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Uberrimae Fidei

The strictest law may become the severest injustice.


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These are all original case digests or case briefs done while the author was studying law school in the Philippines.
Hopefully these digested cases will help you get a good grasp of the salient facts and rulings of the Supreme Court in order to have a better understanding of Philippine
Jurisprudence.
Please forgive any typo/grammatical errors as these were done while trying to keep up with the hectic demands brought about by the study of law.
God bless!

P.S.
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Sunday, February 15, 2015

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RP v Iyoy (Conflict of laws)

Mactan Cebu
International Airport
Authority v Marcos (1996)

II
RP v Iyoy

Mactan Cebu International


Airport Authority v Marcos
GR No 120082, September
11, 1996 FACTS: Petitioner
w...

2005
Article 26 of the Family Code provides:
Art. 26. All marriages solemnized outside the Philippines in accordance with the laws in force in the country where they
were solemnized, and valid there as such, shall also be valid in this country, except those prohibited under Articles 35(1),

MMDA v Concerned
Residents of Manila Bay
(Environmental Law)

(4), (5) and (6), 36, 37 and 38.


WHERE A MARRIAGE BETWEEN A FILIPINO CITIZEN AND A FOREIGNER IS VALIDLY CELEBRATED AND A

Metropolitan Manila
Development Authority v
Concerned Residents of
Manila Bay GR No.
171947-48 December 18,
2008 FACTS: The
complaint...

DIVORCE IS THEREAFTER VALIDLY OBTAINED ABROAD BY THE ALIEN SPOUSE CAPACITATING HIM OR HER
TO REMARRY, THE FILIPINO SPOUSE SHALL LIKEWISE HAVE CAPACITY TO REMARRY UNDER PHILIPPINE
LAW.
ART. 36. A marriage contracted by any party who, at the time of the celebration, was psychologically incapacitated to
comply with the essential marital obligations of marriage, shall likewise be void even if such incapacity becomes manifest
only after its solemnization.

Laguna Lake
Development Authority v
CA (Environmental Law)

Article 15. Laws relating to family rights and duties, or to the status, condition and legal capacity of persons are binding
upon citizens of the Philippines, even though living abroad. (9a)

Laguna Lake Development


Authority v CA GR No.
110120 March 16, 1994
FACTS: The LLDA Legal
and Technical personnel
found that the City ...

ART. 48. In all cases of annulment or declaration of absolute nullity of marriage, the Court shall order the prosecuting
attorney or fiscal assigned to it to appear on behalf of the State to take steps to prevent collusion between the parties and
to take care that the evidence is not fabricated or suppressed.
REPUBLIC OF THE PHILIPPINES, P e t i t i o n e r ,- versus- CRASUS L. IYOY, R e s p o n d e n t

Oposa v Factoran
(Environmental Law)

FACTS:
Crasus married Fely on 16 December 1961 at Cebu City. After the celebration of their marriage, respondent Crasus
discovered that Fely was hot-tempered, a nagger and extravagant. In 1984, Fely left the Philippines for the United
States of America (U.S.A.), leaving all of their five children, the youngest then being only six years old, to the care of
respondent Crasus.
Barely a year after Fely left for the U.S.A., respondent Crasus received a letter from her requesting that he sign the

Categories
civil procedure (32)

enclosed divorce papers; he disregarded the said request. Sometime in 1985, respondent Crasus learned, through the

conflict of laws (12)

letters sent by Fely to their children, that Fely got married to an American, with whom she eventually had a child. At the

constitution (20)

time the Complaint was filed, it had been 13 years since Fely left and abandoned respondent Crasus, and there was no
more possibility of reconciliation between them.

contracts (8)

Oposa v Factoran GR No.


101083 July 30, 1993
FACTS: Petitioners herein
are all minors duly
represented and joined
by their resp...

Caunca v Salazar
(Constitutional Law)
Caunca v Salazar GR. No.
L-2690 January I, 1949

corporation (7)
Respondent Crasus finally alleged in his Complaint that Felys acts brought danger and dishonor to the family, and clearly
demonstrated her psychological incapacity to perform the essential obligations of marriage. Such incapacity, being

Credit Transactions (6)

incurable and continuing, constitutes a ground for declaration of nullity of marriage under Article 36, in relation to Articles

criminal (2)

68, 70, and 72, of the Family Code of the Philippines.

criminal procedure (1)

Fely filed her Answer and Counterclaim with the RTC on 05 June 1997. She asserted therein that she was already an

environmental (6)

American citizen since 1988 and was now married to Stephen Micklus. She argued that her marriage to her American

insurance (10)

husband was legal because now being an American citizen, the law of her present nationality shall govern her status.

labor relations (6)


labor standards (5)

DECISION OF LOWER COURTS:


(1) RTC Cebu: declared the marriage null and void on the basis of Article 36 of the Family Code of the Philippines.

natural resources (8)

(2) CA: affirmed RTC.

negotiable instruments
law (6)

ISSUE:
Where the marriage between Crasus and Fely remains valid and subsisting

obligations (8)
Personal (2)

RULING:

Public International Law

YES.
At most, Felys abandonment, sexual infidelity, and bigamy, give respondent Crasus grounds to file for legal separation
under Article 55 of the Family Code of the Philippines, but not for declaration of nullity of marriage under Article 36 of the
same Code. While this Court commiserates with respondent Crasus for being continuously shackled to what is now a

(2)

Special Commercial Law


(3)

hopeless and loveless marriage, this is one of those situations where neither law nor society can provide the specific

succession (4)

answer to every individual problem.

taxation (92)

I. The totality of evidence presented during trial is insufficient to support the finding of psychological incapacity of Fely.

Torts (70)

The psychological incapacity must be characterized by


(a) Gravity It must be grave or serious such that the party would be incapable of carrying out the ordinary duties
required in a marriage;

Cable Access

manifestations may emerge only after the marriage; and


involved.
Intendment of the law has been to confine the meaning of psychological incapacity to the most serious cases of
personality disorders clearly demonstrative of an utter insensitivity or inability to give meaning and significance to the

Buy Old Cars


School Girl

marriage. The root cause of the incapacity be identified as a psychological illness and that its incapacitating nature must
be fully explained.
II. Article 26, paragraph 2 of the Family Code of the Philippines is not applicable to the case at bar.

Costume
Box Pirates

By its plain and literal interpretation, the said provision cannot be applied to the case of respondent Crasus and his wife
Fely because at the time Fely obtained her divorce, she was still a Filipino citizen.
At the time she filed for divorce, Fely was still a Filipino citizen, and pursuant to the nationality principle embodied in

Bench Mill

Article 15 of the Civil Code of the Philippines, she was still bound by Philippine laws
III. The Solicitor General is authorized to intervene, on behalf of the Republic, in proceedings for annulment and
declaration of nullity of marriages.

Organic Group

While it is the prosecuting attorney or fiscal who actively participates, on behalf of the State, in a proceeding for
annulment or declaration of nullity of marriage before the RTC, the Office of the Solicitor General takes over when the
case is elevated to the Court of Appeals or this Court. Since it shall be eventually responsible for taking the case to the

2000 Lamp

conduct of the prosecuting attorney or fiscal therein to better guarantee the protection of the interests of the State.

Posted by Victor Morvis


Labels: conflict of laws

Calalang v Williams GR
No. 47800 December 2,
1940 FACTS: Pursuant
to the power delegated to it
by the Legislature, the
Director of P...

Tolentino v Secretary of
Finance (1994)
Tolentino v Secretary of
Finance GR No. 115455,
August 25, 1994 FACTS:
The value-added tax (VAT)
is levie...

Pepsi-Cola Bottling
Company v Tanauan
(1976)
Pepsi-Cola Bottling
Company of the Phils, Inc v
Tanauan GR No. L-31156,
February 27, 1976 FACTS:
Pepsi Co...

G.R. No. 168056


September 1, 2005
ABAKADA GURO PARTY
LIST (Formerly AASJAS)
OFFICERS SAMSON S.
ALCANTARA an...

Republic v Equitable
Bank (Negotiable
Instruments Law)
REPUBLIC V. EQUITABLE
BANK 10 SCRA 8 FACTS:
Corporacion had acquired
24 treasury warrants
through Carranza (its
former trusted employee)
who...

Blog Archive

appellate courts when circumstances demand, then it is only reasonable and practical that even while the proceeding is
still being held before the RTC, the Office of the Solicitor General can already exercise supervision and control over the

Calalang v Williams
(Labor Standards)

ABAKADA v Ermita
(Taxation)

(b) Juridical Antecedence It must be rooted in the history of the party antedating the marriage, although the overt
(c) Incurability It must be incurable or, even if it were otherwise, the cure would be beyond the means of the party

Liberty of abode and travel


Sec. 6. The liberty of abode
and of changing the same
wit...

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Uberrimae Fidei: RP v Iyoy (Conflict of laws)


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