Reliance on Title Alone

In Sunshine Finance, the Court required, for the first time, investment and financing corporations to take the necessary precautions to ascertain if there were any flaws in the certificate of title and examine the condition of the property they were dealing with. Although the property involved was mortgaged to and, subsequently, purchased by therein petitioner several years before the said decision was promulgated, we note that the rule was immediately applied to that case.

Our herein assailed ruling expands the ruling in Sunshine Finance to cover realty corporations, which, because of the nature of their business, are, likewise, expected to exercise a higher standard of diligence in ascertaining the status of the property, not merely rely on what appears on the face of a certificate of title. In like manner, our ruling should be applied to the present case; otherwise, it would be reduced to “a mere academic exercise with the result that the doctrine laid down would be no more than a dictum, and would deprive the holding in the case of any force.” (Eagle Realty v. Republic, G.R. No. 151424, July 31, 2009)

Issuance of Warrant of Arrest

In Agunday v. Judge Tresvalles, the Court noted that the requirement to post bail is no longer necessary under the Revised Rule on Summary Procedure. Further, in Martinez, Sr. v. Judge Paguio, the Court observed that under Republic Act No. 6036, bail is not generally required for violation of municipal or city ordinances, and for criminal offenses when the prescribed penalty is not higher than arresto mayor or fine of P2,000 or both. (Cervantes v. Pangilinan, A.M. MTJ-08-1709, July 31, 2009)

Necessity of Standing in Case

Disciplinary proceedings involve no private interest and afford no redress for private grievance. They are undertaken and prosecuted solely for the public welfare, and for the purpose of preserving courts of justice from the official ministration of persons unfit to practice in them. The attorney is called to answer to the court for his conduct as an officer of the court. The complainant is in no sense a party, and has generally no interest in the outcome of the case. This is also the reason why this Court may investigate charges against lawyers regardless of complainant’s standing. (Camara v. Reyes, A.C. No. 6121, July 31, 2009)

Authority to Act for Corporation

The general rule remains that, in the absence of authority from the board of directors, no person, not even its officers, can validly bind a corporation. If a corporation, however, consciously lets one of its officers, or any other agent, to act within the scope of an apparent authority, it will be estopped from denying such officer’s authority. (Westmont v. Inland, G.R. No. 123650, March 23, 2009)