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Case Digest - Conflict of Laws

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    G.R. No. 96492 November 26, 1992 ROMEO REYES, ANGEL PARAYAO, and EMILIO MANANGHAYA, petitioners, vs. THE COURT OF APPEALS, EUFROCINA DE LA CRUZ and VIOLETA DELOS REYES, respondents. FACTS: Juan Mendoza, father of herein defendant Olympio Mendoza, is the owner of Farm Lots Nos. 46 and 106. Devoted to the production of palay, the lots were tenanted and cultivated by Julian dela Cruz, husband of plaintiff Eufrocina dela Cruz. Julian died on September 25, 1979. In her complaint, Eufrocina alleged that upon the death of Julian, she succeeded him as bona fide  tenant of the subject lots; that between July 7 to July 15, 1984, Olympio Mendoza, in conspiracy with the other defendants, prevented her daughter Violeta and her workers through force, intimidation, strategy and stealth, from entering and working on the subject premises; and that until the filing of the instant case, defendants had refused to vacate and surrender the lots, thus violating her tenancy rights. Plaintiff therefore prayed for judgment for the recovery of possession and damages with a writ of preliminary mandatory injunction in the meantime. Defendants Reyes, Parayao, Aguinaldo and Mananghaya, duly elected and/or appointed barangay officials of Bahay Pare, Candaba, Pampanga, denied interference in the tenancy relationship existing between plaintiff and defendant Mendoza, particularly in the cultivation of the latter's farm lots. Claiming that they have always exercised fairness, equity, reason and impartiality in the discharge of their official functions, they asked for the dismissal of the case and claimed moral damages and attorney's fees in the total amount of P165,000.00. For his part, defendant Mendoza raised abandonment, sublease and mortgage of the farm lots without his consent and approval, and non-payment of rentals, irrigation fees and other taxes due the government, as his defenses. He also demanded actual and exemplary damages, as well as attorney's fees. Contention of petitioners  –  It is the position of petitioners that they are not liable jointly and severally with Olympio Mendoza and Severino Aguinaldo because the present petition involves Lot No. 46, and not Lot No. 106 of the estate, which lot was purchased by petitioner Romeo Reyes from Olympio Mendoza's father, Juan, and which he later donated to the barangay Bahay Pare of Candaba, Pampanga, for the construction of the Bahay Pare Barangay High School.      Contention of respondents  –  Private respondents deny petitioners' allegations and contend that it was petitioners who conspired with Olympio Mendoza and Severino Aguinaldo in ejecting them not only from Lot No. 46 but also from Lot No. 106. They maintain that it was in Farmlot No. 46 from where they were ejected and dispossessed, so much so that even if Farmlot No. 106 was removed by the Court of Appeals from the judgment, private respondents should be compensated for the lost income by the petitioners who are solidarily liable with Olympio Mendoza and Severino Aguinaldo. 11  HELD: We find for the private respondents. We rule that the trial court did not err when it favorably considered the affidavits of Eufrocina and Efren Tecson (Annexes B and C ) although the affiants were not presented and subjected to cross-examination. Section 16 of P.D. No. 946 provides that the Rules of Court shall not be applicable in agrarian cases even in a suppletory character. The same provision states that In the hearing, investigation and determination of any question or controversy, affidavits and counter-affidavits may be allowed and are admissible in evidence . Moreover, in agrarian cases, the quantum of evidence required is no more than substantial evidence. This substantial evidence rule was incorporated in section 18, P.D. No. 946 which took effect on June 17, 1976 (Castro vs. CS, G.R. No. 34613, January 26, 1989). In Bagsican vs. Hon. Court of Appeals, 141 SCRA 226, the Supreme Court defined what substantial evidence is: Substantial evidence does not necessarily import preponderant evidence, as is required in an ordinary civil case. It has been defined to be such relevant evidence as a reasonable mind might accept as adequate to support a conclusion and its absence is not shown by stressing that there is contrary evidence on record, direct or circumstantial, for the appellate court cannot substitute its own judgment or criteria for that of the trial court in determining wherein lies the weight of evidence or what evidence is entitled to belief.  14      G.R. No. 81561 January 18, 1991 PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. ANDRE MARTI, accused-appellant . FACTS: The appellant and his common-law wife, Shirley Reyes, went to the booth of the Manila Packing and Export Forwarders , carrying with them four (4) gift wrapped packages. Anita Reyes (the proprietress and no relation to Shirley Reyes) attended to them. The appellant informed Anita Reyes that he was sending the packages to a friend in Zurich, Switzerland. Appellant filled up the contract necessary for the transaction, writing therein his name, passport number, the date of shipment and the name and address of the consignee, namely, WALTER FIERZ, Mattacketr II, 8052 Zurich, Switzerland Anita Reyes then asked the appellant if she could examine and inspect the packages. Appellant, however, refused, assuring her that the packages simply contained books, cigars, and gloves and were gifts to his friend in Zurich. In view of appellant's representation, Anita Reyes no longer insisted on inspecting the packages. The four (4) packages were then placed inside a brown corrugated box one by two feet in size (1' x 2'). Styro-foam was placed at the bottom and on top of the packages before the box was sealed with masking tape, thus making the box ready for shipment . Before delivery of appellant's box to the Bureau of Customs and/or Bureau of Posts, Mr  .  Job Reyes (proprietor) and husband of Anita (Reyes),  following standard operating procedure, opened the boxes for final inspection . When he opened appellant's box, a peculiar odor emitted therefrom .  His curiousity aroused, he squeezed one of the bundles allegedly containing gloves and felt dried leaves inside .  Opening one of the bundles, he pulled out a cellophane wrapper protruding from the opening of one of the gloves .  He made an opening on one of the cellophane wrappers and took several grams of the contents thereof  . Job Reyes forthwith prepared a letter reporting the shipment to the NBI and requesting a laboratory examination of the samples he extracted from the cellophane wrapper. He was interviewed by the Chief of Narcotics Section. Job Reyes informed the NBI that the rest of the shipment was still in his office. Therefore, Job Reyes and three (3) NBI agents, and a photographer, went to the Reyes' office at Ermita, Manila.     Job Reyes brought out the box in which appellant's packages were placed and, in the presence of the NBI agents, opened the top flaps, removed the styro-foam and took out the cellophane wrappers from inside the gloves .   Dried marijuana leaves were found to have been contained inside the cellophane wrappers (tsn, p. 38, October 6, 1987; Emphasis supplied). The NBI agents made an inventory and took charge of the box and of the contents thereof, after signing a Receipt acknowledging custody   of the said effects (tsn, pp. 2-3, October 7, 1987). Thereupon, the NBI agents tried to locate appellant but to no avail. Appellant's stated address in his passport being the Manila Central Post Office, the agents requested assistance from the latter's Chief Security. On August 27, 1987, appellant, while claiming his mail at the Central Post Office, was invited by the NBI to shed light on the attempted shipment of the seized dried leaves. On the same day the Narcotics Section of the NBI submitted the dried leaves to the Forensic Chemistry Section for laboratory examination. It turned out that the dried leaves were marijuana flowering tops as certified by the forensic chemist. (Appellee's Brief, pp. 9-11, Rollo , pp. 132-134). Thereafter, an Information was filed against appellant for violation of RA 6425, otherwise known as the Dangerous Drugs Act. Contention of Marti  –  Appellant contends that the evidence subject of the imputed offense had been obtained in violation of his constitutional rights against unreasonable search and seizure and privacy of communication (Sec. 2 and 3, Art. III, Constitution) and therefore argues that the same should be held inadmissible in evidence. HELD: Evidence is admissible Topic: Search and seizure The case at bar assumes a peculiar character since the evidence sought to be excluded was primarily discovered and obtained by a private person, acting in a private capacity and without the intervention and participation of State authorities. Under the circumstances, can accused/appellant validly claim that his constitutional right against unreasonable searches and seizure has been violated? Stated otherwise, may an act of a private individual, allegedly in violation of appellant's constitutional rights, be invoked against the State?
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