga, and Ison, Ison admitted that she first sold
the fishponds to Vergara. Ramos and Barroga asked her to return their money,
but Ison reneged on her promise.
 Meanwhile, Vergara and eight mamumukot harvested the fish from the fishpond
and took possession of it.
 Ramos and Barroga filed a complaint for estafa against Ison.
 RTC: convicted Ison. CA: affirmed.
ISSUE: Was Ison’s guilt proven beyond reasonable doubt?
HELD: NO
 Col. Vergara's Affidavit, which is part of the evidence submitted by the
prosecution, states that he "requested [Ison] to look for a buyer of [the fishponds]
in CASH in the amount of EIGHT HUNDRED FIFTY THOUSAND PESOS
(P850,000.00)."
o According to Col. Vergara, the Contract to Sell was executed without his
knowledge and consent.
 However, the court found that Col. Vergara's disinterest in filing a complaint or
testifying against Ison militates against the private complainants' claim that Ison
had no authority to enter into the transaction.
 Ison did not employ fraud.
o Col. Vergara had asked Ison to look for a buyer. Although there is no
conclusive proof as to the exact extent or limit of the authority granted to
Ison, the fact remains that she acted upon a color thereof. Col. Vergara's
disinterest in prosecuting Ison for any unlawful acts lends credence to the
foregoing circumstance.
 According to circumstantial evidence, Jess (Barroga’s father) was the one who
introduced Ison to Barroga. It is thus more logical to infer that Jess (and not Ison)
informed his son about matters pertinent to the status and ownership of the
fishponds.
o It can also be presumed that Atty. Ramos knows the intricacies of the law,
had made the necessary inquiries as to the fishponds' ownership, and had
observed due diligence and precaution before agreeing to part with the
amount of P150,000.00 given to Ison.
 Where the inculpatory facts and circumstances are susceptible of two or more
interpretations, one of which is consistent with the innocence of the accused
while the other may be compatible with the finding of guilt, the Court must acquit
the accused because the evidence does not fulfill the test of moral certainty
required for conviction.

REPUBLIC V. AMOR HACHERO


May 30, 2016

FACTS:
 Hachero filed a Free Patent Application before the CENRO of Palawan for the
subject parcel of land. The application was later approved by the PENRO based
on the findings that Hachero had been occupying and cultivating the land himself
since June 12, 1945, and that there was no adverse claim to the land.
 The free patent was issued and the OCT was registered under Hachero’s name.
 However, it was discovered that the subject land was still classified as timberland
and was not susceptible to private ownership.
 The Republic filed a complaint for the cancellation of the free patent and for
reversion.
 Despite personal receipt of the summons and the complaint, however, Hachero
did not file any responsive pleading within the period required by law. Upon the
Republic's motion, the RTC declared Hachero in default. Thereafter, the Republic
was allowed to present its evidence ex-parte.
 The Republic presented its only witness, former CENRO officer Diosdado
Ocampo.
 RTC: decided in favor of Hachero.
 CA: affirmed.
ISSUE: Did the Republic sufficiently prove that the subject land was inalienable?
HELD: YES
 The court held that there is a need to review the findings of the courts below due
to the presence of exceptions to the general rule that the findings of the trial court
are binding and conclusive to the SC.
o 1) when the judgment is based on misapprehension of facts; and 2) when
the findings of fact are contradicted by the evidence on record.
 According to an inspection by the DENR, the subject parcel of land was still
timberland and could not be segregated from the public domain as timberlands
were classified as inalienable and non-disposable public lands.
o The CENRO then issued an Inspection Report and Verification attesting to
such fact.
o They also adduced maps prepared by the NAMRIA which showed that the
subject land was located within the periphery of the land area classified as
unclassified public forest and beyond the alienable and disposable area.
 Since Hachero failed to file any responsive pleading to the complaint, the
presumption of regularity in the performance of official duties applies favorably to
the Republic. This means that the DENR's inspection report and the verification
stating that the subject land is still inalienable has become conclusive.

SPS. MANZANILLA AND REMEDIOS VELASCO V. WATERFIELDS INDUSTRIES


CORP.
July 18, 2014

FACTS:
 Sps. Manzilla are the owners of a parcel of land in Batangas. They leased a
portion thereof to Waterfields, represented by Pres. Aliza Ma.
o The lease shall be for 25 years and there shall be a rental deposit of 216k
to answer for any unpaid rentals, damages, penalties, and unpaid utility
charges.
 Waterfields failed to pay the monthly rental. Ma sent Sps. Manzilla a letter
promising to pay the rentals in arrears by way of check.
o The letter also stated that “the deposit stipulated in our lease contract shall
be used exclusively for the payment of unpaid utilities, if any, and other
incidental expenses only and applied at the termination of the lease.”
 Sps. Manzilla file a complaint for ejectment against Waterfields, alleging that the
latter had committed violations of the lease agreement by not paying rentals on
time.
 Waterfields countered that it did not fail or refuse to pay the monthly rentals but
was just utilizing the rental deposit in the amount of P216,000.00 (equivalent to
one year rentals) as rental payment in accordance with Section 4 of the original
Contract of Lease.
 MTC: found that Ma’s letter amended the contract.
 RTC: affirmed.
 CA: reversed lower courts; held that the rental deposit should have been applied
as payment for unpaid utilities and other incidental expenses.
ISSUE: Did Ma’s letter amend the contract of lease?
HELD: YES.
 Waterfields cannot now contradict its judicial admission that the Contract of
Lease was amended; the doctrine of estoppel likewise bars it from falsifying Ma's
letter in this litigation.
 Section 4, Rule 129 of the Rules of Court provides:
o SEC. 4. Judicial admissions. An admission, verbal or written, made by a
party in the course of the proceedings in the same case, does not require
proof. The admission may be contradicted only by showing that it was
made through palpable mistake or that no such admission was made.
 Waterfields admitted in its Answer the truth of the material allegation that the
contract was amended. It is well- settled that judicial admissions cannot be
contradicted by the admitter who is the party [itself] and binds the person who
makes the same, and absent any showing that this was made thru palpable
mistake (as in this case), no amount of rationalization can offset it.

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