Jurisprudence

Public Domain vs. Public Dominion: A Nuanced Look at Philippine Land Law

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Case Title: Republic of the Philippines vs. Pasig Rizal Co., Inc.
G.R. No.: 213207
Date: February 15, 2022

SEPARATE CONCURRING OPINION

GAERLAN, J.:

Case Antecedent Background:
The case involves a dispute over the ownership and registration of a parcel of land. Pasig Rizal Co., Inc. (respondent) filed an application for registration of title to a parcel of land with the Regional Trial Court (RTC). The RTC granted the application, and the Republic of the Philippines (petitioner) appealed to the Court of Appeals, which affirmed the RTC's decision. The Republic of the Philippines then filed a petition for review on certiorari with the Supreme Court.

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A Contract to Sell is a bilateral contract where the seller retains ownership of the property until full payment of the purchase price

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G.R. No. 222957: Atty. Rogelio B. De Guzman v. Spouses Bartolome and Susan Santos
Date: March 29, 2023

D E C I S I O N

GAERLAN, J.:

Summary:
This case involves a dispute over a Contract to Sell between Atty. Rogelio B. De Guzman (De Guzman) and Spouses Bartolome and Susan Santos (spouses Santos) regarding a house and lot. The spouses Santos failed to pay the monthly installments, and De Guzman sold the property to a third party during the pendency of the case.

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Need for specificity in information and the importance of proving all elements of a crime beyond a reasonable doubt

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G.R. No. 201147. September 21, 2022

Case Digest: People of the Philippines vs. Freddie Sernadilla

D E C I S I O N

GAERLAN, J.:


Case Summary
The Supreme Court affirmed the conviction of Freddie Sernadilla for one count of rape and acquitted him of two counts of child abuse under Republic Act No. 7610. The rape conviction stemmed from Sernadilla's sexual intercourse with a 14-year-old girl, AAA, who was a member of his church. The Court found that Sernadilla employed intimidation due to his moral ascendancy over AAA.

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Understanding the implications of prior convictions on eligibility for public office

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G.R. No. 260374
Case Digest: Buenafe vs. Commission on Elections
D E C I S I O N
ZALAMEDA, J.:
CONCURRING OPINION
GAERLAN, J.:
 
Case Summary
The Supreme Court dismissed petitions challenging Ferdinand R. Marcos Jr.'s 2022 presidential candidacy. The petitioners argued that Marcos Jr. made false material representations in his Certificate of Candidacy (COC) regarding his eligibility due to a prior conviction for failing to file income tax returns.

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Importance of maintaining high moral standards among court personnel and the consequences of engaging in immoral conduct

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A.M. No. P-22-051 [Formerly OCA IPI No. 18-4831-P]. July 20, 2022

Case Digest: Ma. Lourdes A. Galit-Inoy vs. Melvin DC. Inoy
R E S O L U T I O N
INTING, J.:
 
Concuring:
GAERLAN, J.:
 
Case Summary
The case involves an administrative complaint filed by Ma. Lourdes A. Galit-Inoy against her husband, Melvin DC. Inoy, a Court Stenographer III, for immorality. The complaint alleged that respondent had an illicit relationship with a woman named Mary Ann, as evidenced by romantic and intimate photographs and a sex video. The Judicial Integrity Board (JIB) found respondent guilty of Disgraceful and Immoral Conduct and recommended a six-month suspension without pay. The Supreme Court adopted the JIB's findings with modification, classifying the offense as Gross Immorality and suspending respondent for six months and one day without pay.

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  2. Complexities of nullifying a marriage based on psychological incapacity and the need for a more nuanced interpretation of the Family Code
  3. Defective, verification and certification against forum shopping
  4. importance of prospective application of new judicial rulings and the doctrine of operative fact