(1) Ang Yu Asuncion vs CA - Elements of an Obligation

KEY:Lessee, right to first refusal

Facts:
1. Ang Yu Asuncion, et al (petitioners) were lessees of the commercial and residential
spaces of Bobby Cu Unjieng, et al since 1935
2. In 1936, on several occasions, the owners offered to sell the property to the petitioners.
3. The owners offered a price of Php6M while the petitioners made a counter offer of
Php5M.The petitioners then asked the owners to put their offer in writing, and the owners
agreed to the request.
4. Petitioners asked the owner to pecify the terms and conditions of the offer to sell.
5. Owners failed to comply
6. Petitioners found out that the owners were about to sell the property to a third person/
they then filed a complaint against the owners compelling the owners to sell the property
to them.
7. The RTC
1. ruled in favor of the owners
2. no contract because offer to sell was never accepted by the petitioners
8. While this case was still pending in the SC, the owners sold the property to respondent -
Buen Realty and Development Corporation.
9. Buen, then wanted the petitioners to vacate the property.
10. The petitioners wrote a reply stating that the petitioners bought the property subject to
the notice of lis pendens.
11. RTC ruled
1. Declared the deed of sale in favor of Buen - VOID
2. ordered the former owners to execute the deed of sale to lessees
3. Grounds:
1. Right to first refusal
12. The CA reversed the RTC ruling.

Issue:
1. WON Buen Realty can be bound by the writ of execution issued by the judge in favor of
the lessees.

Ruling:
1. No. There is none to execute, because such judgment merely accorded a right of first
refusal to the lessees. (Failure to honor such constitutes another cause of action which
is between the owner and the lessee)
2. An obligation is a juridical necessity to give, to do or not to do (Art. 1156, Civil Code).
Elements:
1. (a) The vinculum juris or juridical tie which is the efficient cause established
by the various sources of obligations (law, contracts, quasi-contracts, delicts and
quasi-delicts); (b) the object which is the prestation or conduct; required to
be observed (to give, to do or not to do); and (c) the subject-persons who,
viewed from the demandability of the obligation, are the active (obligee) and the
passive (obligor) subjects.
3. Remember: There can be no writ of execution if there is no obligation, and there is no
obligation if there is no final decision.
 (2) De La Rama vs Mendiola, Titan Corp. Subject Matter vs. Cause of Action

KEY: Expropriated land to the government

Facts

1. De la Rama sold his land to the government through expropriation subject to

reconveyance of unused portion
2. De la Rama also sold land adjacent to the one he sold to the government to a
construction company (Titan Corp)
3. Dela Rama failed to comply with the contract to sell, thus Titan filed a petition to nullify
the contract before the RTC
4. The contract was annulled and a subsequent compromise agreement was made.
Agreement:
1. Owner must execute deed of absolute sale of the parcel of land in favor of Titan
2. Owner must execute an agreement to sell and buy:
1. In the event that the unused land will be reconveyed, Titan is given the
option to buy returned unused land.
5. Dela Rama sought for the reconveyance of the unused land, which was then issued
6. Titan filed a complaint on grounds that he was denied the right to bid
7. Petition was denied, and elevated to the CA
8. The construction company also filed an execution of the compromise agreement (special
performance case) in another civil case.
9. De la Rama filed a motion before the CA and RTC to dismiss for forum shopping and res
judicata because the execution of the compromise agreement has the same subject
matter as the first civil case.
10. Titan withdrew the petition before the CA.
11. RTC denied the motion.

Issue:
1. Whether or not the specific performance case constitutes the same subject matter and
cause of action with the compromise agreement

Ruling
1. YES.
2. cause of action is the same when they involve the same rights, the same obligation and
the same violation.
3. The subject matters and causes of action of the two cases are likewise identical
4. A subject matter
1. the item with respect to which the controversy has arisen, or concerning which
the wrong has been done, and it is ordinarily the right, the thing, or the contract
under dispute.
5. In the case at bar, both the first and second actions involve the same real property.
6. A cause of action, broadly defined, is an act or omission of one party in violation of the
legal right of the other.
7. Same cause of action because:
1. there is an identity in the facts essential to the maintenance of the two actions, or
where the same evidence will sustain both actions.
 (3) Bachrach Corp vs CA - subject matter vs. cause of action

KEY: Lessee sa Port gi eject. lol

Facts:
1. Bachrach leased government lands at the Manila Port are under the control of the
Director of Lands
2. C. Aquino (president at that time) transferred the management of the entire port area to
the Philippine Ports Authority (PPA)
3. PPA increased the rental fees of Bachrach to 1500%
4. Bachrach refused to pay rental fees.
5. PPA filed an unlawful detainer case against Bachrach for non-payment of rent.
6. Granted by RTC and while it was pending in the CA, Bachrach supposedly entered into
a compromise agreement
7. CA ruled in favor of PPA. The decision became final
8. Bachrach filed a case against PPA for not honoring the compromise agreement
9. RTC dismissed the specific performance case by res judicata via same cause of action
with the ejectment case
10. CA affirmed the RTC decision
11. Bachrach elevated to the SC

Issue:
1. Whether or not the specific performance case constitutes the same subject matter and
the same cause of action with the ejectment case.
Ruling
1. NO
2. A cause of action, broadly defined, is an act or omission of one party in violation of the
legal right of the other.
3. The subject matter, on the other hand, is the item with respect to which the controversy
has arisen, or concerning which the wrong has been done, and it is ordinarily the right,
the thing, or the contract under dispute.

4. In unlawful detainer case,

1. Subject matter- the contract of lease between the parties
2. Cause of action- the breach thereof, arising from petitioner's non-payment of
rentals
5. In the specific performance case,
1. subject matter - the compromise agreement allegedly perfected between the
same parties
2. cause of action - the averred refusal of PPA to comply therewith.
 (4) Pelayo vs Lauron Sources of obligations

KEY: Asawa nanganak, Parents-in-law nanawag

Facts:
1. Dr. Pelayo was called to render medical service in the childbirth to a woman at the
request of her father and mother-in-law.
2. After a difficult childbirth, the woman died and the father and mother-in-law refused to
pay the bill.
3. Dr. Pelayo sued to receive payment for his services
Issue:
1. Whether or not the father and mother-in-law is obligated to pay Dr. Pelayo for his
medical services.

Ruling:
1. No.
2. Obligations may arise from law or contracts.
3. AS TO LAW: Obligation to pay medical services is dependent on the obligation to
support
a. SUPPORT is provided by LAW.
b. Obligations by law NOT presumed must be expressed.
1. Per law: spouses
2. NO Law: support from strangers. Inlaws, as to support, are strangers.
4. AS TO CONTRACT: No contract between inlaws and pelayo.
5. OTHER SOURCES: NOT between inlaws and pelayo; but between pelayo and wife
(whom husband is bound to support).
6. THUS:
a. DISMISSED because of insufficiency of cause of action (no legal right, then no
duty to respect right, no such right violated)
1. Person obliged by law to support the wife is the husband.
2. It does not matter if it was the father and mother-in-law who called the
doctor it would be a quasi-contract to the husband.
 (5) De la Cruz vs Northern Theatrical Enterprises Sources of obligations (law)

KEY: Guard nakapatay

Facts:
1. Domingo Dela Cruz, petitioner, worked as a guard of Northern Theatrical Enterprises.
2. One day, a man wanted to enter the cinema without a ticket, but Dela Cruz refused.
3. The man attacked Dela Cruz with bolo; Dela Cruz was cornered and killed (revolver)
man in self-defense.
4. Dela Cruz was charged with homicide. Dismissed for lack of cause of action.
5. Dela Cruz charged again. He was finally acquitted.
6. In both cases, Dela Cruz hired an attorney and incurred expenses to defend self.
7. Dela Cruz demanded reimbursement from ex-employer. Ex-employer refused.
1. Thus, present case (also incuded claim for damages for lost income, for moral
suffering, etc)
8. CFI no principal-agent relationship; no law obligating ex-employer to pay for kind of
expenses.

Issue:
WON Dela Cruz may recover damages and reimbursements from ex-employer.

HELD:
- NO.
- No law = no legal obligation = no right to recover reimbursements/damages
o No principal-agent relationship
o Law available is ONLY as to expenses directly caused by employer-employee
relationship during performance of duty
BUT in case at bar
Performance of duty is not direct cause
Direct cause is the filing of erroneous charges (for which he had
to incur expenses to defend himself) not the performance of
duty
o Had no charges been filed, the killing in performance of
duty would not have necessitated any defense-expenses
o Filing of erroneous charges = effective intervening
cause/proximate cause
- THUS: SC affirms lower courts ruling. No cause of action.
1. Damages caused to employee by stranger while said employee in performance
of duties = no law = no enforceable right.
 (6) Manzano vs Lazaro contractual obligations

Key: Vice-Mayor won via popularity, voidable contract ratified by payment

Facts:
1. Manzano, a vice mayor candidate and Lazaro, campaign manager entered into a
Professional Services Contract which stipulates:
1. list of responsibilities of both parties
2. remuneration scheme:
1. 70k/month for 3 months compensation
2. Bonus 200k if Manzano wins
2. For last month paid 15K, 20k balance payable after delivery of inventory
1. Lazaro complied; demanded 20k balance and 200k bonus
1. 20K - Manzano conditioned again liquidation (prepare audited FS)
2. 200K no mention
3. RTC
1. Lazaro filed to enforce Manzanos payment
2. Manzanos reply:
1. Invalid contract alleged vitiated consent (fraud of expertise)
2. Lazaro not entitled to bonus since manzano won from his popularity, not
lazaros services.
3. Ruling: Favor of Lazaro
4. CA affirmed RTC ruling.
5. Manzano elevated to the SC

Issue:
1. Whether or not the contract between Manzano and Lazano is enforceable.

Ruling:
1. YES
2. SC not trier of facts; Manzanos allegations already dismissed as uncorroborated/without
evidence/self-serving by all lower courts.
3. Valid contracts have force of law between parties.
1. As to vitiated consent
1. vitiated consent = voidable (not void and unenforceable)
1. voidable = valid until voided;
2. infact it was ratified by:
1. payment of earlier instalments
2. condition of performance
2. As to non-payable due to reciprocal non-performance of responsibility
1. Alleged non-performance defeated by implied proofs that Manzano
acknowledges performance:
1. payment of earlier instalments
2. condition of performance
1.
4. Voidable contract ratified. Contract not contrary to law, morals, good customs, public
policy or public order. Contract is valid, fully enforceable.
 (7) William Golangco Construction Corporation vs. Philippine Commercial
International Bank contractual obligations

KEY: DEFECTIVE GRANITITE FINISHING

Facts:

1. WGCC and PCIB entered into a contract of construction for an extension of PCIB tower
2. According the contract, any defects on the construction including the granitite-finishing
will be guaranteed by WGCC in a period of 1 year.
3. Building was eventually turned-over (with concurrence of PCIBs own
engineer/consultant)
4. Granitite-finishing started peeling off:
1. Within 1 year WGCC repaired.
2. After 1 year PCIB asked a third party to change the finishing
5. PCIB filed a case in the CIAC (Construction Industry Arbitration Commission) to hold
WGCC liable for the cost of the third party repair.
6. CIAC ruled in favor of PCIB which was affirmed in the CA.

Issue:

1. WON WGCC could be held liable for the third party cost of repairing/redoing the granitite
finishing that peeled off after the 1 year period.
Ruling:
1. NO
2. Grounds:
1. Per LAW (MAIN PRINCIPLE): Contract has force of law between the parties
insofar as they are not contrary to law, morals, good customs, public policy or
public order (LMGPP).
1. SC RULED: 1 year limit is not contrary to LMGPP = contract is valid
2. Per Contract: Unfulfilled obligation clause provides that contractor remains liable
for unperformed obligations
1. SC RULED: the defects after 1 year is not part of unfulfilled obligations
since already beyond 1 year period (such stipulation not contrary to law)
3. Per LAW: Acceptance relieves contractor of liability except when (a) hidden
defects no expected to be recognized; (b) expressly reserved rights against
contractor
1. SC RULED:
1. Defects in materials NOT HIDDEN
1. PCIB had own expert
2. Work was supervised, transparent
3. PCIB itself supplied the materials for granitite finish
2. No reservation of right anywhere in contract
3. RTC-CA decisions SET ASIDE.
 (8) Dio vs St. Ferdinand Memorial Park contractual obligations

KEY: MAUSOLEUM , rule 69

Facts:
1. Dio bought cemetery land from St. Ferdinand Memorial Park (SFMP) and AGREED to all
the Rules and Regulations (and all modifications, amendments); including:
1. Rule 69: any construction of mausoleums shall be constructed by SFMP; albeit
design may come from lot-owner.
2. Dio then buried the remains of her family members.
3. Dio wants to build a Mausoleum thru a private contractor; she informed, consulted and
asked for permission from SMFP
4. SMFP responded:
1. Rule 69
2. Construction at minimum Php100K
5. RTC:
1. Dios complaints:
1. Rules and Regulations invalid because its a contract of adhesion;
2. Php100K too large and unreasonable (priv. contractor only 60k)
6. RTC and CA ruled in favor of SMFP.
7. Dio elevated to the SC

Issue:
1. Whether or not SMTPs Rules and Regulations are invalid.
Ruling:
1. NO
2. Grounds:
1. LEGAL BASIS (MAIN PRINCIPLE): Contracts have the force of law between
the parties insofar as they are not contrary LMGPP.
2. SC RULED:
1. Contract of adhesion valid contract so long as not contrary to LMGPP
1. You are FREE to sign OR reject contract all you want
2. Stipulations NOT contrary as it vested full ownership, but subject to
rules and regulations.
1. Accepted them freely when she signed agreements in beginning
without protest
2. Even available for viewing in SFMP office
3. Due diligence: before signing any contract, you are expected to
have read it
1. Dio was a businesswoman = experienced
4. Act of informing, and asking permission = shows that she knew
the rules/restrictions
5. Date when Rule 69 was established (before or after Dio signed) is
immaterial since contract stipulated rules, regulation, all
amendments, additions and modifications.
3. Where contract is valid, parties are bound. Petition DENIED.
 (9) National housing authority vs CA contractual obligations

KEY: PARI DELICTO, NO CONTRACT

Facts:
1. Grace Baptist Church sent to the NHA a letter of interest to buy NHA property.
2. NHA approved the request, but didnt state the amount to be paid thereof.
3. Church occupied property and introduced improvements (though not yet sold). NHA did
not contest.
4. THEN, NHA issued Resolution No. 2126, stating the price the church had to pay
(700/sqm; total 430K).
5. Church then gave a managers check of 55K in full payment of the properties.
6. NHA returned the check stating that the amount was insufficient.
7. RTC:
1. Church filed a complaint for specific performance and damages against the NHA.
2. RTC ruled:
1. No perfected sales contract; church should return possession and pay
rent for occupied period.
8. CA: affirmed RTC (no perfected sales contract); but with modifications:
1. Ordered NHA to sell to Church the property at Php700/sqm in the interest of
equity since Church already occupied and introduced improvements.

Issue:
1. WON NHA can be compelled to sell the subject lots to the Church in the absence of any
perfected contract of sale between the parties?

Ruling:
1. NO
2. There is no contract perfected:
1. No meeting of minds (NHA offered price -> Church made counter-offer -> NHA
rejected);
1. Never reached perfection (i.e. stages of contracts: negotiation, perfection,
consummation) since no concurrence of offer and acceptance; no MOM.
3. Notwithstanding, NO contract = NOT auto-equity justice;
1. Equity cannot be applied although no contract, there still are laws available to
govern the parties:
1. Contract stipulations govern the parties; BUT contracts are NOT the
ONLY source of law to govern rights and obligations between parties.
4. Applicable law (not contract; not equity) is other civil code provisions:
1. Pari delicto (Church occupied knowing not yet sold; NHA allowed) = good faith
2. Article 488 applies:
1. Application: IF value of land considerably more than value of
improvements introduced, Church cant be obliged to buy land, instead
should pay reasonable rent, after paying proper indemnity.
5. THEREFORE:
1. At this point: NHA CANNOT be compelled;
2. Instead: case remanded to RTC:
1. To determine values of improvements vs land; and so on in compliance
with CC Art. 488.
 (10) Tui Peck vs CA contractual obligations

KEY: PIGGERY AND LUMBER BUSINESS

Facts
1. Joaquin Tiu Singco, the father, owned Argentina trading, a business for trading lumber,
hardware and general merchandise
2. He was assisted by Spouses Rubiato and Tan King.
3. When he died, his son Tiu Peck took over the business.
4. After continued assistance by Spouses Rubiato and Tan King, they became partners
5. Later, they entered into a liquidation agreement to share the business into the piggery
business and the lumber / hardware business
6. Spouses Rubiato and Tan King got the piggery business and Tiu peck got the lumber /
hardware business
7. 3 years later, Spouses Rubiato and Tan King asked the RTC for further partitioning of
land.
8. RTC ruled that the land was co-owned by them which the CA affirmed with modifications
9. Tiu Peck elevated to the SC

Issue:
1. Whether or not the liquidation agreement was binding with the force of law before the
RTC ruling
Ruling:
1. Yes, SC ruled that a liquidation agreement because it was voluntarily entered upon by
both parties has the force of law between them.
2. In this case, SC ruled that the actuations of the parties like the taking of the piggery
business shows voluntariness in the liquidation agreement
 (11)BPI vs Sarmiento quasi-contracts

KEY: MANAGER WA MI TRABAHO, GI SWELDOHAN

Facts:

1. Sarmiento is an assistant manager to a branch in BPI

2. After allegations of anomalous transactions in BPI Espana, Sarmiento did not attend
work but still received salary
3. BPI filed a case in the RTC to recover the salary of Sarmiento stating it was solutio
indebiti
4. RTC and CA ruled in favor of Sarmiento

Issue:
1. WON BPI may demand reimbursement of Sarmientos salary on grounds of solution
indebiti

Ruling
1. NO
2. Principle: Requisites of solutio indebiti:
1. Requisite 1: NO right to receive/obligation to pay exists (i.e. NO employer-
employee relationship exists)
2. Requisite 2: Mistake in payment;
3. Per SC: both requisites are absent:
1. Requisite 1: There WAS an employer-employee relationship
1. Nature of Managerial position expected not always in office
2. Only followed orders of audit VP (VP denied, but unsubstantiated)
3. Not suspended, not sanctioned, not reprimanded; instead fully paid her
salary without reservations
2. Requisite 2: Accordingly, there can have been no mistake in payment (since
Sarmiento was fully entitled to receiving the salary
4. No quasi-contract of solution indebiti created; BPI cannot ask for reimbursement.
 (12) Perez vs Pomar implied contracts

KEY: TRANSLATOR, SOAP BUSINESS ABANDONED

Facts:
1. Pomar rendered translation services to Perez and the Military
2. There was no written contract for such services verbal
3. Pomar went to the CFI to ask for what was his due for his services
4. Perez contended that since there was no written agreement or proven verbal agreement,
there was no contract

Issue:
1. Whether or not there was a contract between Perez and Pomar

Ruling:
1. YES, there is an implied contract.
2. Actuations of the parties show that there is a contract:
1. Consent between parties manifested:
1. in Perez continuing rendering of services;
2. in Pomar continuing acceptance/benefiting of services rendered;
2. Whether service was requested by Pomar OR volunteered by Perez is
immaterial;
1. So long as said services were accepted,
2. and it was not intended to be gratuitous (Perez expected compensation)
3. ALSO corollary to the principle against unjust enrichment, insofar as Pomar was
benefited at the expense of Perez (time and management of Perez own business),
Perez should be allowed to recover from Pomar.
 (13) Reyes vs Lim quasi contract

KEYWORD: Bagag nawong, mao pay nakasala.

Facts:
1. Lim bought a parcel of land from Reyes with a downpayment of 10 million.
2. After the downpayment, Reyes sold the land to another buyer.
3. Reyes filed a petition to rescind the contract.
4. Lim sued in the RTC for cancelling the subsequent sale.
5. Lim requested the RTC to deposit the 10 million in the clerk of court pending litigation

issue:

1. whether or not RTC can order Lim to deposit the 10 million pending litigation under the
principle of unjust enrichment.

ruling:

1. yes, under art. 22 of the civil code, there is a provision against unjust enrichment. The
RTC is empowered by "equity" to rule such measures pending litigation to avoid unjust
enrichment.
 (14) Rodzssen Supply vs Far East Bank unjust enrichment

KEY: Hydraulic Loaders

Facts:
1. Rodzssen Supply opened a letter of credit in Far East Bank for 30-days in favor of
Ekman for 5 units of hydraulic loaders which was extended
2. The first 3 loaders were delivered and paid by the bank on time
3. The last 2 loaders were delivered late to the bank and it was Rodzssen who paid for it
4. Rodzssen asked for reimbursement from the bank but the bank refused
5. Rodzssen sued in the RTC to recover the payment
6. RTC and CA ruled in favor of the bank
7. Rodzssen went to the SC

Issue:
1. Whether or not Rodzssen can recover the amount paid for the loaders?

Ruling:
1. Yes, SC explained that since the Letter of Credit expired, there was no obligation on the
part of the bank to pay.
2. SC ruled that the receipt of the loaders would be unjust enrichment and that it should be
given back to Rodzssen
3. SC explained when both parties to a transaction are mutually negligent in the
performance of their obligations, the fault of one cancels the negligence of the other.
Thus, their rights and obligations may be determined equitably. No one shall enrich
oneself at the expense of another.
 (15) People vs Catubig delict

KEY: FATHER RAPED DAUGHTER

Facts:
1. The accused Danilo Catubig, who has 5 children, told 4 of his children to go to their
Aunts house (located nearby) and stay there for a while.
2. One daughter was left behind, Dannilyn Catubig, and he told her to go inside their room.
3. When inside, her father then removed her panty, told her to stay on the bed, and then he
started raping her.
4. The auntie, who was suspicious of what the accused was doing to Dannilyn, then
informed Dannilyns mother.
5. Dannilyns mother then told Dannilyn to say everything to her. Thats when Dannilyn
confessed that her father raped her again (she was already raped several times by her
father).
6. The accused denied the accusation saying that the rape charge was only brought
against him because of the ill will between him and his wife and daughter Dannilyn.
7. The RTC convicted the accused of the crime of rape, sentence with DEATH.
8. Automatic review to SC.

Issue:
1. WON a person criminally liable shall also be civilly liable.

Ruling:
1. Yes
2. A person criminally liable is also civilly liable.
3. The civil liability depends on the nature of the crime committed.
4. For the crime of rape, moral damages are always assumed.
5. Actual damages would be based on the actual costs, and the potential earning capacity
of the victim.
6. Exemplary damages are there to serve as a warning, or a deterrent, in order to
discourage the other people from committing the crime.
1. Delict aggravating circumstances
2. Quasi-delict grave negligence
3. Contact and quasi-contract defendant acted in wanton fraudulent, malevolent,
reckless manner
 (16) Air France vs Carrascoso quasi-delict

KEY: FIRST CLASS TICKET

Facts
1. Carrascoso acquired a first class ticket in Air France
2. In a stopover, Carrascoso was made to vacate his first class seat to a white man despite
his objection.
3. Carrascoso filed a case in the CFI for damages against Air France
4. Air France defended that:
1. a first class ticket does not guarantee a first class seat and
2. that there was no liability because such a contract was overridden by verbal
agreement;
3. and even without said verbal agreement, given a contractual relation exists,
moral damages are NOT proper.
5. CFI and CA ruled in favor of Carrascoso

Issue:
1. Whether or not Air France has an obligation to pay damages to Carrascoso.

Ruling:
1. YES
2. Quasi-delicts may arise from contractual obligations
3. Notwithstanding the contractual relation
1. A transport contract is attended with a public duty (unlike generally other
contracts); Carrascosos expulsion was a breach of public duty = quasi delict.
2. A quasi-delict obligation may still arise from the negligent handling in
contractual obligations.
3. Consequently, congruent with the concept of quasi-delict:
1. Moral and exemplary damages may be awarded.
2. MORAL: Due to the humiliation caused.
3. EXAMPLARY: defendant have "acted in a wanton, fraudulent, reckless,
oppressive, or malevolent manner
 (17) Makati Stock Exchange vs. Campos exclusive enumeration of sources of
obligations

KEY: NORM NOT AN ENUMERATED SOURCE

Facts:
1. Campos was declared thru a resolution chairmen emeritus for life of the Makati Stock
Exchange (MSKE)
2. MKSE board made another subsequent resolution (second resolution) denying Campos
further enjoyment of right to equally subscribe to IPOs (notwithstanding that such right
to subscribe is available to all active members of the board, which Campos is the
chairman emeritus of)
3. Campos filed a case in the SICD arguing that the resolution was unjust.
4. SICD ruled in favour of Campos; which SEC en banc reversed; which, in turn, CA set
aside (i.e. ruled in favor of SICD and Campos)
5. MSKE elevated to SC

Issue:
1. WON there is a cause of action in Campo petition to nullify the second resolution.

Ruling:
1. NO.
2. Petition did not sufficiently establish a cause of action:
1. LEGAL BASES:
1. Definition of cause of action act or omission in violation of a right
2. Requisites of cause of action right; obligation to respect/not violate
right; actual breach of right
1. RIGHT in legal sense
1. is defined as claim/title on the interest of whatsoever
enforceable by law
2. must be sourced from the exclusive enumeration in Article
1157 (5 sources)
2. FACTS:
1. Right claimed by Campos;
1. does not originate from any of the 5 enumerated sources
2. sourced only from norm/practice/custom NORMALLY
3. THUS: Campos has no legally enforceable right since such right does not originate
from any of the 5 sources.