Matabuena v.
Cervantes Respondent does not necessarily
G.R. No. L-28771 (March 31, 1971)
FACTS:
Felix Matabuena cohabitated with Respondent.
During this period, Felix Matabuena donated to
Respondent a parcel of land. Later the two were
married. After the death of Felix Matabuena, his
sister, Petitioner, sought the nullification of
the donation citing Art.133 of the Civil Code
Every donation between the spouses during
the marriage shall be void.
The trial court ruled that this case was not
covered by the prohibition because the donation
was made at the time the deceased and
Respondent were not yet married and were
simply cohabitating.
ISSUE:
W/N the prohibition applies to donations
between live-in partners.
HELD:
Yes. It is a fundamental principle in statutory
construction that what is within the spirit of the
law is as much a part of the law as what is
written. Since the reason
for the ban on donations between spouses d
uring the marriage is to prevent the possibili
ty of undue influence and improper pressure
being exerted by one spouse on the other, there
is no reason why this prohibition shall not apply
also to common-law relationships.
The court, however, said that the lack of th
e donation made by the deceased to
mean 15 years as a coterminous employee of 4
that the Petitioner will have exclusive rights to
the disputed property because the relationship
between Felix and Respondent were legitimated
by marriage.
Chua v. Civil Service Commission
February 7, 1992
Facts:
In line with the policy of streamlining and
trimming the bureaucracy, R.A.6683 (2
December 1988) was enacted to provide for the
early retirement and voluntary separation of
government employees as well as involuntary
resignation to those affected due to
reorganization. Those who may avail were
regular, casual, temporary and emergency
employees, with rendered service minimum of
two years.
Sec. 2. Coverage. This Act shall cover all
appointive officials and employees of the
National Government, including government-
owned or controlled corporations with original
charters, as well as the personnel of all local
government units. The benefits authorized
under this Act shall apply to all regular,
temporary, casual and emergency employees,
regardless of age, who have rendered at least a
total of two (2) consecutive years of government
service as of the date of separation. Uniformed
personnel of the Armed Forces of the Philippines
including those of the PC-INP are excluded from
the coverage of this Act.
Petitioner Lydia Chua was hired by the National
Irrigation Administration Authority (NIA) for over
successive NIA projects. Petitioner Lydia Chua,
believing that she is qualified to avail of the
benefits of the program, filed an application on
January 30, 1989 with the NIA but was denied
and later on with the CSC who was likewise
denied. She was instead offered a separation
benefits of monthly basic pay for each year of
service.
a) co-terminous with the project When the
appointment is co-existent with the duration of
a particular project for which purpose
employment was made or subject to the
availability of funds for the same;
Issue:
Whether or not petitioner was entitled to avail
of the early retirement benefit as a coterminous
employee.
Held:
It was stated that a coterminous employee is a
non-career civil servant like casual and
emergency employees, because of that they are
entitled to the same benefits as long as they
complied with the requirements of the law,
which in this case, was done by Linda Chua. On
that note, the court believes that the denial of
petitioners application for early retirement
benefits by the NIA and CSC is unreasonable,
unjustified and oppressive due to the fact that
she is entitled to the benefits of the same law
because she served the government not only for
two (2) years which is the minimum requirement
under the law but for fifteen (15) years. In four
(4) governmental projects.
Wherefore, the petition is granted.
Alfon v. Republic
[GR L-51201, 29 May 1980]
Facts: Maria Estrella Veronica Primitiva Duterte
was born on 15 May 1952 at the UST Hospital to
Filomeno Duterte and Estrella. She was
registered at the Local Civil Registrars Office as
Maria Estrella Veronica Primitiva Duterte. On 15
June 1952, she was baptized as Maria Estrella
Veronica Primitiva Duterte at the St. Anthony de
Padua Church, Singalong, and Manila. Estrella
Veronica Primitiva Duterte has been taken cared
of by Mr. and Mrs. Hector Alfon. She lived in
Mandaluyong for 23 years with her uncle, Hector
Alfon. When Maria Estrella started schooling,
she used the name Estrella S. Alfon. She
attended her first grade up to fourth year high
school at Stella Maris College using the name
Estrella S. Alfon. After graduating from high
school she enrolled at the Arellano University
and finished Bachelor of Science in Nursing. Her
scholastic records from elementary to college
show that she was registered by the name of
Estrella S. Alfon. Petitioner has exercised her
right of suffrage under the same name. She has
not committed any felony or misdemeanor.
She filed a verified petition on 28 April 1978
praying that her name be changed from Maria
Estrella Veronica Primitiva Duterte to Estrella S.
Alfon. The CFI (Branch XXIII) partially denied
petitioners prayer on 29 December 1978,
granting the change of first name but not the
surname.
The Supreme Court modified the appealed order registered at the Local Civil Registrars Office as
in as much as that petitioner is allowed to change Maria Estrella Veronica Primitiva Duterte. On 15
not only her first name but also her surname so June 1952, she was baptized as Maria Estrella
as to be known as Estrella S. Alfon; without costs. Veronica Primitiva Duterte at the St. Anthony de
Padua Church, Singalong, Manila. Estrella
1. Principally is not equivalent to exclusively
Veronica Primitiva Duterte has been taken cared
The word principally as used in article 364 of
of by Mr. and Mrs. Hector Alfon. She lived in
the Civil Code is not equivalent to exclusively
Mandaluyong for 23 years with her uncle, Hector
so that there is no legal obstacle if a legitimate
Alfon. When Maria Estrella started schooling,
or legitimated child should choose to use the
she used the name Estrella S. Alfon. She
surname of its mother to which it is equally
attended her first grade up to fourth year high
entitled. In the case at bar, the lower court erred
school at Stella Maris College using the name
in reasoning that as legitimate child of Filomeno
Estrella S. Alfon. After graduating from high
Duterte and Estrella Alfon she should principally
school she enrolled at the Arellano University
use the surname of her father.
and finished Bachelor of Science in Nursing. Her
scholastic records from elementary to college
2. Grounds for change of name
show that she was registered by the name of
The following may be considered, among others,
Estrella S. Alfon. Petitioner has exercised her
as proper or reasonable causes that may warrant
right of suffrage under the same name. She has
the grant of a petitioner for change of name; (1)
not committed any felony or misdemeanor.
when the name is ridiculous, tainted with
dishonor, or is extremely difficult to write or
She filed a verified petition on 28 April 1978
pronounce; (2) when the request for change is a
praying that her name be changed from Maria
consequence of a change of status, such as when
Estrella Veronica Primitiva Duterte to Estrella S.
a natural child is acknowledged or legitimated;
Alfon. The CFI (Branch XXIII) partially denied
and (3) when the change is necessary to avoid
petitioners prayer on 29 December 1978,
confusion (1 Tolentino 660, Civil Code of the
granting the change of first name but not the
Philippines, 1953 ed; Haw Liong v. Republic). In
surname.
the case at bar, to avoid confusion, the petition
of name should be granted as the petitioner has The Supreme Court modified the appealed order
been using the name of Estrella S. Alfon since in as much as that petitioner is allowed to change
childhood. not only her first name but also her surname so
as to be known as Estrella S. Alfon; without
Alfon v. Republic [GR L-51201, 29 May 1980]
costs.
Second Division, Abad Santos (p): 4 concur
1.Principally is not equivalent to exclusively The
Facts: Maria Estrella Veronica Primitiva Duterte
word principally as used in article 364 of the
was born on 15 May 1952 at the UST Hospital to
Civil Code is not equivalent to exclusively so
Filomeno Duterte and Estrella. She was
that there is no legal obstacle if a legitimate or covered by the Labor Code or by laws and
legitimated child should choose to use the regulations governing the civil service.
surname of its mother to which it is equally
entitled. In the case at bar, the lower court erred
Held: Yes, pursuant to Article 12-B, Sec 1 of 1973
in reasoning that as legitimate child of Filomeno
Consti.
Duterte and Estrella Alfon she should principally
use the surname of her father.

2.Grounds for change of name The following

may be considered, among others, as proper or
reasonable causes that may warrant the grant of
a petitioner for change of name; (1) when the
name is ridiculous, tainted with dishonor, or is
extremely difficult to write or pronounce; (2)
when the request for change is a consequence of
a change of status, such as when a natural child
is acknowledged or legitimated; and (3) when
the change is necessary to avoid confusion (1
Tolentino 660, Civil Code of the Philippines, 1953
ed; Haw Liong v. Republic). In the case at bar, to
avoid confusion, the petition of name should be
granted as the petitioner has been using the
name of Estrella S. Alfon since childhood.

National Housing Corp. v. Juco

134 SCRA 172 (1985)

Facts: Juco was an employee of the NHA. He filed

a complaint for illegal dismissal w/ MOLE but his
case was dismissed by the labor arbiter on the
ground that the NHA is a govt-owned corp. and
jurisdiction over its employees is vested in the
CSC. On appeal, the NLRC reversed the decision
and remanded the case to the labor arbiter for
further proceedings. NHA in turn appealed to the
SC.

Issue: Are employees of the National Housing

Corporation, a GOCC without original charter,