1/30/25, 8:34 AM Young Builders Corp. vs. Benson Industries, Inc.

Title
Young Builders Corp. vs. Benson Industries, Inc.

Case Decision Date

G.R. No. 198998 Jun 19, 2019

YBC sued BII for unpaid construction fees and extra works. BII countered, citing delays
and defects. Courts ruled YBC failed to authenticate key evidence, leading to dismissal
of claims.

Jur.ph - Case Digest (G.R. No. 198998)

Legal Reasoning Model

Facts:

1. Contractual Agreement:

In 1994, Young Builders Corporation (YBC) was contracted by Benson Industries,

Inc. (BII) to construct BII's commercial building in Cebu City.
YBC claimed the construction was on an "accomplishment billing basis," meaning
payment was based on the progress of the work.

2. Monetary Claims:

As of May 18, 1998, YBC alleged it had accomplished works worth Php54,022,551.39
under the main contract, of which only Php40,678,430 was paid, leaving a balance
of Php13,344,121.39.
YBC also claimed it performed extra works amounting to Php11,839,110.99,
resulting in a total collectible of Php24,832,352.38.

3. BII's Defense:

BII denied the "accomplishment billing basis" and asserted the construction was
based on a timetable, which YBC failed to meet.
BII argued that YBC delayed and abandoned the project, used defective materials,
and performed substandard work.
BII also denied YBC's claim for extra works, stating these were remedial works
necessitated by YBC's poor performance.

4. RTC Decision:

The Regional Trial Court (RTC) ruled in favor of YBC, ordering BII to pay
Php24,832,352.38 plus interest, attorney’s fees, and litigation expenses.

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1/30/25, 8:34 AM Young Builders Corp. vs. Benson Industries, Inc.

5. CA Decision:

The Court of Appeals (CA) reversed the RTC decision, finding that YBC failed to
prove its claims. The CA excluded YBC's Accomplishment Billing (Exhibit "B") as
evidence due to lack of authentication and ruled that YBC's cause of action lacked
sufficient evidence.

Issue:
1. Whether the CA erred in excluding YBC's Accomplishment Billing (Exhibit "B") as
evidence, despite BII's failure to specifically deny its genuineness under oath.
2. Whether the CA erred in holding that the letter from BII's Ernesto Dacay, Sr. (Exhibit
"F") was not duly authenticated.
3. Whether the CA erred in reversing the RTC's decision based on its findings that:
YBC's Accomplishment Billing had no probative value.
The letter from Ernesto Dacay, Sr. (Exhibit "F") was not duly authenticated.
The Certification of BII (Exhibit "E") that the building was completed was
contradicted by YBC's own evidence.

Ruling:
The Supreme Court DENIED YBC's petition, affirming the CA's decision.

1. Accomplishment Billing (Exhibit "B"):

The Court ruled that the Accomplishment Billing is not an actionable document
under the Rules of Court. It is merely evidentiary and does not require a specific
denial under oath by BII.
YBC failed to authenticate the Accomplishment Billing as required by Section 20,
Rule 132 of the Rules of Court. Without proper authentication, the document
cannot be given probative value.

2. Ernesto Dacay, Sr.'s Letter (Exhibit "F"):

The Court agreed with the CA that the letter was inadmissible due to YBC's failure
to authenticate it.

3. Certification (Exhibit "E"):

The Court upheld the CA's ruling that the Certification, being a photocopy, violated
the Best Evidence Rule. Additionally, YBC's witness admitted that the building was
not completed, contradicting the Certification.

4. Burden of Proof:

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1/30/25, 8:34 AM Young Builders Corp. vs. Benson Industries, Inc.

YBC failed to present preponderant evidence to substantiate its claims. The Court
emphasized that the plaintiff must rely on the strength of its own evidence, not the
weakness of the defendant's.

Ratio:

1. Actionable Documents:

Only documents that form the basis of a claim or defense are considered
actionable. The Accomplishment Billing, being merely evidentiary, does not qualify
as an actionable document.

2. Authentication of Private Documents:

Private documents must be authenticated by proving their due execution and

authenticity, either through the testimony of the person who executed them or by
evidence of the genuineness of the signature. YBC failed to meet this requirement.

3. Best Evidence Rule:

Secondary evidence, such as photocopies, is inadmissible unless the original

document is proven lost or unavailable without bad faith. YBC did not justify the
use of a photocopy of the Certification.

4. Burden of Proof in Civil Cases:

The plaintiff must prove its case by preponderance of evidence. YBC failed to
present sufficient evidence to establish its claims, leading to the dismissal of its
complaint.

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1/30/25, 8:35 AM Go vs. Court of Appeals

Title
Go vs. Court of Appeals

Case Decision Date

G.R. No. 244681 Mar 29, 2023

Petitioner’s registered levy on property challenged by prior unregistered sale; SC

upheld Colet’s ownership, citing proper summons and priority of vested rights.

Jur.ph - Case Digest (G.R. No. 244681)

Legal Reasoning Model

Facts:
Background of the Case:

Petitioner Vicente C. Go filed a complaint for recovery of sum of money, breach of

contract, and damages against Setcom Inc. and other defendants (collectively,
defendants) in Civil Case No. 06-115453 before the Regional Trial Court of Manila (RTC-
Manila).
The case involved a contract for the supply of radio equipment awarded by the Bangko
Sentral ng Pilipinas to Setcom. Petitioner alleged that he invested funds and agreed to
share profits with the defendants, but they reneged on the agreement and obtained
another financier.

RTC-Manila Decision:

On 15 December 2008, the RTC-Manila ruled in favor of petitioner, ordering the

defendants to return P1.7 million with 12% interest, pay moral damages of P100,000,
attorney’s fees of P100,000, and costs of the suit.
The decision became final and executory, and a writ of execution was issued. The
subject property, owned by Spouses Francisco and Ma. Teresa Bernardo, was sold at an
execution sale to petitioner for P4 million on 15 September 2011.
The Notice of Levy on Execution and Certificate of Sale were registered on the title of
the subject property on 29 April 2011 and 24 November 2011, respectively. However,
petitioner failed to consolidate his title.

Spouses Colet’s Claim:

Spouses Rafael and Rosario Colet filed a complaint for cancellation of encumbrance,
quieting of title, and damages against petitioner in Civil Case No. Q-13-72861 before the
RTC of Quezon City (RTC-QC).
They claimed to have purchased the subject property from Spouses Bernardo via a
Deed of Absolute Sale dated 9 May 2005, took possession, and received the owner’s
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1/30/25, 8:35 AM Go vs. Court of Appeals

duplicate copy of the title. However, they only discovered the encumbrances in 2012
when they attempted to register the property under their name.
Petitioner was declared in default for failing to file an answer, and the RTC-QC ruled in
favor of Spouses Colet, ordering the cancellation of the encumbrances in petitioner’s
favor.

Petitioner’s Motion and Appeal:

Petitioner filed a Motion for Reconsideration and to Admit Attached Answer, which was
denied by the RTC-QC.
He then filed a Petition for Annulment of Judgment with the Court of Appeals (CA),
arguing that the RTC-QC lacked jurisdiction due to improper service of summons and
that his registered levy on the property should prevail over Spouses Colet’s prior
unregistered sale.
The CA dismissed the petition, finding it procedurally and substantively defective.
Petitioner’s motion for reconsideration was also denied.

Issue:
1. Whether the CA erred in dismissing the Petition for Annulment of Judgment.
2. Whether the RTC-QC acquired jurisdiction over petitioner despite alleged improper
service of summons.
3. Whether petitioner’s registered levy on the property enjoys preference over Spouses
Colet’s prior unregistered sale.

Ruling:
The Supreme Court denied the petition and affirmed the CA’s Resolutions dated 28
February 2018 and 17 December 2018. The Court held that:

1. Service of Summons:

The RTC-QC properly acquired jurisdiction over petitioner. The sheriff made
diligent efforts to serve summons personally at the addresses provided by
petitioner but was unsuccessful. Service by publication was justified under the
circumstances.
Petitioner’s inconsistent addresses and failure to provide evidence of his residence
undermined his claim of improper service.

2. Priority of Interests:

Spouses Colet’s prior unregistered sale of the property in 2005 vested ownership
in them before petitioner’s levy in 2011. Under the ruling in Miranda v. Spouses
Mallari, a prior unregistered sale prevails over a subsequent registered levy if
ownership had already vested in the buyer before the levy.
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1/30/25, 8:35 AM Go vs. Court of Appeals

The Court distinguished the case from Khoo Boo Boon v. Belle Corp., where the
issue arose in the context of execution proceedings, not a direct adjudication of
ownership rights.

Ratio:

1. Jurisdiction and Service of Summons:

Proper service of summons is essential to satisfy due process. While personal

service is preferred, substituted service or service by publication may be resorted
to if personal service is impossible despite diligent efforts.
The sheriff’s attempts to serve summons at petitioner’s addresses, as indicated in
his own documents, were sufficient to justify service by publication. Petitioner’s
inconsistent addresses and lack of evidence to support his claims further
weakened his argument.

2. Priority of Interests in Property:

A prior unregistered sale prevails over a subsequent registered levy if ownership

had already vested in the buyer before the levy. This is consistent with the
principle that registration is not a mode of acquiring ownership but merely a
means of binding third parties.
The Court emphasized that the Torrens system does not diminish substantive
rights but requires courts to weigh annotations on titles against evidence of prior
ownership.

Conclusion:
The Supreme Court upheld the CA’s dismissal of the Petition for Annulment of Judgment,
ruling that the RTC-QC properly acquired jurisdiction over petitioner and that Spouses
Colet’s prior unregistered sale of the property took precedence over petitioner’s registered
levy. The Court emphasized the importance of diligent service of summons and the need to
balance the Torrens system’s reliance on registration with substantive rights of ownership.

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1/30/25, 8:36 AM Survivors of Agrichemicals in Gensan, Inc. vs. Standard Fruit Co.

Title
Survivors of Agrichemicals in Gensan, Inc. vs. Standard Fruit Co.

Case Decision Date

G.R. No. 206005 Apr 12, 2023

Workers allege health harm from DBCP exposure, sue foreign firms; Supreme Court
revives case, validates summons and cause of action, rejects prescription claims.

Jur.ph - Case Digest (G.R. No. 206005)

Legal Reasoning Model

Facts:
Parties Involved:
Petitioners: Survivors of Agrichemicals in Gensan (SAGING), Inc., its Chairperson Arturo G.
Luardo, and its members.
Respondents: Standard Fruit Company, Standard Fruit and Steamship Co., DOLE Food
Company Inc., DOLE Fresh Fruit Company, Inc., Del Monte Fresh Produce N.A. Inc., and
Del Monte Tropical Fruit Co.

Background of the Case:

The petitioners filed a complaint for damages against the respondents, alleging that the
members of SAGING suffered health issues such as cancer, sterility, and reproductive
injuries due to exposure to nematodes containing the chemical dibromochloropropane
(DBCP). The petitioners claimed that the respondents negligently manufactured,
distributed, and failed to warn about the dangers of DBCP, which was banned in the U.S. in
the 1960s.

Procedural History:

1998: Petitioners, then known as Davao Banana Plantation Workers Association of

Tiburcia, Inc., filed a complaint for damages.
2002: The Court of Appeals dismissed the complaint without prejudice due to
improper service of summons.
2009: The Supreme Court issued an Entry of Judgment, finalizing the dismissal.
2010: Petitioners refiled the complaint.
2012-2013: The Regional Trial Court dismissed the complaint, citing lack of jurisdiction
over the respondents (improper service of summons) and failure to state a cause of
action.

Issue:

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1. Whether the summonses on the foreign corporations were validly served, allowing the
trial court to acquire jurisdiction over them.
2. Whether the complaint sufficiently states a cause of action.
3. Whether the petitioners' action has prescribed or is barred by laches.

Ruling:
The Supreme Court granted the petition, reversed the trial court's orders, and remanded
the case for resolution on the merits. The Court held that:

1. The extraterritorial service of summons was valid under the amended rules, and the
trial court erred in dismissing the case for lack of jurisdiction.
2. The complaint sufficiently stated a cause of action, and the non-inclusion of the real
parties in interest in the title was a technical defect that could be resolved by amending
the complaint.
3. The action was not barred by prescription or laches, as the filing of the complaint in
1998 interrupted the prescriptive period, and the immediate refiling in 2010 showed
due diligence.

Ratio:
1. Service of Summons: The amended Rule 14, Section 12 of the Rules of Court (effective
March 14, 2011) allows extraterritorial service of summons on foreign private juridical
entities that have transacted business in the Philippines, even for actions in personam.
The petitioners sufficiently alleged that the respondents transacted business in the
Philippines by manufacturing and distributing DBCP-containing products.
2. Cause of Action: The complaint, filed by SAGING with its members, sufficiently stated a
cause of action. The non-inclusion of the members' names in the title was a technical
defect that could be corrected by amendment, in line with the objectives of justice and
judicial efficiency.
3. Prescription and Laches: The filing of the complaint in 1998 interrupted the
prescriptive period, and the refiling in 2010 was within the four-year prescriptive
period for quasi-delict. The immediate refiling also negated any claim of laches.

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1/30/25, 8:38 AM Rodriguez vs. Government of the United States of America

Title
Rodriguez vs. Government of the United States of America

Case Decision Date

G.R. No. 251830 Jun 28, 2021

A petitioner challenged her default declaration in extradition proceedings, alleging due

process violations. The Supreme Court ruled the default order void, nullifying
subsequent proceedings and remanding the case for proper adjudication on its merits.

Jur.ph - Case Digest (G.R. No. 251830)

Legal Reasoning Model

Facts:
Petition for Extradition:
In 2001, the Government of the United States of America (represented by the Philippine
Department of Justice) filed a petition for the extradition of spouses Eduardo Tolentino
Rodriguez and Imelda G. Rodriguez (petitioner) from the Philippines to the U.S. The
spouses allegedly committed several offenses in California, including presenting
fraudulent claims, grand theft, and bribery.

Failure to File an Answer:

Despite repeated orders from the Regional Trial Court (RTC) of Manila, petitioner did not
file an answer to the petition for extradition. Instead, she filed numerous motions,
including motions for deferment, clarification, and inhibition of judges.

Declaration of Default:
On November 18, 2016, the RTC allowed the U.S. Government to present evidence ex parte,
effectively declaring petitioner in default. This order was based on an oral motion made by
the U.S. Government’s counsel during a hearing, which petitioner’s counsel did not oppose.

Appeal and Certiorari:

Petitioner filed a motion to set aside the default order, which was denied. She then filed a
petition for certiorari with the Court of Appeals (CA), arguing that the default order violated
her right to due process. The CA dismissed the petition, stating it had become moot after
the RTC granted the extradition petition. Petitioner appealed to the Supreme Court.

Issue:
1. Whether the CA erred in disregarding the issue of the validity of the RTC’s order
declaring petitioner in default.
2. Whether the RTC wrongfully declared petitioner in default.
3. Whether the CA erred in affirming the RTC’s ruling granting the petition for extradition.

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1/30/25, 8:38 AM Rodriguez vs. Government of the United States of America

Ruling:
The Supreme Court ruled in favor of petitioner, reversing the CA’s decision.

1. Validity of the Default Order:

The Court held that the issue of the default order’s validity was not rendered moot by
the RTC’s extradition decision. The CA erred in failing to resolve this issue, as it directly
affected the validity of the extradition proceedings.

2. Wrongful Declaration of Default:

The RTC erred in declaring petitioner in default. The declaration was based on an oral
motion made during a hearing, which violated the Rules of Court requiring a written
motion and notice to the defending party. The RTC also improperly proceeded with the
hearing despite the unavailability of petitioner’s main counsel, violating her right to
due process.

3. Nullity of the Extradition Decision:

Since the default order was void, the subsequent ex parte proceedings and the
extradition decision were also null and void. The Court remanded the case to the RTC,
instructing it to admit petitioner’s answer and proceed with the case on its merits.

Ratio:

1. Due Process in Default Proceedings:

A party may only be declared in default upon a written motion by the claiming party,
with notice to the defending party. The court cannot motu proprio declare a party in
default. Violating these requirements constitutes a denial of due process.

2. Effect of a Void Default Order:

A void default order renders all subsequent proceedings based on it null and void. A
judgment by default predicated on a void order has no legal effect.

3. Policy Against Default Judgments:

The policy of the law is to decide cases on their merits. Default judgments are
disfavored, and courts should ensure that all parties are given a fair opportunity to
present their defenses.

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1/30/25, 8:39 AM Lafarge Cement Philippines Inc. vs. Continental Cement Corporation

Title
Lafarge Cement Philippines Inc. vs. Continental Cement Corporation

Case Decision Date

G.R. No. 155173 Nov 23, 2004

Dispute over retained funds from a cement business sale; petitioners filed
counterclaims for bad faith, alleging baseless complaint and unwarranted attachment.
RTC dismissed counterclaims, but SC reversed, ruling them compulsory and requiring
summons for new parties.

Jur.ph - Case Digest (G.R. No. 155173)

Legal Reasoning Model

Facts:
Background of the Case
The case originated from a Letter of Intent (LOI) executed on August 11, 1998, between
Petitioner Lafarge Cement Philippines, Inc. (Lafarge) and Respondent Continental Cement
Corporation (CCC). The LOI outlined Lafarge’s agreement to purchase CCC’s cement
business, formalized later in a Sale and Purchase Agreement (SPA) on October 21, 1998. A
key provision of the SPA, Clause 2(c), required the retention of P117,020,846.84 from the
purchase price to cover potential liabilities from CCC’s pending case with the Supreme
Court (GR No. 119712).

Dispute Over the Retained Amount

After the Supreme Court ruled in favor of Asset Privatization Trust (APT) in GR No. 119712,
CCC instructed Lafarge to release the retained amount to APT. However, Lafarge allegedly
refused, prompting CCC to file a "Complaint with Application for Preliminary Attachment"
on June 20, 2000, in the Regional Trial Court (RTC) of Quezon City (Civil Case No. Q-00-
41103). CCC sought to compel Lafarge to pay the retained amount and alleged bad faith on
Lafarge’s part.

Petitioners’ Counterclaims
Lafarge, Luzon Continental Land Corporation (LCLC), Continental Operating Corporation
(COC), and Philip Roseberg (petitioners) filed an Answer with Compulsory Counterclaims
ad Cautelam. They denied CCC’s allegations and counterclaimed for damages against CCC,
its majority stockholder Gregory T. Lim, and corporate secretary Anthony A. Mariano.
Petitioners alleged that Lim and Mariano acted in bad faith by filing a baseless complaint
and procuring an unwarranted writ of attachment.

Trial Court’s Decision

The RTC dismissed petitioners’ counterclaims against Lim and Mariano, ruling that:

1. The counterclaims were not compulsory.

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1/30/25, 8:39 AM Lafarge Cement Philippines Inc. vs. Continental Cement Corporation

2. The Supreme Court’s ruling in Sapugay v. Court of Appeals was inapplicable.

3. Petitioners violated procedural rules on joinder of causes of action.
Petitioners’ Motion for Reconsideration was denied, prompting the present Petition for
Review.

Issue:
1. Whether the RTC erred in ruling that CCC had no personality to move to dismiss the
counterclaims on behalf of Lim and Mariano.
2. Whether the RTC erred in ruling that:
Petitioners’ counterclaims against Lim and Mariano were not compulsory.
Sapugay v. Court of Appeals was inapplicable.
Petitioners violated the rule on joinder of causes of action.

Ruling:
The Supreme Court granted the Petition and reversed the RTC’s Orders.

1. Compulsory Counterclaims - The counterclaims against CCC, Lim, and Mariano were
deemed compulsory because they arose from the same transaction and involved the
same factual and legal issues as CCC’s complaint.

2. Joinder of Third Parties - Petitioners properly impleaded Lim and Mariano in the
counterclaims, even though they were not parties to the original complaint. The Court
applied Sapugay v. Court of Appeals, which allows the inclusion of new parties in
compulsory counterclaims when necessary for complete relief.

3. CCC’s Authority to Dismiss Counterclaims - While CCC could raise defenses applicable
to Lim and Mariano, it lacked the authority to move to dismiss the counterclaims on
their behalf.

4. Jurisdiction Over Lim and Mariano - Before the trial court could adjudicate the
counterclaims against Lim and Mariano, summons must be served on them to ensure
due process.

Ratio:

1. Compulsory Counterclaims - A counterclaim is compulsory if it arises from the same

transaction or occurrence as the opposing party’s claim, and its adjudication would
avoid multiplicity of suits. Petitioners’ counterclaims fulfilled this criterion, as they
stemmed directly from CCC’s alleged bad faith in filing the complaint and securing the
writ of attachment.

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1/30/25, 8:39 AM Lafarge Cement Philippines Inc. vs. Continental Cement Corporation

2. Inclusion of New Parties - Rule 14, Section 12 of the Rules of Court permits the
impleading of new parties in compulsory counterclaims when their presence is
necessary for complete relief. Lim and Mariano, as alleged co-tortfeasors, were
indispensable parties to the counterclaims.

3. Solidary Liability - Petitioners’ allegations of bad faith against Lim and Mariano
justified piercing the corporate veil to hold them personally liable. The Court
emphasized that solidary liability in tort claims allows a creditor to sue any or all
debtors jointly or severally.

4. Due Process - The trial court must serve summons on Lim and Mariano to acquire
jurisdiction over them. Without proper notice, the counterclaims against them cannot
proceed.

5. CCC’s Limited Authority - CCC could invoke defenses available to Lim and Mariano but
could not act on their behalf without explicit authorization.

The Supreme Court remanded the case to the RTC to proceed with the counterclaims and
ordered the service of summons on Lim and Mariano.

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