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FRANCISCO N. VILLANUEVA v. CA

This case has been cited 5 times or more.

2010-03-02
BRION, J.
We explained the concept of an obiter dictum in Villanueva v. Court of Appeals[32] by saying: It has been held that an adjudication on any point within the issues presented by the case cannot be considered as obiter dictum, and this rule applies to all pertinent questions, although only incidentally involved, which are presented and decided in the regular course of the consideration of the case, and led up to the final conclusion, and to any statement as to matter on which the decision is predicated. Accordingly, a point expressly decided does not lose its value as a precedent because the disposition of the case is, or might have been, made on some other ground, or even though, by reason of other points in the case, the result reached might have been the same if the court had held, on the particular point, otherwise than it did. A decision which the case could have turned on is not regarded as obiter dictum merely because, owing to the disposal of the contention, it was necessary to consider another question, nor can an additional reason in a decision, brought forward after the case has been disposed of on one ground, be regarded as dicta. So, also, where a case presents two (2) or more points, any one of which is sufficient to determine the ultimate issue, but the court actually decides all such points, the case as an authoritative precedent as to every point decided, and none of such points can be regarded as having the status of a dictum, and one point should not be denied authority merely because another point was more dwelt on and more fully argued and considered, nor does a decision on one proposition make statements of the court regarding other propositions dicta.[33] [emphasis supplied.]
2010-02-22
PUNO, C.J.
Our FariƱas ruling on the equal protection implications of the deemed-resigned provisions cannot be minimalized as mere obiter dictum. It is trite to state that an adjudication on any point within the issues presented by the case cannot be considered as obiter dictum.[29] This rule applies to all pertinent questions that are presented and resolved in the regular course of the consideration of the case and lead up to the final conclusion, and to any statement as to the matter on which the decision is predicated.[30] For that reason, a point expressly decided does not lose its value as a precedent because the disposition of the case is, or might have been, made on some other ground; or even though, by reason of other points in the case, the result reached might have been the same if the court had held, on the particular point, otherwise than it did.[31] As we held in Villanueva, Jr. v. Court of Appeals, et al.:[32]
2009-12-04
CARPIO MORALES, J.
To be sure, the Court had on several occasions decreed that a local government unit has the power to classify and convert land from agricultural to non-agricultural prior to the effectivity of the CARL.[23] In Agrarian Reform Beneficiaries Association v. Nicolas,[24] it reiterated that
2009-12-01
NACHURA, J.
To be sure, an adjudication on any point within the issues presented by the case cannot be considered as obiter dictum.[71] This rule applies to all pertinent questions, which are presented and decided in the regular course of the consideration of the case, and led up to the final conclusion, and to any statement as to the matter on which the decision is predicated.[72] For that reason, a point expressly decided does not lose its value as a precedent because the disposition of the case is, or might have been, made on some other ground, or even though, by reason of other points in the case, the result reached might have been the same if the court had held, on the particular point, otherwise than it did.[73] As we held in Villanueva, Jr. v. Court of Appeals, et al.:[74]
2009-08-04
CHICO-NAZARIO, J.
The Court is not persuaded. The Court resolved the BDO case on both procedural and substantive grounds. The declaration of the Court in the BDO case - that the Petition therein should be denied because the CTA en banc committed no reversible error in rendering its assailed decision - was purposely and categorically made. An additional reason in a decision (or in this case, a resolution), brought forward after the case has been disposed of on one ground, is not to be regarded as dicta. So, also, where a case presents two or more points, any one of which is sufficient to determine the ultimate issue, but the court actually decides all such points, the case becomes an authoritative precedent as to every point decided; none of such points can be regarded as having the status of a dictum, and one point should not be denied authority merely because another point was more dwelt on and more fully argued and considered; nor does a decision on one proposition make statements of the court regarding other propositions dicta.[13]