25 Firestone Ceramics vs.

CA

G.R. No. 127022. June 28, 2000.

Facts: This case involves consolidated petitions seeking the transfer of

certain land-related cases to the Court En Banc. The land in question is a 99-
hectare tract, presumed to be owned by the Republic of the Philippines, but
adjudicated to private individuals by a court alleged to lack jurisdiction. The
petitioners, including the Republic of the Philippines and Firestone Ceramics,
Inc., filed motions to refer the case to the Court En Banc. Initially, the
Third Division denied the motion, but the majority of the Supreme Court later
agreed that the cases were of sufficient importance to warrant the Court En
Banc’s attention.

Issue: Whether or not the Supreme Court properly exercised its residual power
to treat these cases as en banc cases.

Ruling: Yes, the Supreme Court properly exercised its residual power to treat
the cases as en banc cases. The Court En Banc found that these cases were of
sufficient importance, given the issues raised, including the classification of
land and the enormous value of the area involved. Therefore, the petitioners'
motions for reconsideration were meritorious and the cases were set for oral
argument before the Court En Banc.

Principle: The Court can exercise its residual power to refer cases to the
Court En Banc if it deems them to be of sufficient importance, as per Supreme
Court Circular No. 2-89, dated February 7, 1989. This power ensures that
significant cases receive proper attention and resolution by the full Court.

1
 26 Oil and Natural Gas Commission vs. CA

G.R. No. 114323 July 23, 1998

Facts:
Oil and Natural Gas Commission (ONGC), a foreign corporation owned by the
Government of India, had a commercial dispute with Pacific Cement Company
(Pacific), a Philippine corporation. Pacific failed to deliver the agreed oil
well cement to India and later delivered an alternative, which was not up to
specifications. As per their contract, the dispute was submitted to
arbitration, and the arbitrator, Shri Malhotra, ruled in favor of ONGC. The
decision was then confirmed by an Indian court. ONGC filed for the enforcement
of the foreign judgment in the RTC of Pasig. Pacific opposed the enforcement,
arguing that the judgment was incomplete and lacked the necessary findings of
fact and law, and the RTC dismissed the case, asserting that the arbitrator’s
award was void. The Court of Appeals affirmed the dismissal, further stating
that the foreign judgment could not be enforced due to its lack of explanation.

Issue:
Whether or not the judgment of the foreign court is enforceable in this
jurisdiction in view of the private respondent's allegation that it is bereft
of any statement of facts and law upon which the award in favor of the
petitioner was based.

Ruling:
Yes, the judgment of the foreign court is enforceable in this jurisdiction. The
Supreme Court held that even in this jurisdiction, incorporation by reference
is permissible, especially when the decision of the foreign court, though
brief, effectively adopted the arbitrator's detailed award. The Court
emphasized that the validity of a foreign judgment is not negated merely
because the procedural rules of the foreign court differ from those of the
Philippine courts. Furthermore, a foreign judgment is presumed to be valid and
binding in the country from which it originates unless proven otherwise.
Pacific, who opposed the enforcement, failed to rebut this presumption, and
thus the Court ordered the enforcement of the foreign judgment.

Principle:
A foreign judgment is presumed valid and binding, and its enforcement may only
be contested on grounds such as lack of jurisdiction, fraud, collusion, or
clear mistake of law or fact. In this case, the Court affirmed the principle
that the validity of a foreign judgment is upheld unless successfully
challenged.

2
 27 Ampong vs. CSC

G.R. No. 167916, August 26, 2008

REYES R.T., J.:

Facts:
Petitioner Sarah P. Ampong, a former public school teacher, later appointed as
Court Interpreter III in the Regional Trial Court, was involved in a dishonesty
case. In 1991, she took a professional examination for a colleague, Evelyn
Junio-Decir, who then claimed to have passed the exam under her name. The Civil
Service Commission (CSC) investigated the incident, charged both Ampong and
Decir with dishonesty, and dismissed them from the service. Ampong moved for
reconsideration, arguing that since she was already a judicial employee, only
the Supreme Court had jurisdiction over disciplinary matters concerning her.
The CSC maintained jurisdiction, asserting that it had concurrent jurisdiction
over civil service employees, including judicial employees, and denied her
appeal. The Court of Appeals (CA) affirmed the CSC's decision, leading Ampong
to petition the Supreme Court.

Issue:
Whether or not the Civil Service Commission (CSC) has administrative
jurisdiction over a judicial employee for acts committed while the employee was
still part of the executive branch of government.

Ruling:
No, the CSC does not have exclusive administrative jurisdiction over judicial
employees for acts committed while they were part of the executive branch.
However, the Supreme Court ruled against the petition on the ground of
estoppel. Since Ampong had participated in the proceedings, admitted her
wrongdoing, and requested clemency without raising the jurisdictional issue
earlier, she was estopped from challenging the CSC's jurisdiction. The Court
emphasized that while the Supreme Court holds administrative supervision over
judicial employees, the CSC has concurrent jurisdiction over all government
employees, including those who later join the judiciary.

Principle:
The principle established by the Court is that active participation in
proceedings without timely objection to jurisdiction leads to estoppel.
Additionally, while administrative supervision over judicial employees rests
with the Supreme Court, the Civil Service Commission retains concurrent
jurisdiction over such employees concerning their acts before they enter the
judiciary.

3
 28 Fuentes vs. Office of the Ombudsman-Min.

G.R. No. 124295, October 23, 2001

PARDO, J.:

Facts: This case involves a petition for certiorari assailing the action of the
Ombudsman-Mindanao investigating Judge Renato A. Fuentes for a violation of
Republic Act No. 3019, Section 3(e), also known as the Anti-Graft and Corrupt
Practices Act. The case stemmed from the implementation of a writ of execution
in an expropriation case where certain equipment, including serviceable ones,
was auctioned off without proper knowledge of the Department of Public Works
and Highways (DPWH). The Ombudsman initiated an investigation against Judge
Fuentes, despite the fact that the Supreme Court had the authority over
judicial personnel and was not in possession of any administrative case against
Fuentes. The Ombudsman filed a criminal complaint against Fuentes, which led to
this petition.

Issue: Whether or not the Ombudsman may conduct an investigation of acts of a

judge in the exercise of his official functions alleged to be in violation of
the Anti-Graft and Corrupt Practices Act, in the absence of an administrative
charge for the same acts before the Supreme Court.

Ruling: Yes, the petition was granted. The Supreme Court ruled that the
Ombudsman did not have the authority to investigate the judge or initiate the
criminal or administrative complaint. The Ombudsman’s actions encroached upon
the judiciary's exclusive power to supervise its own members. Article VIII,
Section 6 of the Constitution vests in the Supreme Court the exclusive
administrative supervision over all courts and court personnel. Therefore, the
Ombudsman must refer the case to the Supreme Court for appropriate action.

Principle: The principle used by the Court is the doctrine of judicial

independence and the separation of powers, which grants the Supreme Court
exclusive administrative supervision over all courts and judicial personnel,
prohibiting the Ombudsman from investigating judicial acts without a referral
from the Supreme Court.

4
 29 Inonog vs. Judge Ibay

A.M. No. RTJ-09-2175, July 28, 2009

LEONARDO-DE CASTRO, J.:

Facts: Venancio P. Inonog, the complainant, was cited in contempt of court by

Judge Francisco B. Ibay of the Regional Trial Court (RTC) in Makati City. The
incident arose when Inonog, a security-driver for the Chief of the Business
Permit Division of Makati, parked his vehicle in a spot that was reserved for
the judge. The parking space was indicated by a nameplate, which Inonog was
unaware of. As a result, Judge Ibay ordered him to show cause why he should not
be cited for contempt. Inonog failed to attend the hearing, which led to the
judge finding him guilty of indirect contempt and imposing a fine of P1,000 and
a five-day imprisonment. Later, the fine was increased to P2,000, with a stern
warning. Inonog filed an administrative complaint against Judge Ibay for gross
abuse of authority.

Issue: Whether or not Judge Ibay violated judicial powers in citing Inonog for
contempt of court without proper notice and opportunity to be heard, as
required under the Rules of Court.

Ruling: Yes, the Supreme Court found that Judge Ibay violated judicial powers.
The Court held that the contempt proceedings were not properly conducted
according to the procedural requisites set forth in Rule 71 of the Rules of
Court. Inonog was not given sufficient notice or an opportunity to be heard,
which is a fundamental requirement before a person can be punished for indirect
contempt. The Court concluded that the charges against Inonog were based on
flimsy grounds, and the procedure followed by Judge Ibay was flawed, leading to
an unjust ruling.

Principle: The Court emphasized the principle that contempt proceedings must
strictly follow the procedural requirements, including proper notice and an
opportunity to be heard, particularly when the charge involves indirect
contempt, which is a criminal matter.

5
 30 Francisco Chavez vs. JBC

G.R. No. 202242, April 16, 2013

MENDOZA, J.:

Facts:
The case concerns the composition of the Judicial and Bar Council (JBC),
specifically the inclusion of two members from Congress (Senator Francis Joseph
G. Escudero and Congressman Niel C. Tupas, Jr.) as ex officio members of the
JBC. The petitioner, Francisco I. Chavez, challenged the constitutionality of
having two legislative representatives in the JBC. He argued that the
Constitution specifies only one representative from Congress, not two. The
respondents contended that the Constitutional Commission intended to allow two
representatives due to the change from a unicameral to a bicameral legislature.
They also argued that this dual representation did not undermine the balance
intended by the Constitution.

Issue:
Whether or not the practice of the Judicial and Bar Council to admit two
members of Congress as part of its composition violates the Constitution's
provisions regarding the composition of the JBC.

Ruling:
No. The Supreme Court ruled that the inclusion of two Congress representatives
in the JBC violates the 1987 Constitution. The Court emphasized that the plain
and unambiguous language of Section 8, Article VIII of the Constitution
specifies only "a representative of Congress," meaning one, not two. The Court
noted that the Constitution intended for the JBC to have seven members, and any
expansion beyond this number, including dividing a single vote between two
Congress members, was unconstitutional. The presence of two legislative
representatives undermines the equality among the three branches of government.
The Court found that while the prior actions of the JBC were valid under the
doctrine of operative facts, its current composition was unconstitutional and
should be reformed to comply with the Constitution.

Principle:
The principle of constitutional interpretation dictates that where the language
of the Constitution is clear and unambiguous, it must be given its literal
meaning. The concept of equality among the three branches of government,
especially in the judicial appointment process, is enshrined in the
Constitution, and any deviation from the established constitutional framework
undermines this balance

6
 31 Nitafan vs. CIR

G.R. No. 78780, July 23, 1987

MELENCIO-HERRERA, J.:

Facts: Petitioners, judges of the Regional Trial Court, filed a petition

seeking to prevent the Commissioner of Internal Revenue and the Financial
Officer of the Supreme Court from deducting withholding taxes from their
salaries. They argued that such deductions violated the 1987 Constitution,
which guarantees that judicial salaries should not be diminished during their
tenure. The petitioners contended that taxation on their salaries infringed on
the principle of judicial independence, which should be protected by the
Constitution.

Issue: Whether or not the withholding tax on the salaries of judges violates
the 1987 Constitution, specifically the provision stating that judicial
salaries shall not be decreased during their tenure.

Ruling: No, the withholding tax on the salaries of judges does not violate the
1987 Constitution. The Supreme Court ruled that the Constitution does not
exempt the salaries of judges from income tax. The intent of the 1987
Constitutional Commission, as revealed during deliberations, was to subject
judicial salaries to the same tax laws that apply to all government employees.
The Court emphasized that the salaries of judges and justices are not
diminished by income tax deductions, and the constitutional provision against
salary diminution refers to the base salary, not the tax obligations.

Principle: The primary principle affirmed by the Court is the independence of

the judiciary, but this does not extend to exemptions from general taxation.
The Court recognized that the framers of the 1987 Constitution intended for
judicial salaries to be subject to income tax, aligning with the principle of
equality among government branches in terms of tax obligations. The decision
upholds the general uniformity in taxation and clarifies that the provision
against salary diminution does not apply to income tax deductions.

7
 32 Senate vs. Ermita

G.R. No. 169777, April 20, 2006

CARPIO MORALES, J.:

Facts: On September 23, 2005, the Senate of the Philippines issued invitations
for a public hearing regarding the North Rail Project and other issues,
inviting executive and military officials as resource persons. However, many
invited officials did not attend due to prior commitments. On September 27,
2005, Senate President Drilon received a letter from Executive Secretary Ermita
requesting the postponement of the hearing. The following day, Executive Order
No. (E.O.) 464 was issued by the President, which prohibited executive
officials from attending Senate hearings without the President's consent. This
led to a dispute between the Senate and the Executive over the scope of the
Senate's power to summon executive officials.

Issue: Whether or not E.O. 464 contravenes the power of inquiry vested in
Congress.

Ruling: Yes. The Supreme Court ruled that E.O. 464 undermines the power of
Congress to conduct inquiries in aid of legislation. Congress has the
constitutional power of inquiry, as expressly provided under Section 21,
Article VI of the Constitution. This power is essential for effective
legislation, and the executive branch cannot withhold information from Congress
without asserting a valid claim of executive privilege. The Court held that
E.O. 464, by allowing the executive branch to evade congressional inquiries
without valid claims of privilege, frustrates Congress's right to obtain
information necessary for legislation. Therefore, Sections 2(b) and 3 of E.O.
464 were declared void, as they improperly restricted the Senate's power of
inquiry.

Principle: The judiciary affirmed that the power of inquiry is inherent in

Congress’s legislative function, and the executive cannot frustrate this power
by invoking executive privilege without providing specific justifications. This
ruling highlights the separation of powers and the essential role of judicial
review in ensuring that no branch of government undermines the constitutional
functions of another.