Pari Delicto

The case under consideration comes within the exception above adverted to.  Here [De Los Santos] desires to nullify a transaction which was done in violation of the law. Ordinarily the principle of pari delicto would apply to her because her predecessor-in-interest has carried out the sale with the presumed knowledge of its illegality, but  because the subject of the transaction is a  piece of public land, public policy requires that she, as heir, be not prevented from re-acquiring it because it was given by law to her family for her home and cultivation. This is the policy  on which our homestead law is predicated.  This right cannot be waived. “It is not within the competence of any citizen to barter away what public policy by law seeks to preserve”. We are, therefore, constrained to hold that [De Los Santos] can maintain the present action it  being in furtherance of this fundamental aim of our homestead law [De los Santos v. Roman Catholic Church of Midsayap, 94 Phil. 405 (1954)].

Appeal of Criminal Case by Offended Party

The People is the real party in interest in a criminal case and only the OSG can represent the People in criminal proceedings pending in the CA or in this Court. This ruling has been repeatedly stressed in several cases and continues to be the controlling doctrine. 

While there may be rare occasions when the offended party may be allowed to pursue the criminal action on his own behalf (as when there is a denial of due process), this exceptional circumstance does not apply in the present case (Dante LA. Jimenez, etc. Vs. Hon. Edwin Sorongon, etc., et al., G.R. No. 178607. December 5, 2012).

Custody of the Law for Adjudication of Reliefs

As  a  rule,  one  who  seeks  an  affirmative  relief  is  deemed  to  have submitted  to  the  jurisdiction  of  the  court.  Filing pleadings seeking affirmative  relief  constitutes  voluntary  appearance,  and  the  consequent jurisdiction of one's person to the jurisdiction of the court.

Thus,  by  filing several motions before the RTC seeking the  dismissal of  the  criminal  case,  respondent  Alamil  voluntarily  submitted  to  the jurisdiction  of  the  RTC.  Custody of the law  is  not  required  for  the adjudication of reliefs other than an application for bail (Dante LA. Jimenez, etc. Vs. Hon. Edwin Sorongon, etc., et al., G.R. No. 178607. December 5, 2012).

Effect of Reversal of Judgment

This Court has always recognized the general rule that in appellate proceedings, the reversal of the judgment on appeal is binding only on the parties in the appealed case and does not affect or inure to the benefit of those who did not join or were not made parties to the appeal. An exception to the rule exists, however, where a judgment cannot be reversed as to the party appealing without affecting the rights of his co-debtor, or where the rights and liabilities of the parties are so interwoven and dependent on each other as to be inseparable, in which case a reversal as to one operates as a reversal as to all. This exception, which is based on a communality of interest of said parties, is recognized in this jurisdiction. In the instant case, the rights and liabilities of Solid Builders and PNB Republic are, no doubt, intertwined and inseparable. The enforcement of the rights of Solid Builders under the contract it entered into with PNB Republic is completely dependent upon the latter's performance of its obligations thereunder. Assuming that Solid Builders' offer to purchase the disputed properties is subsequently proven to be superior to that of First Leverage, PNB Republic shall be required to proceed with its contract to sell the subject properties to Solid Builders. Thus, to allow the execution of the RTC judgment, by requiring PNB Republic to sell the questioned lots to First Leverage, without first determining with finality whether the latter's offer to buy the disputed properties is indeed superior to Solid Builders' offer would not only result in the deprivation of Solid Builders' right to due process but, more importantly, an unwarranted defeat or forfeiture of its substantive rights (First Leverage and Services Group, Inc. Vs. Solid Builders, Inc, G.R. No. 155680. July 2, 2012).

Reinstatement

Under the law and prevailing jurisprudence, an illegally dismissed employee is entitled to reinstatement as a matter of right. However, if reinstatement would only exacerbate the tension and strained relations between the parties, or where the relationship between the employer and the employee has been unduly strained by reason of their irreconcilable differences, particularly where the illegally dismissed employee held a managerial or key position in the company, it would be more prudent to order payment of separation pay instead of reinstatement (Bank of Lubao, Inc. Vs. Rommel J. Manabat, et al., G.R. No. 188722. February 1, 2012).

Appeal - Certiorari

In the present case, the Order of the RTC dismissing the complaint against respondent is a final order because it terminates the proceedings against respondent but it falls within exception (g) of the Rule since the case involves two defendants, Intermodal and herein respondent and the complaint against Intermodal is still pending. Thus, the remedy of a special civil action for certiorari availed of by petitioner before the CA was proper and the CA erred in dismissing the petition (D.M. Ferrer & Associates Corporation Vs. University of Santo Tomas, G.R. No. 189496. February 1, 2012).

Appeal from Acquittal

The state may challenge the lower court’s acquittal of the accused or the imposition of a lower penalty on the latter in the following recognized exceptions: (1) where the prosecution is deprived of a fair opportunity to prosecute and prove its case, tantamount to a deprivation of due process; (2) where there is a finding of mistrial;  or (3) where there has been a grave abuse of discretion.  (Artemio Villareal Vs. People of the Philippines/People of the Philippines Vs. The Honorable Court of Appeals, et al./Fidelito Dizon Vs. People of the Philippines/Gerarda H. Villa Vs. Manuel Lorenzo Escalona II, et al., G.R. No. 151258/G.R. No. 154954/G.R. No. 155101/G.R. Nos. 178057 & G.R. No. 178080. February 1, 2012)