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Jurisprudence

Can a judge be sanctioned for using harsh and offensive language in court premises? | A.M. No. 23-04-15-SC

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.

Can a judge be sanctioned for using harsh and offensive language in court premises? | A.M. No. 23-04-15-SC Read More »

Is the evidence from a government-issued laptop and audit admissible as evidence in an administrative case? | A.M. No. RTJ-20-2579

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.

Is the evidence from a government-issued laptop and audit admissible as evidence in an administrative case? | A.M. No. RTJ-20-2579 Read More »

Does the doctrine of corporate opportunity apply if the corporation is financially able to undertake its business? | GR Nos. 20070-71

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.

Does the doctrine of corporate opportunity apply if the corporation is financially able to undertake its business? | GR Nos. 20070-71 Read More »

Can the repeated and successive rehiring of a project employee ripen into regular employment? | G.R. No. 192514

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.

Can the repeated and successive rehiring of a project employee ripen into regular employment? | G.R. No. 192514 Read More »

Can repeated threatening and humiliating text messages constitute psychological violence under R.A. No. 9262? | G.R. No. 276927

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.

Can repeated threatening and humiliating text messages constitute psychological violence under R.A. No. 9262? | G.R. No. 276927 Read More »

Can an extrajudicial settlement excluding compulsory heirs still be partially valid? | G.R. No. 258887

In this case, the children from a deceased wife’s first marriage discovered that their father and his second family executed an extrajudicial settlement transferring the entirety of conjugal properties to themselves while falsely claiming they were the only heirs. The Supreme Court ruled that while the extrajudicial settlement excluding compulsory heirs is void and inexistent, the conveyances may still be recognized to the extent of the surviving spouse’s undivided share in the co-owned property. Applying the doctrine “Quando res non valet ut ago, valeat quantum valere potest,” the Court held that a contract must be recognized as far as it is legally possible to do so.

Can an extrajudicial settlement excluding compulsory heirs still be partially valid? | G.R. No. 258887 Read More »

Is a DOLE Certificate of Registration conclusive proof that a manpower provider is a legitimate independent contractor? | G.R. No. 221043

In this case, production operators assigned to an electronics company were told they would be absorbed as regular employees if they passed an exam. When they failed, their services were terminated, prompting them to file a complaint for illegal dismissal and regularization against the manpower provider and the principal company. While the manpower agency brandished its official DOLE registration, the Supreme Court ruled that a certificate of registration alone is not conclusive proof of legitimacy, and the totality of the facts proved they were engaged in prohibited labor-only contracting.

Is a DOLE Certificate of Registration conclusive proof that a manpower provider is a legitimate independent contractor? | G.R. No. 221043 Read More »

Can the BIR rely on defective waivers to extend its prescriptive period for tax assessments?  | G.R. No. 249241-42

In this case, the Bureau of Internal Revenue (BIR) issued a final tax deficiency assessment against a corporation based on two executed waivers meant to extend the legal prescriptive period. The corporation protested, arguing the waivers were void due to structural defects, including missing tax amounts, an unauthorized corporate signature, and the lack of the Commissioner’s signature. The Supreme Court ruled that because the BIR failed in its mandatory duty to ensure strict legal compliance before accepting the waivers, the extensions were void, the assessments had prescribed, and the doctrine of estoppel could not save the BIR’s inaction.

Can the BIR rely on defective waivers to extend its prescriptive period for tax assessments?  | G.R. No. 249241-42 Read More »

Does Article 148 of the Family Code apply to property acquired by same-sex couples? | G.R. No. 267469

In this landmark case, a same-sex couple purchased a house and lot, registering it solely under one partner’s name for bank convenience. Upon separating, the registered partner executed an “Acknowledgement” recognizing the other’s 50% financial contribution, but later refused to sell the property or split the proceeds. The Supreme Court ruled that because same-sex couples are legally incapacitated to marry under Philippine law, their property relations are governed by Article 148 of the Family Code. The signed Acknowledgement constituted valid proof of actual contribution, making them legal co-owners.

Does Article 148 of the Family Code apply to property acquired by same-sex couples? | G.R. No. 267469 Read More »

Can a trial court dismiss a probate petition on its own initiative due to improper venue? | G.R. No. 216107

In this case, a trial court motu proprio (on its own initiative) dismissed a petition for the probate of a will because the decedent allegedly resided in a different city at the time of death. The petitioner challenged the dismissal, arguing that venue is procedural and waivable. The Supreme Court ruled that improper venue is not jurisdictional, and a court cannot dismiss a case on this ground unless an interested party seasonably raises an objection.

Can a trial court dismiss a probate petition on its own initiative due to improper venue? | G.R. No. 216107 Read More »

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