DBPS Law Firm

DBPS Law Firm Law Practice. Litigation (Civil, Criminal, Administrative, Election, and Labor Cases), Corporate, Business Law

24/02/2026

The (SC) has affirmed the authority of the National Labor Relations Commission (NLRC) to execute the terms of a Collective Bargaining Agreement (CBA) in cases involving unfair labor practices (ULP).

In a Decision written by Associate Justice Japar B. Dimaampao, the SC’s Third Division upheld the NLRC’s order directing Guagua National Colleges (GNC) to pay its employees the agreed economic benefits, but adjusted how those benefits were computed.

The case arose from negotiations in 2009 to renew the five-year CBA between GNC and its unions. Although GNC agreed to provide benefits such as a rice subsidy, loyalty pay, and clothing allowance, it continued to delay signing the draft CBA. Frustrated, the unions filed a notice of strike.

The NLRC ruled that GNC bargained in bad faith, which is an unfair labor practice. It also declared the final CBA draft as the parties’ agreement. NLRC ordered GNC to pay its employees the agreed benefits covering 2009 up to the present date, which at that time was 2017.

GNC questioned the order directing them to pay, arguing that only voluntary arbitrators—not the NLRC—had the power to enforce the CBA terms.

Upholding the authority of the NLRC, the SC clarified that while voluntary arbitrators generally handle CBA implementation, the Labor Code authorizes the NLRC to enforce CBA provisions when gross violations amounting to ULP are involved.

The SC said that in this case, it was the NLRC which was best positioned to enforce the CBA, having reviewed it. Sending the case to voluntary arbitrators for implementation would only cause delays, increase the likelihood of multiple lawsuits, and prolong the resolution of rights and obligations between the parties.

However, the SC ruled that the computation of benefits was incorrect. It held that the computation should exclude the signing bonus and cover only the five-year CBA term, or the years 2009 to 2014.

Read the full text of the Press Release at https://tinyurl.com/3j53bt6j.

Read the full text of the Decision at https://tinyurl.com/yc46kjar.

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

24/02/2026

The (SC) has ruled that a Special Power of Attorney (SPA) automatically ceases upon the death of the person who granted it, and any acts carried out by the agent afterwards are void, unless covered by narrow exceptions under the law.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division held that Jessica Alova Uberas lost her authority under the SPA to act on behalf of her father, Meliton Alova, upon his death in 1998.

In 1998, Meliton executed an SPA in favor of Jessica over the subject conjugal property. He died later that year. Despite the death of his father, Jessica still used the same SPA in 2003 to execute a mortgage over the said property in favor of San Miguel Foods, Inc. (SMFI) to secure her loan from the company. Jessica failed to pay the loan and the property was foreclosed where SMFI emerged as the winning bidder.

Felicidad Alova and Decelyn Alova Pution, the widow and other daughter of Meliton, filed a case to nullify the mortgage and the foreclosure sale.

Both the Regional Trial Court (RTC) and the Court of Appeals (CA) determined that Meliton’s death ended the agency. However, the RTC found that because the SPA had the conformity of Felicidad, Meliton’s wife, the mortgage was valid on her ½ share of the conjugal property. On the other hand, the CA declared the mortgage invalid, citing that it was not executed on behalf of Spouses Meliton and Felicidad.

SMFI appealed to the SC, which partly ruled in its favor. The Court upheld the agency’s termination but validated the mortgage and foreclosure sale with respect to Jessica’s undivided share in the property.

The SC explained that under an SPA, which is a contract of agency, a principal authorizes an agent to act on his or her behalf in transactions with third persons. Agency is personal, representative, and derivative, and it ends upon the death of either the principal or the agent.

Any act by the agent after the principal’s death is void, unless it falls under two Civil Code exceptions: (1) when the agency was for the parties’ common interest, and (2) when the agent, unaware of the death or agency’s end, contracted with a third party in good faith.

In this case, there was no showing that these exceptions were applicable. Jessica was fully aware of her father’s death, and the SPA was not made for their mutual benefit.

The SC also reiterated that for an agent’s act to bind the principal, the deed must clearly be made, signed, and sealed in the principal’s name.

Here, although Jessica was described in the beginning of the deed as Meliton’s attorney-in-fact, the mortgage was signed by Jessica in her personal capacity, as it was neither executed nor sealed in Meliton’s name, and without indication that she was acting as attorney-in-fact.

The Court also ruled that Meliton’s wife, Felicidad, was not bound as a principal under the SPA, as she only provided her marital conformity.

However, the Court clarified that the mortgage and foreclosure sale were not entirely void. Jessica automatically became a co-owner of the property after her father’s death. When she signed the mortgage, she encumbered her share in the property to secure her obligation to SMFI. Therefore, the mortgage and foreclosure sale were valid only for Jessica’s share.

The Court remanded the case to the RTC to determine Jessica’s share in the subject property and to annotate the shares of Meliton’s other heirs, and that of SMFI which acquired Jessica’s interest.

Read the full text of the press release at https://tinyurl.com/27t9k6vy

Read the full text of the Decision at https://sc.judiciary.gov.ph/260071-san-miguel-foods-inc-vs-felicidad-d-alova-and-decelyn-alova-pution/

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

24/02/2026

The (SC) has reiterated the rules in determining the appropriate legal actions for recovery of possession and/or ownership of land and the corresponding prescriptive periods in filing them. These remedies are: 𝙖𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or ejectment, 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖, and 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

In a Decision written by Associate Justice Ricardo R. Rosario, the SC 𝙀𝙣 𝘽𝙖𝙣𝙘 held that Lea Victa-Espinosa (Espinosa) correctly filed an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 to recover possession of her land within a year from dispossession. It explained that 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 may be filed not only when the dispossession lasted for a year but also when it lasted for a year or less when there is no allegation that the deprivation is by force, intimidation, threat, strategy, or stealth.

The SC also ruled that Espinosa’s action is not 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 as she did not seek in her complaint the recovery of ownership of the land.

After purchasing the property, Espinosa found that Spouses Noel and Leny Agullo were occupying a part of it. When they refused to leave despite her demand, Espinosa filed a complaint for recovery of possession in the Regional Trial Court (RTC).

The RTC dismissed the complaint for being filed too early. It explained that Espinosa may still file forcible entry, an ejectment suit, within one year from the time she learned of the deprivation of physical possession of the land. Since an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 can only be filed after that one-year period, RTC ruled that her complaint was premature.

The Court of Appeals reversed the RTC’s decision, finding that Espinosa’s complaint was not an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 but an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖, as she sought to recover possession based on her ownership of the property.

In their Petition before the SC, Spouses Agullo sought to reinstate the ruling of the RTC dismissing the case and insisted that Espinosa’s case was an 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 that was filed prematurely, as less than a year had passed since the alleged dispossession.

The Court denied the Petition but clarified that the action is not accion reivindicatoria but accion publiciana. It reiterated the actions available for recovery of possession and/or ownership of land:

• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or a summary ejectment case;
• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖; and
• 𝘼𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙞𝙣𝙩𝙚𝙧𝙙𝙞𝙘𝙩𝙖𝙡 or summary ejectment proceeding is filed to recover physical possession of land when the dispossession was due to force, intimidation, threat, strategy, or stealth and has not lasted for more than a year.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 is filed when the dispossession lasted for more than a year, or even for a year or less, if it is not due to force, intimidation, or similar means.

𝘼𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 is filed to recover both ownership and possession based on that ownership.

The Court explained that in 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖, the issue is who has the better right to possess the land, without necessarily claiming ownership. In contrast, 𝙖𝙘𝙘𝙞𝙤𝙣 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖 involves determining who owns the land, with possession granted to the rightful owner.

As what is sought in the complaint is recovery of possession and not ownership, and there is no allegation that Spouses Agullo disputed Espinosa’s title, the action is 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 and not 𝙧𝙚𝙞𝙫𝙞𝙣𝙙𝙞𝙘𝙖𝙩𝙤𝙧𝙞𝙖.

The Court also held that contrary to the findings of the RTC, the action was not premature, because 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖 may be filed even within one year from dispossession if no force, intimidation, threat, strategy, or stealth was used. Since Espinosa did not claim that Spouses Agullo used any of these means, the action was correctly filed not as ejectment suit but 𝙖𝙘𝙘𝙞𝙤𝙣 𝙥𝙪𝙗𝙡𝙞𝙘𝙞𝙖𝙣𝙖.

The SC thus ordered the RTC to proceed to trial and decide the case.

Read the full text of the press release at https://tinyurl.com/y7nr9hzx

Read the full text of the Decision at https://tinyurl.com/38e2xzfa

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

24/02/2026

The (SC) has ruled that a public institution must vacate the land it occupies if it lacks permission from the rightful owner and the owner has a better right of possession.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division ordered the Department of Education (DepEd) to vacate and return a parcel of land to its owner, Princess Joama Marcosa A. Caleda (Caleda).

In 2014, Caleda bought a 10,637 square meter rice land in Cagayan through an Extrajudicial Settlement of Estate with Waiver of Rights and Sale signed by the heirs of the registered owner, Bueno Gallebo (Gallebo).

However, when Caleda later visited the land for a relocation survey, she discovered that it was being occupied by the Solana Fresh Water Fishery School (the School), a public institution under DepEd Regional Office 2.

Caleda sent several demand letters for DepEd to vacate the land, but received no reply. She then filed a case to recover possession of the land and remove any structures built on it.

DepEd argued that government agencies cannot be evicted from land already used for public purposes. It claimed it had the right to take over the property through its power of eminent domain, and that Caleda’s only remedy was to ask for just compensation.

Ruling in favor of Caleda, the SC found that the latter had clearly proven her better right to the property. Her land title was valid and accurately described the land, unlike the School’s deed of sale, which referred to an adjacent lot.

The SC emphasized that while the government can take private property for public use through its power of eminent domain, this must be done through proper legal proceedings and with payment of just compensation. Because no expropriation process was initiated in this case, the School could not retain the land simply by offering to pay for it.

The SC also clarified that a public institution can only prevent eviction if the property owner fails to assert their rights in time, which is considered an implied acceptance.

In this case, Caleda acted quickly—sending demand letters, talking to DepEd, registering her claims, and filing a case within two years of discovering the School’s occupation of the property.

Read the full text of the Press Release at https://tinyurl.com/y35skjpf.

Read the full text of the Decision at https://tinyurl.com/58ja5trh.

24/02/2026

The (SC) has clarified that disputes involving condominium contracts should be decided by the Human Settlements Adjudication Commission (HSAC), formerly the Housing and Land Use Regulatory Board (HLURB), and not the Regional Trial Court (RTC).

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division nullified the RTC’s ruling that held Vivien M. Cadungog (Cadungog) and Sung Ha Jung (Sung) civilly liable to each other over a contract to sell involving a condominium unit.

Under the contract, Cadungog, a developer of a condominium building in Cebu City, agreed to deliver a unit to Sung once he completed payment of PHP 3.5 million. Sung paid a PHP 175,000 downpayment, and later PHP 3 million, leaving a balance of PHP 258,950. Because of the unpaid amount, Cadungog refused to deliver the unit.

Sung then filed a criminal complaint before the RTC against Cadungog, citing a violation of Presidential Decree No. (PD) 957 or the 𝘚𝘶𝘣𝘥𝘪𝘷𝘪𝘴𝘪𝘰𝘯 𝘢𝘯𝘥 𝘊𝘰𝘯𝘥𝘰𝘮𝘪𝘯𝘪𝘶𝘮 𝘉𝘶𝘺𝘦𝘳𝘴’ 𝘗𝘳𝘰𝘵𝘦𝘤𝘵𝘪𝘷𝘦 𝘋𝘦𝘤𝘳𝘦𝘦.

The RTC acquitted Cadungog, but ordered her to either: deliver the unit upon full payment of the purchase price, or return the amount Sung had already paid. Cadungog argued that it was the HLURB and not the RTC which had jurisdiction over the civil aspect of her case.

Ruling in Cadungog’s favor, the SC declared as null and void the RTC’s decision on the civil matter of the case.

It explained that while civil liability can be decided in a criminal case, this does not apply when the liability arises from a contract, as in this case.

The SC emphasized that the civil dispute between Cadungog and Sung stemmed from their contract to sell.

Further, under PD 957, as amended, the HLURB (now reconstituted as the HSAC) has exclusive jurisdiction over cases involving contractual and legal obligations between buyers and developers of real estate projects. At the time Sung filed the complaint, it was the HLURB that had authority over such cases.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=151440.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=151432.

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

Address

Olongapo
2200

Opening Hours

Monday 9am - 6pm
Tuesday 9am - 6pm
Wednesday 9am - 6pm
Thursday 9am - 6pm
Friday 9am - 6pm

Website

Alerts

Be the first to know and let us send you an email when DBPS Law Firm posts news and promotions. Your email address will not be used for any other purpose, and you can unsubscribe at any time.

Contact The Practice

Send a message to DBPS Law Firm:

Shortcuts

Share

Category