Elena Salenillas and Bernardino Salenillas vs.

Honorable Court of Appeals and Honorable Raymundo Seva, Judge of branch 38 of the
Regional Trial Court of Camarines Norte and William Guerra
G.R. No. 78687
31 January 1989

Statutory Principle:
Between two statutory interpretations, that which better serves the purpose of the law should
prevail.

Facts:

Spouses Florencia H. de Enciso and Miguel Enciso have a property in Camarines Norte which is
issued by virtue of Free Patent Application No. 192765, under the Public land Act with Original Certificate
of Title No. P-1248. On February 28, 1970, the Enciso spouses, by an Absolute Deed of Sale, sold the
property in favor of their daughter, Elena and her husband, Bernardino Salenillas, for a consideration of
P900.00. A Transfer Certificate of Title No. T-8104 was issued in their name. On December 4, 1975, the
Sallenillas mortgaged the property in favor of the PNB-Daet Camarines Norte Branch as security for a loan
of P2,500.00. Due to the spouses failure to pay the loan, an extrajudicial foreclosure proceeding was made
for the mortgage pursuant to Act No. 3135. The property was sold at a public auction wherein private
respondent, William Guerra, emerged as the highest bidder and as a result thereof a "Certificate of Sale"
was issued to him. On November 17, 1983, in attempt to place the property in the possession of the William
Guerra, the petitioners refused to vacate and surrender the possession of the same and instead offered to
repurchase it under Section 119 of the Public Land Act. Spouses Salenillas made a formal offer to
repurchase the property notwithstanding the motion for alias writ of possession filed by William Guerra
with the Trial Court. The private respondent, on the other hand, states that the sale of the contested
property by the patentees to the Salenillas disqualified the latter from being legal heirs vis-a-vis the said
property. As such, they no longer enjoy the right granted to heirs under the provisions of Section 119 of
the Public Land Act.

Issue:
(1) Whether or not the petitioners have the right to repurchase the contested property under
Section 119 of the Public Land Act; and
(2) Assuming the answer to the question is in the affirmative, whether or not their right to
repurchase had already prescribed.
Ruling:
The Supreme Court ruled in favour of Spouses Salenillas. They are granted by the law the right to
repurchase their property and their right to do so subsists.
Under the Commonwealth Act 141 – Public Land Act, Section 119 provides: "Every conveyance of
land acquired under the free patent or homestead provisions, when proper, shall be subject to repurchase
by the applicant, his widow, or legal heirs, within the period of five years from the date of the conveyance,
regardless of its nature.” The very purpose of this legal provision is to give the homesteader or patentee
every chance to preserve for himself and his family the land that the State had gratuitously given him as a
reward for his labor in clearing and cultivating it.
On the case at hand, Elena Salenillas is legally the heir and the daughter of the Enciso’s, whom are
the original patentees. Republic Land Act, in speaking of “legal heirs”, makes no distinction. Ubi lex non
distinguit nec nos distinguere debemos. Furthermore, the two offers of the petitioners to repurchase the
property, first on November 17, 1983, and the second, formally, on August 31, 1984 were both made within
the prescribed five-year period from the time it was sold in a public auction. Hence, the prescriptive period
have not yet expired. Therefore, it is just proper to invoke the section 119 of Public Land Act as their basis
of their right to repurchase the property.
J. M. Tuason & Co., Inc., Jose M. Tuason, Nicasio A. Tuason, Teresa Tuason, Celso S. Tuason
and Severo A. Tuason vs.
Hon. Herminio C. Mariano, Presiding Judge of the Court of First Instance of Rizal, Manuela
Aquial, Maria Aquial, Spouses Jose M. Cordova and Saturnina C. Cordova
G.R. No. L-33140
23 October 1978

Statutory Principle:
Interest Rei Publicae ut finis sit lithium – In the interest of society as a whole, litigation must
come to an end.

Facts:
On October 1, 1965, Manuela Aquial and Maria Aquial filed a complaint in forma pauperis in the
Court of First Instance of Rizal Pasig Branch X, wherein they prayed that they be declared the owners of a
parcel of land located at Balara, Marikina, Rizal. They alleged that sometime in 1960, J. M. Tuason & Co.,
Inc. had fraudulently and erroneously included their land in OCT No. 735 of the Registry of Deeds of Rizal.
Plaintiffs Aquial prayed that OCT No. 735 and the titles derived therefrom be declared void due to certain
irregularities in the land registration proceeding. The spouses Jose M. Cordova and Saturnina C. Cordova,
who had bought eleven hectares of the disputed land from the plaintiffs, were allowed to intervene in the
case.
The lower court denied the petitioner’s motion to dismiss on the grounds of lack of jurisdiction,
improper venue, prescription, laches and prior judgment. The grounds of the motion to dismiss were
pleaded as affirmative defenses in the answer of defendants Tuason and J. M. Tuason & Co., Inc. Thus, they
insisted that a preliminary hearing be held on those defenses. On February 11, 1971, the Tuason and J. M.
Tuason & Co., Inc. filed the instant civil actions of certiorari and prohibition praying, inter alia, that the trial
court be ordered to dismiss the complaint and enjoined from proceeding in the said case.
Issue:
(1) Whether or not Spouses Aquial and Spouses Cordova have a valid claim on the land dispute.
(2) Whether or not OCT No. 735 and the titles derived therefrom can be questioned at this late hour
by the Spouses Acquial and Cordova.
Ruling:
Spouses Aquial and Spouses Cordova have no valid claim on the subject land. OCT No. 735 shall not
anymore be questioned given that the ruling is simply a reiteration or confirmation of the holding in the
cases directly or incidentally sustaining such OCT.
Under Land Registration Act 496 : Those holders of Spanish title originally registered under Spanish
Mortgage Law are qualified to re-register their ownership of land. And upon enactment of PD 892, Spanish
titles not re-registered may no longer be used as evidence of land of ownership in all registration
proceedings. The reason of which is the proliferation of Dubious Spanish titles which have raised conflicting
claims of ownership and tended to destabilize the Torrens System of registration.
On the case at hand, the supposed irregularities in the land registration proceeding, which led to
the issuance of the decree upon which OCT. No. 735 was based, are the same issues raised in Civil Cases
Nos. 3621, 3622 and 3623 of the lower court. The 1965 decision of Judge Eulogio Mencias in those cases,
validates the OCT No. 735, which is annexed to the complaint of the Aquials. It becomes evident that the
OCT No. 735 is valid and no longer be open to attack. Interest rei publicae ut finis sit litium – it is against
public policy that matters already decided on the merits be relitigated again and again, consuming the
court’s time and energies at the expense of other litigants.
 Erectors, Inc. v.
National Labor Relations Commission, Hon. Julio Andres, Jr. and Florencio Burgos

G.R. No. 104215

8 May 1996

Statutory Principle:
Laws should only be applied prospectively unless the legislative intent to give them effect is expressly
declared or is necessarily implied from the language used.

Facts:
In September 1979, petitioner recruited Florencio Burgos to work as service contract driver in Saudi
Arabia for a period of twelve (12) months with a salary of US$165.00 and an allowance of US$165.00 per
month. They further agreed that he shall be entitled to a bonus of US$1,000.00 if after the 12-month
period, he renews or extends his employment contract without availing of his vacation or home leave. Their
contract dated September 20, 1979, was duly approved by the Ministry of Labor and Employment.
However, in December, 1979, Florencio was notified that the position of service driver was no longer
available. Another contract was executed, of which his position was changed into helper/laborer with a
salary of US$105.00 and an allowance of US$105.00 per month. This subsequent contract was not
submitted to the Ministry of Labor and Employment for approval.
After Florencio left for Saudi and completing one year of work abroad as a laborer, he renewed his
contract for another year before returning to the Philippines in 1981. Upon returning in the Philippines, he
invoked his first employment contract. He demanded from the petitioner the difference between his salary
and allowance as indicated in the said contract, and the amount actually paid to him, plus the contractual
bonus which should have been awarded to him for not availing of his vacation or home leave credits.
However, Erector his claims. Thus, Florencio filed with the Labor Arbiter a complaint against the Erector for
underpayment of wages and non-payment of overtime pay and contractual bonus. The NLRC decided the
case in favor of Florencio, awarding the latter for the difference between his allowance as a Service Driver
against his position as Helper/Laborer and the US$1000 bonus. Erector appealed to respondent National
Labor Relations Commission (NLRC). It questioned the jurisdiction of the Labor Arbiter over the case in view
of the enactment of E.O. No. 797.

Issue:
(1) Whether or not NLRC committed grave abuse of discretion tantamount to lack of jurisdiction in
affirming the Labor Arbiter's judgment in the case a quo.

Ruling:
No, the NLRC did not commit any grave abuse of discretion tatamount to lack of jurisdiction over
the case at hand. The rule is that jurisdiction over the subject matter is determined by the law in force at
the time of the commencement of the action. On March 31, 1982, at the time Florencio Burgos filed his
complaint against the petitioner, the prevailing laws were Presidential Decree No. 1691 and Presidential
Decree No. 1391 which vested the Regional Offices of the Ministry of Labor and the Labor Arbiters with
"original and exclusive jurisdiction over all cases involving employer-employee relations including money
claims arising out of any law or contracts involving Filipino workers for overseas employment.“
Furthermore, E.O. No. 797 did not divest the Labor Arbiter's authority to hear and decide the case filed by
Florencio Burgos prior to its effectivity. Laws should only be applied prospectively unless the legislative
intent to give them retroactive effect is expressly declared or is necessarily implied from the language
used. The Court fail to perceive in the language of E.O. No. 797 any intention to give it retroactive effect.
Thus, at the time of the filing of the complaint, the Labor Arbiter had clear jurisdiction over the same.