Stonehill v.

Diokno Digest
Stonehill v. Diokno
20 SCRA 283 (1967)
Concepcion, CJ

Facts:
1. Respondent (prosecution) made possible the issuance of 42 search
warrants against the petitioner and the corporation to search persons
and premises of several personal properties due to an alleged violation
of Central Bank Laws, Tariff and Custom Laws, Internal Revenue Code
and the Revised Penal Code of the Philippines. As a results, search and
seizures were conducted in the both the residence of the petitioner and
in the corporation's premises.

2.The petitioner contended that the search warrants are null and void
as their issuance violated the Constitution and the Rules of Court for
being general warrants. Thus,he filed a petition with the Supreme
Court for certiorari, prohibition, mandamus and injunction to prevent
the seized effects from being introduced as evidence in the deportation
cases against the petitioner. The court issued the writ only for those
effects found in the petitioner's residence.

Issue: Whether or not the petitioner can validly assail the legality of
the search and seizure in both premises

RULING: No, he can only assail the search conducted in the residences
but not those done in the corporation's premises. The petitioner has no
cause of action in the second situation since a corporation has a
personality separate and distinct from the personality of its officers or
herein petitioner regardless of the amount of shares of stock or interest
of each in the said corporation, and whatever office they hold therein.
Only the party whose rights has been impaired can validly object the
legality of a seizure--a purely personal right which cannot be exercised
by a third party. The right to object belongs to the corporation ( for the
1st group of documents, papers, and things seized from the offices and
the premises).
La Bugal-Blaan Tribal Association, Inc. Vs Ramos
Natural Resources and Environmental Laws

G.R. No. 127882; January 27, 2004

FACTS:
This petition for prohibition and mandamus challenges the
constitutionality of Republic Act No. 7942 (The Philippine Mining Act of
1995), its implementing rules and regulations and the Financial and
Technical Assistance Agreement (FTAA) dated March 30, 1995 by the
government with Western Mining Corporation(Philippines) Inc. (WMCP).
Accordingly, the FTAA violated the 1987 Constitution in that it is a
service contract and is antithetical to the principle of sovereignty over
our natural resources, because they allowed foreign control over the
exploitation of our natural resources, to the prejudice of the Filipino
nation.

ISSUE:
What is the proper interpretation of the phrase Agreements involving
Either Technical or Financial Assistance contained in paragraph 4,
Section 2, Article XII of the Constitution.

HELD:
The Supreme Court upheld the constitutionality of the Philippine Mining
Law, its implementing rules and regulations insofar as they relate to
financial and technical agreements as well as the subject Financial and
Technical Assistance Agreement.
Full control is not anathematic to day-to-day management by the
contractor, provided that the State retains the power to direct overall
strategy; and to set aside, reverse or modify plans and actions of the
contractor. The idea of full control is similar to that which is exercised
by the board of directors of a private corporation, the performance of
managerial, operational, financial, marketing and other functions may
be delegated to subordinate officers or given to contractual entities,
but the board retains full residual control of the business.
 BUATIS VS. PEOPLE & ATTY. PIERAZ
Facts:
1 On18August1995,thewifeofRespondentAtty.JoseJ.Pierazretrievedaletter,notcontainedinan
envelope,fromtheirmailboxaddressedtoherhusband.
2 Thelettercontainedmaliciousandinsultingwords.TheletterwassignedbyhereinPetitionerJoseBuatis,
Jr.,attorneyinfactofoneMrs.TeresitaQuingco.
3 Notpersonallyknowingwhothesenderwas,nonetheless,Respondentrepliedtotheletter.Reactingtothe
insultingwordsusedbyPetitioner,RespondentfiledacomplaintforlibelagainstBuatis,Jr.Ontheother
hand,Petitionersdefensewasdenial.
4 Petitionerinvokesthatsuchletterwasforhisclientscause,Mrs.Quingco,presidentofanassociation
subjectedtodemolition,andasthelatterscounsel,itishisresponsibilitytodefendhisclient.
5 Aftertrialonthemerits,theRegionalTrialCourt(RTC)foundPetitionerguiltyofthecrimeoflibel
invokingthatcallingthelawyerwithwordsinutil,stupidandcapableonlyofusingEnglishcarabaowas
prejudicialtothegoodnameofRespondentandanaffronttohisgoodstandingasalawyer.
6 PetitionerappealedtotheCourtofAppeals(CA)butthelatteraffirmedtheRTCsdecisioninitsentirety.
TheCAfoundPetitionerswordsusedinthelettertobedefamatoryastheyimpeachedthegoodreputation
ofRespondentasalawyer.
7 TheCAdeniedPetitionersMotionforReconsiderationaswell.Hence,thispresentcase.
ISSUE:
1 Whetherornottheletterislibelous?
2 Whetherornottheappellatecourterredinnotfindingtheallegedlibelousletterasoneofthosefalling
underthepurviewofprivilegecommunication?
RULING:TheCourtheldYES.
RATIO:
1 Foranimputationtobelibelous,theimputationmustbe:(1)defamatory;(2)malicious;(3)begiven
publicity;and,(4)victimmustbeidentified.
2 Allrequisitesarepresentsincetheletterwasnotcontainedinanenvelopeandfurnishednotonlyto
Respondent,hence,therewasapublication.Second,thevictimwasidentifiablesinceitisaddressed
specificallytoRespondent.
3 Theissueismoreonwhethertheletterwasdefamatoryandmaliciousastocomplywithalltherequisites
oflibel.Thecourtheldthatitwasbecausethewordsusedinthesaidlettercastedaspersiononthe
character,integrityandreputationofRespondentasalawyer.Noevidenceneednotbeadducedtoproveit.
4 Thus,whentheimputationisdefamatory,thereisnoneedtoproveifitismaliciousforthelawpresumes
thatitiswithmalice.
5 TheletterofPetitionershowedthathemalevolentlycastigatedRespondentforwritingsuchademandletter
tohisclient.Therewasnothingintheletterthatshowedthegoodintentionandjustifiablemotiveof
Respondentforthebenefitofhisclient.
Qualifiedprivilegedcommunication
1 TheCourtheldNo.thecourtsaidthatinorderforastatementtofallwithinthepurviewofaqualified
privilegedcommunication,thefollowingrequisitesmustconcur:
1 Thepersonmadesuchcommunicationhadalegal,moralorsocialdutytomakethesameorhadaninterest
toprotect;
2 Thecommunicationisaddressedtoanofficerorsuperiorhavingsomeinterestandhavethepowerto
protectsuch;and,
3 Statementsthereinaremadeingoodfaithandwithoutmalice.
2 Theletterdoesnotcontainanyexplanationconcerningthestatusofpetitionersclientbutonlymere
insultingwordswhicharetotallyirrelevanttohisdefense;
3 Theletterwascraftedinaninjuriouswaythanwhatisnecessaryinansweringademandletterwhich
exposedRespondenttopublicridiculehencenegatinggoodfaithandshowingmaliciousintentonthepart
ofPetitioner.
Sincetheletterisnotaprivilegedcommunication,maliceispresumed,thusalibelousoneunderArticle
354oftheRevisedPenalCode.
NOTES.
Petitioners did not dispute that Marcos was a former President and Commander-in-
Chief, a legislator, a Secretary of National Defense, a military personnel, a veteran,
and a Medal of Valor awardee. For his alleged human rights abuses and corrupt
practices, we may disregard Marcos as a President and Commander-in-Chief, but we
cannot deny him the right to be acknowledged based on the other positions he held
or the awards he received. In this sense,
We agree with the proposition that Marcos should be viewed and judged in his
totality as a person. While he was not all good, he was not pure evil either. Certainly,
just a human who erred like us.
It is undeniable that former President Marcos was forced out of office by the people
through the so-called
EDSA Revolution
. Said political act of the people should
not be automatically given a particular legal meaning other than its obvious
consequence - that of ousting him as president.
To do otherwise would lead the Court to the treacherous and perilous path of having
to make choices from multifarious inferences or theories arising from the various acts
of the people. It is not the function of the Court, for instance, to divine the exact
implications or significance of the number of votes obtained in elections, or the
message from the number of participants in public assemblies.
If the Court is not to fall into the pitfalls of getting embroiled in political and
oftentimes emotional, if not acrimonious, debates, it must remain steadfast in abiding
by its recognized guiding stars clear constitutional and legal rules - not by the
uncertain, ambiguous and confusing messages from the actions of the people.

There is none so blind as he who refuses to see. Associate Justice Diosdado Peraltas
ponencia in the Marcos burial cases will go down in history as the cowardly
rationalizations of a willfully blind man; he deserves the opprobrium coming his way.
He still has six years to serve in the Supreme Court, but his legacy will be forever
defined by this badly written, ill-thought-through, deliberately obtuse majority
decision.
Peraltas opinion begins: In law, as much as in life, there is need to find closure.
Issues that have lingered and festered for so long and which unnecessarily divide the
people and slow the path to the future have to be interred. To move on is not to
forget the past. This New Age-speak is nonsense, misleadingly so, because closure
does not come from any Court ruling but from a ruling that is truly just.
The opinion ends with a similar lame attempt at an overview: There are certain
things that are better left for historynot this Courtto adjudge. The Court could
only do so much in accordance with the clearly established rules and principles.
Beyond that, it is ultimately for the people themselves, as the sovereign, to decide, a
task that may require the better perspective that the passage of time provides.
ADVERTISEMENT

That squeaking you hear? Thats the sound of Peralta and the eight justices who
joined the majority trying to fit their bottoms on the fence theyre sitting on. The
people had already decided: They ousted Marcos, supported the restoration of
democratic institutions, overwhelmingly ratified the Constitution. It takes an extra
amount of determination to ignore history.
In between the beginning and the end is judicial hackwork. Incredibly, Peralta does
not grant any of the points raised by the petitioners in Ocampo v Enriquez. Even the
legal standing of Marcos own human rights victims to sue is not recognized. And in
the rush to confirm judgment, Peralta runs roughshod over the very power granted
the Court by the post-Marcos Constitution. Three quick points:
The heart of Peraltas argument is that President Duterte did not commit a grave
abuse of discretion when he issued his order; this reasoning depends on a labored
and unconvincing argument that the order to honor a dictator (recognized as such by
law and previous judgments) is not in fact contrary to the Constitution, law, or
jurisprudence.
His secondary argument is that burial in the Libingan ng mga Bayani is not
tantamount to hailing Marcos as a hero. We can disagree, but we can also note that
his own reasoning proves that burial there will honor Marcos (emphases mine): In
fact, the privilege of interment at the LNMB has been loosen [sic] up through the
years. Since 1986, the list of eligible [sic] includes not only those who rendered active
military service or military-related activities but also non-military personnel who were
recognized for their significant contributions to the [sic] Philippine society. Why
should the nation Marcos brutalized seek to honor him, in a place that the Court itself
recognizes is a national shrine?
And while Peralta is at pains to argue the limits of Marcos ouster (It is undeniable
that former President Marcos was forced out of office by the people through the so-
called EDSA Revolution. Said political act of the people should not be automatically
given a particular legal meaning other than its obvious consequencethat of ousting
him as president), he is content to accept the Solicitor Generals argument that a
mere election gives Mr. Dutertes powers wide latitude.
Justice Peralta invokes history, but he does not understand it the way we do: For him,
history is not so much the fruit of the ongoing and collective effort of a community of
actors, including judges like him who have repeatedly pronounced on the perfidy of
Marcos rule, as rather something distant, something inchoate, something he is gladly
not a part of.
The judgment of history on the Marcoses is clear and has been clear for a generation.
That he, an Ilokano like the late dictator, cannot bring himself to acknowledge it is
proof, if more proof were needed, of moral and intellectual cowardice.
Republicvs.CAandMolina
G.R.No.108763February13,1997

FACTS:

ThecaseatbarchallengesthedecisionofCAaffirmingthemarriageof
therespondentRoridelMolinatoReynaldoMolinavoidintheground
ofpsychologicalincapacity.Thecouplegotmarriedin1985,aftera
year,Reynaldomanifestedsignsofimmaturityandirresponsibilityboth
ashusbandandafatherpreferringtospendmoretimewithfriends
whomhesquanderedhismoney,dependsonhisparentsforaidand
assistanceandwasneverhonestwithhiswifeinregardtotheir
finances.In1986,thecouplehadanintensequarrelandasaresult
theirrelationshipwasestranged.Roridelquitherworkandwenttolive
withherparentsinBaguioCityin1987andafewweekslater,
Reynaldoleftherandtheirchild.Sincethenheabandonedthem.

ISSUE:Whetherornotthemarriageisvoidonthegroundof
psychologicalincapacity.

HELD:

ThemarriagebetweenRoridelandReynaldosubsistsandremains
valid.Whatconstitutespsychologicalincapacityisnotmereshowing
 ofirreconcilabledifferencesandconflictionpersonalities.Itis
indispensablethatthepartiesmustexhibitinclinationswhichwouldnot
meettheessentialmaritalresponsibilitesanddutiesduetosome
psychologicalillness.Reynaldosactionatthetimeofthemarriagedid
notmanifestsuchcharacteristicsthatwouldcomprisegroundsfor
psychologicalincapacity.TheevidenceshownbyRoridelmerely
showedthatsheandherhusbandcannotgetalongwitheachotherand
hadnotshowngravityoftheproblemneitheritsjuridicalantecedence
noritsincurability.Inaddition,theexperttestimonybyDrSison
showednoincurablepsychiatricdisorderbutonlyincompatibility
whichisnotconsideredaspsychologicalincapacity.

Thefollowingaretheguidelinesastothegroundsofpsychological
incapacitylaidsetforthinthiscase:

2 burdenofprooftoshownullitybelongstotheplaintiff
3 rootcausesoftheincapacitymustbemedicallyandclinicallyinclined
4 suchincapacityshouldbeinexistenceatthetimeofthemarriage
5 suchincapacitymustbegravesoastodisablethepersonincomplying
withtheessentialsofmaritalobligationsofmarriage
6 suchincapacitymustbeembracedinArt.6871aswellasArt220,221
and225oftheFamilyCode
7 decisionoftheNationalMatrimonialAppellateCourtortheCatholic
Churchmustberespected
courtshallordertheprosecutingattorneyandthefiscalassignedtoitto
actonbehalfofthestate.