Case Digest

Facts Miguel Aquino had three sons: Arturo, Rodolfo, and Abbulah. Arturo and a woman named Maria Angela Kuan Ho had relations, resulting in the birth of Angela Aquino, their illegitimate child. Maria and Arturo also had plans to get married. Sadly, Arturo passed away on January 10, 1999, before Angela was born and before he and Maria could officially marry. Though Maria and Arturo never got married, Miguel treated his granddaughter very fondly. In fact, he paid for all of Maria’s expenses during her pregnancy and had Angela live with the Aquinos in their ancestral home. Angela’s uncles, Rodolfo and Abbulah, were also quite fond of her, and Rodolfo was made to be one of Angela’s godfathers. Things changed drastically after Miguel’s death. Upon settlement of his estate, it was found that Angela was included among the heirs who would receive portions of the estate. Her uncles, Rodolfo and Abbulah, opposed this. This is because according to them: ISSUE: Can an illegitimate child inherit from his/her direct ascendants? YES. Children, regardless of their circumstances at birth, are QUALIFIED to inherit from their direct ascendants. There was no specification in the term “grandchildren” whether only legitimate children are allowed to inherit from their grandparents, so there was no need to qualify, much less restrict, the application to only legitimate grandchildren. It is unfair for an illegitimate child to be placed in an unfair situation wherein he/she is only inheriting half as much as his/her legitimate counterparts. The ponencia did away with the terms “illegitimate” and “legitimate” when referring to children based on their parent’s status. Instead, Justice Leonen used the terms “marital” and “nonmarital” children.

Facts Grace Poe was found abandoned as a newborn infant in the Parish Church of Jaro, Iloilo in 1968. At age 5, she was adopted by celebrity spouses Fernando Poe, Jr. and Susan Roces. She initially pursued a degree in Developmental Studies at the University of the Philippines but opted to continue her studies abroad and left for the U.S. in 1988. She immigrated to the U.S. in 1991 after her marriage to Theodore Llamanzares, who was based in the U.S. at the time. In 2001, she became a naturalized American citizen. In 2004, Grace Poe returned to the Philippines to support her father’s candidacy for President. After her father’s death, she and her husband decided to reside permanently in the Philippines in 2005. On 7 July 2006, Grace Poe took her Oath of Allegiance to the Republic of the Philippines pursuant to the Citizenship Retention and Re-acquisition Act of 2003. The BI declared that she is deemed to have reacquired her Philippine citizenship while her children are considered as citizens of the Philippines. Consequently, the BI issued Identification Certificates (ICs) in her name and in the names of her three children. In 2010, President Benigno S. Aquino III appointed Grace Poe as Chairperson of the Movie and Television Review and Classification Board (MTRCB). Before assuming her post, she executed an “Affidavit of Renunciation of Allegiance to the United States of America and Renunciation of American Citizenship” before a notary public in Pasig City on 20 October 2010, in satisfaction of the legal requisites stated in Section 5 of R.A. No. 9225. The following day, she submitted the said affidavit to the BI and took her oath of office as Chairperson of the MTRCB. From then on, Grace Poe stopped using her American passport. On 2 October 2012, she filed with the COMELEC her Certificate of Candidacy (COC) for Senator for the 2013 Elections wherein she answered “6 years and 6 months” to the question “Period of residence in the Philippines before May 13, 2013.” She obtained the highest number of votes and was proclaimed Senator on 16 May 2013. On 15 October 2015, Grace Poe filed her COC for the Presidency for the May 2016 Elections. In her COC, Grace Poe declared that she is a natural-born citizen and that her residence in the Philippines up to the day before 9 May 2016 would be ten (10) years and eleven (11) months counted from 24 May 2005. Her filing of her COC for President in the upcoming elections triggered the filing of several COMELEC cases against her which were the subject of these consolidated cases. These cases argued that Grace Poe cannot be considered as a natural-born Filipino on account of the fact that she was a foundling, and that international law does not confer natural-born status and Filipino citizenship on foundlings. They also argued that she fell short of the ten-year residency requirement of the Constitution as her residence could only be counted at the earliest from July 2006, when she reacquired Philippine citizenship under the said Act. Issue ISSUE 1: Should Grace Poe be considered a natural-born Filipino citizen? YES. Grace Poe’s blood relationship with a Filipino citizen is DEMONSTRABLE. To deny full Filipino citizenship to all foundlings and render them stateless just because there may be a theoretical chance that one among the thousands of these foundlings might be the child of not just one, but two, foreigners is downright discriminatory, irrational, and unjust. ISSUE 2: Does Grace Poe satisfy the 10-year residency requirement of the Constitution? YES. Grace Poe’s claim that she will have been a resident for ten (10) years and eleven (11) months on the day before the 2016 elections, is true. This period of residence corresponds to a beginning date of 25 May 2005 when she returned for good from the U.S. Ruling The petition was thus GRANTED. GRACE POE is DECLARED QUALIFIED to be a candidate for President in the National and Local Elections of 9 May 2016.

Facts: Mabao was a a former teacher at BWS. She started working on June 7, 2007 as a grade school teacher. She was granted regular status in 2010.  Sometime in September 2016, Mabao approached the head of the administrative team and Deloso, the grade school principal of BWS, to discuss the matter of her pregnancy which was two months along the way. The father of Mabao’s baby was her boyfriend. In order to avoid any unpleasant remarks from the faculty and staff of BWS, Mabaoapproached them even before her bump became evident. The following day, Mabao was summoned to the conference room of BWS where Deloso verbalysuspended Mabao, telling her not to report to her classes starting the next day until she could present documents showing that she was already married to her boyfriend. Thereafter, she was summoned to the office of the head of the administrative team and was asked to receive a Disciplinary Form and a letter stating that she was indefinitely suspended without pay. Ruling of the Labor Arbiter The Labor Arbiter held that Mabao was constructively dismissed. Ruling of the NLRC The NLRC found that Mabao’s suspension is not tantamount to constructive dismissal. Ruling of the Court of Appeals The Court of Appeals affirmed the NLRC’s ruling that there was no constructive dismissal, but held that Mabao was illegally suspended. Issue Was Mabao illegally suspended? Did Mabao abandon her employment? Supreme Court’s Ruling Mabao was illegally suspended. In the eyes of the law, there is a standard of morality that binds all those who come before it, which is public and secular, not religious. It is important to make this distinction as the Court’s jurisdiction extends only to public and secular morality. The Court has previously ruled in similar cases that premarital sexual relations resulting in pregnancy out of wedlock cannot be considered disgraceful or immoral when viewed against the prevailing norms of conduct. Sexual intercourse between two consenting adults who have no legal impediment to marry, lie respondent and her boyfriend, is not deemed immoral. No law proscribes such, and said conduct does not contravene any fundamental state policy enshrined in the Constitution. Mabao’s suspension on the ground of engaging in premarital sexual relations resulting in pregnancy out of wedlock is therefore illegal. Mabao abandoned her employment. To constitute abandonment, the employer must prove that: (1) the employee failed to report for work or must have been absent without valid or justifiable reason; and (2) there is a clear intention on the part of the employee to sever the employer-employee relationship by some overt act. BWS gave respondent three return to work notices. Despite receipt and knowledge of the return to work notices, respondent failed to return to work. Aside from failing to return to work despite due notice, Mabao clearly manifested her desire to end her employment in her letter where she unequivocally stated that she “could no longer go back to work for the school”. The letter is respondent’s overt act manifesting her clear intention to sever her employment with petitioners.

Facts Jonald O. Torreda (petitioner) was hired by Investment and Capital Corporation of the Philippines (respondent) on May 17, 2010 as an IT Senior Manager. He was tasked to supervise his team in the Information Technology (IT) Department and manage the IT-related projects. He reported to William M. Valtos, Jr. (Valtos), the Officer­ in-Charge of the IT Department and the Group President of the Financial Service of respondent. Sometime during his employment, he had a falling out with the senior management for its interference with the functions of the IT department. On January 5, 2012, petitioner went to the office of Valtos for a closed-door conference meeting supposedly regarding his IT projects. In said meeting, Valtos discussed another matter with petitioner and told him that if his performance were to be appraised at that time, Valtos would give him a failing grade because of the negative feedback from the senior management and the IT staff. The performance appraisal of petitioner, however, was not due until May 2012. Torreda was then gave petitioner a prepared resignation letter and asked him to sign; otherwise, the company would terminate him. The said letter indicated that the resignation of petitioner would be effective on February 4, 2012. Petitioner refused to sign the resignation letter but such refusal was not accepted. Thus, Valtos edited the resignation letter. Petitioner thought of leaving the room by making an excuse to go to the restroom, but Valtos and respondent’s legal counsel followed him.  Because of Valtos’ insistence, petitioner placed his initials in the resignation letter to show that the letter was not official. Valtos then accompanied petitioner to his room to gather his belongings and escorted him out of the building. Petitioner was not allowed to report for work anymore and his company e-mail address was deactivated.  Six (6) days after the incident, petitioner filed the instant complaint for illegal dismissal (constructive), moral and exemplary damages and attorney’s fees against respondent. For its part, respondent countered that petitioner was not illegally dismissed because he voluntarily resigned. Respondent stated that while Valtos admitted that he gave a resignation letter to petitioner on January 5, 2012, petitioner himself edited the letter to include courteous words and voluntarily signed the same. Valtos also admitted that the performance appraisal of petitioner was not due until May 2012.  Issue 1. Whether or not the resignation letter was voluntarily signed Respondent argues that since petitioner edited the resignation letter and added words of courtesy, it was improbable for him to involuntarily sign the letter. It further asserts that it was impossible to coerce petitioner to sign a prepared resignation letter because he had a managerial position and a high educational status.  These numerous facts and circumstances certainly contradict the voluntariness of petitioner’s resignation. Any reasonable person in the petitioner’s position would have felt compelled to give up his position. Assuming arguendo that petitioner edited the said letter and inserted words of courtesy, these are insufficient to prove the voluntariness of his resignation in light of the various circumstances which demonstrated that he did not have a choice in his forced resignation.

FACTS Aileen R. Macabangon is a barangay kagawad of Muntay, Kolambugan, Lanao del Norte. She mediated between Argelyn M. Labargan and Edna Jumapit in a barangay conciliation to settle their dispute. Labargan’smother, Virginia, told her that she should not mediate “because she is dumb, has not gone to school and is ignorant.”   Macabangon was walking past Labargan’s house one day, when she heard Labargan yelled from her house’s terrace that the she was “dull”, “uneducated”, “ignorant”, and biased against Labargan in the barangay conciliation proceedings.  “Si Aileen konsehan nga bugo, walaygrado! Ignorante!”   Many people heard these remarks as Labargan’sterrace was just beside the highway.   The Municipal Circuit Trial Court found Labargan guilty of grave oral defamation. The Regional Trial Court and Court of Appeals upheld the conviction. ISSUE:    WON Labargan is guilty of Grave Oral Defamation under the Revised Penal Code RULING:     The Supreme Court ruled that Petitioner Labargan is not guilty of grave oral defamation.    In acquitting Labargan, the Supreme Court ruled that offensive remarks against public officers do not constitute defamation, if they relate to their discharge of official duties, unless actual malice is proven.   Under Article 358 of the Revised Penal Code, there is oral defamation or slander when (1) there is an imputation of a crime, or of a vice or defect, real or imaginary, or any act, omission, status or circumstances; (2) made orally; (3) publicly; (4) and maliciously; (5) directed to a natural or juridical person, or one who is dead; and (6) which tends to cause dishonour, discredit or contempt of the person defamed. As the law assumes that a defamatory allegation is malicious, or made with knowledge that it is false, the person who made the defamatory remarks has the burden of proving there was no malice.   However, when it comes to defamation against public officers in relation to their duties, the prosecution has the burden to prove there was actual malice in the defamatory remarks. The Court recognizes that the right to free speech empowers citizens to hold public officers accountable because public office is a public trust.   In the present case, the object of the complaint were statements against Macabangon, a barangay kagawad. The imputations were criticisms of her competence as a barangay kagawad, originating from her supposed partiality against Labargan in the barangay conciliation proceedings. These relate to Macabangon’s discharge of her official duties as a public officer.  The Court concluded by stressing that while Labargan’s statements against Macabangon may be offensive, they are not actionable by themselves. “Being ‘sensitive’ has no place in this line of service, more so when allowing otherwise has the potential to create a chilling effect on the public.”    The prosecution did not show that actual malice attended Labargan’s declarations. It was not established whether the defamatory statements were made with knowledge that these were false, or with reckless disregard as to its falsity.   Due to the prosecution’s failure to prove malice in uttering the defamatory statements, the Supreme Court finds that Labargan is not guilty of grave oral defamation.

Facts Lingganay was hired by the respondents as a bus driver sometime in 2013. In October 2013, he figured in an accident while driving the company bus along Maharlika Hi-way in Brgy. Concepcion, Quezon Province.  On 30 December 2016, Lingganay was involved in another accident—this time, with a motorcycle. On 01 May 2017, Lingganay again figured in an accident as he crashed into the rear portion of a Toyota Wigo while driving the company bus along the San Juanico Bridge, Samar.  On 29 May 2017, respondents decided to terminate Lingganay from Employment for transgressing the company rules and regulations on health and safety, i.e. “Violation 8.1.4 – Any form of laxity, reckless driving, and gross negligence, resulting to damages to property, injuries, death, and other casualties.”  This prompted Lingganay to file a complaint for illegal dismissal with money claims against respondents.  The Labor Arbiter (LA) ruled in favor of the respondents and dismissed Lingganay’s complaint, which the NLRC affirmed. The Court of Appeals (CA) agreed with the labor tribunals that Lingganay was validly dismissed  as he repeatedly violated the Health and Safety Rules of the Company, and also on the ground of gross and habitual neglect of duties in accordance with Art. 282 of the Labor Code.  Lingganay insists that even if he was indeed negligent in the performance of his tasks, it was not shown that his negligence was both gross and habitual, since his past mishaps were merely minor.  Hence, this present petition for review on certiorari.  Issue Whether or not Lingganay was validly dismissed from employment.  Ruling YES. The Supreme Court  (SC) held that respondents validly terminated Lingganay from employment for transgressing the company rules and regulations on health and safety, and for his gross and habitual neglect of his duties under Art. 297(b) of the Labor Code.  Furthermore, the SC declared that even assuming arguendo that the employee’s gross negligence was not habitual, the element of habituality may be dispensed with in instances when the recklessness caused substantial damage or loss to the employer.  Here, the infraction of Lingganay when he crashed into the Toyota Wigo caused substantial damage to the car in the amount of Php99,000.00 and to the company bus amounting to Ph6,500. Respondents were compelled to pay the full amount of Php99,000 just to avoid any possible legal suit against the company. This damage was so substantial that respondents cannot be legally compelled to continue his employment. 

Doctrine: Insurers must not be allowed to delay the payment of claims by filing frivolous cases in court, hoping that the inevitable may be put off for years—or even decades—by the pendency of these unnecessary court cases Facts Romeo obtained an accident insurance policy from several insurance companies including Philam Life Insurance. One day, as he was coming out of the bathroom, Romeo tripped causing his right eye to hit the arm rest of a chair. He called out to his spouse, Luisa, who promptly rushed to his side Romeo was immediately brought to the clinic Dr. Villanueva. After a series of check-ups, he underwent an enucleation, a surgical procedure involving the removal of his right eye. On account of the surgery, he incurred medical expenses in the sum of PHP 31,060.00. Consequently, Romeo filed written notices of injury with the insurance companies. To his dismay, his claims were disapproved based on the joint affidavit of their former household helpers who denied the occurrence of the accident.  The disapproval of the claims prompted Romeo and Luisa (spouses Soriano) to lodge separate complaints before the RTC against the insurance companies for accident insurance proceeds, specific performance, damages, and attorney’s fees. During the trial, spouses Soriano presented themselves and Dr. Villanueva as witnesses. On the other hand, Philam Life proffered the testimony of the househelperand the medical opinion of Dr. Dr. Valenton, a credited physician of Philam Life. In due course, the RTC rendered its Judgment, dismissing the complaints based on the equipoise rule. Issue Whether or not the RTC erred in not granting Romeo the insurance proceeds? Ruling Yes. In civil cases, the quantum of evidence to be observed is preponderance of evidence. Preponderance of evidence means that the evidence adduced by one side is superior to or has greater weight than that of the other. It means that evidence which is more convincing to the Court as worthy of belief than that which is offered in opposition thereto.  Jurisprudence teaches that when the evidence of the parties are evenly balanced or when there is doubt on which side the evidence preponderates, the decision should be against the party with the burden of proof, according to the equipoise doctrine. Here, the RTC erred in applying the equipoise rule considering that the spouses Soriano were able to prove through preponderance of evidence that Romeo’s injury was caused by an accident, thus entitling him to the proceeds of the subject accident insurance policies. Their testimonies were sufficiently corroborated by the testimony of Dr. Villanueva, who clearly explained the findings he gathered in his examination of Romeo on January 29, 2001 or the day of the accident Determined to prove that Romeo was not entitled to the insurance benefits, PhilamLife raised Dr. Valenton ‘s medical opinion to controvert Dr. Villanueva’s testimony. It claims that Dr. Villanueva found no abrasion or hematoma. However, a perusal of Dr. Villanueva’s testimony plainly reveals that he “observed sub-conjunctival harmorhage, hemorrhage occuring in between the consubjunctival sclera of the eye. In contrast, Dr. Valenton, by his own admission, did not personally examine Romeo, but merely offered a different interpretation based on the findings made by Dr. Villanueva Hence, the Court ordered Philam Life, along with the other insurance companies, to pay jointly and severally actual damages or medical reimbursement to spouses Soriano in the amount of PHP 31,060.00 and the insurance proceeds for the permanent and irrecoverable loss of sight and of Romeo’s right eye.  In so ruling, the Court commiserated with the two-decade plight of spouses Soriano, surpassing the death of Romeo. Certainly, insurers must not be allowed to delay the payment of claims by filing frivolous cases in court, hoping that the inevitable may be put off for years—or even decades—by the pendency of these unnecessary court cases. They employ this period to benefit from collecting the interest and returns on both the premiums previously paid by the insured clients and the insurance proceeds which should otherwise go to their beneficiaries.  Philam Life’s deliberate delay in the payment of insurance proceeds and protracted litigation warrant the imposition of exemplary damages. This imposition serves as a warning to insurers or insurance companies of the consequences of unreasonably denying or delaying the payment of legitimate claims. Hence, aside from the insurance claim, Philam Life was also ordered to pay exemplary damages in the amount of PHP 50,000.00 with interest.

Doctrine: Employer’s insulting words and hostile behavior toward an employee constitutes constructive dismissal Facts: In 2009, Bartolome was hired by Toyota Q. Ave as a marketing professional trainee of its Vehicle Sales Department. He became a regular employee in 2010, tasked in selling of Toyota’s cars, products, and services.  On December 2015, Bartolome received a Notice of Decision for Habitual Absences for October 2015 and a Notice of Explanation for the same offense for November 2015. He also received a notice putting him on a 7-day suspension for  another offense.  A meeting was set by management for the purpose and Bartolome brought his sibling along, who was a lawyer. After the meeting, he thought that the matter was settled but then the president of the company, in another meeting, uttered remarks against him, especially for bringing his sibling along.  This began a series of incidents which lead Bartolome to resign: These series of events and the hostile working environment become unbearable for him to continue working, and thereafter, he resigned.  Even when he was processing his clearance, he was treated like a stranger. His last pay did not include his commissions and his 13th month pay. ISSUE: Was Bartolome constructively dismissed?  YES. The foregoing chain of events created a hostile working environment that made it impossible and unbearable for petitioner to continue working for TQAI. On this score, we emphasize that these events were not even refuted by respondents themselves. In weighing the argument of the parties, it is important to examine the evidence presented. As substantial evidence, or “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,” the detailed series of events supported by documentary evidence of petitioner must be given credence over the general denial of the respondents. The uttered words of respondents against petitioner, contrary to the respondents’ allegation, are not self-serving statements. Here, petitioner’s account of the events which rendered his employment conditions unbearable, leaving him with no other choice but to resign, was “candid, straightforward[,] and categorical.” It came from matters of his own personal knowledge. It should not be brushed aside, more so since it was unrefuted by the other party and was even amply corroborated by documentary evidence. Verily, petitioner was constructively dismissed. Surely, the calculated and combined acts of his higher ups constitute acts of disdain and hostile behavior, supporting the conclusion that they were collectively easing out petitioner who consequently had no choice but leave his employment. This is constructive dismissal pure and simple. Though the labor arbiter found nothing extraordinary about the resignation letter as it did not exactly indicate a tone of anger nor some sense of ingratitude, the circumstance before the resignation would show that he did not contemplate nor had any intention of resigning from the company were it not for respondents’ hostile and disdainful actions. When he tried to process his clearance on April 21, 2016, he was treated like a “stranger-criminal” and subjected to undue harassment. Notably, the document titled “special release of claim and/or quitclaim” dated July 9, 2016, bore, beside his signature, the term “w/o prejudice.” It was an unequivocal reservation of his right to bring an action against respondents despite his execution thereof. Thus, merely 24 days after, on August 4, 2016, he filed a Complaint for illegal/constructive dismissal and money claims against respondents. Doubtless, his resignation was involuntary and bore a clear reservation to file an action against respondents.