Tuesday, September 20, 2016

Solinap vs. Locsin GR No. 146737. December 10, 2001

Facts:
               Respondent Juan E Locsin, Jr. filed with the RTC a Petition for Letters of Administration praying that he be appointed Administrator of the Intestate Estate of Juan “Jhonny” Locsin.  He alleged, among others, (a) that he is an acknowledged natural child of the late Juan C. Locsin; (b) that during his lifetime, the deceased owned personal properties which include undetermined savings, current and time deposits with various banks, and 1/6 portion of the undivided mass of real properties owned by him and his siblings, namely: Jose Locsin, Jr., Manuel Locsin, Maria Locsin Yulo, Lourdes Locsin and Ester Locsin; and (c) that he is the only surviving legal heir of the decedent.
                However, before the scheduled hearing, oppositions has been filed on the ground that respondent is not a child or an acknowledged natural child of the late Juan C. Locsin, who during his lifetime, never affixed “Sr.” in his name; respondent’s claim as natural child is barred by prescription; and there is no filial relationship between herein respondent and the deceased.
                To support his claim, respondent submitted a machine copy (marked as Exhibit “D”) of his Certificate of Live Birth No. 477 found in the bound volume of birth records in the Office of the Local Civil Registrar of Iloilo City. Exhibit "D" contains the information that respondent's father is Juan C. Locsin, Sr. and that he was the informant of the facts stated therein, as evidenced by his signatures. To prove the existence and authenticity of Certificate of Live Birth No. 477 from which Exhibit "D" was machine copied, respondent presented Rosita J. Vencer, the Local Civil Registrar of Iloilo City. She produced and identified in court the bound volume of 1957 records of birth where the alleged original of Certificate of Live Birth No. 477 is included. Respondent also offered in evidence a photograph (Exhibit "C") showing him and his mother, Amparo Escamilla, in front of a coffin bearing Juan C. Locsin's dead body. The photograph, respondent claims, shows that he and his mother have been recognized as family members of the deceased.
In their oppositions, petitioners claimed that Certificate of Live Birth No. 477 (Exhibit "D") is spurious. They submitted a certified true copy of Certificate of Live Birth No. 477 found in the Civil Registrar General, Metro Manila, marked as Exhibit "8", indicating that the birth of respondent was reported by his mother, Amparo Escamilla, and that the same does not contain the signature of the late Juan C. Locsin.

Issue:
                Whether or not respondent is entitled to the issuance of letters of administration.

Ruling:
                No.
The Roces ruling regarding illegitimate filiation is further elucidated in Fernandez vs. Court of Appeals[17] where this Court said that "a birth certificate not signed by the alleged father (who had no hand in its preparation) is not competent evidence of paternity."
A birth certificate is a formidable piece of evidence prescribed by both the Civil Code and Article 172 of the Family Code for purposes of recognition and filiation. However, birth certificate offers only prima facie evidence of filiation and may be refuted by contrary evidence. Its evidentiary worth cannot be sustained where there exists strong, complete and conclusive proof of its falsity or nullity. In this case, respondent's Certificate of Live Birth No. 477 entered in the records of the Local Civil Registry has all the badges of nullity. Without doubt, the authentic copy on file in that office was removed and substituted with a falsified Certificate of Live Birth.
At this point, it bears stressing the provision of Section 23, Rule 132 of the Revised Rules of Court that "(d)ocuments consisting of entries in public records made in the performance of a duty by a public officer are prima facie evidence of the facts therein stated." In this case, the glaring discrepancies between the two Certificates of Live Birth have overturned the genuineness of Exhibit "D" entered in the Local Civil Registry. What is authentic is Exhibit "8" recorded in the Civil Registry General.
Incidentally, respondent's photograph with his mother near the coffin of the late Juan C. Locsin cannot and will not constitute proof of filiation, lest we recklessly set a very dangerous precedent that would encourage and sanction fraudulent claims. Anybody can have a picture taken while standing before a coffin with others and thereafter utilize it in claiming the estate of the deceased.
Respondent Juan E. Locsin, Jr. failed to prove his filiation with the late Juan C. Locsin, Sr.. His Certificate of Live Birth No. 477 (Exhibit "D") is spurious. Indeed, respondent is not an interested person within the meaning of Section 2, Rule 79 of the Revised Rules of Court entitled to the issuance of letters of administration.


                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

Comilang vs Barcena GR No. 146853. February 13, 2016

Facts:
                Respondents, together with their mother Dominga, filed a complaint for annulment of document with damages against petitioner Salvador Comilang. The complaint alleges that respondents are the owner of a parcel of land and house built thereon; respondents acquired the subject property through their earnings while working abroad; and the subject property was declared for taxation purposes in the Dominga’s name as administrator.
                Petitioner caused the execution of a Deed of Donation over said property by taking advantage of Dominga’s blindness, old age and physical infirmity.
                RTC rendered decision in favor of respondents and deed of donation null and void.
                CA sustained the conclusion of the RTC that the donation is void.
                Petitioner assails the CAs application of the principle of implied trust to nullify the Deed of Donation executed in his favor. He asserts that the existence of an implied trust between respondents and Dominga in relation to the subject property was never treated by the RTC nor was it brought in issue on appeal before the CA. Petitioner further argues that Margaritas statement on the witness stand that Dominga told her that the respondents sent her money to buy the subject property, should not have been given weight or credence by the RTC and the CA because it is hearsay and has no probative value.

Issue:
                Whether or not Margarita’s testimony is hearsay.
               
Ruling:
                No.
Anent Margaritas testimony that Dominga told her that the respondents sent her (Dominga) money to buy the subject property, it cannot be categorized as hearsay evidence. Margaritas testimony was not presented to prove the truth thereof, but only to establish the fact that Dominga narrated to Margarita the source of the funds used in the purchase of the subject property. What was sought to be admitted in evidence, and what was actually admitted in evidence, was the fact that the statement was made by Dominga to Margarita, not necessarily that the matters stated by her were true. The said utterance is in the nature of an independently relevant statement which may be admitted in evidence as such, but not necessarily to prove the truth thereof.

Thus, while it is true that the testimony of a witness regarding a statement made by another person, if intended to establish the truth of the fact asserted in the statement, is clearly hearsay evidence, it is otherwise if the purpose of placing the statement in the record is merely to establish the fact that the statement was made or the tenor of such statement.  Regardless of the truth or falsity of a statement, when the fact that it has been made is relevant, the hearsay rule does not apply and the statement may be shown. As a matter of fact, evidence as to the making of the statement is not secondary but primary, for the statement itself may constitute a fact in issue, or be circumstantially relevant as to the existence of such a fact.  For this reason, the statement attributed to Dominga regarding the source of the funds used to purchase the subject property related to the court by Margarita is admissible if only to establish the fact that such statement was made and the tenor thereof.

Besides, the testimony of Margarita is not the main basis for the RTCs decision. In fact, her testimony is not indispensable. It merely serves to corroborate the testimonies of the respondents on the source of the funds used in purchasing the subject property. The testimonies of all three witnesses for the plaintiffs were found to be convincing and credible by the RTC. This Court will not alter the findings of the RTC on the credibility of witnesses, principally because trial courts have vastly superior advantages in ascertaining the truth and in detecting falsehood as they have the opportunity to observe the manner and demeanor of witnesses while testifying.


                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             

Sison vs Ambalada GR No. L-9943. March 18, 1915

Facts:
Julian Ambalada and Modesta Afable lived together as husband and wife from 1870 until 1886, when Modesta Afable died. During their union, eight children were born to them, of whom Maria Ambalada alone survived her mother. This Maria married Sancho Sison, having three children, Vicente, Maria Consolacion, and Conrado, all surnamed Sison.

These three grandchildren of Ambalada and Afable have instituted the present suit against Julian Ambalada seeking liquidation of the estate belonging to the conjugal partnership between Julian Ambalada and Modesta Afable, and partition of the property constituting it, so that to them might be adjudicated the half of its products belonging to the portion of the spouse who died first, Modesta Afable. For this purpose the plaintiffs enumerate in their complaint six parcels of land as constituting the conjugal partnership property mentioned.

The defendant Julian Ambalada denies the existence of the conjugal partnership he said to have had with Modesta Afable, to whom, he avers, he was never legally married. He acknowledges in his written answer that he had by Modesta Afable among other children (four altogether enumerated in the instrument) Maria Ambalada, who, he says was born on September 11, 1875, and died on November 12, 1902, leaving the plaintiffs as her sole descendants.

Issue:
Whether or not there is valid marriage between Julian and Modesta.

Ruling:
Yes.
Julian admitted that he was capitan municipal, Modesta Afable was called capitana, because she was publicly accepted in that town as was his lawful wife, and when after Modesta's death he tried to get married in Navotas he represented himself to be a widower, and in his personal cedula he was stated to be married when he sought title to the land.

The legal presumption is that a man and woman living together as husband and wife have entered into a lawful contract of marriage (Code Civ, Proc., sec. 334, No. 28.); but presumptions established by law may be destroyed by proof to the contrary (Civil Code, art. 1251). Proof to the contrary rests upon the defendant, and he has adduced more whatever, for proof to overcome the legal presumption is not constituted by absence of the marriage certificate in the books of the parish of Balayan, wherein it is seen that other entries as important as that of the marriage in question are lacking. Lack of record of an act or fact in certain books of registry is not per seproof of the non-existence of the fact or act, outside of the cases where the laws specifically requires as essential evidence the record itself or the inscription of the fact or act to be proven.

The judgment appealed from is affirmed in so far as it declares that there was a legal marriage between Julian Ambalada and Modesta Afable.


Wednesday, January 13, 2016

Corporation Law: Pointers

Corporation
-          It is an artificial being created by operation of law, having the right of succession and the powers, attributes and properties expressly authorized by law or incident to its existence. (Sec 2, BP 68)

Components of a Corporation
a.        Incorporators
-          Those mentioned in the articles of incorporation as originally forming and composing the corporation, having signed the articles and acknowledged the same before a notary public.
-          They have no powers beyond those vested in them by the statute.
1.        They must be natural persons;
2.        At least five (5) but not more than fifteen (15)
3.        They must be of legal age
4.        Majority must be residents of the Philippines
5.        Each must own or subscribe to at least one share.
b.        Corporators
-          All the stockholders and members of a corporation including the incorporators who are still stockholders.
c.        Stockholders and members
-          Stockholders are persons who hold or own shares in a stock corporation while members are those who compose the non-stock corporation.
d.        Directors and trustees
-          The Board of Directors is the governing body in a stock corporation.
-          The Board of Trustees is the governing body in a non-stock corporation.
-          They exercise the powers of the corporation.
e.        Corporate officers
-          They are the officers who are identified as such in the Corporation Code, the Articles of Incorporation or the By-laws of the corporation.
f.         Promoter
-          A self constituted organizer who finds an enterprise or venture and helps to attract investors, forms a corporation and launches it in business, all with a view to promotion profits.
-          Liability of promoter
GR:          The promoter binds himself personally and assumes the responsibility of looking to the proposed corporation for reimbursement.
XPN:       
1.        Express or implied agreement to the contrary
2.        Novation, not merely adoption or ratification of the contract.

Doctrine of piercing the veil of corporate entity
-          A corporation is a legal entity distinct from persons composing it.
-          It is a theory introduced for the purposes of convenience and to serve the ends of justice.
-          When can be disregarded:
a.        When it is used as a shield to perpetuate fraud, to defeat public convenience, justify wrong or defend crime.
b.        When used to shield blatant violation of the prohibition against forum shopping.

Different kinds of Corporation
Stock Corporation
-          Corporations which have capital stock divided into shares and are authorized to distribute to the holders of such shares dividends or allotments of the surplus profits on the basis of shares held.
-          Organized or profit

Non-Stock Corporation
-          All other corporations are non-stock corporations.
-          One where no part of the income is distributable as dividends to its members, trustees, or officers, subject to the provisions of the Code on dissolution.

Public Corporation
-          One formed or organized for the government of a portion of the state.
-          Its purpose is for the general good and welfare.

Private Corporation
-          One formed for some public purpose, benefit, aim or end.
-          It may be stock or non-stock, government-owned or controlled or quasi-public.

Close Corporation
-          One whose articles of incorporation provide that:
1.        All the corporation’s issued stock of all classes, exclusive of treasury shares, shall be held of record by not more than a specified number o persons, not exceeding twenty (20);
2.        All the issued stock of all classes shall be subject to one or more specified restrictions on transfer permitted by this Title; and
3.        The corporation shall not list in any stock exchange or make any public offering of any of its stock of any class.
-          Notwithstanding the foregoing, a corporation shall not be deemed a close corporation when at least two-thirds (2/3) of its voting stock or voting rights is owned or controlled by another corporation which is not a close corporation within the meaning of this Code.

Educational Corporation
-          One organized for educational purposes.

Religious Corporations
-          One organized for religious purposes

Corporation sole
-          It is one formed for the purpose of administering and managing, as trustee, the affairs, property and temporalities of any religious denomination, sect, or church, by the chief archbishop, bishop, priest, rabbi, or other presiding elder of such religious denomination, sect or church.

Corporation aggregate
-          It is a religious corporation incorporated by more than one person.

Eleemosynary Corporation
-          One organized for a charitable purpose.

Domestic Corporation
-          On formed, organized, or existing under the laws of the Philippines.

Foreign Corporation
-          One formed, organized or existing under any laws other than those of the Philippines and whose law allows Filipino citizens and corporations to do business in its own country and state.

Corporation created by special laws or charter
-          Corporations which are governed primarily by the provisions of the special law or charter creating them.

Subsidiary Corporation
-          One in which control, usually in form of ownership of majority of its shares, is in another corporation.

Parent Corporation
-          Its control lies in its power, directly or indirectly, to elect the subsidiary’s directors thus controlling its management policies.

Corporation De Jure
-          A corporation organized in accordance with the requirements of the law.

De Facto Corporation
-          The due incorporation of any corporation claiming in good faith to be a corporation under this Code, and its right to exercise corporate powers, shall not be inquired into collaterally in any private suit to which such corporation may be a party. Such inquiry may be made by the Solicitor General in a quo warranto proceeding. (Sec 20)
-          A corporation where there exists a flaw in its incorporation.
-          Requisites:
1.        Organized under a valid law.
2.        Bona fide compliance with formalities of law.
3.        User of corporate powers.
4.        SEC issuance of certificate of incorporation.

Corporation by estoppel
-          All persons who assume to act as a corporation knowing it to be without authority to do so shall be liable as general partners for all debts, liabilities and damages incurred or arising as a result thereof.
-          Where a group of persons misrepresent themselves as a corporation, they are subsequently stopped from claiming lack of corporate life in order to avoid liability.

Different Kind of Shares
Common shares
-          The most common type of shares, which enjoy no preference but the owners thereof are entitled to management of the corporation and to equal pro-rata division of profits after preference. It represents a residual ownership interest in the corporation.

Preferred Shares
-          Stocks which are given preference by the issuing corporation in dividends and the distribution of assets of the corporation in case of liquidation or such other preferences as may be stated in the AOI which do not violate the Corporation Code. (Sec. 6)

Par Value Shares
-          These shares are with a stated value set out in the AOI.
-          Par Value is minimum issue price of such share in the AOI which must be stated in the certificate.

No-par Value Shares
-          These are shares without a stated value.

Founder’s share
-          These are shares, classified as such in the AOI, which are given certain rights and privileges not enjoyed by the owners of other stocks.

Redeemable shares
-          These are shares which permit the issuing corporation to redeem or purchase its shares.

Treasury Shares
-          These are shares which have been issued and fully paid for, but subsequently re-acquired by the issuing corporation by purchase, redemption, donation, or through some other lawful means. Such shares may again be disposed of for a reasonable price fixed by the BOD.

Convertible shares
-          A type of preferred stock that the holder can exchange for a predetermined number of common shares at a specified time.

Non-Voting shares
GR:          Non-Voting Shares are not entitled to vote.
XPN:
1.        Amendment of the AOI
2.        Adoption and amendment of by-laws
3.        Sale, lease, exchange, other disposition of all or substantially all of the corporate property
4.        Incurring, creating or increasing bonded indebtedness
5.        Increase or decrease of capital stock
6.        Merger or consolidation
7.        Investment of corporate funds in another corporation or business
8.        Dissolution of the corporation.


Corporation
Partnership
Governing Law
Corporation Code
Civil Code
Manner of creation
By law
By mere agreement
Number of incorporators
5 to 15 incorporators
XPN: Corporation sole
2 or more persons
Commencement of juridical personality
Date of issuance of the certificate of incorporation by SEC
Moment of execution of the contract
Powers
Only powers expressly granted by law
Any power authorized by partners
Management
Board of Directors/ Board of Trustees
agent
Effect of mismanagement
Suit must be in the name of the corporation
Partner can sue a co-partner
Right of succession
Have the right of succession
No right
Transferability of interest
Without consent
Consent
Extent of liability to third persons
Extent of the shares
Personally and subsidiarily
XPN: Limited
Term of existence
50 years
Extendible for 50 years
Any period (stipulation)


Forms of Stock
Authorized Capital Stock
-          The amount fixed in the AOI to be subscribed and paid by the stockholders of the corporation.

Subscribed Capital
-          25% of the Authorized Capital Stock that is covered by subscription agreements whether fully paid or not.

Paid-Up Capital
-          25% of the Subscribed Capital which has been subscribed and actually paid.
-          It should not be less than P5000.

Outstanding Capital Stock
-          The total shares of stock issued to subscribers or stockholders, whether or not fully or partially paid except treasury shares so long as there is binding subscription agreement.

Capital
-          Properties and assets of the corporation that are used for its business or operation.

Qualification of Board of Directors
1.        Every director must own at least one (1) share of the capital stock of the corporation of which he is a director, which share shall stand in his name on the books of corporation.
Trustees of non-stock corporations must be members thereof.
2.        A majority of the directors or trustees of all corporations organized under this Code must be residents of the Philippines.
3.        He must not have been convicted by final judgment of an offense punishable by imprisonment for a period exceeding six (6) years or a violation of the Corporation Code, committed within five (5) years before the date of his election.
4.        He must be of legal age.
5.        He must possess other qualifications as may be prescribed in the by-laws of the corporation.

Election of Directors or Trustees (Sec 24)
1.        Straight voting
Every stockholder may vote such number of shares for as many persons as there are directors to be elected.
2.        Cumulative Voting for one candidate
A stockholder is allowed to concentrate his votes and give one candidate as many votes as the number of directors to be elected multiplied by the number of his shares shall equal.
3.        Cumulative Voting by distribution
A stockholder may cumulate his shares by multiplying also the number of his shares by the number of directors to be elected and distribute the same among as many candidates as he shall see fit.
*Cumulative voting is not available in non-stock corporations.

Disqualification of directors, trustees or officers (Sec.27)
1.        No person convicted by final judgment of an offense punishable by imprisonment for a period exceeding six (6) years, or
2.        A violation of this Code committed within five (5) years prior to the date of his election or appointment, shall qualify as a director, trustee or officer of any corporation.

Section 144. Violation of the Code.
                Violations of any of the provisions of this Code or its amendments not otherwise specifically penalized therein shall be punishable by a fine not less than one thousand (P1000) pesos but not more than ten thousand (P10 000) pesos or by imprisonment for not less than thirty (30) days but not more than five (5) years, or both, in the discretion of the court. If the violation is committed by a corporation, the same way, after notice and hearing, be dissolved in appropriate proceedings before the Securities and Exchange Commission: Provided, That such dissolution shall not preclude the institution of appropriate action against the director, trustee or officer of the corporation responsible for said violation: Provided, further, That nothing in this section shall be construed to repeal the other causes for dissolution of a corporation provided in this Code.

Interlocking Director
                There is an interlocking director in a corporation when one (or some or all) of the directors in one corporation is (or are) a director in another corporation.
a.        If the interests of the interlocking director in the corporations are both substantial (stockholdings exceed 20% of Outstanding Capital Stock).
GR:          A contract between two or more corporations having interlocking directors shall not be invalidated on that ground alone.
XPN:        If the contract is fraudulent or not fair and reasonable.

Powers of the Corporation
General Powers (Sec 36 CCP)
1.        Sue and be sued in its corporate name;
2.        Succession;
3.        Adopt and use a corporate seal;
4.        Amend Articles of Incorporation;
5.        To adopt, amend or repeal by-laws;
6.        For stock corporations – issue stocks to subscribers and to sell treasury stocks;
For non-stock corporations – admit members;
7.        Purchase, receive, take, or grant, hold, convey, sell, lease, pledge, mortgage and otherwise deal with real and personal property, pursuant to its lawful business;
8.        Enter into merger or consolidation with other corporations;
9.        To make reasonable donations for public welfare, hospital, charitable, cultural, scientific, civil or similar purposes. Prohibited: donations in aid of any political party or candidate for purposes of partisan political activity;
10.     To establish pension, retirement and other plans for the benefit of directors, trustees, officers and employees;
11.     Other powers essential or necessary to carry out its purposes.

Specific Powers
1.        Power to extend or shorten corporate term;
2.        Increase/Decrease Corporate Stock;
3.        Incur, create bonded indebtedness;
4.        To deny pre-emptive right;
5.        Sell, dispose, lease, encumber all or substantially all of corporate assets;
6.        Purchase or acquire own shares;
7.        To invest in another corporation, business other than the primary purpose;
8.        To declare dividends;
9.        To enter into management contract;
10.     To amend the articles of incorporation.

Trust Fund Doctrine
                It means that the capital stock, properties and other assets of a corporation are regarded as equity in trust for the payment of corporate creditors. Stated simply, it states that all funds received by the corporation in payment of the shares of stock shall be held in trust for the corporate creditors and other stockholders of the corporation. Under such doctrine, no fund shall be used to buy back the issued shares of stock except only in instances specifically allowed by the Corporation Code.

Cases where the trust fund doctrine is violated
1.        When the corporation releases or condones payment of the unpaid subscription.
2.        When there is payment of dividends without unrestricted retained earnings.
3.        When properties are transferred in fraud of creditors.
4.        When properties are disposed or undue preference is given to some creditors even if the corporation is insolvent.

Stockholder’s suits and remedies
1.        Individual suit
One brought to assert a right by a stockholder peculiar to himself. Suits brought by a stockholder for the issuance to him a stock certificate, payment of his dividend, payment to him of the book value of his stocks, in those instances where the law allows him the right of appraisal, are individual suit.
2.        Representative Suit
One brought by a stockholder in his own behalf, and in behalf of other stockholders similarly situated, and having a common cause against the corporation.
3.        Derivative Suit
A suit brought by a stockholder, for and in behalf of the corporation and against any person, also a stockholder, director, officer, or third person. The right can be availed of by the stockholder after he has exhausted intra-corporate remedies, by requesting the board to act, and the board does not act at all.
An action brought by minority stockholders in the name of the corporation to redress wrongs committed against it, for which the directors refuse to sue. It is a remedy designed by equity and has been the principal defense of the minority shareholders against abuses by the majority.
Requisites:
1.        Cause of action in favor of the corporation;
2.        Refusal of corporation to sue, and;
3.        Party filing the suit is a stockholder.