Case Digest

In G.R. No. 243414, GDI Lighting Solutions hired Jasmin Unating in 2012 as a Market Assistant, later promoting her to Manager/Supervisor, and claimed she was merely an independent contractor under a Manpower Service Agreement. The Supreme Court found she was an employee: the agreement was undated, unnotarized, and unwitnessed, while she presented a company ID and emails showing work directly related to the company’s main business, and GDI Lighting offered no proof of substantial capital as a legitimate contractor. Where the evidence is in equipoise, doubts are resolved in favor of labor.

In G.R. No. 277047, the Supreme Court dealt with Spouses Carlos, who bought tires from Tire Star, Inc. on installment and paid with six post-dated checks that were all dishonored for “Account Closed.” Under BP 22, knowledge of insufficient funds is presumed only if the drawer fails to pay within five banking days after receiving notice of dishonor, so service of that notice is essential. Tire Star’s messenger testified that the notice was personally served at the spouses’ store and accepted by their employee, and the spouses offered only a bare denial, which the Court found insufficient. The Court upheld the conviction and the legal interest running from extrajudicial demand. It also standardized the rules going forward: notice of dishonor may be served personally, by registered mail, or electronically, and the service must be proven by an affidavit narrating its circumstances, with supporting documentation.

The Court ruled that Lobetania, Dimaiwat, Velasco, and Aguirre’s voluntary resignations barred their illegal dismissal claims, and in any case all petitioners—including Bance, who did not resign—were validly dismissed for just cause (breach of trust and fraud involving missing funds and an abused tuition-discount scheme). Still, because the University skipped the required two-notice procedure, Bance was awarded P30,000 in nominal damages despite the dismissal itself being upheld as valid.

In G.R. No. 203194, the Supreme Court ruled that a mortgage covering two separate obligations doesn’t merge them into one cause of action—since a mortgage is merely accessory to the principal loans it secures, foreclosing on one debt doesn’t bar a separate collection suit on a distinct, independent debt, even if both are secured by the same mortgage and due at the same time.

In this case, the heirs of a registered landowner sought to recover possession of a property occupied by their relatives, who claimed they had purchased the land decades earlier through an oral agreement with the deceased owner. Although no written deed of sale existed, the buyers had long possessed and cultivated the property and presented tax declarations and receipts showing payment of taxes over the years. The Supreme Court ruled that while the Civil Code requires sales of real property to be in writing for enforceability, an oral sale that has already been partially or fully executed may still be considered valid and binding. The Court emphasized that delivery of the property and continued possession are strong indicators that the sale had been consummated.

In this case, a Regional Trial Court judge confronted a PAO lawyer who briefly parked near a PWD access ramp inside the Justice Hall of Marikina. Although the lawyer repeatedly apologized, the judge publicly berated him using harsh and demeaning language, later proceeding to the PAO office to continue his tirade in front of witnesses. While the Supreme Court recognized that the judge’s concern for maintaining order and accessibility within court premises was legitimate, it held that his manner of enforcement was improper and disproportionate. The Court ultimately admonished the judge, reminding members of the judiciary that they must always exercise courtesy, restraint, and conduct consistent with the dignity of judicial office.

In this case, incriminating iPhone message backups were discovered in a government-issued laptop previously assigned to a judge and later returned to the Supreme Court for repair. Subsequent forensic examination and judicial audits uncovered evidence of bribery, improper dealings with lawyers and litigants, and negligence in handling court exhibits. The Supreme Court ruled that judges and government employees have no reasonable expectation of privacy over files stored in government-issued devices, especially where official policies allow monitoring and audits. The Court further held that the exclusionary rule and the “fruit of the poisonous tree” doctrine do not apply in administrative proceedings involving evidence obtained from government property.

In this case, TOPROS alleged that its president and director, together with several individuals, formed competing corporations and diverted corporate assets, resources, clients, and business opportunities for their own benefit. Upon review, the Supreme Court held that a corporate officer or director may be held liable for violating fiduciary duties when he appropriates a business opportunity that rightfully belongs to the corporation. The Court reiterated that liability may arise when the corporation is financially capable of pursuing the opportunity, the opportunity falls within its line of business, the corporation has an interest or expectancy in it, and the officer’s actions place him in conflict with his duties to the corporation.

In this case, a laborer-carpenter was repeatedly and successively rehired by a construction corporation a total of 38 times for various projects spanning nearly 31 years. Upon the completion of his last project, the company terminated his services, claiming he was merely a project employee whose employment automatically ceased. The Supreme Court ruled that he had attained regular employment status, holding that continuous and successive rehiring for tasks that are vital, necessary, and indispensable to the employer’s usual business transforms a project employee into a regular employee, regardless of the execution of project contracts.

In this case, a man repeatedly sent threatening, degrading, and humiliating text messages to his former partner after learning that she was involved with another man. He threatened to expose intimate photos, embarrass her before creditors and neighbors, accuse her of wrongdoing, and even implied harm against her and her family. The victim later suffered mental anguish, sleepless nights, emotional distress, and damage to her reputation. The Supreme Court ruled that the series of harassing text messages constituted psychological violence under Section 5(h)(5) of the Anti-Violence Against Women and Their Children Act, emphasizing that harassment causing substantial emotional or psychological distress is punishable under the law.