CIVIL LAW:OBLIGATIONS AND CONTRACTS; TENDER OF PAYMENT OF A JUDGMENT NOT SAME AS TENDER OF PAYMENT OF CONTRACTUAL DEBT.
Moreover, as previously shown, the rights and obligations of the parties arose from a judgment, not from contract and therefore the Civil Code requirements as to consignation are not applicable.  Thus, in case of refusal of a tender of the amount due on a judgment, the court may direct the money to be paid in court and when this is done, order satisfaction of the judgment to be entered.  The tender of payment of a judgment is not the same as tender of payment of a contractual debt and consignation of the money due from a debtor to a creditor.  The requisites of consignation under Art. 1256 et seq. do not apply to the former.
CRIMINAL LAW:DRUG-PUSHING; MAY BE COMMITTED ANYTIME AND ANY PLACE.
Drug-pushing when done on a small level as in this case belongs to that class of crimes that may be committed at anytime and at any place. After the offer to buy is accepted and the exchange is made, the illegal transaction is completed in a few minutes. The fact that the parties are in a public place and in the presence of other people may not always discourage them from pursuing their illegal trade as these factors may even serve to camouflage the same. Hence, the Court has sustained the conviction of drug pushers caught selling illegal drugs in a billiard hall (People v. Rubio, G.R. No. 66875, June 19, 1986, 142 SCRA 329; in front of a store; along a street at 1:45 p.m. (People v. Toledo, G.R. No. 67609, November 22, 1985), and in front of a house (People v. Policarpio, G.R. No. 69844, February 23, 1988).
REMEDIAL LAW:APPEALS; DUTY OF APPELLANT TO PROSECUTE HIS APPEAL WITH REASONABLE DILIGENCE.
A rule long familiar to practitioners in this jurisdiction is that it is the duty of the appellant to prosecute his appeal with reasonable diligence. He cannot simply fold his arms and say that it is the duty of the Clerk of Court of First Instance under the provisions of Section 11, Rule 41 of the Rules of Court to transmit the record on appeal to the appellate court. It is appellants duty to make the Clerk act and, if necessary, procure a court order to compel him to act. He cannot idly sit by and wait till this is done. He cannot afterwards wash his hands and say that delay in the transmittal of the record on appeal was not his fault. For indeed, this duty imposed upon him was precisely to spur on the slothful.
LABOR LAW:STRIKES; RETURN-TO-WORK ORDER; MAY BE ENFORCED WHETHER THE STRIKE IS LEGAL OR ILLEGAL.
One other point that must be underscored is that the return-to-work order is issued pending the determination of the legality or illegality of the strike. It is not correct to say that it may be enforced only if the strike is legal and may be disregarded if the strike is illegal, for the purpose precisely is to maintain the status quo while the determination is being made. Otherwise, the workers who contend that their strike is legal can refuse to return to work to their work and cause a standstill on the company operations while retaining the positions they refuse to discharge or allow the management to fill. Worse, they will also claim payment for work not done, on the ground that they are still legally employed although actually engaged in the activities inimical to their employer's interest.
COMMERCIAL LAW:FOREIGN CORPORATIONS; SINGLE ACT MAY INDICATE PURPOSE OF FOREIGN CORPORATION TO DO BUSINESS IN THE STATE.
The rule stated in the preceding section that the doing of a single act does not constitute business within the meaning of statutes prescribing the conditions to be complied with by foreign corporations must be qualified to this extent, that a single act may bring the corporation within the purview of the statute where it is an act of the ordinary business of the corporation. In such a case, the single act or transaction is not merely incidental or casual, but is of such character as distinctly to indicate a purpose on the part of the foreign corporation to do other business in the state, and to make the state a base of operations for the conduct of a part of the corporations' ordinary business.
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