R.D. Armenion Law Office

18/08/2025

06/08/2025

The invalidated a sale of two parcels of land because the buyer knew that the seller was not the real owner.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division cancelled the sale made by Bayani S. Cerilla (Cerilla) to Edward C. Ciacho (Ciacho). The SC found that Ciacho knew the sold properties did not belong to Cerilla.

The properties were inherited by Adolfo De Guia which were about to be foreclosed due to unpaid debt. De Guia asked Cerilla to pay off the mortgage. They signed a deed of sale, and land titles were transferred to Cerilla’s name.

After a few months, another agreement was signed to re-sell the properties to De Guia. The latter filed adverse claim on the titles.

Cerilla and De Guia entered into a subsequent agreement where Cerilla would buy the properties for PHP 15 Million but only after De Guia ejects the illegal settlers from the properties.

As De Guia failed to remove the illegal settlers, Cerilla had to undertake the same but was not successful in doing so. As a result, Cerilla incurred expenses for ejectment which caused him to obtain a loan from a bank and from Ciacho.

Ciacho agreed to lend Cerilla with the properties as collateral. Because Cerilla could not pay the loan, Ciacho asked him to sign a deed of sale on the properties but with a request from Cerilla not to register the same.

De Guia learned that Ciacho registered the properties under his name. Thus, he filed a case with the RTC to invalidate the sale. After finding in favor of De Guia, the case was appealed to the Court of Appeals.

Both RTC and CA found that Cerilla had no authority to sell the properties as he was just a mere “accommodation party” to avoid foreclosure of the properties but was not the real owner.

The Court agreed with the RTC and CA finding that there was no real intention to transfer ownership from De Guia to Cerilla. Even after the land titles were transferred under his name, Cerilla did not act as if he owned the lands.

Under the Civil Code, for a sale to be valid, the parties must agree to the sale. The parties’ actions during and after the agreement can serve as basis to determine their intent. The seller must also be the owner of the property or has authority to sell.

Here, the re-sale of the properties from Cerilla to De Guia within a short period of time coupled with the fact that Cerilla asked Ciacho not to register the properties under his name, indicate that there was no intention on the part of De Guia to transfer ownership of the properties.

The Court added that Ciacho cannot claim to be an innocent buyer because he was aware of facts that should have raised doubts about Cerilla’s ownership. He knew of the earlier sale between De Guia and Cerilla and the former’s claim as annotated on the titles.

Read the full text of the press release at https://sc.judiciary.gov.ph/sc-no-valid-sale-if-buyer-knows-seller-is-not-true-owner/

Read the full text of the Decision https://sc.judiciary.gov.ph/259051-edward-c-ciacho-vs-spouses-adolfo-t-de-guia-and-fe-alma-v-de-guia-et-al/

Read the Separate Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/259051-separate-concurring-opinion-justice-alfredo-benjamin-s-caguioa/

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

07/07/2025

For inquiries, you may call Notarial Section at 268-9270

27/05/2025

27/05/2025

In a Decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the Court discouraged legal actions brought about by a broken heart and a broken promise as it reiterated that a mere breach of a promise to marry is not an actionable wrong as long as it does not palpably and unjustifiably contradict good customs.

The Court found that Jhonna Guevarra was NOT liable for damages to her former fiancee, Jan Banach, a German national, after breaking up with him when she discovered that he was not a divorcee, but was still married to a third wife.

The Court ruled that there was no legal basis to order Guevarra to return the PHP 500,000.00 sent by her ex-fiance for a supposed conjugal home since she was justified in breaking off their engagement and Banach’s actions were tainted with fraud and deceit since he lied about his marital status and even hid his true name from Guevarra.

Furthermore, the Court explained that since the money was given as a gift to help Guevarra and her family with their possible eviction from their home, the legal principle of unjust enrichment cannot be applied to compel her to return the cash to Banach.

Read the full text of the decision at https://sc.judiciary.gov.ph/26981/.

27/05/2025

Copies of recent pleadings involving public interest are regularly uploaded to the Public Pleadings page of the website.

VISIT https://sc.judiciary.gov.ph/public-pleadings/ or SCAN the QR code for the latest upload:

- PAMALAKAYA, et al.'s (petitioner's) Verified Petition in G.R. No. 277351 (PAMALAKAYA, et al. v. Philippine Reclamation Authority, et al.)

- Sands Mining and Development Corporation's (respondent's) Comment in G.R. No. 277351

-Silverquest Mining Resources, Inc.'s (respondent's) Comment in G.R. No. 277351

- Frabelle Fishing Corporation's (respondent's) Motion to Admit Comment to the Petition for Writ of Kalikasan and Writ of Continuing Mandamus with Damages in G.R. No. 277351

- Provincial Government of Cavite's (respondent's) Comment in G.R. No. 277351

- City Government of Parañaque's (respondent's) Comment in G.R. No. 277351

- Manila Goldcoast Development Corporation's (respondent's) Comment in G.R. No. 277351

- Myed-Nikkel Resources Corporation's (respondent's) Comment in G.R. No. 277351

- City Government of Bacoor's (respondent's) Motion to Adopt the Comment of Private Respondent Frabelle Fishing Corporation in G.R. No. 277351

- Philippine Reclamation Authority's (respondent's) Comment in G.R. No. 277351

- City of Manila's (respondent's) Comment in G.R. No. 277351

- Cargon Mining Corp's (respondent's) Comment in G.R. No. 277351

16/12/2024

The Supreme Court (SC) reiterated that premarital sexual relations leading to pregnancy are not immoral and do not justify suspending an employee.

The SC ruled that Bohol Wisdom School (BWS), a Christian school, illegally suspended a grade school teacher for becoming pregnant outside marriage.

It held that sexual relations between two unmarried, consenting adults are not immoral. No law prohibits this, nor does it go against any fundamental state policy found in the Constitution.

The SC clarified that under the law, the standard of morality applicable to all is public and secular, not religious.

Public and secular morality refers to conduct that is prohibited due to its harmful effects on human society rather than being based on religious beliefs.

The SC held that if the government were to otherwise base public policies and morals on religious beliefs, this would require everyone to conform to a religious program or agenda.

As the teacher’s pregnancy cannot be considered immoral, it was not a valid ground for her suspension.

The SC ordered BWS to pay the teacher backwages and benefits due her during the period she was suspended.

The Decision was from the Supreme Court’s First Division, written by Associate Justice Ricardo R. Rosario.

Read the full text of the press release: https://sc.judiciary.gov.ph/sc-school-cannot-suspend-unmarried-teacher-for-being-pregnant/

Read the full text of the Decision: https://sc.judiciary.gov.ph/252124-bohol-wisdom-school-dr-simplicio-yap-jr-and-raul-h-deloso-vs-miraflor-mabao/



Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy

12/12/2024

The Supreme Court underscored that a writ of mandamus may not compel the Commission on Elections (COMELEC) to exercise its discretion in a certain way, such as granting or denying a request to open and recount ballot boxes.

Mandamus is an extraordinary writ that compels a person, tribunal, corporation, board, or officer to carry out a legally required action if it has failed or refused to do so. This action must be ministerial, meaning that its performance does not involve the exercise of discretion or judgment.

In dismissing the petition, the Supreme Court held that the issue did not involve a ministerial act by the COMELEC, as the requested recount of physical ballots requires the exercise of the COMELEC's discretion and judgment. It also ruled that petitioners failed to establish any clear, complete, and specific legal right to a recount.

The Court found that the petitioners failed to identify any law requiring the recount of the physical ballots in the 2022 National and Local elections. Moreover, the COMELEC Resolution expressly states that the COMELEC “may, upon Petitioner’s instance, order the conduct of the recount of the ballots.”

Nevertheless, the Court found that the COMELEC was guilty of official inaction when it acted on the motions beyond the period prescribed by its own rules.

The Decision is from the Supreme Court En Banc, written by Associate Justice Jose Midas P. Marquez.

Read the full text of the press release at: https://sc.judiciary.gov.ph/sc-comelec-cannot-be-compelled-to-grant-or-deny-request-for-ballot-recount/

Read the full text of the Decision at: https://sc.judiciary.gov.ph/273136-eliseo-mijares-rio-jr-augusto-cadelina-lagman-and-franklin-fayloga-ysaac-vs-commission-on-elections-en-banc/



Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/

09/12/2024

The Supreme Court (SC) held that the Bar examination scores of individual Bar takers are sensitive personal information under the Data Privacy Act. Thus, they cannot be disclosed without the prior consent of the examinees.

In Bar Matter No. 4968, the SC En Banc approved the Guidelines on Requests for Disclosure of A Law School’s Bar Examinations Performance (Guidelines).

Under the Guidelines, the SC may approve requests from law schools for Bar exam scores, as long as these scores are aggregated, averaged, or anonymized and do not identify any individual Bar exam taker.

Requests from law schools must be signed by the dean or an equivalent official, and must state a legitimate purpose, such as reviewing and improving law degree programs and performance on future Bar exams.

The Office of the Bar Confidant is the office tasked to review and act upon such requests.

Read the full text of the press release at: https://sc.judiciary.gov.ph/sc-individual-bar-exam-score-cannot-be-disclosed-without-examinees-consent/

Read the full text of Bar Matter No. 4968 at: https://sc.judiciary.gov.ph/4968-re-disclosure-of-an-individual-bar-takers-scores/



Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/