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POLICE POWER
Ayala Land Inc sold parcel of land to Spouses Jose Critina Yuson with a restriction
that the property shall be used exclusively for the establishment and maintenance
of a preparatory school, However, the spouses evaded such restriction and thus it is
violates zoning ordinance. The court ruled that zoning ordinance in question, while
valid as a police measure, was not intended to affect existing rights protected by
the impairment clause. It is always a wise policy to reconcile apparently conflicting
rights under the Constitution and to preserve both instead of nullifying one against
the other. - The Learning Child, Inc. and Sps. Felipe And Mary Anne Alfonso
vs. Ayala Alabang Village Association, et al., G.R. No. 134269 July 7, 2010
LEGISLATIVE DEPARTMENT

HRET
The 2004 HRET Rules on summons is silent on how the summons should be served
on the protestee. Significantly, Rule 80 of the 2004 HRET Rules provides that the
1997 Rules of Civil Procedure applies by analogy or suppletorily in so far as the
latter may be applicable and not inconsistent therewith as well as with the orders,
resolutions and decisions of the HRET. In view of the failure of the HRET Rules to
specify the authorized modes of service of summons, resort then is necessary to
Sections 6 and 7, Rule 14, 1997 Rules of Civil Procedure. In the case at bar, the
service of the summons was made through registered mail, which is not among the
allowed modes of service under Rule 14 of the Rules of Court. - Datu Pax Pakung
S. Mangudadatu vs. The House of Representatives Electoral Tribunal and
Angelo O. Montilla, G.R. No. 179813, December 18, 2008
EXECUTIVE DEPARTMENT

POWER OF REORGANIZATION
The President, by virtue of Section 31, Chapter 10, Title III, Book III of the
Administrative Code of 1987, has the continuing authority to reorganize the Office
of the President, "in order to achieve simplicity, economy and efficiency." As such,
the issuance of Executive Order No. 378 by President Arroyo was well within her
prerogative. Its constitutionality can be derived from the exercise of a delegated
legislative power granted by law. Moreover, it purports to institute necessary
reforms in government in order to improve and upgrade efficiency in the delivery of
public services by redefining the functions of the NPO and limiting its funding to its
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own income and to transform it into a self-reliant agency able to compete with the
private sector. - Atty. Sylvia Banda, Consoricia O. Penson, Radito V.
Padrigano, et al., vs. Eduardo R. Ermita, in his capacity as Executive
Secretary, The Director General of the Philippine Information Agency and
The National Treasurer, G.R. No. 166620, April 20, 2010
PARDONING POWER
When the pardon extended to former President Estrada shows that both the
principal penalty of reclusion perpetua and its accessory penalties are included in
the pardon. The first sentence refers to the executive clemency extended to former
President Estrada who was convicted by the Sandiganbayan of plunder and imposed
a penalty of reclusion perpetua. The latter is the principal penalty pardoned which
relieved him of imprisonment. The sentence that followed, which states that "(h)e is
hereby restored to his civil and political rights," expressly remitted the accessory
penalties that attached to the principal penalty of reclusion perpetua. Hence, from
the text of the pardon that the accessory penalties of civil interdiction and perpetual
absolute disqualification were expressly remitted together with the principal penalty
of reclusion perpetua.
Furthermore, the third preambular clause of the pardon, i.e., [w]hereas, Joseph
Ejercito Estrada has publicly committed to no longer seek any elective position or
office, neither makes the pardon conditional, nor militate against the conclusion
that former President Estradas rights to suffrage and to seek public elective office
have been restored. A preamble is really not an integral part of a law. It is merely an
introduction to show its intent or purposes. It cannot be the origin of rights and
obligations. Where the meaning of a statute is clear and unambiguous, the
preamble can neither expand nor restrict its operation much less prevail over its
text. Hence if the pardon was intended be conditional, it should have explicitly
stated the same in the text of the pardon itself. Since it did not make an integral
part of the decree of pardon, the 3rd preambular clause cannot be interpreted as a
condition to the pardon extended. - Atty. Alicia Risos-Vidal and Alfredo S. Lim
vs. Commission on Elections and Joseph Ejercito Estrada, G.R. No. 206666,
January 21, 2015
EXECUTIVE PRIVILEGE
Majority of the above jurisprudence have found their way in our jurisdiction. In
Chavez v. PCGG, this Court held that there is a governmental privilege against
public disclosure with respect to state secrets regarding military, diplomatic and
other security matters. In Chavez v. PEA, there is also a recognition of the
confidentiality of Presidential conversations, correspondences, and discussions in
closed-door Cabinet meetings. In Senate v. Ermita, the concept of presidential
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communications privilege is fully discussed. As may be gleaned from the above
discussion, the claim of executive privilege is highly recognized in cases where the
subject of inquiry relates to a power textually committed by the Constitution to the
President, such as the area of military and foreign relations. Under our Constitution,
the President is the repository of the commander-in-chief, appointing, pardoning,
and diplomatic, powers. Consistent with the doctrine of separation of powers, the
information relating to these powers may enjoy greater confidentiality than others.
The above cases, especially, Nixon, In Re Sealed Case and Judicial Watch, somehow
provide the elements of presidential communications privilege, to wit:
1) The protected communication must relate to a quintessential and nondelegable presidential power;
2) The communication must be authored or solicited and received by a
close advisor of the President or the President himself. The judicial test is
that an advisor must be in operational proximity with the President.
3) The presidential communications privilege remains a qualified privilege
that may be overcome by a showing of adequate need, such that the
information sought likely contains important evidence and by the
unavailability of the information elsewhere by an appropriate investigating
authority.
In the case at bar, Executive Secretary Ermita premised his claim of executive
privilege on the ground that the communications elicited by the three (3) questions
fall under conversation and correspondence between the President and public
officials necessary in her executive and policy decision-making process and, that
the information sought to be disclosed might impair our diplomatic as well as
economic relations with the Peoples Republic of China. Simply put, the bases are
presidential communications privilege and executive privilege on matters relating to
diplomacy or foreign relations.
Using the above elements, we are convinced that, indeed, the communications
elicited by the three (3) questions are covered by the presidential communications
privilege. First, the communications relate to a quintessential and non-delegable
power of the President, i.e. the power to enter into an executive agreement with
other countries. This authority of the President to enter into executive agreements
without the concurrence of the Legislature has traditionally been recognized in
Philippine jurisprudence. Second, the communications are received by a close
advisor of the President. Under the operational proximity test, petitioner can be
considered a close advisor, being a member of President Arroyos cabinet. And third,
there is no adequate showing of a compelling need that would justify the limitation
of the privilege and of the unavailability of the information elsewhere by an
appropriate investigating authority. - Romulo Neri vs. Senate Committee on
Accountability Of Public Officers and Investigations, Senate Committee on
Trade and Commerce, and Senate Committee on National Defense and
Security, G.R. No. 180643, March 25, 2008
If what is involved is the presumptive privilege of presidential communications when
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invoked by the President on a matter clearly within the domain of the Executive, the
said presump-tion dictates that the same be recognized and be given preference or
priority, in the absence of proof of a compelling or critical need for disclosure by the
one assailing such presumption. - Romulo L. Neri vs. Senate Committee on
Accountability of Public Officers and Investigations, Senate Committee on
Trade and Commerce, and Senate Committee on National Defense and
Security, G.R. No. 180643, September 04, 2008
JUDICIAL DEPARTMENT

Section 6 of RA No. 8246, cited by the CA Justices as a legal basis for the aforesaid
waiver, does not allow any provision of the said law to be used to justify the transfer
of any member of the CA to any place or station without his or her consent.
However, the movement from one station to another concerned here is occasioned
by the operation of the IRCA, and not by the construction of the provision of RA No.
8246. To our mind, the said provision of law guarantees that a Member of the Court
of Appeals shall not be transferred without his consent from a station where he
ought to be. The said station is determined not by RA No. 8246 but by the rule on
the reorganization of Divisions contained in the IRCA. The said rule is anchored on
the solitary standard supplied by R.A. No. 8246, which is seniority. - RE: Request of
Thelma J. Chiong For Investigation of the Alleged Justice For Sale In CACebu, A.M. No. 07405CA, February 22, 2008
CONSTITUTIONAL COMMISION

COMMISSION ON AUDIT
In Rodolfo S. de Jesus vs. COA, the Court upheld the authority and jurisdiction of the
COA to rule on the legality of the disbursement of government funds by a water
district and declared that such power does not conflict with the jurisdiction of the
courts, the DBM, and the LWUA. Citing Section 2, Subdivision D, Article IX of the
Constitution, the Court declared that it is the mandate of the COA to audit all
government agencies, including GOCCs with original charters. Indeed, the
Constitution specifically vests in the COA the authority to determine whether
government entities comply with laws and regulations in disbursing government
funds, and to disallow illegal or irregular disbursements of government funds. This
independent constitutional body is tasked to be vigilant and conscientious in
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safeguarding the proper use of the governments, and ultimately the peoples,
property. - Rebecca A. Barbo, Eleonora R. De Jesus, and Antonio B. Magtibay
vs. Commission on Audit, G.R. No. 157542, October 10, 2008
As the sole constitutional body mandated to examine, audit and settle all accounts
pertaining to the revenue and receipts of, and expenditures or uses of funds and
property owned or held in trust by, or pertaining to, the government, including
government-owned or controlled corporations, the Commission on Audit is in the
best position to determine which allowances and benefits may be properly allowed
under the circumstances. Using the "public purpose" test, there must be a showing
that the additional allowances and benefits are necessary or relevant to the
fulfillment of the official duties and functions of the government officers and
employees. Otherwise, absent the direct and substantial relationship between the
performance of the public functions and the grant of the disputed allowances, the
disallowance of those benefits cannot be invalidated. - Ramon R. Yap vs.
Commision on Audit, G.R. No. 158562, April 23, 2010
COA had exclusive jurisdiction to decide on the allowance or disallowance of money
claims arising from the implementation of Republic Act No. 6758 (Compensation and
Position Classification Act of 1989). - Manolito Agra et al., vs. Commission On
Audit, G. R. No. 167807, December 6, 2011

COMMISSION ON ELECTION
By virtue of the 1987 Constitution, the COMELEC has the power to investigate and
prosecute cases of violations of election laws. Assuming it was acting as the
National Board of Canvassers at the time it held Bedol in contempt, the board was
still exercising quasi-judicial functions. - Lintang Bedol vs. Commission On
Elections, G.R. No. 179830, December 03 2009
CIVIL SERVICE COMMISION
Both the appointing authority and the appointee are equally real parties in interest
who have the requisite legal standing to bring an action challenging a CSC
disapproval of an appointment. The CSCs disapproval of an appointment is a
challenge to the exercise of the appointing authoritys discretion. The appointing
authority must have the right to contest the disapproval. The appointee is rightly a
real party in interest too. He is also injured by the CSC disapproval, because he is
prevented from assuming the office in a permanent capacity. - Liza M. Quirog and
Rene L. Relampagos vs. Governor Erico B. Aumentado / Civil Service
Commission vs. Court of Appeals and Gov. Erico B. Aumentado, G.R. No.
163443 & G.R. No. 163568, November 11, 2008
A person taking the civil service examinations for another constitutes dishonesty
and grave misconduct. Also, in case where there are discrepancies in the application
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form or personal data sheet such as birth date, bare allegations of want of
knowledge will not hold water unless there is presentation of competent proof. Civil Service Commission vs. Fatima A. Macud, G.R. No. 177531, September
10, 2009
BILL OF RIGHTS

DUE PROCESS
Due process in an administrative context does not require trial type proceedings
similar to those in courts of justice; where opportunity to be heard either through
oral arguments or through pleadings is accorded, there is no denial of procedural
due process. - Atty. Emmanuel Pontejos vs. Hon. Aniano A. Desierto and
Restituto Aquino, G.R. No. 148600, July 7, 2009
During appeals in criminal cases, the Office of the Solicitor General has the power to
represent the State and the failure of the Court of Appeals to notify the State
through the OSG of the pending proceeding shall constitute deprivation of due
process and shall render all subsequent proceedings null and void. - People of the
Philippines vs. Arturo F. Duca, G.R. No. 171175, October 30, 2009
EQUAL PROTECTION
In view of the various stages of deliberation in the selection process and as a
consequence of his/her duty to faithfully enforce the relevant laws, the discretion of
the President in the matter of the Order of National Artists is confined to the names
submitted to him/her by the National Commission for Culture and Arts (NCCA) and
the Cultural Center of the Philippines (CCP) Boards.
There was a violation of the equal protection clause of the Constitution when the
former President gave preferential treatment to respondents Guidote-Alvarez,
Caparas, Maosa and Moreno The conferment of the Order of National Artists on
said respondents was therefore made with grave abuse of discretion and should be
set aside. - National Artist For Literature Virgilio Almario et al. vs. The
Executive Secretary et al., G.R. No. 189028, July 16, 2013
SEARCHES AND SEIZURES
Without valid justification for the in flagrante delicto arrests of accused-appellants,
the search of accused-appellants persons incidental to said arrests, and the
eventual seizure of the shabu from accused-appellants possession, are also
considered unlawful and, thus, the seized shabu is excluded in evidence as fruit of a
poisonous tree. Without the corpus delicti for the crime charged, then the acquittal
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of accused-appellants is inevitable. - People of the Philippines vs. Rolando S.
Delos Reyes, alias "Botong," and Raymundo G. Reyes, alias "Mac-Mac,"
G.R. No. 174774, August 31, 2011

EXPROPRIATION

In the context of the States inherent power of eminent domain, there is taking
where the owner is actually deprived or dispossessed of his property; where there is
a practical destruction or a material impairment of the value of his property; or
when he is deprived of the ordinary use thereof. There is a taking when the
expropriator enters private property not only for a momentary period but for a more
permanent duration, for the purpose of devoting the property to a public use in such
a manner as to oust the owner and deprive him of all beneficial enjoyment thereof.
It cannot be said that the right of eminent domain may be exercised by simply
leasing the premises to be expropriated. In a lease contract, the owner was
compensated and not deprived of the ordinary and beneficial use of his property by
its being diverted to public use, there is no taking within the constitutional sense. Philippine National Oil Company vs. Leonilo A. Maglasang and Oscar S.
Maglasang, G.R. No. 155407, November 11, 2008
RIGHTS OF THE ACCUSED
An accuseds right to have a speedy, impartial, and public trial is guaranteed in
criminal cases by Section 14(2), Article III of the Constitution. This right to a speedy
trial may be defined as one free from vexatious, capricious and oppressive delays,
its salutary objective being to assure that an innocent person may be free from
the anxiety and expense of a court litigation or, if otherwise, of having his guilt
determined within the shortest possible time compatible with the presentation and
consideration of whatsoever legitimate defense he may interpose. Intimating
historical perspective on the evolution of the right to speedy trial, we reiterate the
old legal maxim, justice delayed is justice denied.
A verbal judgment or order of dismissal is a violation of Section 1, Rule 120 of the
Revised Rules of Criminal Procedure hence, such order is, in contemplation of law,
not in esse, therefore, ineffective. - Monico V. Jacob and Celso L. Legarda vs.
Hon. Sandiganbayan Fourth Division and The Office of the Ombudsman,
G.R. No. 162206, November 17, 2010
LAW ON PUBLIC OFFICERS

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ACCOUNTABILITY OF PUBLIC OFFICERS

Dishonesty is incurred when an individual intentionally makes a false statement of
any material fact, practicing or attempting to practice any deception or fraud in
order to secure his examination, registration, appointment, or promotion. It is
understood to imply the disposition to lie, cheat, deceive, or defraud;
untrustworthiness; lack of integrity; lack of honesty, probity or integrity in principle;
lack of fairness and straightforwardness; the disposition to defraud, deceive or
betray. Negligence as the omission of the diligence which is required by the nature
of the obligation and corresponds with the circumstances of the persons, of the
time, and of the place. In the case of public officials, there is negligence when there
is a breach of duty or failure to perform the obligation, and there is gross negligence
when a breach of duty is flagrant and palpable. Given the fact that respondent was
able to successfully overcome the onus of demonstrating that he does not possess
any unexplained wealth and that the omissions in his SALNs did not betray any
sense of bad faith or the intent to mislead or deceive on his part considering that
his SALNs actually disclose the extent of his and his wifes assets and business
interest. - Office of the Ombudsman vs. Arnel A. Bernardo, Attorney V,
Bureau of Internal Revenue (BIR) G.R. No. 181598, March 6, 2013
ADMINISTRATIVE LAW

The PNP Chief had no jurisdiction to entertain appeal in the guise of a motion for reinvestigation filed by petitioners against the decision of Inspection and Legal Affairs
Division of the CPDC. The motion for re-investigation filed by Judge Angeles with
the PNP Chief is in substance an appeal from the decision of the CPDC District
Director. Since the PNP Chief had no jurisdiction, all actions taken by the PNP Chief
pursuant to the appeal is void. - Judge Adoracion G. Angeles vs. P/Insp. John A.
Mamauag, Spo2 Eugene Almario, SPO4 Erlinda Garcia and SPO1 Vivian
Felipe, G.R. No. 153624, October 24, 2008
Courts will decide cases, otherwise moot and academic, if: first, there is a grave
violation of the Constitution; second, the exceptional character of the situation and
the paramount public interest is involved; third, when the constitutional issue raised
requires formulation of controlling principles to guide the bench, the bar and the
public; and fourth, the case is capable of repetition yet evading review, the above
exceptions do not find application in the instant case. - Office of the Deputy

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Ombudsman for Luzon, et al. vs. Jesus D. Francisco, Sr., G.R. No. 172553,
December 14, 2011
ELECTION LAW

DISQUALIFICATION
After a candidate has been proclaimed by the COMELEC, no case for disqualification.
Should COMELEC find probable cause that the proclaimed winner has violated the
Omnibus Election Code and an action for disqualification is instituted as a result, the
Commission should file an information against the winner with regular courts but
shall still dismiss the disqualification case. - Roberto Albaa, Katherine Belo,
Generoso Derramas, Vicente Duran, Ricardo Araque, Merlinda Degala,
Gabriel Aranas, Ernesto Bitoon and Juvic Deslate, vs. Pio Jude S. Belo,
Rodolfo Deocampo and Lorencito Diaz, G.R. No. 158734, October 2, 2009
POLITICAL PARTIES
The twin requirements of due notice and hearing are indispensable before the
COMELEC may properly order the cancellation of the registration and accreditation
of a party-list organization.
Indubitably, if the term-sharing agreement was not actually implemented by
the parties thereto, it appears that SENIOR CITIZENS, as a party-list organization,
had been unfairly and arbitrarily penalized by the COMELEC En Banc. Verily, how
can there be disobedience on the part of SENIOR CITIZENS when its nominees, in
fact, desisted from carrying out their agreement? Hence, there was no violation of
an election law, rule, or regulation to speak of. Clearly then, the disqualification of
SENIOR CITIZENS and the cancellation of its registration and accreditation have no
legal leg to stand on. - Coalition Of Associations of Senior Citizens in the
Philippines, Inc. [Senior Citizens Partylist], represented herein by its
Chairperson and First Nominee, Francisco G. Datol, Jr. vs. Commission on
Elections, G.R. No. 206844-45, July 23, 2013
ELECTIONS PROHIBITED ACTS
When a security guard carries the firearm within the vicinity of the workplace that
he is assigned, the subsequent use of the said firearm shall not constitute a
violation of the Gun Ban Rule. - Juanito R. Rimando vs. Commission On
Elections and Norma O. Magno, G.R. No. 176364, September 18, 2009
After a candidate has been proclaimed by the COMELEC, no case for disqualification.
Should COMELEC find probable cause that the proclaimed winner has violated the
Omnibus Election Code and an action for disqualification is instituted as a result, the
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Commission should file an information against the winner with regular courts but
shall still dismiss the disqualification case. - Roberto Albaa, Katherine Belo,
Generoso Derramas, Vicente Duran, Ricardo Araque, Merlinda Degala,
Gabriel Aranas, Ernesto Bitoon and Juvic Deslate vs. Pio Jude S. Belo,
Rodolfo Deocampo and Lorencito Diaz, G.R. No. 158734, October 2, 2009
JURISDICTION IN ELECTION LAW
Since it is the COMELEC which has jurisdiction to take cognizance of an appeal from
the decision of the regional trial court in election contests involving elective
municipal officials, then it is also the COMELEC which has jurisdiction to issue a writ
of certiorari in aid of its appellate jurisdiction. Clearly, petitioner erred in invoking
this Court's power to issue said extraordinary writ. - Ceriaco Bulilis vs. Victorino
Nuez, Hon. Presiding Judge, 6th MCTC, Ubay, Bohol, Hon. Presiding Judge,
RTC, Branch 52, Talibon, Bohol, G.R. No.195953, August 9, 2011

The Court held that his case must be distinguished from other cases where the
disqualified candidate was shown to be merely leasing a residence in the place
where he sought to run for office. - Representative Danilo Ramon S. Fernandez
vs. House of Representatives Electoral Tribunal and Jesus L. Vicente, G. R.
No. 187478, December 21, 2009
ELECTION PROTEST
COMELEC cannot outright dismiss an appeal due to non-payment of appeal fees
when the Commission itself has promulgated an order clarifying the rules and
promoted liberal construction thereof.
- Constancio D. Pacanan, Jr. vs.
Commission on Elections and Francisco M. Langi, Sr., G.R. No. 186224,
August 25, 2009
LOCAL GOVERNMENTS

PUBLIC CORPORATIONS
Not all corporations, which are not government owned or controlled, are ipso facto
to be considered private corporations as there exists another distinct class of
corporations or chartered institutions which are otherwise known as "public
corporations." These corporations are treated by law as agencies or
instrumentalities of the government which are not subject to the tests of ownership
or control and economic viability but to different criteria relating to their public
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purposes/interests or constitutional policies and objectives and their administrative
relationship to the government or any of its Departments or Offices. - Boy Scouts
of the Philippines vs. Commission On Audit, G.R. No. 177131, June 7, 2011
POWERS OF LOCAL GOVERNMENT UNITS
Under the Local Government Code, two requisites must be met before a national
project that affects the environmental and ecological balance of local communities
can be implemented: prior consultation with the affected local communities, and
prior approval of the project by the appropriate sanggunian. Absent either of these
mandatory requirements, the projects implementation is illegal. Accordingly, the
information dissemination conducted by respondent province months after the
Environmental Compliance Certificates had already been issued was insufficient to
comply with this requirement under the Local Government Code. Had they been
conducted properly, the prior public consultation should have considered the
ecological or environmental concerns of the stakeholders and studied measures
alternative to the project, to avoid or minimize adverse environmental impact or
damage. In fact, respondent Province once tried to obtain the favorable
endorsement of the Sangguniang Bayan of Malay, but this was denied by the latter.
- Boracay Foundation, Inc., vs. The Province of Aklan, represented by
Governor Carlito S. Marquez, the Philippine Reclamation Authority, and the
DENR-EMB (Region VI) G.R. No. 196870, June 26, 2012
SOCIAL JUSTICE

For sure, the NHAs Order of relocating [Petitioner Magkalas] to her assigned lot and
demolishing her property on account of her refusal to vacate was consistent with
the laws funda-mental objective of promoting social justice in the manner that will
inure to the common good. [Magkalas] cannot disregard the lawful action of the
NHA which was merely implementing P.D. No. 1315. It is also worth noting that
[Magkalas] continued refusal to leave the subject property has hindered the
development of the entire area. Indeed, [Magkalas] cannot invoke the social justice
clause at the expense of the common welfare. - Caridad Magkalas vs. National
Housing Authority, G.R. No. 138823, September 17, 2008

ACADEMIC FREEDOM

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While most agree that the right to criticize the judiciary is critical to maintaining a
free and democratic society, there is also a general consensus that healthy criticism
only goes so far. Many types of criticism leveled at the judiciary cross the line to
become harmful and irresponsible attacks. These potentially devastating attacks
and unjust criticism can threaten the independence of the judiciary. The court must
"insist on being permitted to proceed to the disposition of its business in an orderly
manner, free from outside interference obstructive of its functions and tending to
embarrass the administration of justice. - Re: Letter of The Up Law Faculty
entitled "Restoring Integrity: A Statement by the Faculty of the University
of the Philippines College of Law on the Allegations of Plagiarism and
Misrepresentation in the Supreme Court, A.M. No. 10-10-4-SC, March 8,
2011

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