UV Law

30/03/2026

The SupremeCourtPH (SC) has clarified that a complaint or petition may only be dismissed for failure to state a cause of action after an examination of the complaint or information itself, together with its annexes—strictly excluding the pleadings or submissions of other parties, reconciling conflicting rulings on the issue.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division ruled that the lower courts erred in dismissing a petition for quieting of title for supposedly failing to state a cause of action and in interchanging this concept with “dismissal for lack of cause of action.”

A cause of action is the act or omission by which a party violates a right of another, the three elements of which are:

1. a right in favor of the plaintiff by whatever means and under whatever law it arises or is created;

2. an obligation on the part of the named defendant to respect or not to violate such right; and

3. an act or omission on the part of the named defendant violative of the right of the plaintiff or constituting a breach of the obligation of defendant to the plaintiff which the latter may maintain an action for recovery of damages.

The case arose from a land dispute between the groups of Inocencio Taganile and Filomena Delos Santos Dolar.

Taganile’s group claims that it has occupied a portion of land along Dr. Sixto Antonio Avenue in Rosario, Pasig City, since 1970. After learning that the land had been registered in the name of Dolar’s group, they filed a petition before the Regional Trial Court (RTC) to challenge the title.

Dolar’s group, on the other hand, claims that Taganile’s group were mere lessees. They filed a motion to dismiss the petition, arguing that it did not state a cause of action because it lacked supporting documents.

The RTC dismissed the case after considering both the petition and the evidence presented by Dolar’s group. It ruled that the petition failed to state a cause of action because it did not include proof of the Taganile’s group’s claim to the land. The Court of Appeals (CA) affirmed this ruling.

The SC disagreed. It clarified the difference between failure to state a cause of action and lack of cause of action.

A cause of action exists when a legal right is violated. Courts cannot hear a civil case unless there is a cause of action. A case may be dismissed if the complaint does not state one, or if the party later fails to prove it with evidence. These are different grounds.

To determine whether a complaint fails to state a cause of action, the court looks only at what is written in the complaint and assumes the allegations are true. If, even assuming those facts are true, the court still cannot grant the relief asked for, it can dismiss the complaint on this ground.

In contrast, to determine whether a case lacks a cause of action, the court looks at the evidence presented.

The SC noted that confusion arose from past rulings that allowed courts, in some instances, to look beyond the complaint, such as when the allegations appear to be legally impossible or unfounded. This blurred the difference between failure to state a cause of action and lack of cause of action.

To settle the issue, the SC ruled that courts may dismiss a complaint for failure to state a cause of action only by examining the complaint and its attachments—nothing more. Courts must not consider other pleadings or submissions at this stage.

The SC explained:

“Once the trial court considers other pleadings submitted by the parties or evidence admitted during the proceedings, it is no longer determining a failure to state a cause of action, but rather the very existence of one. In doing so, the ground for dismissing the complaint or petition ceases to be ‘failure to state a cause of action’ and becomes ‘lack of cause of action.’”

Applying this rule, the SC found that the RTC and CA improperly relied on the submissions and evidence of Dolar’s group. They prematurely ruled on the existence of a cause of action without giving Taganile’s group the chance to present evidence.

The SC also found that, based on the allegations alone, the petition was able to establish a case for quieting of title, noting Taganile group’s claims of long-standing possession and houses built on the property since the 1970s.

The SC directed that the case be returned to the RTC to continue the proceedings and receive evidence on the parties’ claims.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=162612

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=162606

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

30/03/2026

17/12/2025

EMOTIONAL ANGUISH OR ANXIETY DUE TO BREAK UP NOT AUTOMATICALLY VAWC— SUPREME COURT

The Supreme Court (SC) held that emotional anguish and anxiety arising from a romantic breakup do not automatically constitute psychological violence punishable under Republic Act No. 9262, or the Anti-Violence Against Women and Their Children (VAWC) Act.

In a decision penned by Associate Justice Alfredo Benjamin Caguioa, the SC's Third Division acquitted Ronel Caridaoan of violating Section 5(i) of RA 9262 filed by his former live-in partner, who claimed to have suffered emotional anguish allegedly caused by his infidelity.

The Court found that the complainant failed to establish that her emotional suffering was directly caused by Caridaoan's actions, noting that they had already broken up when he entered into another relationship.

It stressed that psychological violence under RA 9262 is a mala in se offense, which technically provides that criminal intent is an essential element of the crime.

20/10/2025

MARKET VALUE OF PROPERTY NOT THE SOLE DETERMINANT OF JUST COMPENSATION IN EXPROPRIATION CASES—SUPREME COURT

JUST IN: The Supreme Court (SC) clarified that just compensation in land expropriation cases must be based on all relevant factors using a “totality of circumstances” approach, by taking into consideration all facts about the property’s condition, surroundings, existing improvements, and capabilities, not just market value.

In a ruling authored by Associate Justice Samuel Gaerlan, the SC’s First Division remanded a case involving the Pasay City Government and Arellano University back to the Regional Trial Court (RTC) to reassess the amount of just compensation owed to the University.

The case stemmed from the complaint filed by Arellano University before the RTC in 2015, claiming that the Pasay City government took its 805-square-meter parcel of land in Barangay San Isidro and turned it into a public road, now known as Menlo Street, without going through proper expropriation proceedings or paying just compensation.

Since both parties never came into agreement, the matter was referred to a board of commissioners made up of Pasay LGU officials. The board used a base value of PHP200 per square meter (sqm) based on the 1978 General Revision of the City Assessor’s Office, then added 6% annual interest from 1978, the year the street was discovered, up to 2017, resulting in a value of PHP2,060/sqm.

The university disagreed with the computation, saying that the interest should be based on the rates published by the Bangko Sentral ng Pilipinas. Applying this and other factors such as inflation, fiscal policies, and fluctuations in currency rates, the university proposed a total compensation of PHP 5,793,664.63.

The RTC adopted the commissioners’ base value but applied a different interest rate, ordering Pasay LGU to pay PHP 161,000.00 plus 12% annual interest from 1978 to 2018. But the Court of Appeals held that the RTC’s computation relied only on the 1978 assessment and ignored other relevant factors and thus sent the case back to the RTC.

This was affirmed by the Supreme Court, saying the RTC’s decision was based on incomplete data. It cited Article III, Section 9 of the Constitution: private property cannot be taken for public use without just compensation.

The high court noted that just compensation must be real, substantial, full, and ample, and that determining this amount is a matter for the courts to decide. It explained that although local government assessors provide appraisals, these are not controlling in expropriation cases. Such appraisals often cover broad areas and do not account for specific property differences. They rely on general descriptions and may be inaccurate. And while tax values can serve as a guideline, they cannot substitute for a comprehensive assessment of just compensation.

The highest bench stressed that courts must use a “totality of circumstances” approach, considering all facts about the property’s condition, surroundings, existing improvements, and capabilities. These include the zonal valuation of the Bureau of Internal Revenue, acquisition cost, tax declarations, size, shape, location, and the current value of similar properties.

Since the RTC relied only on the Pasay City Assessor’s 1978 assessment. The BIR’s zonal valuation was barely mentioned, and no other data sources appear to have been considered. Since the amount of just compensation is based on incomplete or inaccurate data.

18/09/2025

| The Supreme Court (SC) ruled that being irresponsible in doing household chores and taking care of children may be considered evidence of psychological incapacity to comply with marital obligations, a ground for nullification of marriage.

In a 13-page decision authored by Associate Justice Samuel Gaerlan, the SC's Third Division has declared void from the beginning the marriage between Arnold Alfonso and Michelle Pamintuan-Alfonso on the ground of the latter's psychological incapacity as provided under Article 36 of the Family Code.

Arnold and Michelle were high school classmates. In 1997, or eight years after their graduation, they unexpectedly met. Since then, they have become close and regularly exchanged phone calls.

Despite being in a relationship with another man, Michelle often visited Arnold's apartment. Later on Michelle and Arnold spent the night at the latter's apartment, where the two engaged in unprotected sexual in*******se that resulted in Michelle's unexpected and unwanted pregnancy.

At first, Michelle was contemplating aborting the child, but Arnold convinced her otherwise and offered marriage. After the wedding, Michelle and Arnold resided at the parental house. They were blessed with three children.

A year later their relationship turned sour. Arnold noticed the changes in Michelle's behavior. Michelle would be verbally aggressive towards him, crying loudly to gain sympathy from their neighbors. She also refused to do household chores or care for their children, instead relying on her mother to fulfill her domestic responsibilities.

Arnold also observed that Michelle has a luxurious lifestyle, which caused her to obtain looming debts from various people. It reached the extent that Arnold's father paid Michelle's debt to save her from being sued.

Over time, Arnold felt Michelle's growing coldness towards him. Michelle disavowed fulfilling his sexual needs by making excuses that she is tired and not in the mood.

Sometime in 2010, Michelle informed Arnold that she had secured a job that required deployment to Bicol for one month. However, to his surprise, Arnold later learned that Michelle was having an affair with another man. Since then, Michelle has refused to communicate with him and their children.

This paved the way for Arnold to file a petition for nullification of their marriage on the ground of Michelle's psychological incapacity to fulfill her marital obligations.

Initially, the Regional Trial Court (RTC) granted the petition and nullified their marriage, but it was later reversed by the Court of Appeals. This prompted Arnold to elevate the case before the Supreme Court.

In granting Arnold's petition, the high court held that he was able to illustrate that the incapacity of Michelle was so grave or serious that it already impaired her from carrying out the required ordinary marital duties. It gave credence to the psychological report, which diagnosed Michelle with histrionic personality disorder and antisocial personality disorder.

The SC also emphasized that the incapacity of Michelle was incurable, as the pattern of persistent failure to assume her essential marital obligations was proven. It also took into account the instance where Michelle entered into an illicit affair with another man.

“In every marriage lies the vinculum juris—the juridical bond that unites the spouses in a legally and morally binding union governed by law. This vinculum juris imposes upon each spouse the essential marital obligations of mutual love, respect, fidelity, and support,” the Supreme Court said.

“Thus, in the present case, we hold that Michelle's psychological incapacity existed prior to and during the celebration of the marriage; the vinculum juris is deemed never to have validly arisen,” it added.

15/09/2025

25/07/2025

The (SC) En Banc, during its session today, July 25, 2025, has declared the Articles of Impeachment against Vice President Sara Z. Duterte unconstitutional, noting that it is barred by the one-year rule under Article XI, Section 3(5) of the Constitution and that it violates the right to due process enshrined in the Bill of Rights. Therefore, the Senate could not acquire jurisdiction over the impeachment proceedings.

However, the SC said it is not absolving Vice President Duterte from any of the charges against her. But any subsequent impeachment complaint may only be filed starting February 6, 2026.

The ruling of the SC is immediately executory. It shall be deemed served on the petitioners and promulgated upon publication in the SC website and receipt of the parties of their digital copy in accordance with A.M. No. 25-05-16-SC or the Guidelines on the Transition to Electronic Filing in the Supreme Court.

The case stemmed from four impeachment complaints against Vice President Duterte. The first three were filed before the House of Representatives (HOR) by private individuals and different groups on December 2, 4, and 19, 2024.

A fourth complaint was lodged by a resolution approved by more than one-third of the HOR members of the 19th Congress on February 5, 2025, which was transmitted as the Articles of Impeachment to the Senate on the same day. This was followed by two petitions filed before the SC challenging its constitutionality.

The SC voted 13-0-2, with the Justices present voting unanimously to grant the petitions to annul the Articles of Impeachment, and Justice Alfredo Benjamin S. Caguioa inhibiting and Justice Maria Filomena D. Singh on leave.

The Decision, written by Senior Associate Justice Marvic M.V.F. Leonen, ruled that all legal issues involving impeachment proceedings are subject to judicial review, “considering the nature of the offices and the institutions that are subject to impeachment, its effect on the independence of constitutional departments and organs, and its nature as a constitutional process.”

In declaring that the Articles of Impeachment were barred by the one-year rule, the Decision differentiated the first three complaints from the fourth complaint. The first three, it said, were filed under Article XI, Section 3(2) of the Constitution which allows any citizen to file a verified complaint with an endorsement by any HOR member. The fourth one was through Article XI, Section 3(4) of the Constitution through a verified complaint or resolution filed by at least one-third of the HOR members.

The SC took note that the HOR in the 19th Congress did not act on the first three endorsed complaints, which were considered “terminated or dismissed” upon the adjournment of the HOR.

The SC also determined that due process applies to the impeachment process. It laid down the following due process requirements in impeachment proceedings:

1. The Articles of Impeachment or resolution must include evidence when shared with HOR members, especially those who are considering its endorsement.

2. The evidence should be sufficient to prove the charges in the Articles of Impeachment.

3. The Articles of Impeachment and the supporting evidence should be available to all members of the HOR, not only those who are being considered to endorse.

4. The respondent in the impeachment complaint should have been given a chance to be heard on the Articles of Impeachment and the supporting evidence to prove the charges prior to its transmittal to the Senate, despite the number of endorsements from HOR members.

5. The HOR must be given a reasonable time to reach their independent decision of whether they will endorse an impeachment complaint. The SC, however, has the power to review whether this period is sufficient, but petitioner—who invokes the SC’s power to review—should prove that officials failed to perform their duties properly.

6. The basis of any charge must be for impeachable acts or omissions committed in relation to their office and during the current term of the impeachable officer. For the President and Vice President, these acts must be sufficiently grave amounting to the crimes described in Article XI, Section 2 or a betrayal of public trust given by the majority of the electorate. For the other impeachable officers, the acts must be sufficiently grave that they undermine and outweigh the respect for their constitutional independence and autonomy.

7. To ensure that respondent in the impeachment complaint is heard, the HOR is required to:

(a) Provide a copy of the Articles of Impeachment and its accompanying evidence to the respondent to give him/her an opportunity to respond within a reasonable period to be determined by the HOR rules. The Constitution only requires an opportunity to be heard. It is up the respondent to waive this fundamental right and opt to present his/her evidence at the Senate trial; and

(b) Make the Articles of Impeachment, with its accompanying evidence and the comment of the respondent, available to all the members of the HOR. It is the HOR—not one-third of the HOR—that has the sole prerogative to initiate impeachment complaints. Thus, there must be some modicum of deliberation so that each member representing their constituents can be heard and thus convince others of their position. The transmittal however will only take place upon the qualified vote of one-third of the HOR.

Read the full text of the Press Release at https://tinyurl.com/596r7cde.

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

Read the Separate Concurring Opinion of Justice Ramon Paul L. Hernando at https://tinyurl.com/3cjtcpjv.

Read the Separate Concurring Opinion of Justice Henri Jean Paul B. Inting at https://tinyurl.com/3wdhk52w.

Read the Separate Concurring Opinion of Justice Rodil V. Zalameda at https://tinyurl.com/mr47p9ux.

Read the Separate Concurring Opinion of Justice Jhosep Y. Lopez at https://tinyurl.com/mr22rane.

Read the Concurring Opinion of Justice Samuel H. Gaerlan at https://tinyurl.com/u9um2h54.

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

17/07/2025

'JUDICIAL OVERREACH'

| Retired Supreme Court Senior Associate Justice Antonio Carpio said that it is judicial overreach for the Supreme Court to ask members of the House of Representatives whether they actually read the impeachment charges against Vice President Sara Duterte before signing the same.

In an interview with Bilyonaryo News Channel, Carpio noted that the Constitution provides the doctrine of conclusive presumption, where it assumes that the House followed procedure in doing its duty in matters of impeachment.

“I think that’s—I would agree it’s an overreach. Because what’s the point? They already signed, and it’s verified because there’s a verification of them that they read it and that the allegations are true of their own personal knowledge or based on authentic records. I mean, you’d state that under oath. That should be enough already,” Carpio said.

He cited as an example situations where the Supreme Court rendering its ruling and a president signing an executive order.

“Well, you know, we never asked the Supreme Court whenever they come up with a decision resolution whether those who signed the decision resolution perused the charges and went over the evidence. I mean, that’s considered. If you sign it, that means you have studied it,” Carpio said.

“We don’t ask, for example, the President, if he signs an Executive Order, ‘Mr. President, did you read that before you signed it? Did you understand it? ” he added.

Carpio explained that the Supreme Court should have trusted the process made by the House and taken full faith and credit for the articles of impeachment.

“I mean, you have to take it for what it says there. Yeah, you take it at face value. But you cannot question those who signed. Did you read it? Did you understand what you were signing? I mean, that is supposed to be conclusively understood already by those who signed,” Carpio said.

“They signed it; they verified under oath that they read it, that it’s, that the allegations are true of their personal knowledge or based on authentic documents; they should take it at face value because that’s an official record,” Carpio added.

31/05/2025

25/05/2025

UV Law Office is honored and grateful for the opportunity to be part of the legal team of Congressman Carl Cari, Representative of the 5th District of Leyte, during the recently concluded midterm elections.

We likewise extend our sincere appreciation to Mayor Lemuel Gin K. Traya for the warm accommodation and exceptional hospitality extended to our team throughout the duration of our legal engagement in their municipality.

01/05/2025

Muling pinagtibay ng na ang mga testimonya mula sa pamilya at mga kaibigan ng asawa ay makatutulong na patunayan ang psychological incapacity sa mga kasong naglalayong mapawalang-bisa ang kasal.

Sa isang Desisyon na isinulat ni Senior Associate Justice Marvic M.V.F. Leonen, idineklara ng Second Division ng Korte na walang bisa ang kasal nina Jeffery A. Green (Jeffery) at Rowena Manlutac Green (Rowena) dahil sa psychological incapacity ni Rowena.

Magka-relasyon sa loob ng apat na taon sina Jeffery at Rowena bago sila nagpakasal. Makalipas ng apat pang taon, nagsampa ng petisyon si Jeffery para mapawalang-bisa ang kanilang kasal dahil pareho umano silang psychologically incapacitated. Bilang katibayan, nagsumite si Jeffery ng isang psychiatric evaluation report batay sa mga standard test at panayam sa kanyang sarili, kay Rowena, sa isang mutual na kaibigan, at sa ina ni Rowena.

Ayon sa report, madalas na napababayaan ni Rowena ang kanilang finances at ang kanilang mga utang ay umabot na sa PHP 4 milyon. Inakusahan din ni Jeffery si Rowena ng panloloko at pagsisinungaling tungkol sa paternity ng kanilang anak.

Pinaboran ng RTC ang petisyon at idineklara na si Rowena ay psychologically incapacitated na tuparin ang kanyang mga tungkulin sa pag-aasawa. Ito ay pinagtibay ng Court of Appeals at Korte Suprema.

Sa nullity of marriage cases, binigyang-diin ng Korte Suprema na maaaring suriin ang psychological incapacity hindi lang base sa pahayag ng mag-asawa kundi pati sa mga malalapit sa kanila. Ito para maiwasan ang potensyal na bias mula sa asawa na nagsampa ng petisyon.

Iginiit ng Korte Suprema na kung ang kabuuan ng mga ebidensya ay mapatutunayan ang psychological incapacity ng isang asawa noong araw na ipagdiwang ang kasal, ang kasal ay maaaring mapawalang-bisa sa ilalim ng Article 36 ng Family Code.

Basahin ang buong teksto ng press release sa https://sc.judiciary.gov.ph/sc-family-and-friends-testimonies-can-prove-psychological-incapacity-in-nullity-of-marriage-cases/.

Basahin ang buong teksto ng Desisyon https://sc.judiciary.gov.ph/255706-rowena-manlutac-green-vs-jeffery-a-green-and-the-republic-of-the-philippines/.