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10/08/2026

Madalas nating mabasa o marinig ang mga salitang Latin sa mga balita, korte, at iba’t ibang usaping legal. Pero ano nga ba ang ibig sabihin ng mga ito sa wika at sa paraang hindi ka malilito?

30/07/2026

Online notarization now allowed anywhere in the Philippines.

13/07/2026

𝐀 𝐏𝐡𝐨𝐭𝐨𝐜𝐨𝐩𝐲 𝐂𝐚𝐧 𝐁𝐞 𝐉𝐮𝐬𝐭 𝐚𝐬 𝐄𝐟𝐟𝐞𝐜𝐭𝐢𝐯𝐞 𝐚𝐬 𝐭𝐡𝐞 𝐎𝐫𝐢𝐠𝐢𝐧𝐚𝐥 𝐢𝐧 𝐂𝐨𝐮𝐫𝐭

Many still believe that only the original document can be admitted as evidence in court. The Supreme Court has clarified that this is no longer always the case.

𝐈𝐧 𝐭𝐡𝐞 𝐜𝐚𝐬𝐞 𝐨𝐟 𝐏𝐞𝐨𝐩𝐥𝐞 𝐯𝐬. 𝐋𝐚𝐬𝐭𝐢𝐦𝐨𝐬𝐚, 𝐭𝐡𝐞 𝐒𝐮𝐩𝐫𝐞𝐦𝐞 𝐂𝐨𝐮𝐫𝐭 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐚 𝐩𝐡𝐨𝐭𝐨𝐜𝐨𝐩𝐲 𝐢𝐬 𝐚𝐝𝐦𝐢𝐬𝐬𝐢𝐛𝐥𝐞 𝐚𝐬 𝐚 𝐝𝐮𝐩𝐥𝐢𝐜𝐚𝐭𝐞 𝐚𝐧𝐝 𝐡𝐚𝐬 𝐭𝐡𝐞 𝐬𝐚𝐦𝐞 𝐞𝐯𝐢𝐝𝐞𝐧𝐭𝐢𝐚𝐫𝐲 𝐯𝐚𝐥𝐮𝐞 𝐚𝐬 𝐭𝐡𝐞 𝐨𝐫𝐢𝐠𝐢𝐧𝐚𝐥 𝐮𝐧𝐝𝐞𝐫 𝐑𝐮𝐥𝐞 𝟏𝟑𝟎, 𝐒𝐞𝐜𝐭𝐢𝐨𝐧𝐬 𝟑 𝐚𝐧𝐝 𝟒 𝐨𝐟 𝐭𝐡𝐞 𝟐𝟎𝟏𝟗 𝐀𝐦𝐞𝐧𝐝𝐦𝐞𝐧𝐭𝐬 𝐭𝐨 𝐭𝐡𝐞 𝟏𝟗𝟖𝟗 𝐑𝐞𝐯𝐢𝐬𝐞𝐝 𝐑𝐮𝐥𝐞𝐬 𝐨𝐧 𝐄𝐯𝐢𝐝𝐞𝐧𝐜𝐞, 𝐮𝐧𝐥𝐞𝐬𝐬 𝐭𝐡𝐞𝐫𝐞 𝐢𝐬 𝐚 𝐠𝐞𝐧𝐮𝐢𝐧𝐞 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧 𝐚𝐬 𝐭𝐨 𝐭𝐡𝐞 𝐚𝐮𝐭𝐡𝐞𝐧𝐭𝐢𝐜𝐢𝐭𝐲 𝐨𝐟 𝐭𝐡𝐞 𝐨𝐫𝐢𝐠𝐢𝐧𝐚𝐥 𝐨𝐫 𝐢𝐭 𝐰𝐨𝐮𝐥𝐝 𝐛𝐞 𝐮𝐧𝐣𝐮𝐬𝐭 𝐨𝐫 𝐢𝐧𝐞𝐪𝐮𝐢𝐭𝐚𝐛𝐥𝐞 𝐭𝐨 𝐚𝐝𝐦𝐢𝐭 𝐭𝐡𝐞 𝐝𝐮𝐩𝐥𝐢𝐜𝐚𝐭𝐞.

On November 17, 2012, at around 4:30 p.m. in Cansojong, Talisay City, Cebu, Ybo Lastimosa allegedly shot Ildefonso Vega, Jr. three times while the latter was on his motorcycle outside a cockpit arena. The prosecution relied on the testimonies of eyewitnesses Elmer Cañeda and Vicente Cortes, who positively identified Lastimosa as the gunman, and on the testimony of the victim's wife, Dureza Vega, who presented a photocopy of Ildefonso's death certificate after failing to produce the original. In his defense, Lastimosa denied the accusation and claimed that he was at his residence in Cebu City at the time of the incident. The Regional Trial Court convicted him of Homicide, but the Court of Appeals modified the conviction to Murder after finding that the killing was attended by treachery. On appeal before the Supreme Court, Lastimosa argued that the prosecution failed to prove the corpus delicti because it presented only a photocopy of the death certificate instead of the original.

The Supreme Court held that the photocopy of the victim's death certificate was admissible in evidence. It ruled that under the 2019 Revised Rules on Evidence, a photocopy is considered a "duplicate" and is admissible to the same extent as the original unless:
(1) a genuine question is raised regarding the authenticity of the original, or
(2) it would be unjust or inequitable to admit the duplicate instead of the original.

𝐓𝐡𝐞 𝐂𝐨𝐮𝐫𝐭 𝐞𝐱𝐩𝐥𝐚𝐢𝐧𝐞𝐝 𝐭𝐡𝐚𝐭 𝐭𝐡𝐞 𝟐𝟎𝟏𝟗 𝐚𝐦𝐞𝐧𝐝𝐦𝐞𝐧𝐭𝐬 𝐚𝐛𝐚𝐧𝐝𝐨𝐧𝐞𝐝 𝐭𝐡𝐞 𝐩𝐫𝐞𝐯𝐢𝐨𝐮𝐬 𝐝𝐢𝐬𝐭𝐢𝐧𝐜𝐭𝐢𝐨𝐧 𝐛𝐞𝐭𝐰𝐞𝐞𝐧 𝐞𝐥𝐞𝐜𝐭𝐫𝐨𝐧𝐢𝐜 𝐚𝐧𝐝 𝐩𝐚𝐩𝐞𝐫-𝐛𝐚𝐬𝐞𝐝 𝐝𝐨𝐜𝐮𝐦𝐞𝐧𝐭𝐬, 𝐦𝐚𝐤𝐢𝐧𝐠 𝐝𝐮𝐩𝐥𝐢𝐜𝐚𝐭𝐞𝐬 𝐨𝐟 𝐛𝐨𝐭𝐡 𝐞𝐪𝐮𝐚𝐥𝐥𝐲 𝐚𝐝𝐦𝐢𝐬𝐬𝐢𝐛𝐥𝐞. Applying the procedural rules retroactively, the Court found that the photocopy of the death certificate was a valid duplicate because its authenticity was never questioned and no showing of unfairness was made. Thus, the photocopy was properly admitted and served to corroborate the testimony of the victim's wife regarding the victim's death.

𝐏𝐞𝐨𝐩𝐥𝐞 𝐯𝐬. 𝐋𝐚𝐬𝐭𝐢𝐦𝐨𝐬𝐚
𝐆.𝐑. 𝐍𝐨. 𝟐𝟔𝟓𝟕𝟓𝟖, 𝐅𝐞𝐛𝐫𝐮𝐚𝐫𝐲 𝟎𝟑, 𝟐𝟎𝟐𝟓

Read the full text here:
https://sc.judiciary.gov.ph/wp-content/uploads/2025/05/265758.pdf

08/07/2026

𝐂𝐚𝐧 𝐎𝐜𝐜𝐮𝐩𝐚𝐧𝐭𝐬 𝐑𝐞𝐟𝐮𝐬𝐞 𝐭𝐨 𝐕𝐚𝐜𝐚𝐭𝐞 𝐀𝐟𝐭𝐞𝐫 𝐚 𝐅𝐢𝐧𝐚𝐥 𝐏𝐚𝐫𝐭𝐢𝐭𝐢𝐨𝐧 𝐉𝐮𝐝𝐠𝐦𝐞𝐧𝐭?

𝐓𝐡𝐞 𝐒𝐮𝐩𝐫𝐞𝐦𝐞 𝐂𝐨𝐮𝐫𝐭 𝐡𝐚𝐬 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭𝐥𝐲 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐚𝐟𝐭𝐞𝐫 𝐚 𝐟𝐢𝐧𝐚𝐥 𝐣𝐮𝐝𝐠𝐦𝐞𝐧𝐭 𝐢𝐧 𝐩𝐚𝐫𝐭𝐢𝐭𝐢𝐨𝐧, 𝐚𝐧 𝐡𝐞𝐢𝐫 𝐜𝐚𝐧𝐧𝐨𝐭 𝐜𝐨𝐧𝐭𝐢𝐧𝐮𝐞 𝐨𝐜𝐜𝐮𝐩𝐲𝐢𝐧𝐠 𝐚 𝐩𝐨𝐫𝐭𝐢𝐨𝐧 𝐚𝐰𝐚𝐫𝐝𝐞𝐝 𝐭𝐨 𝐚𝐧𝐨𝐭𝐡𝐞𝐫 𝐡𝐞𝐢𝐫 𝐰𝐢𝐭𝐡𝐨𝐮𝐭 𝐥𝐞𝐠𝐚𝐥 𝐛𝐚𝐬𝐢𝐬—𝐚𝐧𝐝 𝐦𝐮𝐬𝐭 𝐯𝐚𝐜𝐚𝐭𝐞 𝐰𝐡𝐞𝐧 𝐫𝐞𝐪𝐮𝐢𝐫𝐞𝐝.

The heirs of Deogracias Umadhay filed an action for partition against the heirs of Juan Hingco, seeking the division of a parcel of land in Iloilo, claiming that each group was entitled to one-half of the property. The heirs of Juan Hingco asserted exclusive ownership, but the trial court rejected their claim and ordered the land partitioned equally between the parties. After a commissioner submitted proposed subdivision plans, the court adjudicated specific portions to each group, a ruling later affirmed by the Court of Appeals. When the decision became final, the trial court issued a writ of ex*****on directing that the Umadhay heirs be placed in possession of the portion awarded to them. The Hingco heirs opposed the writ, arguing that the judgment did not expressly order delivery of possession and that they had houses and improvements on the portion awarded to the Umadhay heirs, which could not be taken without compensation.

The Supreme Court held that the trial court properly issued a writ of ex*****on placing the respondents in possession of the portion of land awarded to them, even though the judgment did not expressly order delivery of possession. It explained that the purpose of a partition is to terminate co-ownership by vesting each party with exclusive ownership and possession of the portion allotted to them. Thus, delivery of possession is a necessary consequence of a final judgment in a partition case and does not require a separate action. The Court also ruled that the petitioners' houses and other improvements had already been considered by the commissioner in making an equitable partition, as required by the Rules of Court. Accordingly, the Court found no abuse of discretion on the part of the trial court and denied the petition.

𝐃𝐨𝐫𝐨𝐭𝐞𝐚 𝐂𝐨𝐧𝐟𝐞𝐬𝐨𝐫, 𝐞𝐭 𝐚𝐥., 𝐯𝐬. 𝐇𝐨𝐧. 𝐏𝐚𝐧𝐭𝐚𝐥𝐞𝐨𝐧 𝐏𝐞𝐥𝐚𝐲𝐨, 𝐞𝐭 𝐚𝐥.
𝐆.𝐑. 𝐍𝐨. 𝐋-𝟏𝟒𝟑𝟓𝟐, 𝐌𝐚𝐫𝐜𝐡 𝟐𝟕, 𝟏𝟗𝟔𝟏

Read the full text here: https://lawphil.net/judjuris/juri1961/mar1961/gr_l-14352_1961.html

24/06/2026

𝐃𝐢𝐬𝐜𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐌𝐚𝐭𝐭𝐞𝐫𝐬: 𝐇𝐨𝐰 𝐂𝐨𝐮𝐫𝐭𝐬 𝐃𝐞𝐜𝐢𝐝𝐞 𝐂𝐫𝐢𝐦𝐢𝐧𝐚𝐥 𝐋𝐢𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐨𝐟 𝐌𝐢𝐧𝐨𝐫𝐬

𝐈𝐧 𝐚 𝐥𝐚𝐧𝐝𝐦𝐚𝐫𝐤 𝐜𝐚𝐬𝐞, 𝐭𝐡𝐞 𝐒𝐮𝐩𝐫𝐞𝐦𝐞 𝐂𝐨𝐮𝐫𝐭 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐝𝐢𝐬𝐜𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐢𝐬 𝐧𝐨𝐭 𝐩𝐫𝐞𝐬𝐮𝐦𝐞𝐝. 𝐓𝐡𝐞 𝐩𝐫𝐨𝐬𝐞𝐜𝐮𝐭𝐢𝐨𝐧 𝐦𝐮𝐬𝐭 𝐩𝐫𝐨𝐯𝐞 𝐢𝐭 𝐚𝐬 𝐚 𝐬𝐞𝐩𝐚𝐫𝐚𝐭𝐞 𝐜𝐢𝐫𝐜𝐮𝐦𝐬𝐭𝐚𝐧𝐜𝐞 𝐛𝐞𝐲𝐨𝐧𝐝 𝐫𝐞𝐚𝐬𝐨𝐧𝐚𝐛𝐥𝐞 𝐝𝐨𝐮𝐛𝐭. 𝐂𝐨𝐮𝐫𝐭𝐬 𝐦𝐚𝐲 𝐢𝐧𝐟𝐞𝐫 𝐢𝐭 𝐟𝐫𝐨𝐦 𝐝𝐢𝐫𝐞𝐜𝐭 𝐨𝐫 𝐜𝐢𝐫𝐜𝐮𝐦𝐬𝐭𝐚𝐧𝐭𝐢𝐚𝐥 𝐞𝐯𝐢𝐝𝐞𝐧𝐜𝐞, 𝐢𝐧𝐜𝐥𝐮𝐝𝐢𝐧𝐠 𝐭𝐡𝐞 𝐦𝐢𝐧𝐨𝐫’𝐬 𝐛𝐞𝐡𝐚𝐯𝐢𝐨𝐫 𝐛𝐞𝐟𝐨𝐫𝐞, 𝐝𝐮𝐫𝐢𝐧𝐠, 𝐚𝐧𝐝 𝐚𝐟𝐭𝐞𝐫 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐬𝐞, 𝐚𝐧𝐝 𝐭𝐡𝐞 𝐬𝐮𝐫𝐫𝐨𝐮𝐧𝐝𝐢𝐧𝐠 𝐜𝐢𝐫𝐜𝐮𝐦𝐬𝐭𝐚𝐧𝐜𝐞𝐬 𝐨𝐟 𝐭𝐡𝐞 𝐜𝐫𝐢𝐦𝐞. 𝐔𝐧𝐝𝐞𝐫 𝐑𝐀 𝟗𝟑𝟒𝟒 𝐚𝐧𝐝 𝐑𝐀 𝟏𝟎𝟔𝟑𝟎, 𝐭𝐡𝐞 𝐬𝐨𝐜𝐢𝐚𝐥 𝐰𝐨𝐫𝐤𝐞𝐫 𝐦𝐚𝐤𝐞𝐬 𝐚𝐧 𝐢𝐧𝐢𝐭𝐢𝐚𝐥 𝐚𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭, 𝐛𝐮𝐭 𝐭𝐡𝐞 𝐜𝐨𝐮𝐫𝐭 𝐦𝐚𝐤𝐞𝐬 𝐭𝐡𝐞 𝐟𝐢𝐧𝐚𝐥 𝐝𝐞𝐭𝐞𝐫𝐦𝐢𝐧𝐚𝐭𝐢𝐨𝐧.

Hermie M. Jacinto was convicted of ra**ng AAA, a five-year-old child, on January 28, 2003. The prosecution proved that the appellant took the victim from a local store to a nearby rice field, where he assaulted and r***d her—a narrative supported by the victim’s positive identification, corroborating witness testimony, and medical certificates confirming severe ge***al and physical injuries. In defense, Jacinto presented an alibi claiming he was at a nearby birthday party and accused a prosecution witness of committing the crime.

The Regional Trial Court found Jacinto guilty beyond reasonable doubt and initially sentenced him to death, but later reduced it to reclusion perpetua upon proof that he was only 17 years old at the time of the incident. The Court of Appeals affirmed the conviction but further modified the sentence to an indeterminate penalty of six years and one day to seventeen years and four months, applying the benefits of Republic Act No. 9344 for children in conflict with the law. Jacinto is now appealing to the Supreme Court, arguing that the evidence is inconclusive and fails to establish his guilt beyond a moral certainty.

The Court affirmed the finding of discernment but modified the imposable penalty consistent with the minor’s status and the governing law.

𝐓𝐡𝐞 𝐂𝐨𝐮𝐫𝐭 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐚 𝐜𝐡𝐢𝐥𝐝 𝐚𝐛𝐨𝐯𝐞 𝟏𝟓 𝐛𝐮𝐭 𝐛𝐞𝐥𝐨𝐰 𝟏𝟖 𝐲𝐞𝐚𝐫𝐬 𝐨𝐥𝐝 𝐢𝐬 𝐞𝐱𝐞𝐦𝐩𝐭 𝐟𝐫𝐨𝐦 𝐜𝐫𝐢𝐦𝐢𝐧𝐚𝐥 𝐥𝐢𝐚𝐛𝐢𝐥𝐢𝐭𝐲 𝐮𝐧𝐥𝐞𝐬𝐬 𝐭𝐡𝐞 𝐩𝐫𝐨𝐬𝐞𝐜𝐮𝐭𝐢𝐨𝐧 𝐩𝐫𝐨𝐯𝐞𝐬 𝐭𝐡𝐚𝐭 𝐡𝐞 𝐚𝐜𝐭𝐞𝐝 𝐰𝐢𝐭𝐡 𝐝𝐢𝐬𝐜𝐞𝐫𝐧𝐦𝐞𝐧𝐭. 𝐓𝐡𝐞 𝐂𝐨𝐮𝐫𝐭 𝐝𝐞𝐟𝐢𝐧𝐞𝐝 𝐝𝐢𝐬𝐜𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐚𝐬 𝐭𝐡𝐞 𝐦𝐢𝐧𝐨𝐫’𝐬 𝐦𝐞𝐧𝐭𝐚𝐥 𝐜𝐚𝐩𝐚𝐜𝐢𝐭𝐲 𝐭𝐨 𝐟𝐮𝐥𝐥𝐲 𝐚𝐩𝐩𝐫𝐞𝐜𝐢𝐚𝐭𝐞 𝐭𝐡𝐞 𝐜𝐨𝐧𝐬𝐞𝐪𝐮𝐞𝐧𝐜𝐞𝐬 𝐨𝐟 𝐡𝐢𝐬 𝐮𝐧𝐥𝐚𝐰𝐟𝐮𝐥 𝐚𝐜𝐭. It must be determined from the totality of facts and circumstances in the record, including the child’s conduct, the nature of the act, and signs of cunning or shrewdness. In this case, the Court considered the choice of an isolated and dark place and the act of boxing the victim to weaken her defense as indicative of discernment.

𝐏𝐞𝐨𝐩𝐥𝐞 𝐨𝐟 𝐭𝐡𝐞 𝐏𝐡𝐢𝐥𝐢𝐩𝐩𝐢𝐧𝐞𝐬 𝐯. 𝐉𝐚𝐜𝐢𝐧𝐭𝐨
𝐆.𝐑. 𝐍𝐨. 𝟏𝟖𝟐𝟐𝟑𝟗, 𝐌𝐚𝐫𝐜𝐡 𝟏𝟔, 𝟐𝟎𝟏𝟏

Read the full text here: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/51379

23/06/2026

𝗠𝗶𝗰𝗿𝗼 𝘁𝗮𝘅𝗽𝗮𝘆𝗲𝗿 𝗸𝗮 𝗯𝗮 𝗻𝗮 𝗺𝗮𝘆 𝗹𝘂𝗺𝗮𝗻𝗴 𝘁𝗮𝘅 𝗹𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝗶𝗲𝘀, 𝗱𝗲𝗹𝗶𝗻𝗾𝘂𝗲𝗻𝘁 𝗮𝗰𝗰𝗼𝘂𝗻𝘁𝘀, 𝗮𝘀𝘀𝗲𝘀𝘀𝗺𝗲𝗻𝘁𝘀, 𝗼 𝘀𝘁𝗼𝗽-𝗳𝗶𝗹𝗲𝗿 𝗰𝗮𝘀𝗲𝘀 𝘀𝗮 𝗕𝗜𝗥?

Hinihikayat ni Commissioner Charlito Martin R. Mendoza ang mga kwalipikadong micro taxpayers na samantalahin ang One-Time Tax Abatement Program. Ito na ang pagkakataon para ayusin ang inyong tax records, maresolba ang mga dating obligasyon sa BIR, at maisara ang mga nakabinbing kaso.

Maaaring mag-apply ang mga kwalipikadong micro taxpayers hanggang Disyembre 31, 2026.

Basahin ang buong Revenue Regulations No. 4-2026 dito:https://bir-cdn.bir.gov.ph/BIR/pdf/RR%20No.%204-2026_Redacted.pdf

19/06/2026

The (SC) has clarified when the processing periods begin for value-added tax (VAT) refund claims.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division updated the summary of rules on the reckoning of the processing periods will start for VAT refund claims under Section 112(A) of the 𝘛𝘢𝘹 𝘊𝘰𝘥𝘦, which was previously explained in the case of 𝘊𝘰𝘮𝘮𝘪𝘴𝘴𝘪𝘰𝘯𝘦𝘳 𝘰𝘧 𝘐𝘯𝘵𝘦𝘳𝘯𝘢𝘭 𝘙𝘦𝘷𝘦𝘯𝘶𝘦 (𝘊𝘐𝘙) 𝘷. 𝘋𝘰𝘩𝘭𝘦 𝘚𝘩𝘪𝘱𝘮𝘢𝘯𝘢𝘨𝘦𝘮𝘦𝘯𝘵 𝘗𝘩𝘪𝘭𝘪𝘱𝘱𝘪𝘯𝘦𝘴 𝘊𝘰𝘳𝘱𝘰𝘳𝘢𝘵𝘪𝘰𝘯, based on changing policies.

- For administrative claims for VAT refund or credit filed 𝗽𝗿𝗶𝗼𝗿 𝘁𝗼 𝗝𝘂𝗻𝗲 𝟭𝟭, 𝟮𝟬𝟭𝟰, the 120-day period starts from the date of the filing of the administrative claim once the taxpayer submits complete documents with the claim or manifests that they will no longer submit additional supporting documents. If the Bureau of Internal Revenue (BIR) does not notify the taxpayer that their documents are incomplete, the 120-day period begins from the taxpayer’s submission. If the BIR notifies the taxpayer that additional documents are needed, the 120-day period begins from the submission or the end of the 30-day period given to submit additional documents.�

- For administrative claims for VAT refund or credit filed 𝗳𝗿𝗼𝗺 𝗝𝘂𝗻𝗲 𝟭𝟭, 𝟮𝟬𝟭𝟰 𝘁𝗼 𝗗𝗲𝗰𝗲𝗺𝗯𝗲𝗿 𝟯𝟭, 𝟮𝟬𝟭𝟳, the 120-day period begins from the date of filing of the administrative claim for refund with complete supporting documents. The taxpayer is not allowed to submit additional documents after the filing of the claim.

- For administrative claims for VAT refund or credit filed 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗝𝗮𝗻𝘂𝗮𝗿𝘆 𝟭, 𝟮𝟬𝟭𝟴 𝘁𝗼 𝗝𝗮𝗻𝘂𝗮𝗿𝘆 𝟭𝟴, 𝟮𝟬𝟮𝟭, the 𝘛𝘢𝘹 𝘙𝘦𝘧𝘰𝘳𝘮 𝘧𝘰𝘳 𝘈𝘤𝘤𝘦𝘭𝘦𝘳𝘢𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘐𝘯𝘤𝘭𝘶𝘴𝘪𝘰𝘯 𝘓𝘢𝘸 (𝘛𝘙𝘈𝘐𝘕 𝘓𝘢𝘸) shortened the 120-day period for the CIR to process administrative claims for VAT refund to 90 days. The 90-day period begins from the submission of the official receipts or invoices and other supporting documents for the application for VAT refund. If the documents are incomplete, the application will not be accepted. Any unsupported claim shall be outrightly disallowed, resulting in full or partial denial of the claim.

- For administrative claims for VAT refund or credit filed 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗝𝗮𝗻𝘂𝗮𝗿𝘆 𝟭𝟵, 𝟮𝟬𝟮𝟭 𝘁𝗼 𝗝𝘂𝗻𝗲 𝟯𝟬, 𝟮𝟬𝟮𝟯, the 90-day period begins from the submission of the official receipts or invoices and other supporting documents for the application for VAT refund. A 𝘊𝘩𝘦𝘤𝘬𝘭𝘪𝘴𝘵 𝘰𝘧 𝘙𝘦𝘲𝘶𝘪𝘳𝘦𝘮𝘦𝘯𝘵𝘴 (𝘊𝘩𝘦𝘤𝘬𝘭𝘪𝘴𝘵) was released by the BIR as basis for the completeness of the submitted documents.

- For administrative claims for VAT refund or credit filed 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗝𝘂𝗹𝘆 𝟭, 𝟮𝟬𝟮𝟯 𝘁𝗼 𝗢𝗰𝘁𝗼𝗯𝗲𝗿 𝟭𝟳, 𝟮𝟬𝟮𝟰, the 90-day period begins from the submission of the official receipts or invoices and other supporting documents for the application for VAT refund, as provided in the 𝘊𝘩𝘦𝘤𝘬𝘭𝘪𝘴𝘵.

- For administrative claims for VAT refund or credit filed 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗢𝗰𝘁𝗼𝗯𝗲𝗿 𝟭𝟴, 𝟮𝟬𝟮𝟰 𝘁𝗼 𝗠𝗮𝗿𝗰𝗵 𝟯𝟭, 𝟮𝟬𝟮𝟱, the 90-day period begins from the acceptance by the processing office of the claim or application for VAT refund with complete documents, as provided in the 𝘊𝘩𝘦𝘤𝘬𝘭𝘪𝘴𝘵. Applications with incomplete documents will not be accepted.

- For administrative claims for VAT refund or credit filed 𝗯𝗲𝗴𝗶𝗻𝗻𝗶𝗻𝗴 𝗔𝗽𝗿𝗶𝗹 𝟭, 𝟮𝟬𝟮𝟱 𝗼𝗻𝘄𝗮𝗿𝗱𝘀, the 90-day period begins from the submission of the certified true copies of the invoices or official receipts and other supporting documents for the application for VAT refund, as provided in the 𝘊𝘩𝘦𝘤𝘬𝘭𝘪𝘴𝘵. If documents are incomplete, the application will not be received and processed by the processing office.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=167773.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164115.

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

19/06/2026

The (SC) has suspended a lawyer for using vulgar words in a social media post.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC’s Second Division found Atty. Jesus Nicardo M. Falcis III guilty of simple misconduct and suspended him from the practice of law for one year.

The case arose from a Twitter post made by Atty. Falcis defending his brother, Nicko, against accusations related to a qualified theft complaint filed by Kris Aquino (Aquino):

“𝘠𝘶𝘯𝘨 𝘮𝘨𝘢 𝘣𝘪𝘢𝘴𝘦𝘥 𝘯𝘢 𝘥𝘪𝘭𝘢𝘸𝘢𝘯 𝘥𝘺𝘢𝘯, 𝘩𝘢𝘭𝘢𝘵𝘢 𝘬𝘢𝘺𝘰. 𝘚𝘢 𝘢𝘭𝘭𝘦𝘨𝘢𝘵𝘪𝘰𝘯𝘴 𝘯𝘪 𝘒𝘳𝘪𝘴, 𝘱𝘢𝘯𝘪𝘸𝘢𝘭𝘢𝘯𝘨 𝘱𝘢𝘯𝘪𝘸𝘢𝘭𝘢 𝘯𝘢 𝘬𝘢𝘺𝘰 𝘢𝘨𝘢𝘥. 𝘗𝘦𝘳𝘰 𝘴𝘢 𝘢𝘭𝘭𝘦𝘨𝘢𝘵𝘪𝘰𝘯𝘴 𝘯𝘢𝘮𝘪𝘯 𝘯𝘢 𝘴𝘩𝘦 𝘵𝘩𝘳𝘦𝘢𝘵𝘦𝘯𝘦𝘥 𝘮𝘺 𝘣𝘳𝘰𝘵𝘩𝘦𝘳, 𝘸𝘢𝘭𝘢 𝘢𝘬𝘰 𝘯𝘢𝘳𝘪𝘳𝘪𝘯𝘪𝘨 𝘴𝘢 𝘪𝘯𝘺𝘰? 𝘗𝘢𝘬𝘺𝘶 𝘬𝘢𝘺𝘰 𝘮𝘨𝘢 𝘨𝘢𝘨𝘰 𝘩𝘢𝘩𝘢 𝘤𝘩𝘦𝘤𝘬 𝘺𝘰𝘶𝘳 𝘤𝘰𝘨𝘯𝘪𝘵𝘪𝘷𝘦 𝘣𝘪𝘢𝘴𝘦𝘴.”

Jason Gene Baltao (Baltao), Aquino’s former business partner, filed a complaint against Atty. Falcis before the Integrated Bar of the Philippines (IBP) for conduct unbecoming of a lawyer.

Atty. Falcis argued that previous SC rulings held that the phrase “𝘱𝘶𝘵𝘢𝘯𝘨 𝘪𝘯𝘢” is often used to express anger or frustration, not to defame. He also claimed that lawyers are entitled to freedom of speech and expression.

The IBP found that Atty. Falcis violated the 𝘊𝘰𝘥𝘦 𝘰𝘧 𝘗𝘳𝘰𝘧𝘦𝘴𝘴𝘪𝘰𝘯𝘢𝘭 𝘙𝘦𝘴𝘱𝘰𝘯𝘴𝘪𝘣𝘪𝘭𝘪𝘵𝘺 𝘢𝘯𝘥 𝘈𝘤𝘤𝘰𝘶𝘯𝘵𝘢𝘣𝘪𝘭𝘪𝘵𝘺 (𝘊𝘗𝘙𝘈) by using offensive language and recommended a penalty of a fine and reprimand.

The SC agreed with the IBP’s findings but imposed a heavier penalty of suspension.

Under Canon II, Section 4 of the CPRA, lawyers must use dignified, gender-fair, child- and culturally-sensitive language in both their professional and personal dealings. They must not use abusive, offensive, or improper language, whether spoken or written, including on social media. Such conduct undermines the dignity of the legal profession.

Section 37 of the same Canon requires lawyers to ensure that their online posts—whether public or shared within a limited audience—uphold the dignity of the profession, protect it from disrepute, and maintain respect for the law.

Section 36 also requires lawyers to understand the benefits, risks, and ethical implications of using social media.

Ruling that Atty. Falcis failed to meet these standards, the SC stressed that he should have understood the risks and consequences of his statements on social media, including how they can spread widely, reach all kinds of audiences, and influence both lawyers and non-lawyers, including children.

The SC held that the lawyer’s oath and their duties and responsibilities serve as the limit of free speech for lawyers.

The SC also reminded lawyers of the nature of social media, which encompasses a wide audience and may not easily be restricted.

The SC explained that Atty. Falcis’ actions amounted to misconduct, defined as intentional wrongdoing or a deliberate violation of a rule or standard of behavior, whether work-related or not. It is considered simple misconduct if there is no corruption or clear intent to violate the law.

The SC increased the penalty from a fine to suspension due to Atty. Falcis’ prior administrative violations, including direct and indirect contempt, and the seriousness of his use of profane and offensive language.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=167468

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=167448

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=167455

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

09/06/2026

𝐑𝐞𝐜𝐨𝐯𝐞𝐫𝐲 𝐨𝐟 𝐂𝐚𝐫𝐧𝐚𝐩𝐩𝐞𝐝 𝐕𝐞𝐡𝐢𝐜𝐥𝐞 𝐃𝐨𝐞𝐬 𝐍𝐨𝐭 𝐁𝐚𝐫 𝐈𝐧𝐬𝐮𝐫𝐚𝐧𝐜𝐞 𝐂𝐥𝐚𝐢𝐦

The Supreme Court emphasized that the subsequent recovery of the car did not negate the loss since theft is consummated upon unlawful taking, and the vehicle was returned in an unserviceable state

In this case, Wilfrido owned a 2003 Jaguar insured with UCPB Insurance for ₱1.8M; on August 24, 2006, his son Andrew was carjacked at gunpoint in Parañaque, and the incident was reported to police later that evening. Wilfrido filed a claim and submitted the required documents, but UCPB Insurance refused payment, arguing the vehicle was later recovered by the TMG and alleging fraud based on guard statements, a TMG report, and lack of cooperation in the investigation. Wilfrido sued for insurance proceeds and damages; the RTC ruled in his favor, holding that theft occurred and recovery did not negate liability, but the CA reversed, finding no total loss and noncompliance with policy conditions, prompting Wilfrido to elevate the case.

The Court granted the petition, ruling that UCPB Insurance is liable to indemnify Wilfrido for the theft of his insured vehicle. It held that theft is a covered risk under the policy, and Wilfrido sufficiently proved the carnapping through credible testimony and corroborating evidence, while UCPB’s contrary evidence was inadmissible hearsay. The Court further ruled that UCPB’s delay of more than 90 days in raising objections to the proof of loss constituted a waiver under the Insurance Code, making the proof submitted sufficient. 𝐈𝐭 𝐞𝐦𝐩𝐡𝐚𝐬𝐢𝐳𝐞𝐝 𝐭𝐡𝐚𝐭 𝐭𝐡𝐞 𝐬𝐮𝐛𝐬𝐞𝐪𝐮𝐞𝐧𝐭 𝐫𝐞𝐜𝐨𝐯𝐞𝐫𝐲 𝐨𝐟 𝐭𝐡𝐞 𝐜𝐚𝐫 𝐝𝐢𝐝 𝐧𝐨𝐭 𝐧𝐞𝐠𝐚𝐭𝐞 𝐭𝐡𝐞 𝐥𝐨𝐬𝐬 𝐬𝐢𝐧𝐜𝐞 𝐭𝐡𝐞𝐟𝐭 𝐢𝐬 𝐜𝐨𝐧𝐬𝐮𝐦𝐦𝐚𝐭𝐞𝐝 𝐮𝐩𝐨𝐧 𝐮𝐧𝐥𝐚𝐰𝐟𝐮𝐥 𝐭𝐚𝐤𝐢𝐧𝐠, 𝐚𝐧𝐝 𝐭𝐡𝐞 𝐯𝐞𝐡𝐢𝐜𝐥𝐞 𝐰𝐚𝐬 𝐫𝐞𝐭𝐮𝐫𝐧𝐞𝐝 𝐢𝐧 𝐚𝐧 𝐮𝐧𝐬𝐞𝐫𝐯𝐢𝐜𝐞𝐚𝐛𝐥𝐞 𝐬𝐭𝐚𝐭𝐞. Finally, the Court found no violation of policy conditions by Wilfrido, stressing that ambiguities or limitations in insurance contracts must be strictly construed against the insurer.

The Court ruled that Wilfrido complied with the insurance policy, while UCPB Insurance acted in bad faith by unreasonably delaying payment; thus, it is liable to pay ₱1.8M insurance proceeds, attorney’s fees, double interest, moral and exemplary damages, and costs of suit.

𝐖𝐢𝐣𝐚𝐧𝐠𝐜𝐨 𝐯. 𝐔𝐂𝐏𝐁 𝐆𝐞𝐧𝐞𝐫𝐚𝐥 𝐈𝐧𝐬𝐮𝐫𝐚𝐧𝐜𝐞 𝐂𝐩., 𝐈𝐧𝐜.
𝐆.𝐑. 𝐍𝐨. 𝟐𝟓𝟕𝟎𝟖𝟔, 𝐀𝐮𝐠𝐮𝐬𝐭 𝟏𝟗, 𝟐𝟎𝟐𝟓

Read the full text here:https://sc.judiciary.gov.ph/wp-content/uploads/2025/08/257086.pdf

04/06/2026

𝐓𝐫𝐚𝐝𝐞𝐦𝐚𝐫𝐤 𝐫𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐦𝐚𝐲 𝐠𝐫𝐚𝐧𝐭 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩—𝐛𝐮𝐭 𝐢𝐟 𝐨𝐛𝐭𝐚𝐢𝐧𝐞𝐝 𝐜𝐨𝐧𝐭𝐫𝐚𝐫𝐲 𝐭𝐨 𝐥𝐚𝐰, 𝐢𝐭 𝐠𝐫𝐚𝐧𝐭𝐬 𝐧𝐨𝐭𝐡𝐢𝐧𝐠 𝐚𝐭 𝐚𝐥𝐥.

The Supreme Court held that, while ownership of a mark is generally acquired through valid registration under the IP Code, registration made contrary to law is void.

In this case, Greenseal Malaysia, which has used and registered the “GREENSEAL” mark abroad since 1986/1993 and distributed its products in the Philippines as early as 2000 through Greenseal Philippines (its exclusive distributor since 2006), sought cancellation of Campbridge’s 2009 Philippine registration of the same mark for sealant, alleging bad faith appropriation. The IPOPHL-BLA and its Director granted cancellation, but the IPOPHL-ODG reversed, upholding Campbridge’s first-to-file registration. On appeal, the CA reinstated the cancellation, recognizing Greenseal’s prior use and trade name rights, prompting Campbridge to elevate the case to the Supreme Court.

The Supreme Court denied Campbridge’s petition and affirmed the CA’s reinstatement of the IPOPHL-BLA ruling cancelling Campbridge’s registration of “GREENSEAL.” 𝐖𝐡𝐢𝐥𝐞 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩 𝐨𝐟 𝐚 𝐦𝐚𝐫𝐤 𝐢𝐬 𝐠𝐞𝐧𝐞𝐫𝐚𝐥𝐥𝐲 𝐚𝐜𝐪𝐮𝐢𝐫𝐞𝐝 𝐭𝐡𝐫𝐨𝐮𝐠𝐡 𝐯𝐚𝐥𝐢𝐝 𝐫𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐮𝐧𝐝𝐞𝐫 𝐭𝐡𝐞 𝐈𝐏 𝐂𝐨𝐝𝐞, 𝐫𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐦𝐚𝐝𝐞 𝐜𝐨𝐧𝐭𝐫𝐚𝐫𝐲 𝐭𝐨 𝐥𝐚𝐰 𝐢𝐬 𝐯𝐨𝐢𝐝. 𝐓𝐡𝐞 𝐂𝐨𝐮𝐫𝐭 𝐡𝐞𝐥𝐝 𝐭𝐡𝐚𝐭 𝐂𝐚𝐦𝐩𝐛𝐫𝐢𝐝𝐠𝐞’𝐬 𝐫𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐰𝐚𝐬 𝐮𝐧𝐥𝐚𝐰𝐟𝐮𝐥 𝐛𝐞𝐜𝐚𝐮𝐬𝐞 𝐢𝐭 𝐚𝐩𝐩𝐫𝐨𝐩𝐫𝐢𝐚𝐭𝐞𝐝 𝐆𝐫𝐞𝐞𝐧𝐬𝐞𝐚𝐥’𝐬 𝐭𝐫𝐚𝐝𝐞 𝐧𝐚𝐦𝐞, 𝐰𝐡𝐢𝐜𝐡 𝐡𝐚𝐝 𝐛𝐞𝐞𝐧 𝐮𝐬𝐞𝐝 𝐢𝐧 𝐭𝐡𝐞 𝐏𝐡𝐢𝐥𝐢𝐩𝐩𝐢𝐧𝐞𝐬 𝐬𝐢𝐧𝐜𝐞 𝟐𝟎𝟎𝟒 𝐚𝐧𝐝 𝐫𝐞𝐠𝐢𝐬𝐭𝐞𝐫𝐞𝐝 𝐰𝐢𝐭𝐡 𝐭𝐡𝐞 𝐒𝐄𝐂 𝐢𝐧 𝟐𝟎𝟎𝟔. Although bad faith was not proven, cancellation was still proper since trade names are protected even without registration under the IP Code and the Paris Convention. The Court clarified that Greenseal’s 1993 Malaysian registration did not give it priority rights in the Philippines but upheld cancellation based on protection of its trade name.

𝐂𝐚𝐦𝐛𝐫𝐢𝐝𝐠𝐞 𝐖𝐚𝐭𝐞𝐫𝐩𝐫𝐨𝐨𝐟𝐢𝐧𝐠 𝐒𝐲𝐬𝐭𝐞𝐦𝐬, 𝐈𝐧𝐜. 𝐯. 𝐆𝐫𝐞𝐞𝐧𝐬𝐞𝐚𝐥 𝐏𝐫𝐨𝐝𝐮𝐜𝐭𝐬 [𝐒𝐃𝐍]. 𝐁𝐇𝐃
𝐆.𝐑. 𝐍𝐨. 𝟐𝟔𝟗𝟑𝟎𝟐, 𝐉𝐚𝐧𝐮𝐚𝐫𝐲 𝟐𝟐, 𝟐𝟎𝟐𝟓

Read the full text here:https://sc.judiciary.gov.ph/wp-content/uploads/2025/04/269302.pdf

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