Centeno Aquisan & Cameyeng Law Office - Baguio City

19/09/2025

Congratulations to our very own founding partner, Alfredo R. Centeno, on being named one of the Golden Pillar of Law Awardees conferred by the Integrated Bar of the Philippines on September 15, 2025. Fifty-three years (and counting) of service and dedication to the legal profession is truly an insipiring and incredible legacy.

IBP GOLDEN PILLAR LAW AWARD | The Integrated Bar of the Philippines, Baguio Benguet Chapter, awarded the IBP Golden Pillar of Law Award to Congressman Mauricio G. Domogan, Atty. Reynaldo U. Agranzamendez, Atty. Edilberto B. Tenefrancia, Atty. Erdolfo V. Balajadia, Atty. Alfredo R. Centeno, Atty. Reynaldo A. Cortes, Atty. Honorato Y. Aquino, Octavio M. Banta, Atty. Edilberto T. Claraval, Atty. Pablito V. Sanidad, Atty. Virgilio F. Bautista, and Atty. Walter R. Carantes on September 15, 2025, during the Flag Raising Ceremony at the Baguio City Hall grounds.
The awards were given in grateful recognition of 50 years of distinguished and dedicated service in the legal profession, whether in private practice or public service. ~ NCO

15/05/2025

Avoid penalties and avail the extended and expanded Estate Tax Amnesty until June 14, 2025.

29/04/2025

"(A)cademic institutions have a "built-in" obligation of providing conducive atmosphere for learning, where there are no constant threats to life and limbs of the students. Thus, the school must ensure the maintenance of peace and order within the campus."

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.

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

06/03/2025

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.

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

29/08/2024

The Supreme Court has ruled that decades-long unjustified absence from the marital home may be considered evidence of psychological incapacity to comply with marital obligations.

Read more at: https://sc.judiciary.gov.ph/sc-unjustified-absence-from-marital-home-considered-psychological-incapacity/

18/05/2024

The Supreme Court has affirmed the conviction of an accused for robbery for demanding money from his ex-girlfriend in exchange for deleting her n**e photos posted on Facebook.

READ: https://sc.judiciary.gov.ph/sc-affirms-imprisonment-of-accused-for-demanding-money-in-exchange-for-deletion-of-ex-girlfriends-n**e-photos/

26/02/2024

15/02/2024

23/01/2024

Attention Business Taxpayers!

Payment of the ₱500 Annual Registration Fee (ARF) is no longer required effective January 22, 2024.

In compliance with Republic Act (RA) no. 11976 or the Ease Of Paying Taxes Act

20/12/2023

SC: In Criminal Law, Intent to Commit Crime is Different from Intent to Perpetrate the Act |

Dispensing with proof of criminal intent for crimes mala prohibita, where criminal intent is not an element, does not discharge the prosecution’s burden of proving, beyond reasonable doubt, that the prohibited act was done by the accused intentionally.

Thus ruled the Supreme Court’s Third Division, in a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, granting the petition for review on certiorari filed by Felix G. Valenzona (Valenzona). The petition challenged the rulings of the Court of Appeals (CA) which had affirmed the Regional Trial Court’s (RTC) conviction of Valenzona for violation of Presidential Decree No. 957 or the Subdivision and Condominium Buyers’ Protective Decree (PD 957).

The Court clarified that while jurisprudence has recognized that a violation of PD 957 is regarded as malum prohibitum, or such offenses which are prohibited regardless of the person’s intent, the prosecution nevertheless still needs to show that the prohibited act was done intentionally by the accused.

The Court thus proceeded to distinguish between ‘intent to commit the crime’ and ‘intent to perpetrate the act’: “[W]hile a person may not have consciously intended to commit a crime regarded as malum prohibitum, he or she may still be held liable if he or she did intend to commit an act that is, by the very nature of things, the crime itself. Thus, for acts that are mala prohibita, the intent to perpetrate the prohibited act under the special law must nevertheless be shown.”

“While volition or voluntariness refers to knowledge of the act being done (as opposed to knowledge of the nature of the act), criminal intent is the state of mind that goes beyond voluntariness, and it is this intent which is punished by crimes mala in se,” held the Court.

Thus, for crimes mala in se, there must be proof of criminal intent, while for crimes mala prohibita, it is sufficient that the prohibited act is done freely and consciously, provided that it is established that the accused had the volition or intent to commit the prohibited act.

Read more at https://sc.judiciary.gov.ph/sc-in-criminal-law-intent-to-commit-crime-is-different-from-intent-to-perpetrate-the-act/.

Read G.R. No. 248584 (Valenzona v. People) in full at https://sc.judiciary.gov.ph/248584-the-people-of-the-philippines-vs-felix-g-valenzona/.