It is also important to bear in mind that in a reciprocal contract like a lease, the period of the lease must be deemed to have been agreed upon for the benefit of both parties, absent language showing that the term was deliberately set for the benefit of the lessee or lessor alone. We are not aware of any presumption in law that the term of a lease is designated for the benefit of the lessee alone.

The falsification of a public document may be a means of committing estafa because before the falsified document is actually utilized to defraud another, the crime of falsification has already been consummated, damage or intent to cause damage not being an element of the crime of falsification of public, official or commercial documents. The damage to another is caused by the commission of estafa, not by the falsification of the document, hence, the falsification of the public, official or commercial document is only a necessary means to commit the estafa. 

This Court has explained that a defendant in a replevin suit, may demand the return of possession of the property replevined by filing a redelivery bond executed to the plaintiff in double the value of the property as stated in the plaintiff's affidavit, within the periods specified in Sections 5 and 6 of Rule 60 of the Rules of Court. Under Section 5, petitioner may "at any time before the delivery of the property to the plaintiff' require the return of the property; in Section 6, he may do so, "within five (5) days after the taking of the property by the officer." Both these periods are mandatory in character. Thus, a lower court which approves a counterbond filed beyond the statutory periods, acts in excess of jurisdiction.

Under Article 256 of the Labor Code, to have a valid certification election at least a majority of all eligible voters in the unit must have cast their votes. It is apparent that incidental to the power of the med-arbiter to hear and decide representation cases is the power to determine who the eligible voters are. In so doing, it is axiomatic that the med-arbiter should determine the legality of the employees' membership in the union. In the case at bar, it obviously becomes necessary to consider first the propriety of the employees' membership withdrawal from the cooperative before a certification election can be had.

Compulsory Motor Vehicle Liability Insurance (third party liability, or TPL) is primarily intended to provide compensation for the death or bodily injuries suffered by innocent third parties or passengers as a result of a negligent operation and use of motor vehicles. The victims and or their dependents are assured of immediate financial assistance, regardless of the financial capacity of the motor vehicle owners.  The insurer's liability accrues immediately upon the occurrence of the injury or event upon which the liability depends, and does not depend on the recovery of judgment by the injured party against the insured