Legally Yours,  Political Law

Del Castillo Case Doctrines (Political Law – Constitutional Law)

Del Castillo Case Doctrines

Summaries of case doctrines penned by Justice Del Castillo.

Political Law Constitutional Law

Alemda v. Office of the Ombudsman
G.R. No. 204267, July 25, 2016The right under Section 16, Article III of the 1987 Constitution (right to speedy disposition of cases) applies to all cases before all judicial, quasi-judicial or administrative bodies and is not limited to criminal proceedings.

Areno, Jr. v. Sky Cable PCC-Baguio
G.R. No. 180302, February 5, 2010

The essence of administrative due process is simply an opportunity to be heard, and a formal or trial-type hearing is not required.

Arnado v. COMELEC
G.R. No. 210164, August 18, 2015

The use of a foreign passport amounts to a repudiation or recantation of the oath of renunciation of foreign citizenship. Such use will revert the dual citizenship status of the individual making him disqualified from running for public office.

Catacutan v. People of the Philippines
G.R. No. 175991, August 31, 2011

Due process simply demands an opportunity to be heard. Disallowing a party to introduce evidence which the court believed to be irrelevant and impertinent to the proceeding does not violate procedural due process.

City of Iloilo v. Contreras-Besana
G.R. No. 168967, February 12, 2010

When the taking of the property sought to be expropriated coincides with the commencement of the expropriation proceedings or takes place subsequent to the filing of the complaint for eminent domain, the just compensation should be determined as of the date of the filing of the complaint.

Daraga Press, Inc. v. Commission on Audit and Department of Education – ARMM
G.R. No. 201042, June 16, 2015

Section 29(1), Article VI of the 1987 Constitution provides that: “No money shall be paid out of the Treasury except in pursuance of an appropriation made by law”. Thus, the lack of appropriation or failure to adduce substantial evidence to prove a money claim against the government entitles the Commission on Audit to deny the same.

Delos Reyes v. Judge Danilo Cruz
A.M. No. RTJ-08-21252, January 18, 2010

Article VIII, Section 15(1) of the Constitution provides that all cases or matters must be decided or resolved within twenty-four months from the date of submission for the Supreme Court and unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts.

Demaala v. Sandiganbayan
G.R. No. 173523, February 19, 2014

Where a party was afforded an opportunity to participate in the proceedings but failed to do so, he cannot complain of deprivation of due process.

Dumaguete Cathedral Credit Cooperative v. Commissioner of Internal Revenue
G.R. No. 182722, January 22, 2010

Section 15, Article XII of the Constitution considers cooperatives as instruments for social justice and economic development. Meanwhile, Section 10, Article II of the Constitution declares that it is the policy of the state to promote social justice in all phases of national development. In relation thereto, Section 2 Article XII of the Constitution states that the promotion of social justice shall include the commitment to create economic opportunities based on freedom of initiative and self-reliance. Thus, cooperatives enjoy a preferential tax treatment which exempts them from payment of withholding tax.

Ho Wai Pang v. People of the Philippines
G.R. No. 176229, October 19, 2011

The absence of an interpreter does not violate the right of the accused to confront witnesses especially when he failed to register his objection to the presentation of the prosecutor’s evidence despite such absence.

King v. Robles
G.R. Nos. 197096-97, December 7, 2015

The Constitution and RA 6770 give the Ombudsman a wide latitude of investigatory and prosecutorial powers on offenses committed by public officers, free from legislative, executive, or judicial intervention. Thus, the use of the Ombudsman of discretion in determining a violation of the Revised Penal Code is not subject to judicial review.

Lacson v. MJ Lacson Development Company, Inc.
G.R. No. 168840, December 8, 2010

Denial of due process means the total lack of opportunity to be heard or to have one’s day in court.

Laurel v. Vardeleon
G.R. No. 202967, August 5, 2015

The right to speedy disposition of cases should not precipitate the loss of a party’s right to present evidence. While a court can dismiss a case on the ground of non-prosequitur, the real test for the exercise of such power is whether, under the circumstances, the plaintiff is chargeable with want of due diligence in failing to proceed with reasonable promptitude.

Manigque-Stone v. Cattleya Land
G.R. No. 195975, September 5, 2016

Under Section 7, Article XII of the 1987 Constitution, aliens, whether individuals or corporations are disqualified from acquiring lands of the public domain. Hence, they are also disqualified from acquiring private lands. The primary purpose of the provision is the conservation of the national patrimony.

Manila Memorial Park v. Secretary of DSWD
G.R. No. 175356, December 2, 2013

The government, through the exercise of police power, can impose upon private establishments the burden of partly subsidizing a government program to promote the health and welfare of a special group of citizens. The tax deduction scheme pursuant to the 20% discount for senior citizens is a valid exercise of police power.

National Power Corporation v. Samar
G.R. No. 197329, September 8, 2014

If the government takes possession of the property before the institution of the expropriation proceedings, the value should be fixed as of the time of the taking of said possession, not of the filing of the complaint.

National Power Corporation v. Spouses Zabala
G.R. No. 173520, January 30, 2013

The determination of just compensation is a judicial function. Statutes, executive issuances fixing or providing for the method of computing just compensation are not binding on courts and, at best, are treated as mere guidelines in ascertaining the amount thereof.

People v. Reyes
G.R. No. 194606, February 18, 2015

The failure to provide a counsel immediately after an arrest does not invalidate the presumption of regularity in the performance of the arresting officer’s official duty. Such failure will not result in the acquittal of the accused since such infraction merely renders inadmissible any extrajudicial confession or admission made during custodial investigation.

People v. Sobrepena, Sr.
G.R. No. 204063, December 5, 2016

In cases involving non-bailable offenses, the determination of whether the evidence of guilt is strong is a matter of judicial discretion that remains with the judge. A summary hearing for such determination will suffice.

Republic v. Batuigas
G.R. No. 183110, October 7, 2013

An ex-parte hearing is not violative of the Revised Naturalization Law (CA 473). Thus, when the OSG was furnished with a copy of the notice of hearing for the reception of evidence ex-parte, there was already a sufficient compliance with the requirement of a public hearing.

Republic v. Huang Te Fu
G.R. No. 200983, March 18, 2015

An applicant for naturalization must show full and complete compliance with the requirements of the Naturalization Law, otherwise, his petition for naturalization will be denied.

Republic v. Kerry Lao Ong
G.R. No. 175430, June 18, 2012

Under the Revised Naturalization Law, the qualification of “some known lucrative trade, profession or lawful occupation”, means only that the person having the employment gets enough for his ordinary necessities in life. It must be shown that there is an appreciable margin in the applicant’s income over his expenses as to provide for an adequate support in case of unemployment, sickness or disability to work.

Spouses Mercado v. Land Bank of the Philippines
G.R. No. 196707, June 17, 2015

While the determination of just compensation is a judicial function, the trial court, acting as a special agrarian court must be guided by the valuation factors under Section 17 of RA 6657. If the guidelines are inapplicable, the RTC must clearly explain the reasons for deviating therefrom.

SR Metals, Inc. v. Hon. Angelo Reyes
G.R. No. 179669, June 4, 2014

While RA 7076 and PD No. 1899 have tackled both definitions of “small-scale mining”, they apply to different classes. PD No. 1899 applies to individuals, partnerships, and corporations, while RA 7076 applies to cooperatives. There is, therefore, no violation of the equal protection clause.

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