A subordinate lien holder is a proper, even a necessary, but not an indispensable, party to a foreclosure proceeding.  Appropriate relief could be granted by the court to the mortgagee in the foreclosure proceeding, without affecting the rights of the subordinate lien holders.  The effect of the failure on the part of the mortgagee to make the subordinate lien holder a defendant is that the decree entered in the foreclosure proceeding would not deprive the subordinate lien holder of his right of redemption.  A decree of foreclosure in a suit to which the holders of a second lien are not parties leaves the equity of redemption in favor of such lien holders unforeclosed and unaffected.

On the matter of conviction of the accused based on circumstantial evidence, the following requisites need to be satisfied:  (1) there must be more than one circumstance;  (2) the facts from which the inferences are derived are proven; and (3) the combination of all the circumstances is such as to produce a conviction beyond a reasonable doubt. Or, as jurisprudentially formulated, a judgment of conviction based on circumstantial evidence can be upheld only if the circumstances proven constitute “an unbroken chain which leads to one fair and reasonable conclusion which points to the defendant, to the exclusion of all others, as the guilty person, i.e. the circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with any other hypothesis except that of guilty.”

No one can dispute that the "essence of compromises, being mutual concessions by the parties, is to avoid or end litigation. It is therefore a well-settled rule that a compromise, once approved by final orders of the court has the force of res judicata between the parties and should not be disturbed except for vices of consent or forgery". In a string of decisions, this Court has repeatedly held that a judgment upon compromise which is a judgment embodying a compromise agreement entered into by the parties in which they make reciprocal concessions in order to terminate a litigation already instituted  is not appealable, is immediately executory and has the effect of res judicata.

With regard to the remedy of appeal to which the petitioners are entitled under the applicable law then, this Court deems it impractical to allow the parties to still pursue their appeal to the Office of the President at this time considering that under the present law, the Labor Code, as amended, the President may only assume jurisdiction only in cases which the latter considers to be of national interest. With respect to those labor cases which do not involve national interest, such as the case at bar, the machinery or body in the Office of the President governing such appeals apparently is no longer existing under the present law. Hence, for just and equitable considerations, this Court instead shall grant the petitioners the opportunity to file a proper petition for certiorari within a reasonable time questioning the decision on the merits of the Secretary of Labor.

The Trust Receipts Law does not seek to enforce payment of the loan, rather it punishes the dishonesty and abuse of confidence in the handling of money or goods to the prejudice of another regardless of whether the latter is the owner. The practice of banks of making borrowers sign trust receipts to facilitate collection of loans and place them under the threats of criminal prosecution should they be unable to pay it may be unjust and inequitable, if not reprehensible.  Such agreements are contracts of adhesion which borrowers have no option but to sign lest their loan be disapproved.  The resort to this scheme leaves poor and hapless borrowers at the mercy of banks, and is prone to misinterpretation.