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Showing posts from July, 2025

Insular Government vs Frank, 13 Phil 239

  Facts  In the early 1900s, George I. Frank, a resident of Chicago, Illinois , entered into a contract with the Insular Government of the Philippine Islands . The agreement, signed on April 17, 1903 , was for two years of government service as a stenographer in Manila. Under the contract, Frank was to receive a salary of $1,200 per year , advance travel expenses , and one-half salary during his journey from Chicago to Manila. This arrangement explicitly incorporated Philippine Civil Service Acts No. 80 and 224 as part of the contractual terms. Notably, the contract stipulated that if Frank resigned prematurely , he would be liable to reimburse the government for the travel expenses and the salary advanced during the trip. Frank began his journey on April 30, 1903 , and arrived in Manila on June 4, 1903 , receiving appropriate compensation during that time. However, on February 11, 1904 , he abruptly terminated his service , breaching the agreed two-year term. As a re...

Miciano vs Brimo, 50 Phil 867

  Facts (Narrative Style): Joseph G. Brimo, a Turkish national, was a long-time resident of the Philippines. During his life in the country, he acquired substantial assets and established a thriving business. Upon his death, he left a last will and testament disposing of his properties, which were situated entirely in the Philippines. He designated several relatives as legatees , including his brother, Andre Brimo . In the second clause of the will, Joseph Brimo made a specific declaration: although he was legally a Turkish citizen (a citizenship acquired by conquest and not by personal choice), he wished that the distribution of his estate be carried out according to Philippine law , as he had lived and acquired all his wealth in the Philippines. He even added a condition that any legatee who would not respect this wish would forfeit his or her inheritance. When the judicial administrator , Juan Miciano, submitted a scheme of partition to the probate court in accordance wit...

Aznar vs Garcia, 7 SCRA 95

  FACTS Edward E. Christensen, an American citizen born in New York and later a resident of California, spent most of his adult life in the Philippines. He arrived in the country in 1901 as a school teacher and lived intermittently between the Philippines and the U.S., but mostly remained in the Philippines after 1913. He did not acquire property or permanent residence in California, and by the time of his death in 1953 at St. Luke’s Hospital in Manila, he had long established his domicile in the Philippines , although he maintained his American citizenship . Christensen executed a last will and testament in Manila on March 5, 1951 , wherein he declared he had only one child , Maria Lucy Christensen Daney , residing in Los Angeles. He explicitly stated that Maria Helen Christensen (Garcia) , although baptized with his surname, was not related to him and had never been adopted . However, in an earlier decision by the Supreme Court (G.R. Nos. L-11483-84) , Helen Christensen Gar...

Bellis vs Bellis, 20 SCRA 358

  Facts Amos G. Bellis, an American citizen born in Texas and domiciled in San Antonio at the time of his death, had a complex family structure. He had five legitimate children from his first wife, Mary E. Mallen (whom he later divorced), three more legitimate children with his second wife, Violet Kennedy, and three illegitimate children, including Maria Cristina Bellis and Miriam Palma Bellis, who were born and raised in the Philippines. In 1952, while in the Philippines, Bellis executed a will. In it, he bequeathed significant sums: $240,000 to his first wife, Mary Mallen, and ₱40,000 each to his three illegitimate Filipino children, totaling ₱120,000. The remainder of his estate—his residuary estate—was allocated in equal shares among his seven legitimate children. When Bellis died in 1958, his will was probated in the Court of First Instance (CFI) of Manila. The executor, People's Bank and Trust Co., distributed the bequests in accordance with the will. The three illegitimat...

Van Dorn vs Romillo, 139 SCRA 139

  Facts  Alice Reyes Van Dorn, a Filipino citizen, and Richard Upton, an American citizen, were married in Hong Kong in 1972. They then settled in the Philippines and had two children. However, their relationship eventually deteriorated. In 1982, a divorce was obtained in Nevada, USA , legally dissolving their marriage. Alice later remarried in Nevada, this time to Theodore Van Dorn. Despite the divorce, in 1983, Richard Upton filed a complaint before the Regional Trial Court of Pasay City , asserting that Alice’s business in Manila— The Galleon Shop —was conjugal property and that he was entitled to manage or receive a share of it. He asked the court to compel Alice to render an accounting of the said business. Alice moved to dismiss the case. She argued that the Nevada divorce decree had already dissolved their marriage and that Richard himself acknowledged in that proceeding that there was no community property or obligations between them. She further asserted that as ...

Tenchavez v. Escaño

  Facts (Narrative Form) This case involves Dr. Tito Tenchavez, a Filipino citizen and Protestant, and VICENTA Escaño, a Filipina Catholic. They met and fell in love while Maria was studying at Siliman University in Dumaguete. Despite the disapproval of Maria's parents due to Tito’s religion, the two persisted in their relationship. Eventually, they were married in a civil ceremony in Dumaguete on June 20, 1948. Their marriage was kept secret at first, due to the expected objections from Maria’s devout Catholic family. When the marriage was eventually discovered, it sparked familial and religious discord. Tito's relationship with Maria became strained. In March 1950, Tito traveled to the United States to pursue further studies. During his absence, Maria, without his consent or knowledge, went to Reno, Nevada, and obtained a divorce decree on June 13, 1950. Subsequently, on May 14, 1953, Maria remarried in Nevada to an American citizen named William Allen. She also acquired A...

FLORESCA v. PHILEX MINING CORP.

  Facts (Narrative Style) In the isolated town of Padcal, Tuba, Benguet, the quiet rhythm of mining life was shattered when an underground fire broke out in Philex Mining Corporation’s mine. This devastating incident claimed the lives of six miners. Their families, suddenly bereft of loved ones and breadwinners, faced not only emotional pain but financial uncertainty. Left without a stable source of income, the widows of the deceased—led by petitioner Romana Floresca and others—sought compensation from Philex under Article 1711 of the Civil Code, arguing that the employer was bound to compensate its workers (or their heirs) for work-related deaths. However, Philex Mining Corporation, the respondent in this case, insisted that the proper remedy was not under the Civil Code but rather through the Workmen’s Compensation Act, a special law that governed work-related injuries and deaths. Philex argued that the Civil Code had been effectively repealed or supplanted in this context and ...

Chua Jan v. Bernas

  Facts: A cockfight occurred in Tabaco, Albay between cocks owned by Chua Jan (plaintiff) and Lucio Bernas (defendant). Each wagered ₱160. The referee declared Bernas's cock the winner. Chua Jan sued in the justice of the peace court, which declared the match a draw . On appeal to the Court of First Instance, the court dismissed the case citing the judge’s unfamiliarity with cockfighting rules and lack of applicable law. The court also ordered the return of the deposit to Chua Jan (the plaintiff), which was being held by the cockpit owner. ⚖️ Issue: Whether the lower court can refuse to decide a case due to the judge’s unfamiliarity with the applicable law or rules. 🧑‍⚖️ Ruling: NO. The Court of First Instance erred in dismissing the case simply because the judge was not familiar with the applicable laws or rules on cockfighting. 💡 Doctrine / Legal Principle: Courts have a duty to decide cases brought before them. A judge cannot excuse himself from dec...

Case digest- Miranda vs. Imperial, G.R. No. L-49090, February 28, 2947

  Facts: This case originated before the Court of First Instance of Albay in late 1941, just before the outbreak of the Pacific War. The plaintiff, Teodora L. Vda. de Miranda, filed a complaint on November 25, 1941, against the defendant spouses Feliciano Imperial and Juana de Imperial. The complaint arose from a loan transaction involving three parcels of riceland that the defendants owned. It was established that before November 17, 1938, the defendant spouses owed a debt of ₱1,000 to Elias Imperial. To secure payment, they had given possession and enjoyment of their three parcels of land to Elias by way of an anticresis contract. This contract entitled Elias to receive the fruits (produce) of the land as interest on the loan. However, despite enjoying the fruits for about 10 years, no part of the loan principal had been amortized. On November 17, 1938, the defendants proposed to Teodora, the plaintiff and sister-in-law to Juana (being the widow of Teodora’s brother), to lend...

Miranda vs. Imperial, G.R. No. L-49090, February 28, 2947

  This is a pre-war case. The complaint was filed before the Court of First Instance of Albay on November 25, 1941, that is, almost on the eve of the outbreak of the Pacific War. The court rendered its decision on March 17, 1943. The case was elevated to this Supreme Court by virtue of the appeal filed by the plaintiff on June 9, 1943. Before it could be decided, the case records were burned along with other records of this Court in the conflagration of Manila during the Battle of Liberation. Therefore, what we have before us is a reconstituted record using documents provided by the lawyers of the appellant, namely: (a) copies of the record on appeal; (b) copies of the brief submitted by the lawyers of the appellant. The appellee has not submitted any brief, either personally or through counsel. Both parties' lawyers were duly notified of the reconstitution proceedings by the commissioner of this Court, but only the lawyers of the appellant appeared and submitted the aforementio...