Atty. Jasmine Nicole Abella

07/05/2026

The has disbarred a lawyer for using a false Mandatory Continuing Legal Education (MCLE) compliance number in his pleadings.

In a 𝘗𝘦𝘳 𝘊𝘶𝘳𝘪𝘢𝘮 Decision, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 disbarred Atty. Jose R. Hidalgo (Atty. Hidalgo) for dishonest conduct in violation of the 𝘊𝘰𝘥𝘦 𝘰𝘧 𝘗𝘳𝘰𝘧𝘦𝘴𝘴𝘪𝘰𝘯𝘢𝘭 𝘙𝘦𝘴𝘱𝘰𝘯𝘴𝘪𝘣𝘪𝘭𝘪𝘵𝘺 𝘢𝘯𝘥 𝘈𝘤𝘤𝘰𝘶𝘯𝘵𝘢𝘣𝘪𝘭𝘪𝘵𝘺 (𝘊𝘗𝘙𝘈).

Atty. Hidalgo represented the defendant in a malicious prosecution case pending before Branch 153, Regional Trial Court, Biñan City. In the answer he filed for his client, Atty. Hidalgo included his MCLE compliance number, which is required for lawyers.

The plaintiff's lawyer filed a motion to expunge Atty. Hidalgo's answer from the records, claiming that he did not actually comply with the MCLE requirements. Attached to the motion was a Certification from the MCLE Office stating that Atty. Hidalgo had not complied from the first compliance period up to the present.

In ordering the disbarment of Atty. Hidalgo, the SC emphasized that Canon II of the 𝘊𝘗𝘙𝘈 requires lawyers to act with propriety and maintain the appearance of propriety in personal and professional dealings, observe honesty, respect and courtesy, and uphold the dignity of the legal profession consistent with the highest standards of ethical behavior.

Lawyers are also required under Canon III to uphold the Constitution, obey the laws of the land, and promote respect for laws and legal processes.

The SC held that Atty. Hidalgo violated these Canons, stating that his act of indicating false information in the pleadings he filed “constitutes bad faith and dishonesty, and shows blatant disrespect of the courts and its rules.”

The SC also fined Atty. Hidalgo PHP 35,000 for willful disobedience, a less serious offense, for ignoring the IBP's order when he did not submit an answer and a verified position paper.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=164745.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164728.

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

07/05/2026

Disbarred o tinanggalan ng lisensya ng ang isang abogado dahil sa paggamit ng pekeng Mandatory Continuing Legal Education (MCLE) compliance number sa kanyang mga isinumiteng pleading.

Sa isang Per Curiam na Desisyon, tinanggal ng En Banc ng Korte Suprema sa pagka-abogado si Atty. Jose R. Hidalgo (Atty. Hidalgo) dahil sa dishonest conduct o hindi tapat na asal na lumalabag sa Code of Professional Responsibility and Accountability (CPRA).

Nagsilbing abogado si Atty. Hidalgo para sa defendant sa isang kaso ng malicious prosecution na nakabinbin sa Branch 153 ng Regional Trial Court (RTC) sa Lungsod ng Biñan. Sa sagot na inihain niya para sa kanyang kliyente, isinama ni Atty. Hidalgo ang kanyang MCLE compliance number na hinihingi sa mga abogado.

Nagsampa ng motion to expunge ang abogado ng nagrereklamo para burahin ang sagot ni Atty. Hidalgo mula sa mga rekord dahil hindi siya sumunod sa mga kahingian ng MCLE. Kalakip ng nasabing mosyon ang isang Sertipikasyon mula sa Tanggapan ng MCLE na nagsasaad na hindi nakadalo sa MCLE si Atty. Hidalgo mula sa unang compliance period hanggang sa kasalukuyan.

Sa pagtanggal ng lisensya ni Atty. Hidalgo, iginiit ng Korte Suprema ang Canon II ng CPRA na nag-aatas sa mga abogado na kumilos nang maayos (propriety) at panatilihin ang imahe ng kaayusan sa personal at propesyunal na pakikipag-ugnayan, maging tapat at magalang, at itaguyod ang dangal ng legal na propesyon alinsunod sa pinakamataas na pamantayan ng etikal na pag-uugali.

Sa ilalim ng Canon III, hinihingi din sa mga abogado na itaguyod ang Konstitusyon, sundin ang mga batas ng lupain, at isulong ang paggalang sa mga batas at prosesong legal.

Sinabi ng Korte Suprema na nilabag ni Atty. Hidalgo ang mga Canon na ito at sinabing ang gawain ng paglalagay ng maling impormasyon sa mga pleading na isinampa niya ay nagpapakita ng bad faith o masamang hangarin at kawalan ng katapatan, at nagpapakita ng lantarang kawalan ng paggalang sa mga hukuman at sa mga panuntunan nito.

Pinatawan si Atty. Hidalgo ng PHP 35,000 na multa para sa willful disobedience o sadyang pagsuway dahil sa hindi pagpansin sa atas ng IBP na magsumite siya ng sagot at isang verified position paper.

Basahin ang press release sa https://sc.judiciary.gov.ph/?p=164745.

Basahin ang Desisyon sa https://sc.judiciary.gov.ph/?p=164728.

Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.

30/03/2026

⚖️ BUYING PROPERTY THROUGH AN AGENT? READ THIS FIRST.
In the Philippines, the golden rule of real estate is simple: No SPA, No Sale. Under Article 1874 of the Civil Code, if a sale of land is made through an agent, their authority MUST be in writing. If it isn’t? The sale is void from the beginning—meaning you could lose your money and the property.

🏡 THE AGENT VERIFICATION CHECKLIST
Before you sign anything or hand over a centavo, verify these 4 pillars of authority:

1. The Special Power of Attorney (SPA)
The agent must present a notarized SPA. Don't just look for a signature; check the details:

Specific Power: It must clearly state the power "to sell" and "to sign the Deed of Absolute Sale." (An SPA "to manage" is NOT an SPA "to sell").

Property Details: Does the TCT number and location match the title exactly?

Apostille: If the owner is abroad, the SPA must have an Apostille or be authenticated by the Philippine Consulate.

2. Scope & Payment Authority
Warning: Not all agents are authorized to touch the money.

Check if the SPA expressly grants the authority to "receive and receipt payments."

Best Practice: Always issue checks directly to the Registered Owner named on the Title, never to the agent, unless explicitly authorized in writing.

3. Validity & Identity
Is the owner still alive? An SPA is automatically revoked upon the death of the principal (Article 1919).

ID Check: Match the agent’s government IDs with the name on the SPA.

Owner Confirmation: If possible, do a quick video call with the owner to confirm the agent’s identity and the agreed price.

4. Professional Credentials
Under the Real Estate Service Act (RESA Law), professional brokers must be licensed by the PRC.

Ask for their PRC ID.

Verify their registration to ensure you are dealing with a professional bound by a code of ethics.

⚠️ COMMON RED FLAGS
🚩 The agent is rushing you to pay "reservation fees" to their personal account.

🚩 The SPA is a photocopy or looks tampered with.

🚩 The agent refuses to let you speak with the owner.

🚩 Discrepancies between the SPA name and the Title name.

💡 PRACTICAL RULE: If you are in doubt, verify with the Registry of Deeds to confirm ownership and check for any encumbrances on the title.

29/03/2026

LEGAL TIP: How to Remove Encumbrances on Your Land Title

Removing an encumbrance on a land title in the Philippines is not one-size-fits-all. The process depends on the type of annotation reflected on your title—so the first step is always proper identification.

🔍 Step 1: Check Your Title Carefully
Secure a Certified True Copy (CTC) from the Registry of Deeds and review all annotations.

📌 Common Encumbrances to Watch Out For:
• Real Estate Mortgage
• Notice of Adverse Claim
• Lis Pendens
• Levy on Ex*****on / Attachment
• Easement / Right of Way
• Deed Restrictions

⚖️ Why This Matters:
Each encumbrance requires a specific legal remedy—some require full payment and ex*****on of a release, others need a court order, while certain annotations may lapse or be cancelled through proper affidavit and registration.

💡 Pro Tip:
Do not assume that an encumbrance is automatically extinguished. Always ensure that proper cancellation is duly recorded with the Registry of Deeds.

📣 For your legal concerns, you may send a message for proper guidance.

24/03/2026

LEGAL TIP: Due Diligence Before Buying Land (Don’t Rely on Title Alone!)

Buying property is a major investment—do your due diligence before you sign anything.

Always request a Certified True Copy of the title from the Registry of Deeds. Never rely solely on the owner’s duplicate copy shown by the seller. While both are technically original, the Registry’s copy reflects the latest and official status of the property.

Review the title carefully for any annotations—these may include mortgages, liens, adverse claims, or notices of lis pendens. A truly “clean” title should be free from encumbrances. If annotations exist, verify that their cancellation has been properly recorded; otherwise, the obligation may still affect the property.

Remember: what appears on the title binds the buyer.

23/03/2026

GOOD NEWS : Updated Rules for Residential Free Patents (DAO 2025-35)

Are you occupying untitled residential land? The DENR has issued Administrative Order No. 2025-35, providing clearer and faster guidelines for securing your land title under Republic Act No. 10023.

✅ Maximum Area Limits:

Highly Urbanized Cities: Up to 200 sq.m.

Other Cities: Up to 500 sq.m.

1st & 2nd Class Municipalities: Up to 750 sq.m.

Other Municipalities: Up to 1,000 sq.m.

22/03/2026

Mother Title to Separate Title: Your Step-by-Step Guide to Subdivision & Transfer

📌 1. Verification & Due Diligence
Before spending on a survey, secure a Certified True Copy (CTC) of the Mother Title from the Registry of Deeds (RD).

Check for: Liens, encumbrances, or "Adverse Claims" that might prevent a subdivision.

Verify: If the title is "Clean," proceed to the technical phase.

📌 2. Subdivision Survey & Approval
Hire a Licensed Geodetic Engineer to conduct the actual field survey.

Approval Path: Since you have a "Mother Title" (already registered land), the subdivision plan must be submitted to the Land Registration Authority (LRA).

Output: You will receive the Approved Subdivision Plan and the Certified Technical Descriptions for each resulting lot.

📌 3. Ex*****on of Deed
Once you have the approved plan (which provides the specific lot numbers and area), have a lawyer draft the Deed of Conveyance (Sale, Donation, or Partition).

Requirement: The deed must be notarized.

Note: The technical description in the deed must match the LRA-approved subdivision plan exactly.

📌 4. Assessor’s Office (Pre-BIR Requirements)

Visit the City or Municipal Assessor’s Office where the property is located.

Request: A Certified True Copy of the Latest Tax Declaration and a Certificate of No Improvement (if the lot is vacant).

Secure: A Tax Clearance (proof that Real Property Tax/Amilyar is paid up to date).

📌 5. Bureau of Internal Revenue (BIR)

File for the Certificate Authorizing Registration (eCAR) at the Revenue District Office (RDO) having jurisdiction over the property.

Taxes Paid: Capital Gains Tax (6%) and Documentary Stamp Tax (1.5%).

Crucial Step: You cannot move to the Registry of Deeds without the eCAR.

📌 6. Local Treasurer’s Office (Transfer Tax)

The "Hidden" Step: Before going to the RD, you must pay the Local Transfer Tax at the City or Provincial Treasurer’s Office.

Rate: Usually 0.5% to 0.75% of the property value. They will issue a Transfer Tax Receipt and stamp your Deed.

📌 7. Registry of Deeds (The Final Registration)

Submit the "Registration Bundle" to the RD:

Original Mother Title

LRA-Approved Subdivision Plan

Notarized Deed (stamped by BIR and Treasurer)

BIR eCAR

Transfer Tax Receipt

Tax Clearance

Result: The Mother Title is cancelled (or annotated), and a new Transfer Certificate of Title (TCT) is issued for the subdivided lot.

📌 8. Final Tax Declaration

Return to the Assessor’s Office with a copy of the new TCT.

Action: Apply for a New Tax Declaration under the new owner’s name. This completes the transfer of ownership in the eyes of the local government.

20/03/2026

The En Banc has approved the Governance Framework on the Use of Human-Centered Augmented Intelligence in the Judiciary, marking a significant step toward modernizing court operations and improving the administration of justice through new technologies.

In a Resolution dated February 18, 2026, in A.M. No. 25-11-28-SC, the SC issued a comprehensive guide on the responsible use of human-centered augmented intelligence in the judicial system, based on three ethical principles: fairness, accountability, and transparency. These principles support “the ethical and responsible use of human-centered augmented intelligence tools in the Judiciary” and “reinforce the public’s faith and confidence in the independence and impartiality of the judicial system.”

The Framework was developed by a working group chaired by Senior Associate Justice Marvic M.V.F. Leonen, with Associate Justices Ramon Paul L. Hernando and Rodil V. Zalameda as vice chairpersons. It was created with the help of other members of the Judiciary, subject matter experts, lawyers, and the academe, and further refined through consultations with the SC En Banc, the SC’s Management Information Systems Office, and the Office of the Chief Attorney. It also draws from global best practices, including the Council of ASEAN Chief Justices Governance Framework on the Use of Artificial Intelligence (AI) for the ASEAN Judiciaries and UNESCO Guidelines for the Use of AI Systems in Courts and Tribunals, ensuring alignment with international standards.

A key feature of the Framework is the use of the term “human-centered augmented intelligence,” which emphasizes that technology must remain centered on humans and should only support, not replace, human reason and judgment.

Read the press release at https://sc.judiciary.gov.ph/?p=162306.

Read the full text of A.M. No. 25-11-28-SC at https://sc.judiciary.gov.ph/25-11-28-sc-re-proposed-governance-framework-on-the-use-of-human-centered-augmented-intelligence-in-the-judiciary-2/

17/03/2026

The ULAS Portal - Phase 1 is scheduled to be launched on March 3 and will be accessed through the Philippine Judiciary Platform (PJP).

View the instructional video on how to create a PJP account at https://www.youtube.com/watch?v=o-BFSgjwY1I

Visit the ULAS microsite at https://sc.judiciary.gov.ph/ulas/

WATCH: How to create an account through the Philippine Judiciary Platform (PJP).eCourt PH can be accessed through the PJP at https://portal.judiciary.gov.ph/...