This paper presents evidence from Philippine languages which suggests a number of modifications in the theory of case grammar. Philippine languages and adjacent related languages mark the case relationship between the verb and one noun phrase in the sentence by a particle on the noun phrase and an affix on the verb, a phenomenon which in recent studies has been called "focus." In "The Case for Case" (ED 019 631) Fillmore, working with Maranao, a Philippine language, incorporates focusing into his general theory of case grammar. The purpose of the present paper is to examine the Philippine situation more closely, since the author considers that what has been written on it from the case grammar point of view usually considers only part of the evidence. Examples used here are drawn largely from Tagalog, Bikol and Waray. In the first sets of examples, Fillmore's underlying case preposition is intuitively clear with some modification, and it is easy to go from there to the correct surface focus. After examining these examples, the author considers a class which suggests that the grammar should account for another underlying case: the associative. (Author/FWB)