The Law Chamber of Christian C. Peliña

10/08/2025

Within a few days of its implementation on 1 July 2025, we filed an initial pleading with the Supreme Court of the Philippines through the eCourt PH Judiciary Portal.

12/03/2025

Great news! E-Notarization is officially approved! Say goodbye to long lines and hello to hassle-free digital notarization!

The has taken an important step towards modernizing legal processes by approving the Rules on Electronic Notarization (E-Notarization Rules) – a significant reform that leverages technology to make notarial services more accessible and efficient nationwide.

Under A.M. No. 24-10-14-SC, the Supreme Court En Banc approved the E-Notarization Rules and the Guidelines on the Accreditation of Electronic Notarization Facility Providers (Accreditation Guidelines). These rules introduce Electronic Notaries Public (ENPs), who are authorized to perform notarial acts for individuals located anywhere in the Philippines and, in certain cases, even abroad.

This expanded jurisdiction addresses a key limitation of the 2004 Rules on Notarial Practice (2004 Notarial Rules), where traditional notaries public were restricted to performing notarizations only within their territorial jurisdiction. By allowing ENPs to provide services across the country, the new rules ensure greater accessibility, particularly for those in remote or underserved areas.

The updated framework enables 3 forms of electronic notarization:
- In-Person Electronic Notarization (both principals and witnesses must be physically present)
- Remote Electronic Notarization (principals and witnesses may connect virtually to ENP via videoconferencing)
- Mixed In-Person and Remote

To enhance security, the E-Notarization Rules implements Multi-Factor Authentication (MFA) such as facial recognition, biometrics, and one-time passwords, in compliance with regulations set by the Bangko Sentral ng Pilipinas. The integrity of the electronic notarial book, or the register showing the chronological record of electronic notarial acts, is also safeguarded against tampering. Additionally, all data stored in the ENFs are protected under the Data Privacy Act.

The E-Notarization Rules applies exclusively to electronic documents in Portable Document Format (PDF) or Portable Document Format Archival (PDF/A). Paper documents with handwritten signatures, notarial wills, and depositions will continue to follow the 2004 Notarial Rules.

A part of the Strategic Plan for Judicial Innovations 2022-2027 (SPJI), this initiative aligns with the Supreme Court’s commitment to innovation and expanded access to justice by allowing notarization for electronic documents, including remote notarization through accredited software applications. This reform supplements the traditional mode of notarization under the 2004 Notarial Rules and marks a key milestone in the Court’s ongoing digital transformation.

The E-Notarization Rules takes effect 15 days after its publication on March 9, 2025.

Read the press release in full at https://tinyurl.com/5e9e7h4a.

Read the full text of A.M. No. 24-10-14-SC, Rules on Electronic Notarization, at https://tinyurl.com/55zvmbrf.

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

26/04/2024

Mandatory.

The mandatory application of the Guidelines on Electronic Submission of Pleadings in Lower Courts has been moved to September 2, 2024, pursuant to Office of the Court Administrator Circular No. 117-2024.

For the full text of the Circular: https://sc.judiciary.gov.ph/guidelines-on-submission-of-electronic-copies-of-pleadings-and-other-court-submissions-being-filed-before-the-lower-courts-pursuant-to-the-efficient-use-of-paper-rule/

28/03/2024

"Gratitude is the fairest blossom which springs from the soul."

Henry Ward Beecher eloquently highlights the beauty and value of gratitude as an innate, deeply felt emotion that enriches one's inner life. Among the various virtues and feelings that can emerge from the human soul, gratitude stands out for its purity and the positive impact it has on both the individual experiencing it and those around them.

Cultivate gratitude to benefit emotional and physical well-being.

28/02/2024

The Future of Judicial Efficiency: Explore the Supreme Court's Official Guidelines on Electronic Submission of Pleadings in Lower Courts. Ensure compliance by 05 April 2024. Details at sc.judiciary.gov.ph.

22/12/2023

May this festive season bring us happiness, peace, and prosperity. We look forward to continuing our partnership and serving your legal needs in the upcoming year.

24/11/2023

Learn to rest; do not quit.

01/11/2023

The medical profession is currently unsettled by the demise of Dr. Benigno (Iggy) Agbayani Jr., a distinguished orthopedic surgeon, while in custody. He was incarcerated on 25 March 2023 after being convicted for Reckless Imprudence Resulting in Serious Physical Injuries. The Supreme Court's sentence ranged from one month and one day of arresto mayor to one year and one day of prision correccional.

The charge stems from an operation performed on 5 January 2006, during which Dr. Agbayani allegedly used an unsterilized arthroscope, leading to a serious infection in the patient's knee. Subsequently, the patient needed additional surgeries and was incapacitated for over thirty days.

My examination of the Supreme Court's Resolution dated 23 June 2023 uncovers a sentencing discrepancy that could have constituted a valid ground for a motion for reconsideration. If granted, this could have reduced Dr. Agbayani's maximum sentence to four months.

Article 365 of the Revised Penal Code is the applicable statute in this case, outlining two potential penalties for reckless imprudence based on the gravity of the resulting act. A deeper examination of Articles 9, 25, and 263 helps classify the injury as a less grave felony, thereby specifying the appropriate penalty to be arresto mayor in its minimum and medium periods, which equates to only one month and one day to four months of imprisonment.

However, the Court's imposed sentence—ranging from arresto mayor to prision correccional—does not conform to this legal framework. Instead, it resembles the penalty for Serious Physical Injury, a charge Dr. Agbayani did not face.

This deviation from the prescribed legal norms can be considered a significant flaw in the Supreme Court's 23 June 2023 Resolution.

The discrepancy between the Court's sentence and the legal provisions merits academic investigation. It calls into question the judiciary's adherence to law and emphasizes the need for thorough review of legal interpretations for the advancement of justice and jurisprudential precision.

This commentary is not aimed at questioning Dr. Agbayani's conviction, but rather to encourage academic discourse on the relevant legal complexities. May this shed light on an important legal quandary and emphasize the necessity for rigorous academic discourse to ensure judicial adherence to statutory mandates. This serves as a stark reminder of the need for ongoing scrutiny of legal proceedings to uphold the principles of justice.

Doctors’ chat groups are all abuzz over the news of Dr. Benigno (Iggy) Agbayani Jr.’s criminal conviction for serious physical injury through reckless imprudence. This was a case from 2006 when a patient filed the cases due to a post-operative site infection. 

11/08/2023

2 more years! 🥳

19/06/2023

Right now.

05/11/2022

Estate Tax Amnesty extended until June 14, 2023!

Revenue Regulations No. 17-2021 amends certain provisions of RR No. 6-2019

Full text: http://ow.ly/xzl730rQS69

03/06/2022

In less than a month from its creation, LADIFA Agriculture Cooperative celebrated its 1st Harvest Festival, and in partnership with the concerned government offices of LGU Surallah and private sectors extended assistance to the indigenous peoples community of Lamluma, Little Baguio, Surallah, South Cotabato.