Lawyerly

GR No. 211263

2015-08-05

PERLAS-BERNABE, J.

That respondent was made to believe that her contract will just be renewed every time it expires was not supported by substantial evidence. It bears stressing that self-serving and unsubstantiated declarations are not sufficient where the quantum of evidence required to establish a fact is substantial evidence, described as more than a mere scintilla.[43] Moreover, Section 3 (d), Rule 131 of the Rules of Court carries a legal presumption that a person takes ordinary care of his concerns. To this, case law dictates that the natural presumption is that one does not sign a document without first informing himself of its contents and consequences.[44] Also, Section 3 (p) of the same Rule equally presumes that private transactions have been fair and regular. It therefore behooves every contracting party to learn and know the contents of a document before he signs the same. To add, since the employment contracts were duly acknowledged before a notary public, it is deemed prima facie evidence of the facts expressed therein and such notarial documents have in their favor the presumption of regularity that may be contradicted only by clear, convincing and more than merely preponderant evidence,[45] which respondent failed to show in this case.

GR No. 159665

2010-08-03

ANSELMO TAGHOY v. SPS. FELIXBERTO TIGOL

BRION, J.

The joint affidavits are very solid pieces of evidence in the petitioners' favor. They constitute admissions against interest made by the respondents under oath. An admission against interest is the best evidence that affords the greatest certainty of the facts in dispute,[37] based on the presumption that no man would declare anything against himself unless such declaration is true.[38] It is fair to presume that the declaration corresponds with the truth, and it is his fault if it does not.[39]

GR No. 166886

2008-07-30

MATTEL v. EMMA FRANCISCO

AUSTRIA-MARTINEZ, J.

x x x x[21] Uy's admission in his Comment and Memorandum of non-compliance with the foregoing requirements is a judicial admission and an admission against interest[22] combined. A judicial admission binds the person who makes the same.[23] In the same vein, an admission against interest is the best evidence which affords the greatest certainty of the facts in dispute.[24] The rationale for the rule is based on the presumption that no man would declare anything against himself unless such declaration is true.[25] Thus, it is fair to presume that the declaration corresponds with the truth, and it is his fault if it does not.[26]

GR No. 174585

2007-10-19

FEDERICO M. LEDESMA v. NLRC HONS. RAUL T. AQUINO

CHICO-NAZARIO, J.

In Machica v. Roosevelt Services Center, Inc.,[32] we had underscored that the burden of proving the allegations rest upon the party alleging, to wit: The rule is that one who alleges a fact has the burden of proving it; thus, petitioners were burdened to prove their allegation that respondents dismissed them from their employment. It must be stressed that the evidence to prove this fact must be clear, positive and convincing. The rule that the employer bears the burden of proof in illegal dismissal cases finds no application here because the respondents deny having dismissed the petitioners.[33] In Rufina Patis Factory v. Alusitain,[34] this Court took the occasion to emphasize: It is a basic rule in evidence, however, that the burden of proof is on the part of the party who makes the allegations ei incumbit probatio, qui dicit, non qui negat. If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[35] It is true that the Constitution affords full protection to labor, and that in light of this Constitutional mandate, we must be vigilant in striking down any attempt of the management to exploit or oppress the working class. However, it does not mean that we are bound to uphold the working class in every labor dispute brought before this Court for our resolution.

GR NO. 155731

2007-09-03

LOLITA LOPEZ v. BODEGA CITY

AUSTRIA-MARTINEZ, J.

It is a basic rule of evidence that each party must prove his affirmative allegation.[10] If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[11]

GR NO. 149669

2006-07-27

L.C. ORDOÑEZ CONSTRUCTION v. IMELDA NICDAO

AUSTRIA-MARTINEZ, J.

On this point, the Court rules in favor of petitioner. Indeed, even if petitioners were not able to present any employment records, respondent Nicdao's Affidavit[8] dated January 21, 1994 submitted to the Labor Arbiter in support of her complaint for illegal dismissal militates against her for it stated that "I am a regular employee of respondent Ordonez, having been employed on [sic] August 1991, x x x." In Rufina Patis Factory v. Alusitain,[9] the Court held that:It is a basic rule in evidence, however, that the burden of proof is on the part of the party who makes the allegations - ei incumbit probatio, qui dicit, non qui negat. If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[10] (Emphasis ours) In said case, respondent Alusitain was claiming retirement benefits from his employer, alleging that he was employed until 1995. The employer countered that Alusitain was employed only until February 20, 1991, presenting as proof Alusitain's resignation letter dated February 19, 1991, and his Affidavit of Separation from Employment submitted to the Social Security System, stating that he was separated from his last employer on February 20, 1991. The Court held therein that the resignation letter and affidavit are admissions against Alusitain's own interest that belie his claim of retiring on January 31, 1995. Moreover, the Court pointed out that since the Affidavit is a notarial document, it has in its favor the presumption of regularity and to contradict the facts stated therein, there must be evidence that is clear, convincing and more than merely preponderant.[11]

GR NO. 147993

2006-07-21

ENRIQUEZ SECURITY SERVICES

CORONA, J.

Thus, in Rufina Patis Factory v. Lucas, Sr.,[11] we held:RA 7641 is undoubtedly a social legislation. The law has been enacted as a labor protection measure and as a curative statute that - absent a retirement plan devised by, an agreement with, or a voluntary grant from, an employer - can respond, in part at least, to the financial well-being of workers during their twilight years soon following their life of labor. There should be little doubt about the fact that the law can apply to labor contracts still existing at the time the statute has taken effect, and that its benefits can be reckoned not only from the date of the law's enactment but retroactively to the time said employment contracts have started. (emphasis ours)

GR NO. 145901

2005-12-15

EASYCALL COMMUNICATIONS PHILS. v. EDWARD KING

CORONA, J.

The burden of proof is on the party who makes the allegation.[10] Here, petitioner merely alleged that respondent was a corporate officer. However, it failed to prove that its by-laws provided for the office of "vice president for nationwide expansion." Since petitioner failed to satisfy the burden of proof that was required of it, we cannot sanction its claim that respondent was a "corporate officer" whose removal was cognizable by the SEC under PD 902-A and not by the NLRC under the Labor Code.

GR NO. 158684

2005-05-16

PATERNO S. MENDOZA v. SAN MIGUEL FOODS

CALLEJO, SR., J.

As a rule, findings of facts and conclusions of the NLRC are, on appeal, accorded great weight and even finality unless it is shown that it has arbitrarily disregarded the evidence before it or misapprehended evidence of such nature as to compel a contrary conclusion if properly appreciated.[26] We find no reason to disturb the said findings of the NLRC.

GR No. 160348

2004-12-17

WILLI HAHN ENTERPRISES v. LILIA R. MAGHUYOP

YNARES-SATIAGO, J.

Respondent's unsubstantiated and self-serving claim that she was coerced into signing the resignation letter does not deserve credence. It is a basic rule in evidence that the burden of proof is on the part of the party who makes the allegations.[10] Respondent failed to discharge this burden.

	GR No. 211263 2015-08-05	OKS DESIGNTECH v. MARY JAYNE L. CACCAM PERLAS-BERNABE, J.
That respondent was made to believe that her contract will just be renewed every time it expires was not supported by substantial evidence. It bears stressing that self-serving and unsubstantiated declarations are not sufficient where the quantum of evidence required to establish a fact is substantial evidence, described as more than a mere scintilla.[43] Moreover, Section 3 (d), Rule 131 of the Rules of Court carries a legal presumption that a person takes ordinary care of his concerns. To this, case law dictates that the natural presumption is that one does not sign a document without first informing himself of its contents and consequences.[44] Also, Section 3 (p) of the same Rule equally presumes that private transactions have been fair and regular. It therefore behooves every contracting party to learn and know the contents of a document before he signs the same. To add, since the employment contracts were duly acknowledged before a notary public, it is deemed prima facie evidence of the facts expressed therein and such notarial documents have in their favor the presumption of regularity that may be contradicted only by clear, convincing and more than merely preponderant evidence,[45] which respondent failed to show in this case.
	GR No. 159665 2010-08-03	ANSELMO TAGHOY v. SPS. FELIXBERTO TIGOL BRION, J.
The joint affidavits are very solid pieces of evidence in the petitioners' favor. They constitute admissions against interest made by the respondents under oath. An admission against interest is the best evidence that affords the greatest certainty of the facts in dispute,[37] based on the presumption that no man would declare anything against himself unless such declaration is true.[38] It is fair to presume that the declaration corresponds with the truth, and it is his fault if it does not.[39]
	GR No. 166886 2008-07-30	MATTEL v. EMMA FRANCISCO AUSTRIA-MARTINEZ, J.
x x x x[21] Uy's admission in his Comment and Memorandum of non-compliance with the foregoing requirements is a judicial admission and an admission against interest[22] combined. A judicial admission binds the person who makes the same.[23] In the same vein, an admission against interest is the best evidence which affords the greatest certainty of the facts in dispute.[24] The rationale for the rule is based on the presumption that no man would declare anything against himself unless such declaration is true.[25] Thus, it is fair to presume that the declaration corresponds with the truth, and it is his fault if it does not.[26]
	GR No. 174585 2007-10-19	FEDERICO M. LEDESMA v. NLRC HONS. RAUL T. AQUINO CHICO-NAZARIO, J.
In Machica v. Roosevelt Services Center, Inc.,[32] we had underscored that the burden of proving the allegations rest upon the party alleging, to wit: The rule is that one who alleges a fact has the burden of proving it; thus, petitioners were burdened to prove their allegation that respondents dismissed them from their employment. It must be stressed that the evidence to prove this fact must be clear, positive and convincing. The rule that the employer bears the burden of proof in illegal dismissal cases finds no application here because the respondents deny having dismissed the petitioners.[33] In Rufina Patis Factory v. Alusitain,[34] this Court took the occasion to emphasize: It is a basic rule in evidence, however, that the burden of proof is on the part of the party who makes the allegations ei incumbit probatio, qui dicit, non qui negat. If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[35] It is true that the Constitution affords full protection to labor, and that in light of this Constitutional mandate, we must be vigilant in striking down any attempt of the management to exploit or oppress the working class. However, it does not mean that we are bound to uphold the working class in every labor dispute brought before this Court for our resolution.
	GR NO. 155731 2007-09-03	LOLITA LOPEZ v. BODEGA CITY AUSTRIA-MARTINEZ, J.
It is a basic rule of evidence that each party must prove his affirmative allegation.[10] If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[11]
	GR NO. 149669 2006-07-27	L.C. ORDOÑEZ CONSTRUCTION v. IMELDA NICDAO AUSTRIA-MARTINEZ, J.
On this point, the Court rules in favor of petitioner. Indeed, even if petitioners were not able to present any employment records, respondent Nicdao's Affidavit[8] dated January 21, 1994 submitted to the Labor Arbiter in support of her complaint for illegal dismissal militates against her for it stated that "I am a regular employee of respondent Ordonez, having been employed on [sic] August 1991, x x x." In Rufina Patis Factory v. Alusitain,[9] the Court held that:It is a basic rule in evidence, however, that the burden of proof is on the part of the party who makes the allegations - ei incumbit probatio, qui dicit, non qui negat. If he claims a right granted by law, he must prove his claim by competent evidence, relying on the strength of his own evidence and not upon the weakness of that of his opponent.[10] (Emphasis ours) In said case, respondent Alusitain was claiming retirement benefits from his employer, alleging that he was employed until 1995. The employer countered that Alusitain was employed only until February 20, 1991, presenting as proof Alusitain's resignation letter dated February 19, 1991, and his Affidavit of Separation from Employment submitted to the Social Security System, stating that he was separated from his last employer on February 20, 1991. The Court held therein that the resignation letter and affidavit are admissions against Alusitain's own interest that belie his claim of retiring on January 31, 1995. Moreover, the Court pointed out that since the Affidavit is a notarial document, it has in its favor the presumption of regularity and to contradict the facts stated therein, there must be evidence that is clear, convincing and more than merely preponderant.[11]
	GR NO. 147993 2006-07-21	ENRIQUEZ SECURITY SERVICES CORONA, J.
Thus, in Rufina Patis Factory v. Lucas, Sr.,[11] we held:RA 7641 is undoubtedly a social legislation. The law has been enacted as a labor protection measure and as a curative statute that - absent a retirement plan devised by, an agreement with, or a voluntary grant from, an employer - can respond, in part at least, to the financial well-being of workers during their twilight years soon following their life of labor. There should be little doubt about the fact that the law can apply to labor contracts still existing at the time the statute has taken effect, and that its benefits can be reckoned not only from the date of the law's enactment but retroactively to the time said employment contracts have started. (emphasis ours)
	GR NO. 145901 2005-12-15	EASYCALL COMMUNICATIONS PHILS. v. EDWARD KING CORONA, J.
The burden of proof is on the party who makes the allegation.[10] Here, petitioner merely alleged that respondent was a corporate officer. However, it failed to prove that its by-laws provided for the office of "vice president for nationwide expansion." Since petitioner failed to satisfy the burden of proof that was required of it, we cannot sanction its claim that respondent was a "corporate officer" whose removal was cognizable by the SEC under PD 902-A and not by the NLRC under the Labor Code.
	GR NO. 158684 2005-05-16	PATERNO S. MENDOZA v. SAN MIGUEL FOODS CALLEJO, SR., J.
As a rule, findings of facts and conclusions of the NLRC are, on appeal, accorded great weight and even finality unless it is shown that it has arbitrarily disregarded the evidence before it or misapprehended evidence of such nature as to compel a contrary conclusion if properly appreciated.[26] We find no reason to disturb the said findings of the NLRC.
	GR No. 160348 2004-12-17	WILLI HAHN ENTERPRISES v. LILIA R. MAGHUYOP YNARES-SATIAGO, J.
Respondent's unsubstantiated and self-serving claim that she was coerced into signing the resignation letter does not deserve credence. It is a basic rule in evidence that the burden of proof is on the part of the party who makes the allegations.[10] Respondent failed to discharge this burden.

RUFINA PATIS FACTORY v. JUAN ALUSITAIN