Victor and Honorata Orquiola vs.

merely relied on the title of her predecessors-in-

Tandang Sora Development Corp interest and tax declarations to prove her alleged
GR No. 141463 ownership of the land. It is our view that the
petitioners are fully entitled to the legal protection
FACTS: of their lot by the Torrens system, unlike the
The petition for review seeks for the petitioner in the Medina case who merely relied on a
reversal of the decision of the Court of Appeals mere Titulo de Composicion.
which dismissed the petition to prohibit Judge
Vivencio Baclig of the RTC of Quezon City from The sale to petitioners of the land took place
issuing a writ of demolition against petitioners from before Pura Kalaw Ledesma claimed the lot.
implementing an alias writ of execution. Petitioners could reasonably relyon Mariano Lising’s
Pura Kalaw Ledesma was the registered Certificate of Title which at the time of purchase
owner of Lot 689 in Tandang Sora, Quezon City. This was still free from any third-party claim. Hence,
parcel of land was adjacent to certain portions of considering the circumstances in this case, we
the Piedad Estates, registered in the name of conclude that petitioners acquired the land subject
Herminigilda Pedro. of this dispute in good faith and for value.
On October 29, 1964, the latter sold lots to As earlier discussed, petitioner spouses acquired
Mariano Lising who then registered both lots in the the land in question without knowledge of any
name of M.B. Lising Realty and subdivided them into defect in the title of Mariano Lising. Shortly
smaller lots. Certain portions of the subdivided lots afterwards, they built their conjugal home on said
were sold to third persons including herein land. As builders in good faith and innocent
petitioners, spouses Victor and Honorata Orquiola. purchasers for value, petitioners have rights over the
In 1969, Pura Kalaw Ledesma, who was then subject property and hence they are proper parties
replaced by Tandang Sora Development sa plaintiff, in interest in any case thereon.
filed a complaint with the RTC of Quezon City  Consequently, private respondents should have
against Lising for allegedly encroaching upon their impleaded them in Civil Case No. Q-12918. Since
lot. The RTC rendered decision in favor with the they failed to do so, petitioners cannot be reached
plaintiffs and issued a writ of demolition against by the decision in said case. No man shall be
defendants. affected by any proceeding to which he is a stranger,
Petitioners herein filed with the CA a and strangers to a case are not bound by any
petition for prohibition with prayer for a restraining judgment rendered by the court. In the same
order and preliminary injunction alleging that they manner, a writ of execution can be issued only
bought the subject parcel of land in good faith and against a party and not against one who did not have
for value, hence, they were parties in interest. his day in court. Only real parties in interest in an
The CA dismissed the petition and held that action are bound by the judgment therein and by
as buyers and successors-in-interest of Mariano writs of execution and demolition issued pursuant
Lising, petitioners were considered privies who thereto.
derived their rights from Lising by virtue of sale and Petition was GRANTED and lower court decision
could be reached by the execution order. was REVERSED and SET ASIDE.

ISSUE: Government of Hong Kong vs. Hon. Olalia

1. WON the alias writ of execution may be GR No. 153675
enforced against petitioner – NO.
2. WON petitioners were innocent FACTS:
purchasers for value and builders in Private respondent Munoz was charged
good faith – YES. before the Hong Kong Court with three (3) counts of
the offense of “accepting an advantage as agent,” in
HELD: violation of Sec 9(1)(a) of the Prevention of Bribery
Medina case markedly differ from the present Ordinance of Hong Kong. He also faces seven (7)
case on major points. First, the petitioner in Medina counts of the offense of conspiracy to defraud,
acquired the right over the houses and lot subject of penalized by the common law of Hong Kong.
the dispute after the original action was commenced On September 23, 1999, the RTC Manila
and became final and executory. In the present issued an Order of Arrest against private respondent.
case, petitioners acquired the lot before the That same day, the NBI agents arrested and detained
commencement. Second, the right over the disputed him.
land of the predecessors-in-interest of the petitioner On November 22, 1999, petitioner Hong
in Medina was based on a title of doubtful Kong Special Administrative Region filed with the
authenticity, while the right over the land of the RTC of Manila a petition for the extradition of
predecessors-in-interest of herein petitioners is private respondent. For his part, private respondent
based on a fully recognized Torrens title. Third, filed, in the same case, a petition for bail which was
petitioners in this case acquired the registered title opposed by petitioner.
in their own names, while the petitioner in Medina
 The petition for bail was denied but was potential extraditee must prove by “clear and
later on granted by respondent judge of Branch 8 convincing evidence” that he is not a flight risk and
subject to following conditions. whill abide with all the orders and processes of the
Petitioner filed an urgent motion to vacate extradition court.
the above Order, but it was denied by respondent In this case, there is no showing that private
judge. Hence, the instant petition. rspondent presented evidence to whoe that he is not
a flight risk.
ISSUE: Petition is DISMISSED. The case is REMANDED
Whether or not the trial court committed to the trial court to determine whether private
grave abuse of discretion amounting to lack or respondent is entitled to bail on the bases of “clear
excess of jurisdiction in admitting private and convincing evidence.”
respondent to bail
Jose Jesus Disini vs. Secretary of Justice
HELD: GR No. 203335
The Court cannot ignore the following
trends in international law: (1) the growing FACTS:
importance of the individual person in public Petitioners claim that the means adopted
international law who, in the 20th century, has by the cybercrime law for regulating undesirable
gradually attained global recognition; (2) the higher cyberspace activities violate certain of their
value now being given to human rights in the constitutional rights. However, the government
international sphere; (3) the corresponding duty of asserts that the law merely seeks to prevent these
countries to observe these universal human rights in tomfooleries from happening and punish their
fulfilling their treaty obligations; and (4) the duty of perpetrators, hence the Cybercrime Prevention Act.
this Court to balance the rights of the individual Pending hearing and adjudication of the issues
under our fundamental law, on one hand, and the presented in these cases, the Court extended the
law on extradition, on the other. original 120-day temporary restraining order (TRO),
The Philippine authorities are under enjoining respondent government agencies from
obligation to make available to every person under implementing the cybercrime law until further
detention such remedies which safeguard their orders.
fundamental right to liberty. These remedies include
the right to be admitted to bail.
If bail can be granted in deportation cases,
ISSUE:
we see no justification why it should not also be
allowed in extradition cases. Likewisem considering Whether or not the cybercrime law is
unconstitutional
that the UDHR applies to deportation casee, there is
no reason why it cannot be invoked in extradition
HELD:
cases. After all, both are administrative proceedings
The Court has in a way found the strict
where the innocence or guilt of the person detained
scrutiny standard, an American constitutional
is not in issue.
construct, determining the constitutionality of laws
Clearly, the right of a prospective
that tend to target a class of things or persons. Such
extraditee to apply for bail in this jurisdiction must
standard was later used to assess the validity of laws
be viewed in the light of the various treaty
dealing with the regulation of speech, gender, or
obligations of the Philippines concerning respect for
race as well as other fundamental rights, as
the promotion and protection of human rights. Thus,
expansion from its earlier applications to equal
the Philippines should see to it that the right to
protection.
liberty of every individual is not impaired.
In the cases before it, the Court finds
Records show that private respondent was
nothing in Section 4(a)(1) that calls for the
arrested on September 23, 1999, and remained
applications of strict scrutiny standard since no
incarcerated until December 20, 2001, when the trial
fundamental freedom, like speech, is involved in
court ordered his admission to bail. In other words,
punishment what is essentially a condemnable act –
he had been detained for over two years without
accessing the computer system of another without
having been convicted of any crime. By any
right. It is a universally condemned conduct.
standard, such an extended period of detention is a
Section 4(a)(3) does not encroach on these
serious deprivation of hid fundamental right to
freedoms at all. It simply punishes what essentially is
liberty. In fact, it was his prolonged deprivation of
a form of vandalism, the act of willfully destroying
liberty which prompted the extradition court to
without right the things that belong to others, in this
grant him bail.
case their computer data, electronic document, or
An extradition proceeding being sui generis,
electronic data message. There is no such freedom
the standard of proof required in granting or denying
to destroy other people’s computer systems and
bail can neither be the proof beyond reasonable
private document. All penal laws, like the
doubt in criminal cases not the standard of proof of
cybercrime law, have of course an inherent chilling
preponderance of evidence in civil cases. The
effect, an in terrorem effects. But to prevent the
State from legislating criminal laws because they
instill such kind of fear is to render the state
powerless in addressing and penalizing socially
harmful conduct.
In Section 4(a)(6), the law is reasonable in
penalizing him for acquiring the domain name in bad
faith to profit, mislead, destroy reputation, or
deprive others who are not ill-motivated of the
rightful opportunity of registering the same. The
challenge to theconsitutionality of the above
mentioned provision on ground of denial of equal
protection is baseless.
Further, petitioners fear that Section 4(b)
(3) violates the freedom of the press in that
journalists would be hindered from accessing the
unrestricted user account of a person in the news to
secure information about him that could be
punished. Evidently, the theft of identity
information must be intended for an illegitimate
purpose. Moreover, acquiring and disseminating
information made public by the user himself cannot
be regarded as a form of theft.