ORIENT INSURANCE COMPANY, petitioner,

vs.
E. P. REVILLA, Judge of First Instance of Manila, and TEAL MOTOR CO., INC., r
The respondent Teal Motor Co., Inc. is plaintiff in a civil action instituted in the Court of First Instance of Manila (civil
case No. 35825) for the purpose of recovering upon two fire insurance policies issued by the Orient Insurance
Company, aggregating P60,000, upon a stock of merchandise alleged to be of the value of P414,513.56, which, with
the exception of salvage valued at about P50,000, was destroyed by a fire on or about January 6, 1929. In one of the
clauses of the policies sued upon is a stipulation to the effect that all benefit under the policy would be forfeited if, in
case of loss, the claim should be rejected by the insurer and action or suit should not be commenced within three
months after such rejection. In the answer of the Orient Insurance Company, interposed in the civil case mentioned, it
is alleged, by way of defense, that the company rejected the claim on April 15, 1929, that notice of such rejection was
given to the plaintiff by letter on the same day, and that suit was not instituted on the policy until August 3, 1929,
which was more than three months after the rejection of the claim.
In a replication to the answer of the defendant, containing the foregoing and other defenses, the plaintiff admitted that
the adjusters of the defendant company had, on April 15, 1929, notified the plaintiff that the Orient Insurance
Company would not pay the claim, basing refusal upon alleged incendiarism and fraud on the part of the plaintiff; and
by way of avoidance, it was alleged in the replication that, after notification of denial of liability by the insurance
company, one E. E. Elser, as representative of the company, expressly requested the plaintiff to defer judicial action
until after the following July 31, stating that three were great possibilities that an extrajudicial compromise might be
arranged in the matter; and it was further asserted, in the replication, that the plaintiff had deferred action, relying
upon this request.

Held: From the foregoing decision and other cases contained in the note referred to, we are led to the conclusion that
the attorney for the defendant in the court below was entitled to examine the whole of the letter (Exhibit 49 and 49-A),
with a view to the introduction in evidence of such parts thereof as may be relevant to the case on trial, and the
respondent judge was in error in refusing to permit the inspection of the letter by said attorney.
It is suggested in the argument for the respondents that the question of the admissibility in evidence of the parts of
the letter not already read into the record was prematurely raised, and that the attorney for the defendant should have
waited until it became his turn to present evidence in chief, when, as is supposed, the question could have been
properly raised. We are of the opinion, however, that if the attorney for the defendant had a right to examine the
letter, it should have been produced when he asked for it on the cross-examination of the witness who had the letter in
his possession. Besides, in the lengthy discussions between court and attorneys, occuring at different times, there was
not the slightest suggestion from the court that the parts of the letter which were held inadmissible would be admitted
at any time. Furthermore, the action of the court in quashing the subpoena duces tecum for the production of the
letter shows that the court meant to rule that the letter could not be inspected at all by the attorney for the defendant.
Objection is also here made by the attorney for the respondents to the use of the writ of mandamus for the purpose of
correcting the error which is supposed to have been committed. The situation presented is, however, one where the
herein petitioner has no other remedy. The letter which the petitioner seeks to examine has been ruled inadmissible,
as to the parts not introduced in evidence by the defendant in the court below, and the respondent judge had not
permitted the document to become a part of the record in such a way that the petitioner could take advantage of the
error upon appeal to this court. It is idle to discuss whether other remedy would be speedy or adequate when there is
no remedy at all. This court is loath, of course, to interfere in course of the trial of a case in a Court of First Instance, as
such interference might frequently prolong unduly the litigation in that court. But this case has been pending before
the respondent judge for a considerable period of time, and undoubtedly the probatory period will be necessarily
extended much longer. Under these circumstances, the action of this court in entertaining the present application will
either be conductive to the speedy determination of case, or at least will not appreciably extend the proceedings.
It goes without saying that the subject matter of the contention is of a nature which makes the use of the writ
ofmandamus appropriate, since the right from the exercise of which the petitioner is excluded is one to which it is
entitled under the law and the duty to be performed is one pertaining to the respondent judge in his official capacity.
From what has been said it follows that the writ of mandamus prayed for will be granted, and the respondent judge is
directed to permit the attorney for the defendant (petitioner here) to inspect the letter (Exhibit 49 and 49-A) with a
view to the introduction in evidence of such parts thereof as may be relevant to the issues made by the pleadings in

civil case No. 35825 and other cases which have been consolidated with it for trial. So ordered, with costs against the
respondent Teal Motor Co., Inc.

Uy Chico vs. The Union Life Assurance Society, Limited

G.R. No. L-9231 January 6, 1915

Facts:
In 1897, petitioners father died. He continued the business still in the name of his father after
buying the share of his brother in the said business. Petitioner filed a case seeking the recovery
of the proceeds of 2 insurance policies on stock of dry goods that was destroyed in a fire. These
policies were surrendered by the petitioners lawyer to the administrator of his fathers estate,
who had compromised with the defendant for of the face value of the insurance that was paid
to the court. He alleged that said policies belong to him and that he was not bound by the
compromised agreement made by the administrator. The company introduced evidence showing
that the petitioner had agreed to the settlement of the policies when his lawyer surrendered the
same to the estates administrator. Petitioner, on the witness stand had been asked if he had any
objection as to his lawyer testifying concerning the surrender of the policies to which he
negatively replied. Whereupon, the lawyer of the petitioner formally withdraw the waiver given
by the petitioner and objected to the testimony on the ground of privileged communication.

Issue:
Whether or not instruction of the client to be delivered to a third person is considered privilege

Held:
No. A similar provision is inserted in section 383, No. 4, of the same Act. It will be noted that the
evidence in question concerned the dealings of the plaintiff's attorney with a third person. Of the
very essence of the veil of secrecy which surrounds communications made between attorney and
client, is that such communications are not intended for the information of third persons or to be
acted upon by them, put of the purpose of advising the client as to his rights. It is evident that a
communication made by a client to his attorney for the express purpose of its being
communicated to a third person is essentially inconsistent with the confidential relation. When
the attorney has faithfully carried out his instructions be delivering the communication to the
third person for whom it was intended and the latter acts upon it, it cannot, by any reasoning
whatever, be classified in a legal sense as a privileged communication between the attorney and
his client. It is plain that such a communication, after reaching the party for whom it was
intended at least, is a communication between the client and a third person, and that the
attorney simply occupies the role of intermediary or agent.

PEOPLE VS. SANDIGANBAYAN

FACTS:

ON 18 MARCH 1986, ATTY. RAMIREZ AND ATTY. ABELLA, PCGG AGENTS, ISSUED A SEQUESTRATION ORDER
AGAINST THE RESTHOUS THE SOLE ISSUE PRESENTED IS WHETHER OR NOT THE MARCH 18, 1986
SEQUESTRATION ORDER AGAINST PROPERTIES OF IMELDA IN LEYTE INCLUDING THE RESTHOUSE AT OLOT.
THEIR ORDER WAS NOT SIGNED BY ANY PCGG COMMISSIONERS.

ISSUE:

IS THEIR ORDER VALID?

RULING:

NO. JUDICIAL OR QUASI-JUDICIAL POWERS MAY NOT BE DELEGATED. IN PCGG V. JUDGE PEA,[1][17] THE
COURT HELD THAT THE POWERS, FUNCTIONS AND DUTIES OF THE PCGG AMOUNT TO THE EXERCISE OF
QUASI-JUDICIAL FUNCTIONS, AND THE EXERCISE OF SUCH FUNCTIONS CANNOT BE DELEGATED BY THE
COMMISSION TO ITS REPRESENTATIVES OR SUBORDINATES OR TASK FORCES BECAUSE OF THE WELL
ESTABLISHED PRINCIPLE THAT JUDICIAL OR QUASI-JUDICIAL POWERS MAY NOT BE DELEGATED.

PETITIONER REPUBLIC ARGUES THAT MRS. MARCOS SHOULD BE DEEMED ESTOPPED FROM QUESTIONING
THE SEQUESTRATION OF HER OLOT RESTHOUSE BY HER ACTIONS IN REGARD TO THE SAME. BUT A VOID
ORDER PRODUCES NO EFFECT AND CANNOT BE VALIDATED UNDER THE DOCTRINE OF ESTOPPEL. FOR
THE SAME REASON, THE COURT CANNOT ACCEPT PETITIONERS VIEW THAT MRS. MARCOS SHOULD HAVE
FIRST SOUGHT THE LIFTING OF THE SEQUESTRATION ORDER THROUGH A MOTION TO QUASH FILED WITH
THE PCGG. BEING VOID, THE SANDIGANBAYAN HAS THE POWER TO STRIKE IT DOWN ON SIGHT.