Normally, the probate of a will does not look into its intrinsic validity. The authentication of a will decides no other questions than such as touch upon the capacity of the testator and the compliance with those requisites or solemnities which the law prescribes for the validity of the wills. It does not determine nor even by implication prejudge the validity or efficiency of the provisions of the will, thus may be impugned as being vicious or null, notwithstanding its authentication. The question relating to these points remain entirely unaffected, and may be raised even after the will has been authenticated.

Since rape and homicide co-exist in the commission of robbery, the offense committed by the appellants is the special complex crime of robbery with homicide, aggravated by rape, punishable under Paragraph 1 of Article 294 of the Revised Penal Code (RPC). It does not matter if the technical name assigned to the offense is rape with homicide and with robbery in band, for the real nature of the crime charged is determined not by the title of the complaint, nor by the specification of the provision of the law alleged to have been violated, but by the facts recited in the complaint or information. (See People v. Oliviera, 67 Phil. 427 [1939]) As the acts constituting robbery with homicide were clearly set forth in the complaint and proven during trial, then the appellants may be held liable for such crime, regardless of the erroneous designation of the offense.

Circumstantial evidence may be resorted to in proving the identity of the accused when direct evidence is not available, otherwise felons would go scot-free and the community would be denied proper protection.  The rules on evidence and jurisprudence sustain the conviction of an accused through circumstantial evidence when the following requisites concur:  (1) there must be more than one circumstance; (2) the inference must be based on proven facts; and (3) the combination of all circumstances produces a conviction beyond doubt of the guilt of the accused.

It must be borne in mind that local private employment agencies, before they can commence recruiting workers for their foreign principal, must submit with the POEA a formal appointment or agency contract executed by the foreign based employer empowering the local agent to sue and be sued jointly and solidarily with the principal or foreign-based employer for any of the violations of the recruitment agreement and contract of employment. Considering that the local private employment agency may sue on behalf of its foreign principal on the basis of its contractual undertakings submitted to the POEA, there is no reason why the said agency cannot likewise sign or execute a certification of non-forum shopping for its own purposes and/or on behalf of its foreign principal.

It is familiar doctrine that if a corporation knowingly permits one of its officers, or any other agent, to act within the scope of an apparent authority, it holds him out to the public as possessing the power to do those acts; and thus, the corporation will, as against anyone who has in good faith dealt with it through such agent, be estopped from denying the agent’s authority.