Lemoncito Law Office

04/01/2026

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SUPREME COURT DECLARES MARRIAGE VOID DUE TO WIFE'S CONTROLLING CONDUCT

The Supreme Court (SC) has affirmed the Court of Appeals (CA) ruling that nullified the marriage of a couple on the ground of the wife's psychological incapacity demonstrated through her domineering and controlling attitude to the extent that she always demands her husband to always update her of his whereabouts.

In a 14-page decision authored by Associate Justice Henri Jean Paul Inting, the SC's Third Division has declared void from the beginning the marriage between a couple on the ground of the wife's psychological incapacity as provided under Article 36 of the Family Code.

The couple were married on January 22, 1995. They had no antenuptial agreement, and their property relations are governed by the regime of absolute community of property.

The husband narrated that even prior to the wedding, the psychological incapacity of his wife, whose childhood was marked with overindulgence at a time when her pathogenic family was still wealthy, was demonstrated by her domineering attitude coupled with her lazy and poor study habits.

He added that after the wedding, the wife's incapacity to perform her marital obligations supposedly became more apparent given that she continued to be domineering and controlling as she required the husband to always update her of his whereabouts. She also displayed an arrogant and haughty attitude, especially towards his mother.

More than these, the husband also claimed that the wife's psychologically abused their children when she physically attacked him in the presence of their kids while he was holding their daughter, and reached the point when she sneaked in the house of the husband's mother to take the kids home without telling anyone. This paved the way for him to file a petition for nullification of marriage.

A clinical psychologist testified that the wife suffered from Narcissistic Personality Disorder with paranoid features, which is categorized as grave, incurable, and with antecedents. The expert recommended the nullification of their marriage.

In her defense, the wife countered that it was the husband who abused their children, not only psychologically but also s*xually. She averred that in times of disagreement, her husband also physically and verbally abused her.

The Regional Trial Court and Court of Appeals (CA) granted the petition and declared void ab initio their marriage. The CA gave much weight to the psychological reports, which showed that the wife's psychological incapacity is grave and incurable. Aggrieved the wife elevated the case before the Supreme Court.

In denying her appeal, the high court found no valid reason to overturn the consistent findings and conclusions of the RTC and the CA, which are supported by the evidence on record.

It cited the landmark case of Tan-Andal vs. Andal, which requires that in order to grant the nullification of marriage due to psychological incapacity, the same must be grave enough to cause the couple's inability, not mere refusal, neglect, or difficulty, to perform the essential marital obligations.

It must also be shown that the psychological incapacity existed prior to or at the time of the celebration of the marriage, and it must be proven that the spouse, by reason of his or her psychological incapacity, persistently fails to comply with the essential marital obligations.

The SC agreed to the CA finding that the evidence presented by the husband is sufficient to establish that the wife suffered from a narcissistic personality disorder with paranoid features through the accounts of his witnesses, corroborated by the psychological report and testimony of the clinical psychologist.

It also emphasized that the nature of the wife's psychological incapacity is severe and pervasive, citing the psychological reports that revealed it affects all areas of her life, to the point that she is unable to perform her essential marital obligations to her husband.

The high court also took into consideration that it is quite apparent that the wife's psychological incapacity, as shown by the behavioral manifestations of her personality disorder, existed even before their marriage, as the same is rooted in her childhood and carried over into her adulthood.

It ruled that since their marriage was declared void, the rules on co-ownership, in relation to Article 147 of the Family Code, govern the liquidation, partition, and distribution of their common properties.

Hence, the highest bench deemed it proper to remand the case back to the trial court, as it appears that both parties have raised issues regarding their property relations in their respective pleadings.

28/08/2025

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The (SC) has ruled that a Special Power of Attorney (SPA) automatically ceases upon the death of the person who granted it, and any acts carried out by the agent afterwards are void, unless covered by narrow exceptions under the law.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division held that Jessica Alova Uberas lost her authority under the SPA to act on behalf of her father, Meliton Alova, upon his death in 1998.

In 1998, Meliton executed an SPA in favor of Jessica over the subject conjugal property. He died later that year. Despite the death of his father, Jessica still used the same SPA in 2003 to execute a mortgage over the said property in favor of San Miguel Foods, Inc. (SMFI) to secure her loan from the company. Jessica failed to pay the loan and the property was foreclosed where SMFI emerged as the winning bidder.

Felicidad Alova and Decelyn Alova Pution, the widow and other daughter of Meliton, filed a case to nullify the mortgage and the foreclosure sale.

Both the Regional Trial Court (RTC) and the Court of Appeals (CA) determined that Meliton’s death ended the agency. However, the RTC found that because the SPA had the conformity of Felicidad, Meliton’s wife, the mortgage was valid on her ½ share of the conjugal property. On the other hand, the CA declared the mortgage invalid, citing that it was not executed on behalf of Spouses Meliton and Felicidad.

SMFI appealed to the SC, which partly ruled in its favor. The Court upheld the agency’s termination but validated the mortgage and foreclosure sale with respect to Jessica’s undivided share in the property.

The SC explained that under an SPA, which is a contract of agency, a principal authorizes an agent to act on his or her behalf in transactions with third persons. Agency is personal, representative, and derivative, and it ends upon the death of either the principal or the agent.

Any act by the agent after the principal’s death is void, unless it falls under two Civil Code exceptions: (1) when the agency was for the parties’ common interest, and (2) when the agent, unaware of the death or agency’s end, contracted with a third party in good faith.

In this case, there was no showing that these exceptions were applicable. Jessica was fully aware of her father’s death, and the SPA was not made for their mutual benefit.

The SC also reiterated that for an agent’s act to bind the principal, the deed must clearly be made, signed, and sealed in the principal’s name.

Here, although Jessica was described in the beginning of the deed as Meliton’s attorney-in-fact, the mortgage was signed by Jessica in her personal capacity, as it was neither executed nor sealed in Meliton’s name, and without indication that she was acting as attorney-in-fact.

The Court also ruled that Meliton’s wife, Felicidad, was not bound as a principal under the SPA, as she only provided her marital conformity.

However, the Court clarified that the mortgage and foreclosure sale were not entirely void. Jessica automatically became a co-owner of the property after her father’s death. When she signed the mortgage, she encumbered her share in the property to secure her obligation to SMFI. Therefore, the mortgage and foreclosure sale were valid only for Jessica’s share.

The Court remanded the case to the RTC to determine Jessica’s share in the subject property and to annotate the shares of Meliton’s other heirs, and that of SMFI which acquired Jessica’s interest.

Read the full text of the press release at https://tinyurl.com/27t9k6vy

Read the full text of the Decision at https://sc.judiciary.gov.ph/260071-san-miguel-foods-inc-vs-felicidad-d-alova-and-decelyn-alova-pution/

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03/07/2025

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| The Supreme Court (SC) held that an acknowledgment receipt cannot be considered a contract of sale if it doesn't clearly show that the seller intends to transfer ownership of the property to the buyer.

In a 14-page decision penned by Associate Justice Maria Filomena Singh, the SC's Third Division has dismissed the claim for Specific Performance and Damages filed by spouses Joselito and Adriana Gopez, who bought a parcel of land from Virgilio Chavez.

In 2011, Chavez decided to sell the two parcels of land they inherited from their predecessors to the Gopezes. Chavez asked that the agreement be formalized in a contract to sell and that Spouses Gopez pay PHP 5 million as a down payment. Later, the Gopezes issued Chavez a check for PHP 200,000 to show their commitment to buy the properties; they also vowed to fully pay the down payment in exchange for the delivery of the contract to sell.

The Gopezes failed to pay the PHP 5 million down payment. Instead, they delayed the preparation of the draft special powers of attorney, extrajudicial settlement of estates, and the contract to sell, which were needed to authorize attorneys-in-fact who would sign for and on behalf of Chavez.

When the Contract to Sell was formally drafted, Chavez noticed that the Spouses Gopez significantly modified the terms earlier agreed upon between the parties by excluding the agreement to pay a PHP 5 million down payment, imposing new conditions, and creating obligations for Chavez.

Meanwhile, the Spouses Gopez claimed that in addition to the initial PHP 200,000 worth of earnest money, they made partial payments of PHP 1.5 million through checks, but by the time Chavez wanted to terminate the agreement. The Spouses Gopez also alleged that the reason why they were unable to immediately prepare the documents is because Chavez failed to deliver the necessary requirements.

Later, the Spouses Gopez discovered that the titles covering the subject properties were cancelled and issued in the names of Chavez and that the same were being offered for sale to third persons. This prompted them to file a claim for specific performance and Dldamages before the Regional Trial Court (RTC).

Initially, the RTC dismissed the said complaint, saying since the parties had entered into a contract to sell and not a contract of sale, the earnest money of PHP 1.5 million did not result in the perfection of the contract. The said decision was later reversed by the Court of Appeals as it held that the acknowledgement receipt contains all the elements of a contract of sale.

As a result, the CA ordered Alvarez to execute the necessary deed of absolute sale in favor of the Spouses Gopez, which in turn required them to pay the whole balance of the purchase price. This paved the way for Chavez to elevate the case before the Supreme Court.

In reinstating the RTC ruling with modification, the high court held that the mention of earnest money between Spouses Gopez and Chavez did not convert the acknowledgement receipt into a contract of sale.

“This Court further finds that the mention of earnest money did not convert the Acknowledgement Receipt into a Contract of Sale. Although earnest money is usually given in a perfected Contract of Sale, it may also be given in a Contract to Sell,” the Supreme Court said.

It clarified that the earnest money worth PHP 200,000 paid by Spouses Gopez was given in a Contract to Sell and will be considered part of the consideration only if the sale is consummated upon full payment of the purchase price.

The SC emphasized that since both parties entered into a contract to sell, Chavez has the right to terminate the agreement due to the spouses Gopez' non-fulfillment of the conditions.

“In contracts to sell, the condition is a positive suspensive condition, while in contracts of sale, the obligation is a negative resolutory condition. In this case, non-fulfillment of the conditions under the Contract to Sell rendered the contract ineffective, and there was no need to rescind the contract anymore. ” the Supreme Court added.

The court declared ineffective the contract to sell between the parties due to the refusal of the Spouses Gopez to prepare the necessary documents to reflect the terms of the agreement and to pay the purchase price.

02/07/2025

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The (SC) has found two managers of a pizza restaurant guilty of simple theft for having kept service charges that should have been paid to the restaurant’s employees.

In a Decision written by Associate Justice Antonio T. Kho, Jr., the SC’s Second Division sentenced Janice Teologo and Jennifer Delos Santos, two store managers at the Shakey’s branch in Angono, Rizal, to 6 months in prison. It also ordered them to pay their fellow employees the withheld service charges.

One of Teologo and Delos Santos’ duties as managers was to give the employees their salaries and shares in the service charges. However, employees of Shakey’s Angono branch reported to franchise owner Big G Philfoods & Entertainment that they had not been receiving their share of service charges.

The employees claimed that notwithstanding this, they had been made to sign payroll documents indicating that they received their shares. They said that according to the store managers, this was pursuant to an alleged company policy.

While the trial court and the Court of Appeals convicted Teologo and Delos Santos of qualified theft, the SC modified the conviction to simple theft.

The 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 provides that the crime of theft is committed by one who takes something that belongs to another without permission, intending to benefit from it, without using violence or force. Theft becomes qualified when it involves the abuse of trust or confidence.

In this case, while the store managers took the service charges meant for the employees, the SC clarified that the victims were the employees, not the employer Big G Philfoods & Entertainment, Inc.

Since there is no special trust relationship between managers and rank-and-file workers, there was no abuse of trust or confidence in this case that would have qualified the theft.

Read the full text of the Press Release at https://tinyurl.com/2f6a4tvb.

Read the full text of the Decision at https://tinyurl.com/36vavmjv.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

26/06/2025

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THE COURT CANNOT FORCE A SPOUSE TO STAY IN A LOVELESS MARRIAGE—SUPREME COURT

| The Supreme Court (SC) has ruled that a spouse’s “inability to love or emotionally connect with their partner,“ if rooted in a genuine personality disorder, could be deemed as evidence to prove psychological incapacity in marital obligations.

In a 16-page decision penned by Senior Associate Justice Marvic Leonen, the SC's Second Division granted the petition of Ronald Boado to annul his marriage to his wife, Florence Galvez-Boado, on the ground of his psychological incapacity.

Their love story started when they met in 1999. Roughly three years later, or in 2002, they decided to settle down and marry each other. Florence and Ronald decided not to live together immediately, as Ronald worked in Saudi Arabia.

During Ronald's brief vacation in 2004, they held a church wedding, after which the husband returned abroad. A year later, he came back to the Philippines, which served as their opportunity to live together. Ronald and Florence were blessed with two children: a son in 2007 and a daughter in 2012. As the years passed by, their relationship began to turn sour due to frequent misunderstandings and periods of separation.

In 2016, Ronald filed a petition for nullification of marriage on the ground of his psychological incapacity. He attached a psychologist's diagnosis, which showed that he had passive-aggressive personality disorder—an illness marked by emotional detachment and difficulty maintaining close relationships.

Initially the Regional Trial Court granted the petition, saying the petitioner had sufficiently proven psychological incapacity in a legal sense, but the said ruling was later reversed by the Court of Appeals. This prompted Ronald to elevate the case before the Supreme Court.

In reinstating the RTC's ruling and deciding in favor of Ronald, the high court said his psychological incapacity had been sufficiently proven. It cited Article 36 of the Family Code, which states that a marriage may be declared void if one or both spouses are psychologically incapable of fulfilling essential marital obligations—even if such incapacity manifested only after the wedding.

The SC found that Ronald's incapacity was deeply rooted in his personal character and had existed before the marriage. It emphasized that psychological incapacity may not be immediately visible and may surface only later in the relationship.

It added that Ronald's inability to emotionally connect stemmed from an upbringing marked by strictness and emotional immaturity from his parents. While he could provide for his family financially, he struggled to meet his wife’s emotional needs, including basic companionship.

“Loving one’s spouse is an important, if not the most important, essential marital obligation,” the Supreme Court said.

The SC ruled to grant Ronald's petition because of his inability as a husband to love his wife, which was caused by his psychological condition, adding that the court cannot force him to stay in a loveless marriage.

25/06/2025

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The has reiterated that a victim’s admission of being in a relationship with her abuser does not imply consent to s*x. Clear and convincing evidence of consent is still required.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC’s Second Division affirmed the conviction of accused Jhopet Hernandez Toralde for r**e of a 14-year old girl.

In 2017, Toralde showed up at the victim’s house unannounced and forced her to have s*x, threatening to show her family a video of them kissing if she refused. Out of fear, the victim gave in. She then reported the incident to the police.

During trial, the defense claimed that Toralde did not force the victim to have s*xual in*******se as he and the victim were in a romantic relationship—a defense known as the “𝘀𝘄𝗲𝗲𝘁𝗵𝗲𝗮𝗿𝘁 𝘁𝗵𝗲𝗼𝗿𝘆.”

The SC, however, rejected Toralde’s sweetheart defense and declared him guilty of r**e under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦, citing that all elements of the crime were present, including the use of threats and intimidation to force s*xual in*******se.

The SC rejected Toralde’s sweetheart defense, affirming that being in a relationship does not grant the right to force s*x. The SC stressed that proving a romantic relationship is not enough—there must be clear evidence of consent.

Toralde was sentenced to suffer the penalty of 𝘳𝘦𝘤𝘭𝘶𝘴𝘪𝘰𝘯 𝘱𝘦𝘳𝘱𝘦𝘵𝘶𝘢, or a maximum of 40 years in prison, and ordered to pay the victim PHP 225,000 in damages.

Read the full text of the Press Release at https://tinyurl.com/nvpvv9fm.

Read the full text of the Decision at https://tinyurl.com/6tzma4tx

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05/06/2025

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The (SC) has ruled that when a Filipino asks a Philippine court to recognize a foreign divorce, they only need to prove the law of the country where the divorce was obtained – not the law of their foreign spouse’s nationality.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division sent a case back to the Court of Appeals (CA) to give a Filipina a chance to properly prove the divorce laws of Kentucky, United States of America (U.S.A).

The Filipina married a Peruvian citizen in New Jersey, U.S.A; they later settled in Kentucky. Due to marital issues, the husband ended the marriage by obtaining a divorce decree from a Kentucky court.

The Filipina then filed a petition before the Regional Trial Court in the Philippines to have the divorce recognized. She submitted a copy of the divorce decree, along with printouts of Kentucky and Peruvian marriage laws.

The SC clarified that in recognition of foreign divorce cases, what matters is the law of the country that issued the divorce decree. Since the divorce was granted in Kentucky, only Kentucky law needed to be proven.

The SC explained that under Article 26 (2) of the Family Code, a Filipino may remarry if their foreign spouse gets a valid divorce abroad that allows them to remarry. Philippine courts must first determine if the divorce was valid under the applicable foreign law, and the Filipino spouse must prove this law.

The SC also emphasized the relevance of the international law principle of comity of nations. This principle allows judicial acts of one country – such as court rulings or decrees – to be recognized in another, based on mutual respect between states. It also acknowledges the authority of a foreign state not only over its citizens but also over other individuals under its jurisdiction, like legal residents.

However, the SC returned the case to the CA to give the Filipina, who submitted a mere printout of Kentucky law, a chance to submit the proper documents.

Read the full text of the Press Release at https://tinyurl.com/4jhyh8vv.

Read the full text of the Decision at https://tinyurl.com/ympmypuz.

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02/05/2025

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The (SC) has reiterated that while notarized documents are presumed authentic, they will be invalidated if proven to be fake.

In a Decision written by Associate Justice Amy C. Lazaro-Javier, the SC’s Second Division cleared Gil Chua (Chua) of liability for Interbrand Logistics and Distribution, Inc.’s (Interbrand) unpaid PHP 150 million loan from the Bank of Commerce (Bank).

The loan was secured by promissory notes and notarized Continuing Surety Agreements (CSAs) signed by several of Interbrand’s officers. Chua was listed as one of the sureties, but unlike the other signatories, he was not an officer, director, or shareholder of the company. When Interbrand failed to pay the loans, the Bank sued the company and all the sureties.

Chua denied any involvement, saying he never signed a CSA nor appeared before a notary public. The Bank, however, insisted that the CSA, as a notarized document, is presumed valid.

Emphasizing that notarization does not cure a forged or fabricated document, the SC ruled that the notarized CAS was questionable and that Chua was not bound by it.

The SC found that Chua successfully challenged the validity of the CSA. He consistently denied signing the document or appearing before a notary. He held no position or interest in Interbrand, and the Bank had no specimen of his signature to verify the CSA.

Additionally, his CSA and another were allegedly signed on the same day in far-apart locations but had identical witnesses, which raised doubts as to their authenticity. The notary public who supposedly notarized the CSA was also never presented in court.

Read the full text of the Press Release at https://tinyurl.com/2zz7wmbd.

Read the full text of the Decision at https://tinyurl.com/5t4dxh45.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

28/04/2025

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The (SC) has held a school civilly liable for negligence after a bullying incident led to the assault of a student during class.

In a Decision written by Associate Justice Mario V. Lopez, the SC’s Second Division found that Mother Goose Special School System, Inc. (Mother Goose School) failed to address a punching incident involving three grade school students inside one of its classrooms.

When the victim’s parents raised the matter with the school, their complaints were ignored, prompting them to file formal requests for investigation. Mother Goose School ultimately concluded the incident was mere "teasing" or "rough play" and took no disciplinary action.

Dissatisfied, the parents filed a complaint for damages against the school, the teachers, and the other students’ fathers.

Ordering Mother Goose School to pay the victim’s parents PHP 650,000 in damages and attorney’s fees, the SC agreed with the trial court and the Court of Appeals that Mother Goose School was grossly negligent in handling the punching incident.

The SC emphasized that schools have a contractual obligation to ensure a safe learning environment. It also reiterated that schools must maintain peace and order within their premises, and even outside campus during school activities. They may avoid liability only upon proof they exercised due diligence.

The SC found Mother Goose School negligent for its lack of proper protocols, failure to inform the victim’s parents promptly, and inaccuracies in its investigation.

Read the full text of the Press Release at https://tinyurl.com/m86ufzwa.

Read the full text of the Decision at https://tinyurl.com/mparp5dp.

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21/04/2025

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The (SC) has ruled that land buyers must verify ownership by checking the certificate of title and reviewing the records in the Registry of Deeds to avoid fraudulent transactions.

In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the Court’s Third Division upheld the rulings of the Regional Trial Court and Court of Appeals which voided the land titles of a married couple who failed to conduct due diligence when they bought the properties from someone who acquired her titles through fraud.

Orencio and Eloisa Manalese purchased two parcels of land from Carina Pinpin, who presented certificates of title in her name and claimed to have bought the properties from the original owners, the late Narciso and Ofelia Ferreras.

However, the administrator of the Ferreras estate, alleged that Pinpin fraudulently obtained duplicate titles by submitting a false affidavit of loss and a forged deed of sale. Pinpin then used these to sell the properties to Spouses Manalese a year later.

The Supreme Court upheld the lower courts’ findings, stressing that buyers must check both the certificate of title and the Registry of Deeds records before purchasing land. Relying solely on a certificate of title is insufficient, especially if there are signs of fraud or irregularity.

In this case, the Spouses Manelese failed to investigate despite multiple warning signs, making them liable for not exercising due diligence. Several key documents were already on record, including the affidavit of loss procured by Pinpin, the issuance of another set of duplicate titles, a second affidavit of loss by a certain Zenaida Ferreras, and the nearly simultaneous registrations of these three annotations on the titles.

Said the Court: “Since petitioners did not inquire into the register, and even without such inquiry, they are nonetheless constructively notified of every registration affecting the said subject properties, they cannot feign ignorance of such
registrations.”

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-land-buyers-must-check-both-title-and-registry-of-deeds-records/.

Read the full text of the Decision at https://tinyurl.com/3njh86mk.

Read the Separate Concurring Opinion of Associate Justice Henri Jean Paul B. Inting at https://tinyurl.com/3k2p236k.

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07/04/2025

Heads Up, Taxpayers!

The BIR has just released Revenue Memorandum Circular No. 28-2025 (dated April 4, 2025), updating the classification and processing times for One-Time Transactions (ONETTs) such as:

1. Transfer of Real Property / Shares of Stocks
2. Donation of Properties
3. Estate of the Decedent

New Processing Time Guidelines:

Simple: 3 working days for OCS, 7 for eCAR
Complex: 7 working days for both
Highly Technical (Estate Tax): 20 working days for OCS, 7 for eCAR

Classification depends on the number of properties involved and whether an ocular inspection is required.

For full details, check the official BIR website: www.bir.gov.ph

17/03/2025

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The (SC) has ruled that a teacher may be held liable to pay damages for harm caused by a student under their supervision if they did not exercise due diligence in preventing the incident.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division upheld the liability of Gil Apolinario (Apolinario), the principal of Brgy. Palale Elementary School in Sta. Margarita, Samar, for damages arising from the death of Francisco De Los Santos (De Los Santos).

The incident involved a 15-year-old student who, under Apolinario’s instruction, cut down a banana plant near the school and on the side of a highway. The plant fell and struck De Los Santos, who was passing by on a motorcycle, leading to his death. De Los Santos’ family then filed a complaint for damages against Apolinario.

Ruling that Apolinario, as the teacher-in-charge, is vicariously liable for damages, the SC held that teachers and school heads are responsible for students’ actions while under their supervision. Even outside school hours, educators must exercise due diligence when assigning tasks to students.

Ordering Apolinario to pay De Los Santos’ heirs PHP 355,000 in damages and litigation expenses, the SC
said that under the Civil Code, a person who causes harm to another due to fault or negligence must pay for the damage done.

This obligation also applies, following the principle of vicarious liability, to teachers-in-charge and school heads who are primarily responsible for their students’ actions while under their supervision unless they can show that they took proper precautions.

Read the full text of the Press Release at
https://tinyurl.com/3dwnztb4.

Read the full text of the Decision at https://tinyurl.com/a6p8nxjf.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.