PGM Law Offices

17/10/2025

18/09/2025

14/08/2025

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25/04/2025

04/04/2025

The (SC) has clarified that the time limit or prescriptive period for prosecuting crimes, including those under the 2022 Rules on Expedited Procedures in the First Level Courts (Rules of Expedited Procedures), stops running once a complaint is filed with the Department of Justice (DOJ), not when the case reaches the court.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC En Banc abandoned its rulings in the 2023 cases of Republic v. Desierto and Corpus, Jr. v. People, which previously held that the prescriptive period for crimes covered by the 1991 Revised Rules on Summary Procedure (Rules on Summary Procedure) stops only when the information is filed in court.

The Rules on Summary Procedure applied to cases handled by first-level courts and cover crimes including those punishable by up to six months of imprisonment and fines up to PHP 1,000. This was replaced in 2022 by the Rules on Expedited Procedures, which expanded the coverage of summary procedure to include those crimes punishable by up to one year of imprisonment and fines up to PHP 50,000.

In 2024, the DOJ issued its Rules on Summary Investigation and Expedited Preliminary Investigation, which provide that a summary investigation shall be done if the prescribed penalty is imprisonment of up to one year.

Given these developments, the SC clarified that the prescriptive period for crimes is tolled upon the filing of a complaint with the prosecution and the start of the summary investigation. This ruling will apply prospectively.

The SC recognized that while criminal cases should ideally be resolved promptly, delays are sometimes unavoidable. Therefore, the State, as the offended party, should not be disadvantaged by delays in the DOJ’s preliminary investigations, even in criminal cases under summary procedure.

The SC also clarified that under Section 281 of the 1997 National Internal Revenue Code, the prescriptive period for criminal tax offenses that are not immediately known starts from the time the violation is discovered. The prescriptive period is interrupted once a preliminary investigation begins.

Read the full text of the Press Release at https://tinyurl.com/26tfrr38.

The full text of the SC En Banc Decision in G.R. No. 258563 shall be uploaded to the SC website once available.

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

10/03/2025

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/.

08/03/2025

Honoring women.
Honoring their strength,
their courage,
their love,
their kindness,
their brilliance.

Happy International Women’s Day! 💜

04/03/2025

The (SC) has ruled that security guards working under a broken period scheme must be paid overtime if their break is too short for personal use.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division ordered Seabren Security Agency (Seabren) to compensate security guards Lorenzo D. Cambila, Jr. and Albajar S. Samad (security guards) for the four-hour breaks or intervals they were required to spend at work beyond their regular duty hours.

Seabren hired the security guards and made them work 12-hour shifts. Their schedule required them to work four hours, take a four-hour break, and work another four hours.

When Seabren ignored their request for a salary increase and reassigned them to a different post, the security guards filed a complaint for constructive dismissal and unpaid overtime pay.

Ruling in favor of the security guards, the Supreme Court found that they were able to show they worked more than eight hours and are thus entitled to overtime pay under the Labor Code.

The SC held that the broken period scheme implemented by Seabren was designed to circumvent labor laws and avoid overtime pay. “It was impractical and costly for minimum wage security guards to leave work, go home, and then come back on the same day,” said the SC.

Read the full text of the Press Release at:
https://sc.judiciary.gov.ph/sc-security-guards-in-broken-shift-scheme-entitled-to-overtime-pay/.

Read the full text of the Decision at:
https://sc.judiciary.gov.ph/261716-lorenzo-d-cambila-jr-et-al-vs-seabren-security-agency-et-al/.

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

28/02/2025

Happy birthday, Atty. Boysie!

We are lucky to have you both as a colleague and a friend. May your special day be filled with remarkable moments and your year ahead be even brighter.

- your PGM Law family

27/02/2025

24/02/2025

22/02/2025

Happy birthday, Atty. Dexter!

We hope your birthday is filled with joy and laughter, and that the coming year brings you all the accomplishments you've worked so hard for.

- your PGM Law family