ASG Law

Tag: Philippine Civil Law

  • Co-Ownership Prevails: Ejectment Action Fails Due to Shared Property Rights

    The Supreme Court ruled that a co-owner cannot be ejected from a property in an unlawful detainer case filed by another co-owner. The Court emphasized that until a formal partition occurs, each co-owner holds rights to the entire property and can possess and enjoy it without infringing on the rights of the other co-owners. This decision underscores the principle that co-ownership grants equal rights of possession, preventing any single co-owner from unilaterally excluding another before a proper legal division.

    When Shared Land Becomes a Battleground: Can One Co-Owner Evict Another?

    The case of Fortunato Anzures v. Spouses Erlinda and Arturo Ventanilla revolves around a property dispute between co-owners. Erlinda Ventanilla and the late Carolina Anzures (Fortunato’s wife) were co-owners of a parcel of land and the residential house standing on it. After Carolina’s death, Erlinda and her spouse filed an action for unlawful detainer against Fortunato, seeking to evict him from the property based on the claim that his occupation was merely tolerated and that they now wished to partition the land. This action was initially granted by the Municipal Trial Court (MTC) and affirmed by the Regional Trial Court (RTC) before being appealed to the Court of Appeals (CA). The CA upheld the lower courts’ decisions, prompting Fortunato to elevate the case to the Supreme Court. At the heart of the legal battle lies the question: Can one co-owner successfully bring an action for unlawful detainer against another co-owner?

    The Supreme Court reversed the CA’s decision, holding that Erlinda and Arturo Ventanilla did not have a cause of action to eject Fortunato Anzures from the property. The Court emphasized that since Fortunato, as an heir of Carolina, was also a co-owner, he was entitled to possess and enjoy the property. This ruling is grounded in the fundamental principles of co-ownership under Philippine civil law. As stated in the decision:

    In a co-ownership, the undivided thing or right belong to different persons, with each of them holding the property pro indiviso and exercising [his] rights over the whole property. Each co­owner may use and enjoy the property with no other limitation than that he shall not injure the interests of his co-owners.

    The Court highlighted that until a formal partition of the property occurs, no co-owner can claim exclusive ownership or possession. Each co-owner has the right to use and enjoy the entire property, provided they do not harm the interests of the other co-owners. This is a critical aspect of co-ownership, ensuring that all parties have equal rights and responsibilities regarding the shared property.

    Building on this principle, the Court examined the evidence presented by both parties to determine the nature of their ownership. The documents revealed a series of transactions, including waivers of rights, deeds of sale, and a deed of donation, which collectively established that Erlinda and Carolina were indeed co-owners of both the land and the house. The Court found that the initial intent of the original owners was to transfer the property, including any improvements, to both Erlinda and Carolina. The Supreme Court noted that respondents cannot claim sole ownership over the house by virtue of an extrajudicial settlement of estate with waiver of rights because the parties waiving their rights no longer had the authority to do so. The Court stated:

    No one can give what one does not have (Nemo dat quod non habet).

    Furthermore, the Court addressed the respondents’ claim that Fortunato’s occupation was based on their tolerance, which is a typical ground for unlawful detainer actions. However, the Court rejected this argument, stating that since Fortunato was also a co-owner, his possession was not merely based on tolerance but on his inherent right as a co-owner to possess and enjoy the property. This distinction is crucial because it clarifies that the legal basis for possession significantly impacts the outcome of an ejectment case.

    This approach contrasts with typical unlawful detainer cases, where the defendant’s right to possess the property has expired or been terminated. In such cases, the plaintiff must prove that the defendant’s initial possession was lawful but subsequently became unlawful due to the expiration of a lease, non-payment of rent, or other breach of contract. However, in cases involving co-ownership, the analysis shifts to determining the rights of each co-owner and whether one co-owner’s actions infringe upon the rights of the others.

    In light of its findings, the Supreme Court suggested that the proper remedy for Erlinda and Arturo Ventanilla was not an action for unlawful detainer but an action for partition. Partition is a legal process by which co-owners can divide the property, either physically or through sale, to terminate the co-ownership. Article 494 of the New Civil Code explicitly states that no co-owner is obliged to remain in the co-ownership, and each may demand partition at any time.

    No co-owner shall be obliged to remain in the co-ownership. Each co-owner may demand at any time the partition of the thing owned in common, insofar as his share is concerned.

    The decision serves as a reminder that the rights and obligations of co-owners are distinct from those of landlords and tenants or other parties with limited possessory rights. It reinforces the principle that co-ownership entails shared rights to possession and enjoyment, and that unilateral actions to exclude another co-owner are generally not permissible without a formal partition or other legal agreement.

    From a practical standpoint, the Court’s ruling underscores the importance of understanding the nature of property ownership before pursuing legal action. In cases involving co-ownership, parties should carefully consider their rights and responsibilities and explore remedies that are consistent with the principles of co-ownership, such as partition or agreements on property use and management.

    FAQs

    What was the key issue in this case? The key issue was whether one co-owner could file an action for unlawful detainer to eject another co-owner from a property they jointly own. The Supreme Court ruled that such an action is not appropriate in cases of co-ownership.
    What is unlawful detainer? Unlawful detainer is a legal action to recover possession of a property from someone who initially had lawful possession but whose right to possess has expired or been terminated. Typically, this applies to cases involving leases or other contractual agreements.
    What is co-ownership? Co-ownership exists when two or more persons own the same property. Each co-owner has rights to the entire property, and their ownership is undivided until the property is partitioned.
    Why did the Supreme Court rule against the ejectment? The Court ruled against the ejectment because Fortunato Anzures, as an heir of a co-owner, also had a right to possess the property. His possession was not merely based on tolerance but on his right as a co-owner.
    What remedy should the respondents have pursued? The proper remedy for the respondents was an action for partition. This legal process divides the property among the co-owners, either physically or through the sale of the property and division of the proceeds.
    What does Nemo dat quod non habet mean? Nemo dat quod non habet is a Latin legal principle meaning “no one can give what one does not have.” In this context, it means that Filomena and Rosalina could not waive rights to the house in favor of Erlinda because they no longer owned it.
    What is the significance of a deed of donation in this case? The deed of donation executed by Carolina in favor of Erlinda was an acknowledgment of their co-ownership. The Court recognized the validity of the deed in solidifying the co-ownership between the parties.
    Can a co-owner be forced to remain in co-ownership? No, Article 494 of the New Civil Code states that no co-owner is obliged to remain in the co-ownership. Each co-owner has the right to demand partition of the property at any time.

    In conclusion, the Supreme Court’s decision in Fortunato Anzures v. Spouses Erlinda and Arturo Ventanilla clarifies the rights and remedies available to co-owners in property disputes. It reinforces the principle that co-ownership grants equal rights of possession and enjoyment, and that an action for unlawful detainer is not the appropriate remedy for resolving disputes among co-owners. The correct course of action is typically partition.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Anzures vs. Ventanilla, G.R. No. 222297, July 9, 2018

  • Registered Vehicle Owners Bear Primary Liability: Protecting Victims of Negligence

    This case underscores the principle that the registered owner of a vehicle is primarily liable for damages caused by its operation, even if the vehicle has been sold but the registration not transferred. The Supreme Court affirmed the decision holding the registered owner responsible for injuries sustained by a pedestrian due to the negligent driving of the vehicle, emphasizing the importance of vehicle registration in protecting the public and ensuring accountability.

    Roadside Tragedy: Who Pays When Negligence Cripples?

    In Davao City, a tragic incident altered the life of Bithuel Macas, a 15-year-old student. While standing on the shoulder of the road, Macas was struck and run over by a Ford Fiera driven by Chona Cimafranca. The accident resulted in severe injuries, ultimately leading to the amputation of both of Macas’ legs. Cimafranca disappeared after the incident, leaving Macas with life-altering disabilities. The vehicle was registered under the name of Medardo Ag. Cadiente. Cadiente argued that he had already sold the vehicle to Rogelio Jalipa before the accident occurred. This defense was tested in court to determine liability for the damages caused to Macas. The core legal question was whether Cadiente, as the registered owner, could be held responsible despite the alleged sale.

    The Regional Trial Court (RTC) initially found Cadiente and Jalipa jointly and severally liable for damages. The Court of Appeals (CA) affirmed this decision, prompting Cadiente to elevate the matter to the Supreme Court (SC). Cadiente contended that Macas’ own negligence contributed to the accident, and also that the CA erred in holding him jointly and severally liable with Jalipa, to whom he claimed to have sold the vehicle. This argument stemmed from the principle of contributory negligence. Contributory negligence, under Article 2179 of the Civil Code, allows a plaintiff to recover damages, but the courts mitigate the damages awarded if the plaintiff’s negligence contributed to the injury.

    However, the SC dismissed Cadiente’s arguments. The Court emphasized that Macas was standing on the shoulder of the road, a space designated for pedestrian use. The Ford Fiera had inexplicably swerved from the cemented road to the shoulder, striking Macas. The Court noted that Cimafranca was solely responsible. It determined that Macas could not have foreseen the vehicle’s erratic movement, which dispelled any notion of negligence on Macas’ part. The Supreme Court underscored the significance of vehicle registration in cases of accidents, referencing its prior ruling in PCI Leasing and Finance, Inc. v. UCPB General Insurance Co., Inc., the court stated:

    …Were a registered owner allowed to evade responsibility by proving who the supposed transferee or owner is, it would be easy for him, by collusion with others or otherwise, to escape said responsibility and transfer the same to an indefinite person, or to one who possesses no property with which to respond financially for the damage or injury done. A victim of recklessness on the public highways is usually without means to discover or identify the person actually causing the injury or damage.

    The Court reiterated that the registered owner of a vehicle remains primarily responsible to the public for any damages or injuries the vehicle may cause. The policy of vehicle registration ensures easy identification of the owner, who can be held accountable in case of an accident, damage, or injury caused by the vehicle.

    Since the Ford Fiera was still registered under Cadiente’s name, the Supreme Court concluded that he could not evade liability for the severe and permanent injuries inflicted upon Macas. The ruling served to affirm the lower courts’ decisions and reinforce the importance of the principle that a registered owner remains accountable for the vehicle’s actions. The findings from the decision by the appellate court:

    WHEREFORE, premises considered, the instant appeal is DENIED and the decision of the Regional Trial Court of Davao City in Civil Case No. 23723-95 is hereby AFFIRME D.

    SO ORDERED.

    FAQs

    What was the key issue in this case? The key issue was whether the registered owner of a vehicle could be held liable for damages caused by the vehicle, even if the vehicle had been sold but the registration had not been transferred.
    Was the victim found to be contributorily negligent? No, the Supreme Court found that the victim was not contributorily negligent, as he was standing on the shoulder of the road, a designated area for pedestrians, when he was struck by the vehicle.
    What is the significance of vehicle registration in this case? The vehicle registration is significant because it helps to easily identify the owner who can be held responsible for damages or injuries caused by the vehicle, ensuring accountability and protecting the public.
    What does ‘jointly and severally liable’ mean? ‘Jointly and severally liable’ means that each party is independently liable for the full amount of the damages, and the plaintiff can recover the entire amount from either party or both.
    Why was the registered owner held liable despite claiming to have sold the vehicle? The registered owner was held liable because the vehicle was still registered under his name at the time of the accident, making him primarily responsible to the public for any damages caused by the vehicle.
    What legal principle does this case highlight? This case highlights the principle that the registered owner of a vehicle bears primary responsibility for damages caused by its operation, emphasizing the importance of maintaining accurate vehicle registration records.
    How did the court address the issue of a third-party defendant? The court affirmed the decision of the lower courts, holding the registered owner liable despite the existence of a third-party defendant to whom the vehicle was allegedly sold.
    What was the final decision of the Supreme Court? The Supreme Court denied the petition, affirming the decision of the Court of Appeals, which held the registered owner liable for damages to the victim.

    This case reaffirms the responsibility of registered vehicle owners, emphasizing the need to ensure proper transfer of vehicle registration to avoid liability. This ruling has significant implications for anyone selling a vehicle, as it underscores the legal requirement to complete the transfer of ownership to prevent future legal ramifications.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Medardo Ag. Cadiente v. Bithuel Macas, G.R. No. 161946, November 14, 2008

  • Co-ownership Rights: Defining Boundaries in Shared Property Disputes

    In Engreso v. De la Cruz, the Supreme Court clarified the rights of co-owners in jointly held properties, particularly concerning physical possession and division. The court affirmed that while a co-owner has the right to their ideal share of the entire property, they cannot claim a specific portion until formal partition. This means a co-owner cannot exclude another co-owner from any specific part of the property before the co-ownership is legally dissolved.

    Dividing Lines: Can a Co-Owner Claim Exclusive Possession Before Partition?

    This case arose from a dispute between two sisters, Hermogena Engreso and Nestoria de la Cruz, over a parcel of land and the residential/commercial building standing thereon. Nestoria claimed ownership of one-half of the property based on a deed of sale from Hermogena. The trial court initially sided with Nestoria, ordering Hermogena to deliver possession of half the property and half the building. However, the Supreme Court, while affirming Nestoria’s co-ownership, modified the decision regarding the building. The central legal question was whether a co-owner could demand possession of a specific portion of a jointly owned structure before the formal partition of the property.

    The Supreme Court grounded its decision on the fundamental principles of co-ownership under Philippine civil law. The Court emphasized that before a property owned in common is actually partitioned, each co-owner possesses only an **ideal or abstract quota or proportionate share in the entire property**. Building on this principle, the Court clarified that a co-owner cannot demand a concrete, specific, or determinate part of the thing owned in common because until division is effected, their right over the thing is represented only by an ideal portion.

    A co-owner has no right to demand a concrete, specific or determinate part of the thing owned in common because until division is effected his right over the thing is represented only by an ideal portion.

    Furthermore, the Court explained the implications of a co-owner bringing an action against another co-owner. Such an action can only lead to the recognition of the co-ownership itself. This approach contrasts with actions seeking exclusive possession or control over a specific part of the property. As a co-owner has a right to possess the shared property, the plaintiff cannot recover any material or determinate part of the property.

    In this case, although Nestoria was indeed the sole owner of a specified portion of the land, she was only a co-owner of the structure standing thereon. The building had been constructed by the sisters’ deceased father, Romeo Gallejoma. This fact introduces succession law into the matter, creating a dynamic relationship between property rights and inheritance rights.

    Following the rules on succession, and absent any proof that Romeo’s estate had been judicially or extrajudicially partitioned, all of his surviving heirs inherited rights to the building at the moment of his death. Leon Gallejoma’s testimony should not prejudice and bind the other heirs who have not relinquished their rights over the aforesaid building.

    The ruling further clarified that Hermogena’s mortgage of the entire property only affected her share, leaving Nestoria’s and the other heirs’ shares unaffected. This underscores the importance of understanding the derivative nature of property rights in co-ownership situations. The Court effectively separated ownership of the land from the building, recognizing Nestoria’s distinct rights to the land and her shared rights to the building.

    FAQs

    What was the key issue in this case? The key issue was whether a co-owner could demand exclusive possession of a specific portion of a jointly-owned property before the property had been formally partitioned.
    What is an ‘ideal share’ in co-ownership? An ideal share refers to a co-owner’s proportionate interest in the entire property, which is abstract until the property is divided. This share does not correspond to a specific physical part of the property.
    Can a co-owner exclude another co-owner from any part of the property? No, a co-owner cannot exclude another co-owner from any specific portion of the property before partition, as each has the right to possess the whole property.
    What happens if a co-owned property is mortgaged by one co-owner? If one co-owner mortgages the property, the mortgage only affects their share and does not bind the other co-owners.
    How does inheritance affect co-ownership rights? When a property is inherited, all heirs become co-owners with rights to the property from the moment of the decedent’s death, absent a formal partition.
    What action can a co-owner bring against another co-owner? A co-owner can bring an action to recognize the co-ownership but cannot claim a specific portion of the property in such an action.
    What happens after a property is partitioned? After partition, each former co-owner becomes the exclusive owner of their specific, allocated portion of the property.
    Did the court uphold the validity of the deed of sale in this case? Yes, the court upheld the validity of the deed of sale, confirming Nestoria’s ownership of the land, but clarified her rights regarding the building.

    This decision underscores the importance of formalizing property divisions and understanding the limitations of co-ownership rights. Clear legal action is required to dissolve co-ownership and give individuals defined ownership of physical property.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Engreso v. De la Cruz, G.R No. 148727, April 09, 2003

  • Conditional Donations: Upholding Intent Despite Technicalities in Philippine Law

    In Republic of the Philippines vs. Leon Silim and Ildefonsa Mangubat, the Supreme Court addressed the validity of a conditional donation of land for school purposes. The court ruled that the donation remained valid even though the original land was exchanged for a larger lot, as the core condition of using the property for educational purposes was still met. This decision underscores the importance of upholding the donor’s intent and the substance of the agreement over strict adherence to formal requirements, especially when the overall purpose of the donation is maintained and enhanced.

    From Donated Land to School Expansion: When Does an Exchange Void a Conditional Gift?

    The case revolves around a donation made by Spouses Leon Silim and Ildefonsa Mangubat to the Bureau of Public Schools (BPS) in Malangas, Zamboanga del Sur. The donation was conditional: the 5,600 square meter parcel of land was to be used “exclusively and forever for school purposes only.” A school building was erected on the land through the efforts of the Parent-Teachers Association. However, due to a government requirement for a one-hectare lot for a new school building project, the donated land was exchanged for a larger lot owned by Teresita Palma. This exchange led to the construction of the new school building on the larger site, but it also triggered a legal challenge when Vice-Mayor Wilfredo Palma began constructing a house on the original donated land.

    The respondents, Spouses Silim, filed a complaint seeking the revocation of the donation, arguing that the exchange violated the condition stipulated in the Deed of Donation. The Regional Trial Court initially dismissed the complaint, finding no breach of the condition since the exchange still served the purpose of expanding and improving school facilities. However, the Court of Appeals reversed this decision, declaring the donation null and void, citing improper acceptance and violation of the condition. The Supreme Court then took up the case to determine whether the Court of Appeals erred in its ruling.

    At the heart of the matter were two key issues: the validity of the acceptance of the donation and whether the exchange of the land constituted a violation of the condition imposed in the donation. The Supreme Court approached these issues by examining the nature of the donation itself. The Court emphasized that the donation was an onerous one, since it required the donee (BPS) to build a school on the donated property. In this context, the Court referred to Article 733 of the New Civil Code:

    Art. 733. Donations with an onerous cause shall be governed by the rules on contracts, and remuneratory donations by the provisions of the present Title as regards that portion which exceeds the value of the burden imposed.

    This provision is significant because it means that onerous donations are primarily governed by the law on contracts, not solely by the law on donations. This distinction is crucial, as it allows for a more flexible interpretation of the terms and conditions attached to the donation, focusing on the intent of the parties rather than strict adherence to donation formalities.

    Regarding the acceptance of the donation, the Court addressed the Court of Appeals’ finding that the acceptance by the BPS District Supervisor was invalid due to the lack of a special power of attorney from the Republic of the Philippines. The Supreme Court disagreed, citing Section 47 of the 1987 Administrative Code, which authorizes government branches and agencies to execute contracts and conveyances when necessary for the service, as long as it’s not prohibited by law. This effectively validated the acceptance made by the District Supervisor, as he was acting within the scope of his authority to facilitate the educational objectives of the BPS.

    Furthermore, the Court emphasized that the respondents were aware of the construction of the school building on the donated land shortly after the donation. This actual knowledge fulfilled the legal requirement that the acceptance of the donation be communicated to the donor. The Supreme Court cited Pajarillo vs. Intermediate Appellate Court to support its view, emphasizing that the purpose of requiring formal acceptance is to ensure communication to the donor. Because the donors clearly knew the school was built, any missing notation was a mere technicality.

    There is no question that the donation was accepted in a separate public instrument and that it was duly communicated to the donors… The purpose of the formal requirement is to insure that the acceptance of the donation is duly communicated to the donor.

    The most critical aspect of the case, however, was the interpretation of the condition that the land be “exclusively used for school purposes.” The respondents argued, and the Court of Appeals agreed, that the exchange of the land violated this condition. However, the Supreme Court took a broader view. The Court defined “school,” “purpose,” and “exclusive” to demonstrate that the exchange did not, in fact, violate the condition. The core purpose of the donation remained the establishment of a school, and the exchange only enhanced that purpose by providing a larger and more suitable site for the school building.

    The Court held that the term “exclusively used for school purposes” should not be interpreted narrowly to defeat the donor’s primary intention. Instead, it should be understood as maintaining the land’s dedication to educational activities. The exchange of the land for a bigger one did not alter or affect this exclusivity; it simply facilitated the fulfillment of the intended purpose on a larger scale. This interpretation aligns with the principle that contracts, including onerous donations, should be construed to give effect to the parties’ intentions.

    To further illustrate the importance of intent, consider the following contrasting views:

    Viewpoint Argument
    Respondents The condition was strictly violated when the specific piece of land was no longer used for a school; the exchange invalidated the donation.
    Supreme Court The condition was substantially complied with because the overarching purpose of establishing a school was maintained and enhanced through the exchange.

    This case emphasizes the importance of the donor’s intent in conditional donations. It serves as a reminder that courts will look beyond the literal wording of a condition to determine whether its underlying purpose has been fulfilled. In cases where the condition is substantially complied with, and the donor’s primary intention is achieved, the donation will generally be upheld.

    Ultimately, the Supreme Court reversed the Court of Appeals’ decision and reinstated the Regional Trial Court’s ruling, upholding the validity of the donation. This decision reflects a practical and equitable approach, prioritizing the fulfillment of the donor’s intended purpose over strict adherence to technical formalities.

    FAQs

    What was the key issue in this case? The key issue was whether the exchange of donated land for a larger lot violated the condition that the land be used exclusively for school purposes, thus invalidating the donation.
    What is a conditional or onerous donation? A conditional or onerous donation is one where the donor imposes certain conditions or obligations on the donee, with the value of the condition being less than or equal to the value of the donation. In this case, the condition was to build a school on the land.
    Why did the Court of Appeals declare the donation null and void? The Court of Appeals declared the donation null and void based on two grounds: lack of proper acceptance of the donation and violation of the condition that the donated lot be exclusively used for school purposes.
    How did the Supreme Court rule on the acceptance of the donation? The Supreme Court ruled that the donation was validly accepted, as the District Supervisor had the authority to accept the donation on behalf of the Bureau of Public Schools under the 1987 Administrative Code. The actual knowledge of the donation and construction of the school also fulfilled the formal requirement of communicating the acceptance to the donor.
    What was the Supreme Court’s interpretation of “exclusively used for school purposes”? The Supreme Court interpreted this condition as maintaining the land’s dedication to educational activities, rather than requiring that the specific piece of land donated be used perpetually. The exchange for a bigger lot was seen as furthering this purpose.
    What is the significance of Article 733 of the New Civil Code in this case? Article 733 states that onerous donations are governed by the rules on contracts, which allows for a more flexible interpretation of the donation’s terms and conditions, emphasizing the intent of the parties.
    What did the Supreme Court ultimately decide? The Supreme Court reversed the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court, upholding the validity of the donation.
    What is estoppel in the context of this case? Estoppel refers to the legal principle preventing someone from arguing something contrary to what they previously stated or implied by their actions. In this case, respondents were estopped from questioning the validity of the donation’s acceptance after a long period of time.

    The Supreme Court’s decision in Republic vs. Silim offers valuable insights into the interpretation of conditional donations in Philippine law. By prioritizing the donor’s intent and the substantial fulfillment of the donation’s purpose, the Court has provided a balanced and pragmatic approach that respects both the letter and the spirit of the law. This case serves as a guide for interpreting similar agreements, ensuring that the underlying objectives of such donations are achieved.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Republic of the Philippines, vs. Leon Silim and Ildefonsa Mangubat, G.R. No. 140487, April 02, 2001