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Magallona v.

Ermita
665 SCRA 476
Facts:
Petitioners challenged the constitutionality of RA 9522 on two principal grounds, namely: (1) RA 9522
reduces Philippine maritime territory, and logically, the reach of the Philippine state’s sovereign power, in
violation of Article 1 of the 1987 Constitution, embodying the terms of the Treaty of Paris and ancillary
treaties, and (2) RA 9522 opens the country's waters landward of the baselines to maritime passage by all
vessels and aircrafts, undermining Philippine sovereignty and national security, contravening the
country’s nuclear-free policy, and damaging marine resources, in violation of relevant constitutional
provisions. The petitioners further contended that RA 9522’s treatment of the KIG as “regime of islands”
not only results in the loss go large maritime area but also prejudices the livelihood of substance
fisherman.

Issue:
Whether or not RA 9522 is constitutional.

Held:
Yes. RA 9522 is a statutory tool to demarcate the country’s maritime zones and continental shelf under
UNCLOS III, not to delineate Philippine territory. The Court also validated as not inconsistent with the
Philippine claim of sovereignty the use if the Framework of Regime of Islands to determine the maritime
zone of the Kalayaan Island Group (KIG) and the Scarborough Shoal. It added that the country’s statutory
claim over Sabah under RA 5446 is retained because RA 9522 does not repeal RA 5446. Finally, the
Court declared that UNLCOS III and RA 9522 are not incompatible with the Constitution’s delineation of
internal waters, because under current norms of international law, the right of innocent passage is
recognized over archipelagic waters or internal waters, however they may be denominated.

Philippine Virginia Tobacco Administration v. Court of Industrial Relations


65 SCRA 416
Facts:
On December 20, 1966, claimants, now private respondents, filed with respondent Court a petition
wherein they alleged their employment relationship, the overtime services in excess of the regular eight
hours a day rendered by them, and the failure to pay them overtime compensation in accordance with
Commonwealth Act No. 444. Their prayer was for the differential between the amount actually paid to
them and the amount allegedly due them. There was an answer filed by petitioner Philippine Virginia
Tobacco Administration denying the allegations and raising the special defenses of lack of a cause of
action and lack of jurisdiction as it is exercising governmental functions and that it is exempt from the
operation of Commonwealth Act No. 444.

Issue:
Whether or not PVTA discharges governmental and not proprietary functions and is exempt from CA No.
444.

Held:
It is an inherent state function which makes government required to support its people and promote their
general welfare. This case explains and portrays the expanded role of government necessitated by the
increased responsibility to provide for the general welfare. The Court held that the distinction and
between constituent and ministrant functions, which the Chief Justice points out, is already irrelevant
considering the needs of the present time. He says that "The growing complexities of modern society have
rendered this traditional classification of the functions of government obsolete." The distinction between
constituent and ministrant functions is now considered obsolete.

Government of the Philippines v. Monte de Piedad


35 SCRA 738
Facts:
Certain contributions and donations were made for the relief victims of an earthquake during the Spanish
regime. Some of the amounts were never distributed but were deposited with the respondent bank, Monte
de Piedad. The government filed an action for recovery of said amounts but this was opposed on the
ground that it was not the correct party to institute the proceedings and that it amounted to taking of
property without due process return the money was wiped out by the change of sovereignty.

Issue:
Whether or not the petition must be granted.

Held:
Yes. The government has the right to institute the suit for the State as parenspartriae in representation of
the beneficiaries, the heirs of the victims and legitimate claimants. It is clear that there is a total
abrogation of the former political relations of the inhabitants of the ceded region and that all laws
theretofore in force which are in conflict with the political character, constitution, or institutions of the
substituted sovereign, lose their force. But it is equally settled in the same public law that the great body
of municipal law which regulates or changed by the new ruler. Applying this principle to the case at bar,
it is clear that the laws governing donations is not political in any sense of the word. They conferred upon
the Spanish Government the right and duty to supervise, regulate, and to some extent control charities and
charitable institutions. The present sovereign, in exempting “provident institutions, savings banks, etc.”
all of which are in the nature of charitable institutions, from taxation, placed such institutions, in so far as
the investment in securities are concerned, under the general supervisions of the Insular Treasurer.
Furthermore, upon the cession of the Philippines Islands the prerogative of the crown of Spain devolved
upon the US. This power still remains with them except so far as they have delegated a portion of it to the
Federal Government. The Sovereign will is made known to us by legislative enactment. The State as a
sovereign is the parenspatriae. This prerogative parenspatriae is inherent in the supreme power of every
State, whether that power is lodged in a royal person or in the legislature, and has no affinity to those
arbitrary powers which are sometimes exerted by irresponsible monarch to the great detriment of the
people and the destruction of their liberties. On the contrary, it is a most beneficent function, and for the
prevention of injury to those who cannot protect themselves.
Co Kim Cham v. Valdez Tan Keh
75 Phil. 113
Facts:
The respondent judge of the lower court refused to take cognizance of and continue the proceeding of
civil case No. 3012 of said court which was initiated under the regime of the so-called Republic of the
Philippines established during the Japanese military occupation of the Philippines. He argued that the
proclamation issued by Gen. Douglas MacArthur had the effect of invalidating and nullifying all judicial
proceedings and judgements of the courts of the said governments. He also argued that the said
governments during the Japanese occupation were notde facto governments.

Issue:
Whether or not the proclamation of Gen. McArthur rendered null and void all judgments and judicial
proceedings of the courts established in the Philippines during the Japanese military occupation

Held:
No. The word “processes” in the proclamation that “all laws, regulations and processes” of the so-called
Republic of the Philippines during the Japanese occupation of the country are “null and void and without
legal effect” may not be construed to embrace judicial processes because to adopt such construction great
inconvenience and public hardship would result and great public interest would be endangered and
sacrificed, for disputes or suits already adjudged would have to be again settled, accrued or vested rights
nullified, sentences passed on criminals set aside, and criminals might easily become immune for
evidence against them may have already disappeared.

Laurel v. Misa
77 Phil 856
Facts:
Anastacio Laurel is a Filipino citizen who was arrested in Camarines Sur in May, 1945, by the United
States Army, and was interned, under a commitment order "for his active collaboration with the Japanese
during the Japanese occupation," but in September, 1945, he was turned over to the Commonwealth
Government, and since then has been under the custody of the respondent Director of Prisons. He now,
demands his release from Bilibid Prison, mainly asserting that Commonwealth Act No. 682, creating
People's Court, specially section 19, under which he is detained as a political prisoner, is unconstitutional
and void.

Issue:
Whether or not the allegiance of the accused as a Filipino citizen was suspended and that there was a
change of sovereignty over the Philippine Islands.

Held:
The accused was found guilty. A citizen owes absolute and permanent allegiance to his government or
sovereign. No transfer of sovereignty was made; hence, it is presumed that the Philippine government still
had the power. Moreover, sovereignty cannot be suspended; it is either subsisting or eliminated and
replaced. Sovereignty per se wasn’t suspended; rather, it was the exercise of sovereignty that was
suspended. Thus, there is no suspended allegiance. Regarding the change of government, there is no such
change since the sovereign – the Filipino people – is still the same. What happened was a mere change of
name of government, from Commonwealth to the Republic of the Philippines.
Ruffy v. Chief of staff
75 PHIL 875
August 20, 1946
Facts:
During the Japanese insurrection in the Philippines, military men were assigned at designated camps or
military bases all over the country. Japanese forces went to Mindoro thus forcing petitioner and his band
move up the mountains and organize a guerilla outfit and call it the "Bolo area". A certain Capt. Beloncio
relieved Ruffy and fellow petitioners of their position and duties in the "Bolo area" by the new authority
vested upon him because of the recent change of command. Capt. Beloncio was thus allegedly slain by
Ruffy and his fellow petitioners.

Issue:
Whether or not the petitioners were subject to military law at the time the offense was committed, which
was at the time of war and the Japanese occupancy.

Held:
The Court held that the petitioners were still subject to military law since members of the Armed Forces
were still covered by the National Defense Act, Articles of War and other laws even during an
occupation. The act of unbecoming of an officer and a gentleman is considered as a defiance of 95th
Article of War held petitioners liable to military jurisdiction and trial. Moreover, they were operating
officers, which makes them even more eligible for the military court's jurisdiction.
In consideration of the foregoing, the petition has no merit and should be dismissed. Thus, the petition is
hereby DENIED.

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