It is only when an extraordinary inflation supervenes that the law affords the parties a relief in contractual obligations.Art. 1250 of the Civil Code provides that "in case an extraordinary inflation or deflation of the currency stipulated should supervene, the value of the currency at the time of the establishment of the obligation shall be the basis of the payment, unless there is an agreement to the contrary." In Filipino Pipe and Foundry Corporation v. NAWASA, the Court explained extraordinary inflation thus: "Extraordinary inflation exists when 'there is a decrease or increase in the purchasing power of the Philippine currency which is unusual or beyond the common fluctuation in the value of said currency, and such decrease or increase could not have been reasonably foreseen or was manifestly beyond the contemplation of the parties at the time of the establishment of the obligation. (Tolentino, Commentaries and Jurisprudence on the Civil Code, Vol. IV, p. 284.)

The Court a quo properly appreciated the aggravating circumstance of treachery which qualified the crime to murder. It was clearly established that the accused-appellant fired six successive shots on the victim, suddenly, without warning, and from behind, giving the victim no chance to flee or to prepare for his defense or to put up the least resistance to such sudden assault. There is treachery when the means, manner or method of attack employed by the offender offered no risk to himself from any defensive or retaliatory act which the victim might have taken.

The rule is that certiorari as a special civil action will not lie unless a motion for reconsideration is filed before the respondent tribunal to allow it an opportunity to correct its imputed errors.[Tan vs. CA, 275 SCRA 568; Quiambao vs. NLRC, 254 SCRA 211.]  There are exceptions to the rule, these are: (1) when the issue raised is purely one of law; (2) where public interest is involved; (3) in cases of emergency; or (4) where special circumstances warrant immediate or more direct action.

This Court has consistently ruled that "disability should not be understood more on its medical significance but on the loss of earning capacity. Permanent total disability means disablement of an employee to earn wages in the same kind of work, or work of similar nature that he was trained for or accustomed to perform, or any kind of work which a person of [his] mentality and attainment could do. It does not mean absolute helplessness." [GSIS VS. CA, 285 SCRA 430 (1998); GSIS VS. CA, 260 SCRA 133 (1996); Bejerano vs. CA, 205 SCRA 598 (1992)] This Court has also held that in disability compensation, it is not the injury which is compensated, but rather it is the incapacity to work resulting in the impairment of one's earning capacity.

Since a negotiable instrument is only a substitute for money and not money, the delivery of such an instrument does not, by itself, operate as payment.  A check, whether a manager's check or ordinary check, is not legal tender, and an offer of a check in payment of a debt is not a valid tender of payment and may be refused receipt by the obligee or creditor. Mere delivery of checks does not discharge the obligation under a judgment. The obligation is not extinguished and remains suspended until the payment by commercial document is actually realized.