Atty. Louise Yanto, CPA

Atty. Louise Yanto, CPA Atty.

Louise Totanes Yanto Law Office
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12/05/2026

SUPREME COURT: DARAB JURISDICTION LIMITED TO AGRARIAN DISPUTES, EXCLUDES ORDINARY LOAN TRANSACTIONS

The Supreme Court (SC) ruled that the Department of Agrarian Reform Adjudication Board (DARAB) exercises primary and exclusive jurisdiction only over "agrarian disputes," which require the existence of a tenurial arrangement such as tenancy or leasehold between the parties and do not extend to ordinary loan transactions.

In an 18-page decision penned by Chief Justice Alexander Gesmundo, the SC's First Division reversed the ruling of the Court of Appeals that invalidated the previous decision of the DARAB, as it ruled that DARAB adjudicators had no jurisdiction over the case because the reallocation of land is an administrative matter under the exclusive jurisdiction of the DAR secretary.

The case stemmed from the action filed by Carmelita Mercado for the annulment of the transfer certificate of title emancipation patent No. against the heirs of Serafin De Guzman. The dispute involves an 8,212-square-meter portion of a larger agricultural land covered by the said title, which is registered in the name of the heirs of De Guzman.

Mercado claimed that this portion was erroneously included in De Guzman's title. She relied on a December 20, 1994, decision by the Provincial Agrarian Reform Adjudicator (PARAD), which ordered the segregation of the portion and the generation of an Emancipation Patent in her favor. Mercado argued that this 1994 PARAD decision had already attained finality and was therefore immutable.

The Heirs of De Guzman countered that one of the heirs, Rogelio, merely lent the disputed portion to Mercado to finance the hospitalization of his daughter. They executed a waiver of rights due to an inability to pay the loan, but the heirs maintained that they had fully paid the land amortization to the Land Bank of the Philippines.

The Regional Agrarian Reform Adjudicator (RARAD) dismissed Mercado's complaint, ruling that the 1994 RARAD decision was void for violating due process and that Mercado was not a rightful reallocatee because the Department of Agrarian Reform (DAR) never issued an order of reallocation.

On appeal, the DARAB set aside the previous decisions, ruling that the DARAB (and its adjudicators) had no jurisdiction over the case because the reallocation of land is an administrative matter under the exclusive jurisdiction of the DAR Secretary.

The CA reversed the DARAB, ruling that the DARAB had jurisdiction over the cancellation of registered emancipation patents. The CA also ruled that the doctrine of immutability of judgment did not apply to the 1994 PARAD decision because agrarian quasi-judicial agencies are not bound by technical rules of procedure. This paved the way for Mercado to elevate the case before the Supreme Court.

In reversing the appellate court ruling, the high court held that DARAB had no jurisdiction over the case. The DARAB exercises primary and exclusive jurisdiction only over "agrarian disputes," which require the existence of a tenurial arrangement (such as tenancy or leasehold) between the parties.

It explained that in this case, there was no tenurial arrangement between Mercado and the heirs of De Guzman; the transaction was merely a loan to finance a hospitalization.

The highest bench also disagreed with the CA's reasoning as to the application of the 1994 PARAD decision. It clarified that the doctrine of immutability of judgment does apply to quasi-judicial agencies like the DARAB. However, the 1994 PARAD decision cannot be enforced as it falls under a recognized exception, being a void judgment.

"A void judgment produces no legal or binding effect, never attains finality, and can be challenged at any time," the Supreme Court said.

12/05/2026

The has clarified that a contractorโ€™s lack of tools, equipment, or machinery does not automatically amount to prohibited labor-only contracting when the contracted work does not require them.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC's Third Division held that MMA Competent Manpower & General Services, Inc. (MMA) is a legitimate job contractor and the employer of petitioners Richard Delera and Dionel Quiling.

MMA is a domestic corporation that offers human resource and support services to clients, including Philippine Foremost Milling Corp. (PFMC), which is involved in flour milling, and Amigo Logistics Corp. (Amigo), which manages logistics such as warehousing and trucking.

MMA assigned petitioners to PFMC and Amigo as feed mill bagger and pollard stacker, respectively. After they were reported for policy violations, MMA preventively suspended but later cleared them of charges.

PFMC and Amigo requested the petitionersโ€™ reassignment. MMA initially had to place them on floating status, but later offered their reassignment to Cavite and Bataan, which they declined. They instead filed a complaint for illegal dismissal, claiming that MMA was a labor-only contractor and that they were regular employees of PFMC and Amigo.

The SC ruled that MMA, which had substantial funds of PHP 27 million, was a legitimate labor contractor even though it lacked tools, equipment, or machinery.

It distinguished between ๐—น๐—ฒ๐—ด๐—ถ๐˜๐—ถ๐—บ๐—ฎ๐˜๐—ฒ ๐—น๐—ฎ๐—ฏ๐—ผ๐—ฟ ๐—ฐ๐—ผ๐—ป๐˜๐—ฟ๐—ฎ๐—ฐ๐˜๐—ถ๐—ป๐—ด, wherein employers may hire a contractor to perform specific jobs provided it has sufficient funds and tools, and prohibited ๐—น๐—ฎ๐—ฏ๐—ผ๐—ฟ-๐—ผ๐—ป๐—น๐˜† ๐—ฐ๐—ผ๐—ป๐˜๐—ฟ๐—ฎ๐—ฐ๐˜๐—ถ๐—ป๐—ด, where a contractor merely provides workers without having sufficient funds and tools, and the workers perform tasks directly related to the employerโ€™s main business.

Citing the case of ๐˜Š๐˜ฐ๐˜ฏ๐˜ฒ๐˜ถ๐˜ฆ๐˜ณ๐˜ฐ๐˜ณ ๐˜๐˜ฏ๐˜ฅ๐˜ถ๐˜ด๐˜ต๐˜ณ๐˜ช๐˜ข๐˜ญ ๐˜—๐˜ฆ๐˜ข๐˜ค๐˜ฆ ๐˜”๐˜ข๐˜ฏ๐˜ข๐˜จ๐˜ฆ๐˜ฎ๐˜ฆ๐˜ฏ๐˜ต ๐˜Š๐˜ฐ๐˜ฐ๐˜ฑ๐˜ฆ๐˜ณ๐˜ข๐˜ต๐˜ช๐˜ท๐˜ฆ ๐˜ท. ๐˜‰๐˜ข๐˜ญ๐˜ช๐˜ฏ๐˜จ๐˜ฃ๐˜ช๐˜ฏ๐˜จ, which provides a limited exception where the work is merely supportive and does not require tools, the SC found that petitioners performed post-production tasks similar to packaging and storing, which merely supported PFMCโ€™s and Amigoโ€™s operations.

Since these duties do not require specialized machinery or technical expertise, the SC ruled that they could be contracted out even without major investment in tools or equipment.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=165353.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164807.

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

12/05/2026

ICC RETAINS JURISDICTION!!

READ: In 2021, the Supreme Court sitting En Banc affirms the legality of the withdrawal from the Rome Statute, the establishing treaty of the International Criminal Court initiated by former president Rodrigo Duterte, saying it is well within his prerogative as a primary architect of the country's foreign policy.

Voting 15-0, the high court also held the president's discretion to withdraw from treaties is not unilateral and is subject to legislative concurrence from the Senate.

While the court upheld the validity of such withdrawal, Justice Leonen made an obiter dictum reservation saying the ICC retains jurisdiction over any and all acts committed by government actors until March 17, 2019, and does not affect the liabilities of individuals charged before the international tribunal for acts committed up to the effectiveness of such withdrawal.

12/05/2026
06/05/2026

The has acquitted a man charged with violence against women and their children, or VAWC, for allegedly refusing to provide financial support to a child not proven to be his, emphasizing that a legal duty to provide financial support arises only after filiation or paternity has been established.

In a Decision written by Associate Justice Japar B. Dimaampao, the SCโ€™s Third Division reversed the rulings of the Regional Trial Court and the Court of Appeals, which found the accused guilty of economic abuse under Republic Act No. 9262, or the ๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜๐˜ช๐˜ฐ๐˜ญ๐˜ฆ๐˜ฏ๐˜ค๐˜ฆ ๐˜ˆ๐˜จ๐˜ข๐˜ช๐˜ฏ๐˜ด๐˜ต ๐˜ž๐˜ฐ๐˜ฎ๐˜ฆ๐˜ฏ ๐˜ข๐˜ฏ๐˜ฅ ๐˜›๐˜ฉ๐˜ฆ๐˜ช๐˜ณ ๐˜Š๐˜ฉ๐˜ช๐˜ญ๐˜ฅ๐˜ณ๐˜ฆ๐˜ฏ ๐˜ˆ๐˜ค๐˜ต ๐˜ฐ๐˜ง 2004 (๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜๐˜ˆ๐˜ž๐˜Š ๐˜ˆ๐˜ค๐˜ต).

The case arose from a complaint filed by a woman against her former boyfriend, accusing him of refusing to provide financial support for her child.

The accused consistently denied he was the father, claiming that the child was born only eight months after they last had sexual relations.

During trial, the woman presented the childโ€™s birth certificate as evidence. However, the portion indicating the fatherโ€™s name, was marked "๐˜•/๐˜ˆ" and left unsigned.

The woman also admitted in court that the accused refused to give financial support because he doubted that he was the childโ€™s father.

In reversing the accusedโ€™s conviction, the SC explained that to convict a person for economic abuse under Section 5(i) of the ๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜๐˜ˆ๐˜ž๐˜Š ๐˜ˆ๐˜ค๐˜ต, the prosecution must show the following: (1) the victim is a woman and/or her child; (2) the woman is the offenderโ€™s wife or partner, or someone with whom the offender has a common child; (3) the offender refused to give financial support due; and (4) the refusal was intended to cause mental or emotional suffering.

In this case, the SC ruled that the prosecution failed to prove two essential elements: that the accused and the woman share a common child, and that the refusal to provide support was done to inflict psychological harm.

As the accusedโ€™s paternity was not proven in this case, no legal obligation to provide support could be imposed.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=164663.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164655.

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

17/04/2026

PROOF THAT THE VICTIM BECAME INSANE NOT REQUIRED IN PSYCHOLOGICAL VIOLENCE

The Supreme Court (SC), speaking through Associate Justice Amy Lazaro-Javier, ruled that proof of intent on the part of the husband in cases of psychological violence due to infidelity under Republic Act No. 9262 is not necessary for conviction, as it only requires proof of emotional anguish and mental suffering.

In a 17-page decision, the SCโ€™s Second Division emphasized that the husbandโ€™s intention in choosing his mistress over his wife is immaterial, noting that his act of leaving the conjugal home and building a family with another woman was done consciously and deliberately.

It added that he cannot escape liability by invoking good intentions, such as remaining civil with his wife or providing financial support to their legitimate son, as the fact remains: he was unfaithful to his wife, and this caused her irreparable emotional and mental suffering.

The high court sentenced the accused to suffer the penalty of up to 8 years imprisonment and a fine of PHP100,000.

17/04/2026

SUPREME COURT SLAPS HUSBAND WITH UP TO 8 YEARS IMPRISONMENT FOR HAVING A MISTRESS THAT CAUSED WIFE MENTAL ANGUISH

The Supreme Court (SC) has convicted a man of psychological violence for causing mental and emotional anguish to his wife after abandoning her to live with his mistress, with whom he had two children, noting that criminal intent to cause such anguish is presumed from the act of infidelity.

In a 17-page decision penned by Associate Justice Amy Lazaro-Javier, the SC's Second Division has affirmed the criminal conviction of the accused for violating Section 5(i) of Republic Act No. 9262, or psychological violence, and sentenced him to suffer the penalty of four to eight years imprisonment.

The case stemmed from the criminal complaints filed by his own wife, whom he left for another woman. The accused and complainant were married in 2005 and had a son in 2008. While the wife was pregnant, she noticed the accused frequently coming home in the wee hours of the morning.

She later discovered a text message on his phone from another woman saying, "AYAW KO NG MAGING KABIT" (I don't want to be a mistress). When confronted, the accused dismissed it as a prank. The following day, he left their conjugal home and never returned, only visiting their son on weekends.

The wife later discovered that the accused was living with his mistress, with whom he fathered two children, and publicly flaunted their relationship and their children on social media. Because of this, the wife suffered mental and emotional anguish and was diagnosed by a psychiatrist with depression (dysthymia).

This prompted her to file a criminal complaint against the accused for psychological violence under Section 5(i) of Republic Act (R.A.) No. 9262, or the Anti-Violence Against Women and Their Children Act of 2004.

The Regional Trial Court (RTC) acquitted the accused based on reasonable doubt, reasoning that the complaint was filed belatedly four years after the separation. It noted that the accused continued to provide financial support, and the marital infidelity allegedly occurred after their de facto separation.

The Office of the Solicitor General (OSG) filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA), arguing that the RTC committed grave abuse of discretion.

The CA reversed the RTC's decision and convicted the husband, ruling that the evidence clearly showed his infidelity caused the wife mental and emotional suffering. This paved the way for him to elevate the case before the Supreme Court, arguing that the CA's reversal of his acquittal violated his constitutional right against double jeopardy.

In dismissing his appeal, the high court ruled that double jeopardy does not attach to void judgments. While a judgment of acquittal is generally final and unappealable, it may be assailed by the People through a petition for certiorari under Rule 65 if it is shown that the trial court acted without jurisdiction or with grave abuse of discretion.

It noted that the trial court committed grave abuse of discretion by acting with an obstinate disregard of basic and established rules of law and erroneously held that marital infidelity committed after a de facto separation falls outside the scope of R.A. No. 9262.

The highest bench emphasized that a mere de facto separation does not sever marriage bonds; thus, any extramarital affair maintained by a spouse still constitutes marital infidelity.

It underscored that marital infidelity is expressly recognized as a form of psychological violence under Section 3(c) in relation to Section (i) of RA No. 9262. The court added that the requirement of specific criminal intent to cause mental and emotional suffering is already satisfied at the moment the perpetrator commits the act of infidelity, as the act is inherently immoral and depraved.

It gave credence to the psychiatric evaluation, which revealed that the wife suffered emotional anguish as a result of the breakdown of her marriage. She had sleep disturbances, constant self-pity, feelings of hopelessness and worthlessness, palpitations, social withdrawal, and depression.

"At any rate, the law does not require proof that the victim became psychologically ill due to the psychological violence done by her abuser. The law only requires emotional anguish and mental suffering to be proven. To establish emotional anguish or mental suffering, jurisprudence only requires that the testimony of the victim be presented in court since such experiences are personal to this party," the Supreme Court said.

"To be sure, whatever ###'s intention was when he chose another woman over his wife is immaterial. For his leaving their conjugal home and building a family with his mistress are acts that were done by him consciously and deliberately. He could not feign innocence by hiding behind good intentions-may they be excuses that he remained civil with AAA or he constantly supported his legitimate son, BBB. The incontrovertible fact remains: he was unfaithful to his wife, and this caused her irreparable mental and emotional hurt." it added.

Aside from imprisonment, he is also ordered to pay a fine of Php100,000.

07/04/2026

The (SC) clarified the application of lascivious conduct under ๐˜™๐˜ฆ๐˜ฑ๐˜ถ๐˜ฃ๐˜ญ๐˜ช๐˜ค ๐˜ˆ๐˜ค๐˜ต (๐˜™๐˜ˆ) ๐˜•๐˜ฐ. 7610, or ๐˜ต๐˜ฉ๐˜ฆ ๐˜š๐˜ฑ๐˜ฆ๐˜ค๐˜ช๐˜ข๐˜ญ ๐˜—๐˜ณ๐˜ฐ๐˜ต๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ ๐˜ฐ๐˜ง ๐˜Š๐˜ฉ๐˜ช๐˜ญ๐˜ฅ๐˜ณ๐˜ฆ๐˜ฏ ๐˜ˆ๐˜จ๐˜ข๐˜ช๐˜ฏ๐˜ด๐˜ต ๐˜ˆ๐˜ฃ๐˜ถ๐˜ด๐˜ฆ, ๐˜Œ๐˜น๐˜ฑ๐˜ญ๐˜ฐ๐˜ช๐˜ต๐˜ข๐˜ต๐˜ช๐˜ฐ๐˜ฏ ๐˜ข๐˜ฏ๐˜ฅ ๐˜‹๐˜ช๐˜ด๐˜ค๐˜ณ๐˜ช๐˜ฎ๐˜ช๐˜ฏ๐˜ข๐˜ต๐˜ช๐˜ฐ๐˜ฏ ๐˜ˆ๐˜ค๐˜ต, in relation to acts of lasciviousness under the ๐˜™๐˜ฆ๐˜ท๐˜ช๐˜ด๐˜ฆ๐˜ฅ ๐˜—๐˜ฆ๐˜ฏ๐˜ข๐˜ญ ๐˜Š๐˜ฐ๐˜ฅ๐˜ฆ (๐˜™๐˜—๐˜Š).

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC ๐˜Œ๐˜ฏ ๐˜‰๐˜ข๐˜ฏ๐˜ค upheld Jeffrey L. Gramaticaโ€™s conviction for lascivious conduct under ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610, but modified another accusedโ€™s (###2660399) conviction for acts of lasciviousness under ๐˜ˆ๐˜ณ๐˜ต๐˜ช๐˜ค๐˜ญ๐˜ฆ 366 ๐˜ฐ๐˜ง ๐˜ต๐˜ฉ๐˜ฆ ๐˜™๐˜—๐˜Š.

In these consolidated cases involving minors, AAA, BBB, and CCC, the Supreme Court laid down guidelines to ensure the proper prosecution of cases under these two distinct laws.

AAA and BBB, both addicted to shabu, engaged in sexual acts with Gramatica and another man in exchange for the drug. Gramatica was later arrested and prosecuted for violation of ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610, which penalizes lascivious conduct committed against a child exploited in prostitution or other sexual abuse.

In the other case, CCC was victimized by her grandfather, ###266039, who touched her private parts while she was sleeping. ###266039 was also charged under ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610.

In his defense, Gramatica claimed that he courted BBB and had a sexual relationship with her but did not know she was a minor because she looked mature. For his part, ###266039 denied the charges and claimed he merely woke CCC up to ask her for help applying his eye medicine.

The Regional Trial Court found both Gramatica and ###266039 guilty of lascivious conduct under ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 towards BBB and CCC, respectively. The Court of Appeals affirmed their convictions.

A minor is considered to have been subjected to other sexual abuse when they are a victim of lascivious conduct under the coercion or influence of an adult. In this case, BBB was 14 and CCC was 17 at the time of the incident. Gramatica was 23, and ###266039 was 62.

Both courts found that Gramatica took advantage of BBBโ€™s youth and vulnerable situation, using his influence over her to make her submit to his sexual demands. Meanwhile, ###266039, due to his age and relationship as CCCโ€™s grandfather, was able to exert control over her and exploit her trust.

The SC affirmed Gramaticaโ€™s conviction under RA 7610, but modified ###266039โ€™s conviction from acts of lasciviousness under ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 to acts of lasciviousness under the RPC explaining that RA 7610 does not apply where the minor is entirely unaware, coerced or unconscious as the victim in that instance is not considered to have โ€œindulgedโ€ in the sexual in*******se.

A plain and straightforward interpretation of ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 provides a clear definition of children subjected to other sexual abuse as those who indulge in sexual in*******se or lascivious conduct due to the coercion or influence of an adult.

The SC clarified the scope of lascivious conduct under ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 and distinguished it from related crimes under the RPC. To ensure uniform and consistent prosecution of cases, the Supreme Court laid down guidelines, considering also RA 11648, which raised the age of sexual consent to 16 years old.

๐™๐™ž๐™ง๐™จ๐™ฉ, ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 applies to children who are 12 years of age (now 16 years old following the amendment under RA 11648) to below 18 who are subjected to sexual abuse.

๐™Ž๐™š๐™˜๐™ค๐™ฃ๐™™, it covers situations where consent is present but defective. The minor may seem to โ€œindulgeโ€ or agree, but does so not out of free will, but because of coercion or influence by an adult. Thus, engaging in sexual acts with a child exploited in prostitution or subjected to sexual abuse is a criminal act, regardless of apparent consent.

๐™๐™๐™ž๐™ง๐™™, it does not apply when the act involves force, intimidation, fraud, deprivation of reason, unconsciousness, or grave abuse of authority. In such cases, the crime falls under acts of lasciviousness under the RPC.

๐™๐™ค๐™ช๐™ง๐™ฉ๐™, if the victim is under 12 or under 16, and the case does not fit Section 5(b), the crime is r**e or acts of lasciviousness under the RPC.

These principles, which distinguish force and intimidation on one hand, and coercion and influence on the other, and limit RA 7610 to minors who are exploited in prostitution or sexual abuse, also apply to other sexual crimes, including r**e.

In this case, BBB was a child exploited in prostitution or other sexual abuse because she had sexual in*******se with Gramatica in exchange for some consideration, namely shabu, which makes him criminally liable under Section 5(b).

Meanwhile, ๐˜š๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ 5(๐˜ฃ) ๐˜ฐ๐˜ง ๐˜™๐˜ˆ 7610 does not apply to ###266039.

The Supreme Court clarified that not all acts of lasciviousness against minors aged 12 to under 18 are covered by RA 7610. The law applies only when minors are subjected to sexual abuse, such as when they โ€œindulgeโ€ or give defective consent to the conduct.

Here, CCC did not indulge in lascivious conduct, as she was asleep and unconscious during the incident. ###266039 did not use coercion or influence, but relied on his moral ascendancy as her grandfather, which counts as intimidation. These circumstances make ###266039 liable for acts of lasciviousness under ๐˜ˆ๐˜ณ๐˜ต๐˜ช๐˜ค๐˜ญ๐˜ฆ 336 ๐˜ฐ๐˜ง ๐˜ต๐˜ฉ๐˜ฆ ๐˜™๐˜—๐˜Š, rather than RA 7610.

For lascivious conduct under Section 5(b) involving BBB, Gramatica was sentenced to a maximum of 17 years, four months, and one day in prison and ordered to pay BBB PHP 150,000 in civil indemnity and damages, as well as a PHP 15,000 fine.

For acts of lasciviousness under ๐˜ˆ๐˜ณ๐˜ต๐˜ช๐˜ค๐˜ญ๐˜ฆ 336 ๐˜ฐ๐˜ง ๐˜ต๐˜ฉ๐˜ฆ ๐˜™๐˜—๐˜Š, ###266039 was sentenced to a maximum of six years in prison and ordered to pay CCC PHP450,000 in civil indemnity and damages with interest.

The SC acknowledged that under current laws, ###266039, โ€œwho committed abhorrent and be***al acts against his minor granddaughter,โ€ faces a penalty lower than that under RA 7610, and called on the legislature to amend existing laws to better protect children.

The SC calls the legislature to review and amend current laws protecting children, thus:

โ€œ๐˜๐˜ฏ ๐˜ญ๐˜ช๐˜ฏ๐˜ฆ ๐˜ธ๐˜ช๐˜ต๐˜ฉ ๐˜ต๐˜ฉ๐˜ฆ ๐˜ข๐˜ฃ๐˜ฐ๐˜ท๐˜ฆ, ๐˜ข๐˜ฏ๐˜ฅ ๐˜ช๐˜ฏ ๐˜ง๐˜ถ๐˜ญ๐˜ง๐˜ช๐˜ญ๐˜ญ๐˜ฎ๐˜ฆ๐˜ฏ๐˜ต ๐˜ฐ๐˜ง ๐˜ต๐˜ฉ๐˜ฆ ๐˜Š๐˜ฐ๐˜ถ๐˜ณ๐˜ตโ€™๐˜ด ๐˜ฅ๐˜ถ๐˜ต๐˜บ ๐˜ต๐˜ฐ ๐˜ถ๐˜ฑ๐˜ฉ๐˜ฐ๐˜ญ๐˜ฅ ๐˜ต๐˜ฉ๐˜ฆ ๐˜Š๐˜ฐ๐˜ฏ๐˜ด๐˜ต๐˜ช๐˜ต๐˜ถ๐˜ต๐˜ช๐˜ฐ๐˜ฏ, ๐˜ธ๐˜ฉ๐˜ช๐˜ค๐˜ฉ ๐˜ฎ๐˜ข๐˜ฏ๐˜ฅ๐˜ข๐˜ต๐˜ฆ๐˜ด ๐˜ต๐˜ฉ๐˜ฆ ๐˜ด๐˜ฑ๐˜ฆ๐˜ค๐˜ช๐˜ข๐˜ญ ๐˜ฑ๐˜ณ๐˜ฐ๐˜ต๐˜ฆ๐˜ค๐˜ต๐˜ช๐˜ฐ๐˜ฏ ๐˜ฐ๐˜ง ๐˜ค๐˜ฉ๐˜ช๐˜ญ๐˜ฅ๐˜ณ๐˜ฆ๐˜ฏ ๐˜ง๐˜ณ๐˜ฐ๐˜ฎ ๐˜ข๐˜ญ๐˜ญ ๐˜ง๐˜ฐ๐˜ณ๐˜ฎ๐˜ด ๐˜ฐ๐˜ง ๐˜ฏ๐˜ฆ๐˜จ๐˜ญ๐˜ฆ๐˜ค๐˜ต, ๐˜ข๐˜ฃ๐˜ถ๐˜ด๐˜ฆ, ๐˜ค๐˜ณ๐˜ถ๐˜ฆ๐˜ญ๐˜ต๐˜บ, ๐˜ฆ๐˜น๐˜ฑ๐˜ญ๐˜ฐ๐˜ช๐˜ต๐˜ข๐˜ต๐˜ช๐˜ฐ๐˜ฏ ๐˜ข๐˜ฏ๐˜ฅ ๐˜ฐ๐˜ต๐˜ฉ๐˜ฆ๐˜ณ ๐˜ค๐˜ฐ๐˜ฏ๐˜ฅ๐˜ช๐˜ต๐˜ช๐˜ฐ๐˜ฏ๐˜ด ๐˜ฑ๐˜ณ๐˜ฆ๐˜ซ๐˜ถ๐˜ฅ๐˜ช๐˜ค๐˜ช๐˜ข๐˜ญ ๐˜ต๐˜ฐ ๐˜ต๐˜ฉ๐˜ฆ๐˜ช๐˜ณ ๐˜ฅ๐˜ฆ๐˜ท๐˜ฆ๐˜ญ๐˜ฐ๐˜ฑ๐˜ฎ๐˜ฆ๐˜ฏ๐˜ต, ๐˜ญ๐˜ฆ๐˜ต ๐˜ต๐˜ฉ๐˜ช๐˜ด ๐˜ด๐˜ฆ๐˜ณ๐˜ท๐˜ฆ ๐˜ข๐˜ด ๐˜ข ๐˜ค๐˜ข๐˜ญ๐˜ญ ๐˜ต๐˜ฐ ๐˜ต๐˜ฉ๐˜ฆ ๐˜ญ๐˜ฆ๐˜จ๐˜ช๐˜ด๐˜ญ๐˜ข๐˜ต๐˜ถ๐˜ณ๐˜ฆ ๐˜ต๐˜ฐ ๐˜ง๐˜ถ๐˜ญ๐˜ง๐˜ช๐˜ญ๐˜ญ ๐˜ช๐˜ต๐˜ด ๐˜ฃ๐˜ฐ๐˜ถ๐˜ฏ๐˜ฅ๐˜ฆ๐˜ฏ ๐˜ฅ๐˜ถ๐˜ต๐˜บ ๐˜ฐ๐˜ง ๐˜ณ๐˜ฆ๐˜ท๐˜ช๐˜ฆ๐˜ธ๐˜ช๐˜ฏ๐˜จ ๐˜ข๐˜ฏ๐˜ฅ ๐˜ข๐˜ฎ๐˜ฆ๐˜ฏ๐˜ฅ๐˜ช๐˜ฏ๐˜จ ๐˜ฐ๐˜ถ๐˜ณ ๐˜ฑ๐˜ณ๐˜ฆ๐˜ด๐˜ฆ๐˜ฏ๐˜ต ๐˜ญ๐˜ข๐˜ธ๐˜ด ๐˜ข๐˜ฏ๐˜ฅ ๐˜ฆ๐˜ฏ๐˜ด๐˜ถ๐˜ณ๐˜ช๐˜ฏ๐˜จ ๐˜ต๐˜ฉ๐˜ฆ ๐˜ด๐˜ข๐˜ง๐˜ฆ๐˜ต๐˜บ, ๐˜ธ๐˜ฆ๐˜ญ๐˜ญ-๐˜ฃ๐˜ฆ๐˜ช๐˜ฏ๐˜จ, ๐˜ข๐˜ฏ๐˜ฅ ๐˜ฅ๐˜ช๐˜จ๐˜ฏ๐˜ช๐˜ต๐˜บ ๐˜ฐ๐˜ง ๐˜ฐ๐˜ถ๐˜ณ ๐˜๐˜ช๐˜ญ๐˜ช๐˜ฑ๐˜ช๐˜ฏ๐˜ฐ ๐˜ค๐˜ฉ๐˜ช๐˜ญ๐˜ฅ๐˜ณ๐˜ฆ๐˜ฏ.โ€

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=162863

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=162842

Read the Separate Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/260233-266039-separate-concurring-opinion-senior-associate-justice-marvic-m-v-f-leonen/

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/260233-266039-concurring-opinion-associate-justice-alfredo-benjamin-s-caguioa/

Read the Separate Concurring Opinion of Associate Justice Rodil V. Zalameda at https://sc.judiciary.gov.ph/260233-266039-separate-concurring-opinion-associate-justice-rodil-v-zalameda/

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

12/11/2025

In light of the damage caused by Typhoon Uwan, our office is offering assistance to individuals who lost important documents during the storm. We will be providing free preparation and notarization of Affidavits of Loss to those affected.

Those who wish to avail may proceed to Atty. Louise Totanes Yanto Law Office, Gache Plaza Building, F. Pimentel Avenue, Daet, Camarines Norte.

This effort is intended solely to help members of the community in restoring necessary records after the typhoon.

Send a message to learn more

02/09/2025

๐๐š๐ฐ๐š๐ญ ๐ฉ๐ข๐ฌ๐จ, ๐ค๐ข๐ญ๐š ๐ง๐  ๐ฉ๐ฎ๐›๐ฅ๐ข๐ค๐จ. ๐Ÿงพ

Weโ€™ve officially filed the ๐๐ฅ๐จ๐œ๐ค๐œ๐ก๐š๐ข๐ง ๐ญ๐ก๐ž ๐๐ฎ๐๐ ๐ž๐ญ ๐๐ข๐ฅ๐ฅ, isang panukalang batas na naglalayong gawing transparent at accessible ang national budget gamit ang blockchain technology.

Walang tago. Walang lusot. Bawat kontrata, bawat proyekto โ€” kayang i-track, i-audit, at unawain ng bawat Pilipino.

๐’๐”๐๐Ž๐‘๐“๐€๐‡๐€๐ ๐š๐ง๐  ๐’๐๐ ๐Ÿ๐Ÿ‘๐Ÿ‘๐ŸŽ ๐จ ๐š๐ง๐  ๐๐ฅ๐จ๐œ๐ค๐œ๐ก๐š๐ข๐ง ๐ญ๐ก๐ž ๐๐ฎ๐๐ ๐ž๐ญ ๐๐ข๐ฅ๐ฅ para sa mas efficient, transparent, at accountable na pamahalaan.

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