You are on page 1of 5

Vda. De Haberer vs.

Court of Appeals
G.R. Nos. L-42699 to L-42709; May 26, 1981 ISSUE:
Whether or not the respondent could claim payment for the
FACTS: damages incurred by the petitioner.
The lower court dismissed 11 complaints for recovery of
parcel of land. Plaintiff dies pending appeal. Counsel notifies the RULING:
court of appellant’s death, and prayed for suspension of the period Mere breach of marriage is not punishable by law.
for filing an appellant’s brief pending appointment of an executor. However, since the respondent was proved to have a good moral
The Court of Appeals denies extension and dismisses the appeal. character, and that she had just let her virginity be taken away by
the petitioner since the latter offered a promise of marriage, then
ISSUE: she could ask for payment for damages. Furthermore, since she let
Whether or not the death of one of the parties in a pending her lover, the petitioner, “deflowered” her since she believed that
case is a proper recourse in dismissing the same. his promise to marry was true, and not due to her carnal desire,
then she could have her claims against the petitioner. Moreover,
RULING: the father of the respondent had already looked for pigs and
The Rules of Court requires appearance of the deceased chicken for the marriage reception and the sponsors for the
legal representatives instead of dismissing the case. Dismissal of marriage, and then damages were caused by the petitioner against
an appeal on the ground of failure to file appellant’s brief must be the respondents, which qualified the claims of the respondent
in accordance with the tenets of justice and fair play. The extension against the petitioner.
should have been granted.

University of the East vs. Jader


Gashem Shookat Baksh vs. Court of Appeals GR No. 132344 - February 17, 2000
GR No. 97336 - February 19, 1993
FACTS:
FACTS: Romeo Jader, a law student of the University of the
Petitioner was a medicine student at Lyceum East, failed to take his regular examination in Practice Court I in his
Northwestern Colleges at Dagupan City. He was an Iranian first semester of his last school year. However, he was able to
exchange student and was 29 years old. Respondent was a former remove the incomplete mark when the Dean of his college
waitress on a luncheonette, and was 22 years old. Petitioner was approved his application to take a removal examination.
allegedly the lover of the respondent, and was said to promise In the 2nd semester, his name appeared in the tentative list
marriage to the latter, which convinced her to live with him in his of candidates for graduation for the
apartment. Decree of Bachelor of Laws and in the invitation for the 35th
It was even alleged that the petitioner went to the house of the Investiture and Commencement Ceremonies, the plaintiff’s name
respondent to inform her family about the marriage on the end of appeared. Thus, he attended the investiture ceremonies and
the semester. However, the marriage did not materialize, with graduated.
several beatings and maltreatment experienced by the respondent On April to September 1998, he took a leave of absence
from the petitioner. from his work and enrolled at the pre-bar review class in Far
The case was filed in the RTC of Pangasinan, and the Eastern University. To his dismay upon knowing that he incurred a
decision was held in favor of the respondent. However, the deficiency, he dropped his review class and was not able to take
petitioner claimed that the judgment of the RTC was an error, for the bar examinations.
the claims of the respondent are not true, and that he did not know He then filed a suit against UE praying for moral and
about the custom of the Filipinos; his acts were in accordance of his exemplary damages arising from the latter’s negligence. The trial
custom. The decision of the RTC was affirmed in toto by the Court court ruled in his favor and was granted for actual damages. The
of Appeals. Hence, the petitioner filed an appeal to the Supreme Court of Appeals affirmed the trial court’s decision with
Court. modification. The CA awarded moral damages. On account of
suffering moral shock, mental anguish, serious anxiety, besmirched
reputation, wounded feelings and sleepless nights and ultimately RULING:
for not having to take the bar exam. Since the present case does not involve the annulment of a
bigamous marriage, the provisions of article 50 in relation to
ISSUE: articles 41, 42 and 43 of the Family Code, providing for the
Whether or not Jader may validly claim for damages. dissolution of the absolute community or conjugal partnership of
gains, as the case maybe, do not apply. Rather the general rule
RULING: applies, which is in case a marriage is declared void ab initio, the
In view of the foregoing issue, the Supreme Court property regime applicable to be liquidated, partitioned and
emphatically enunciated that moral damages cannot be awarded to distributed is that of equal co-ownership.
Romeo Jader. It cannot believe that he suffered shock, trauma, and Since the properties ordered to be distributed by the court a
pain. Along this vein, the Supreme Court held Jader negligent. It quo were found, both by the RTC and the CA, to have been
opined that as a student, he should have been responsible enough acquired during the union of the parties, the same would be
to ensure that all his affairs, especially those appertaining to his covered by the co-ownership. No fruits of a separate property of
academics, are in order. If respondent was indeed humiliated by his one of the parties appear to have been included or involved in said
failure to take the bar, he brought this upon himself by not distribution.
verifying if he has satisfied all the requirements. While the Court
held the University of the East negligent and therefore liable for
actual damages in favor of Jader, the latter was also held liable for Jesus B. Ruiz vs. Encarnacion Ucol
negligence thereby no moral damages can be awarded in his favor. G.R. No. L-45404, August 7, 1987
The decision was affirmed with modification. FACTS:
The laundrywoman for plaintiff-appellant Ruiz filed an
administrative charge
Noel Buenaventura vs. Court of Appeals against defendant-appellee Ucol. Ucol, in her answer, alleged that
G.R. Nos. 127358 - G.R. Nos. 127449; March 31, 2005 Tagaca was
merely used as a tool by Ruiz who wanted to get back at the Ucol's
FACTS: because of a case filed by respondent’s husband against Ruiz. She
Noel Buenaventura filed a position for the declaration of was also alleged to have made remarks that Ruiz instigated the
nullity of marriage on the ground that both he and his wife were complaint and fabricated the charges.
psychologically incapacitated. When the administrative case was dismissed, the petitioner
The RTC in its decision, declared the marriage entered into filed his own criminal complaint for libel against Ucol based on the
between petitioner and respondent null and violation ordered the alleged libelous portion of Ucol's answer.
liquidation of the assets of the conjugal partnership property; The lower court acquitted Ucol on the ground that her guilt
ordered petitioner a regular support in favor of his son in the was not established beyond reasonable doubt. The trial court as to
amount of 15,000 monthly, subject to modification as the necessity the civil liability of the accused made no pronouncement. Instead of
arises, and awarded the care and custody of the minor to his appealing, Ruiz filed a separate complaint for damages based on
mother. the same facts upon which the libel case was founded.
Petitioner appealed before the CA. While the appeal was Ucol filed a motion to dismiss stating that the action had
pending, the CA, upon respondent’s motion issued a resolution prescribed and that the cause of action was barred by the decision
increasing the support pendants like to P20, 000. in the criminal case for libel. The trial court granted the motion to
The CA dismissal petitioner appeal for lack of merit and dismiss on the ground of res judicata. On appeal, the appellate
affirmed in to the RTC decision. Petitioner motion for court certified the case to the Supreme Court.
reconsideration was denied, hence this petition.
ISSUE:
ISSUE: Whether or not the civil action for damages was already
Whether or not co-ownership is applicable to valid marriage. barred by the criminal case of libel.
H.N Bull, who was the master of a vessel transporting cattle,
RULING: carabao and other animals from Formosa to Manila, failed to
The contentions of the petitioner have no merit. Art. 33 of the Civil provide suitable means for securing the animals while they are in
Code, independently of a criminal action for defamation, a civil suit transit. Such neglect was a violation of Act. No. 275 of the
for the recovery of damages arising therefrom may be brought by Philippine Commission, which reads:
the injured party. The civil liability arising from the crime charged “The owners or masters of steam, sailing, or other vessels,
may still be determined in the criminal proceedings if the offended carrying or transporting cattle, sheep, swine, or other
party does not waive to have it adjudged, or does not reserve his animals, from one port in the Philippine Islands to another,
right to institute a separate civil action against the defendant. or from any foreign port to any port within the Philippine
The Supreme Court did not find any defamatory imputation, Islands, shall carry with them, upon the vessels carrying
which causes dishonor, or discredit to the complainant. She was the such animals, sufficient forage and fresh water to provide
victim of an unprovoked, unjustified and libelous attack against her for the suitable sustenance of such animals during the
honor, honesty, character and reputation; she has a right to self- ordinary period occupied by the vessel in passage from the
defense, which she did in her answer, to protect her honesty and port of shipment to the port of debarkation, and shall cause
integrity and the very job upon which her family depend for such animals to be provided with adequate forage and fresh
their livelihood. water at least once in every twenty-four hours from the time
that the animals are embarked to the time of their final
debarkation.”
Bellis vs. Bellis Bull contends that the Philippine courts have no jurisdiction
G.R. No. L-23678 over his offense.

FACTS: ISSUE:
Amos G. Bellis was a citizen and resident of Texas at the Whether or not the Philippines has jurisdiction over this
time of his death. Before he died, he made two wills, one disposing case.
his Texas properties, the other disposing his Philippine properties.
In both wills, the recognized illegitimate children were not given RULING:
any share. Texas has no conflict rule (Rule of Private International When a vessel comes within 3 miles from the headlines
Law) governing successional rights. Furthermore, under Texas law, which embrace the entrance of Manila Bay, the vessel is within the
there are no compulsory heirs. territorial waters and thus, the laws of the Philippines shall apply. A
crime committed on board a Norwegian merchant vessel sailing to
ISSUE: the Philippines is within the jurisdiction of the courts of the
Whether or not such illegitimate children of Bellis be Philippines if the illegal conditions existed during the time the ship
entitled to successional rights. was within the territorial waters – regardless of the fact that the
same conditions existed when the ship sailed from the foreign port
RULING: and while it was on the high seas.
The said illegitimate children are not entitled to their In light of the above restriction, the defendant was found
legitimes. Under Texas law, there are no legitimes. Even if the guilty, and sentenced to pay a fine of two hundred and fifty pesos,
other will was executed in the Philippines, his national law, still, will with subsidiary imprisonment in case of insolvency, and to pay the
govern the properties for succession even if it is stated in his costs.
testate that it shall be governed by the Philippine law.

People vs. Bayotas


US vs. Bull G.R. No. 102007 (236 SCRA 239)
15 PHIL 7
FACTS:
FACTS:
Rogelio Bayotas was charged with rape and eventually marriage with petitioner. Respondent had no previous knowledge of
convicted on June 19, 1991. While the appeal was pending, Bayotas petitioner’s existing marriage to Rosalinda Maluping.
died. The Supreme Court dismissed the criminal aspect of the Donato interposed in her answer the defense that his
appeal; however, it required the Solicitor-General to comment with second marriage was void and since it was solemnized without a
regard to Bayotas’ civil liability arising from his commission of the marriage license and that force, violence, intimidation and undue
offense charged. influence were employed by respondent.
In his comment, the Solicitor-General expressed his view Petitioner filed a motion to suspend the proceedings of the
that the death of accused-appellant did not extinguish his civil criminal case contending that the civil case seeking the annulment
liability as a result of his commission of the offense charged. This of the second marriage raise a prejudicial question which must be
comment was opposed by the counsel of accused-appellant, determined or decided before the criminal case can proceed.
arguing that the death of the accused while judgment of the
conviction is pending appeal extinguishes both criminal and civil ISSUES:
penalties, he cited in support and invoked the ruling of the Court of Whether or not the issue raised in the civil case is a
Appeals in People v. Castillo, which was held that the civil prejudicial question which must be determined before the criminal
obligation in a criminal case takes root in the criminal responsibility case can proceed; and whether or not the petitioner lacked the
and therefore civil liability is extinguished if accused should die legal capacity to contract the second marriage.
before final judgment is rendered.
RULING:
ISSUE: Donato cannot apply the rule on prejudicial question
Whether or not the death of the accused pending appeal of because a case for annulment of marriage can only be considered
his conviction extinguishes his civil liability. as a prejudicial question on the condition that it must be proven
that the petitioner’s consent to the marriage was obtained through
RULING: intimidation, violence and undue influence in order to establish that
Yes, the death of the accused pending appeal of his his act in the subsequent marriage was done involuntarily. In the
conviction extinguishes his civil liability because tire liability is petitioner’s argument that the second marriage should have been
based solely on the criminal act committed. Corollarily, the claim declared null and void on
for civil liability survives notwithstanding the death of the accused, the ground of force, intimidation and violence allegedly employed
if the same may also be predicated from another source of against him by respondent only sometime later cannot be
obligation other than delict, such as law, contract, quasi-contract or considered relevant.
quasi-delict.
Where civil liability survives, an action for recovery may be
pursued but only by way of filing a separate civil action and subject
to Section 1. Rule 11 of the Rules on Criminal Procedure as Eugenio Domingo vs. Court of Appeals
amended. This separate civil action may be enforced either against G.R. No. 127540 - October 17, 2001
the executor/administrator or the estate of the accused depending
on the source of obligation upon which the same is based. FACTS:
Paulina Rigonan owned three parcels of land including the
house and warehouse on one parcel. She allegedly sold them to
Donato vs. Hon. Luna private respondents, the spouses Felipe and Concepcion Rigonan,
G.R. No. L-54598; April 15, 1988 who claim to be her relatives amounting to P850.00. The
petitioners Eugenio Domingo, Crispin Mangabat and Samuel
FACTS: Capalungan, who claim to be her closest surviving relatives,
On January 23, 1979, the City Fiscal of Manila acting thru allegedly took possession of the properties by means of stealth,
Assistant City Fiscal Amado Cantor, filed information for bigamy force and intimidation, and
against Leonila Donato with the Court of First Instance. The private refused to vacate the same. The respondent filed a complaint for
respondent filed a civil action for declaration of nullity of her reinvindicacion against petitioners. The petitioners stated that the
sale was spurious and they are the legitimate owner of the land
being the nearest kin of Paulina. The respondents shown a carbon
copy of the deed of sale not bearing the signature of Paulina only
allege thumb mark of the latter and the deed was tainted with
alterations, defects and irregularities. The trial court found the
deed “fake” and rendered judgment in favor of the petitioners. The
appellate court, however, reversed the decision and declared the
respondents the owner of the properties. On appeal, the petitioners
asserted that there was abundant evidence at the time of the
execution of the sale, the deceased was already senile. She could
have not consented to the sale by merely imprinting her
thumbmark on the deed.

ISSUE:
Whether or not the vendor has the capacity to act on the
alleged sale of her property.

RULING:
The Supreme Court reinstated the decision of the trial court.
There is a serious doubt that the seller consented to the sale of and
the price for her parcels of land. The time of the execution of the
alleged contract, Paulina Rigonan was already of advanced age and
senile. She died an octogenarian barely over a year when the deed
was allegedly executed but before copies of the deed were entered
in the registry. The general rule is that a person is not incompetent
to contract
merely because of advanced years or by reason of physical
infirmities. However, when such age or infirmities have impaired
the mental faculties so as to prevent the person from properly,
intelligently, and firmly protecting her property rights then she is
undeniably incapacitated. The unrebutted testimony of Zosima
Domingo shows that at the time of the alleged execution of the
deed, Paulina was already incapacitated physically and mentally.
She narrated that Paulina played with her waste and urinated in
bed.