Hagoriles and Rabia Law Offices

20/08/2026

20/08/2026

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19/08/2026

𝐥𝐞𝐜𝐭𝐫𝐨𝐧𝐢𝐜 𝐍𝐨𝐭𝐚𝐫𝐢𝐳𝐚𝐭𝐢𝐨𝐧 (𝐞𝐍𝐨𝐭𝐚𝐫𝐢𝐳𝐚𝐭𝐢𝐨𝐧) 𝐢𝐬 𝐜𝐨𝐦𝐢𝐧𝐠 𝐬𝐨𝐨𝐧!
Starting 𝐎𝐜𝐭𝐨𝐛𝐞𝐫 𝟏𝟗, 𝟐𝟎𝟐𝟔, eNotarization will officially become operational following, among others, the commissioning of the first batch of qualified Electronic Notaries Public (ENPs), who will perform notarial acts in accordance with the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘌𝘭𝘦𝘤𝘵𝘳𝘰𝘯𝘪𝘤 𝘕𝘰𝘵𝘢𝘳𝘪𝘻𝘢𝘵𝘪𝘰𝘯.
For more information, you may refer to the Electronic Notary Services (ENS) microsite at https://sc.judiciary.gov.ph/enotarization/.
For concerns and questions, you may submit them through the ENS Helpdesk Form at https://tinyurl.com/ENSHelpdeskForm
You may access the Rules on Electronic Notarization at https://tinyurl.com/RulesOnElectronicNotarization

27/07/2026

The (SC) has ruled that a sale of land remains valid even if the deed of sale designates a different lot number from what was actually sold, as long as the parties’ true agreement can be clearly shown. The deed may then be corrected to match what the parties actually agreed to.
In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the sale of a 491-square-meter parcel of land in Cebu City between buyers Genara and Felipe Abay, Sr. (the Abays) and sellers Crispin Caballes and the heirs of Trinidad Caballes-Gallardo (the Gallardos), despite the mistake in the designation of the lot number in the deed of sale.
The property formed part of the estate of Margarita Lopez, who had nine children, including Crispin and Trinidad.
The Abays visited the site with Crispin and Tomas Gallardo, one of Trinidad’s heirs before buying the property. During the visit, they were showed them the land’s boundaries. Tomas even helped the Abays build a concrete fence around it.
The Abays openly occupied the property for about 20 years until their possession was disrupted when workers of spouses Jacinto and Chiok Ngo Lim Young (the Youngs), who are claiming ownership over the property, entered it, destroyed the fence, and built their own posts.
The Abays discovered that a title over the property had been issued in the Youngs’ name. This prompted them to file a complaint before the Regional Trial Court (RTC) to cancel the title.
The Gallardos challenged this, arguing that the documents the Abays presented referred to a different lot, Lot No. 6036-B, and not the lot they were occupying, which was Lot No. 7. While both lots were located in the same area, they were separate properties and were not beside each other. The Youngs supported the Gallardos’ position and maintained that they were buyers in good faith.
The RTC ruled in favor of the Abays which ruling was reversed by the Court of Appeals (CA). The CA held that the documents presented by the Abays showed that they purchased Lot No. 6036-B and not Lot No. 7, which they claimed to own and possess.
The SC disagreed and reiterated its pronouncements in previous cases upholding the validity of the sale and allowing the correction of a contract to reflect the parties’ true agreement in instances where the deed of sale failed to accurately describe the land intended by the parties.
The SC stressed that a person buys property based on what they see on the ground, such as its boundaries, landmarks, and improvements, and not by its technical lot number. Ordinary buyers cannot be expected to identify property based only on survey descriptions or legal documents.
Under the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦, a written document may be corrected when, because of a mistake, it does not express the parties’ actual agreement.
The SC explained that a contract may be reformed or corrected if: (1) the parties agreed on the transaction; (2) the written document does not express their true agreement; and (3) the error was caused by a mistake, fraud, accident, or unfair conduct.
In this case, all these requirements were present.
Thus, the Court declared deemed reformed the Deeds of Sale and Extrajudicial Settlement and Sale by changing the designation of the property sold from “Lot No. 6036-B” to “Lot 7” and the Abays as absolute owners of such property.
Read the full text of the press release at https://sc.judiciary.gov.ph/?p=169523
Read the full text of the Decision at https://sc.judiciary.gov.ph/266298-spouses-genera-and.../
Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution

The (SC) has ruled that a sale of land remains valid even if the deed of sale designates a different lot number from what was actually sold, as long as the parties’ true agreement can be clearly shown. The deed may then be corrected to match what the parties actually agreed to.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the sale of a 491-square-meter parcel of land in Cebu City between buyers Genara and Felipe Abay, Sr. (the Abays) and sellers Crispin Caballes and the heirs of Trinidad Caballes-Gallardo (the Gallardos), despite the mistake in the designation of the lot number in the deed of sale.

The property formed part of the estate of Margarita Lopez, who had nine children, including Crispin and Trinidad.

The Abays visited the site with Crispin and Tomas Gallardo, one of Trinidad’s heirs before buying the property. During the visit, they were showed them the land’s boundaries. Tomas even helped the Abays build a concrete fence around it.

The Abays openly occupied the property for about 20 years until their possession was disrupted when workers of spouses Jacinto and Chiok Ngo Lim Young (the Youngs), who are claiming ownership over the property, entered it, destroyed the fence, and built their own posts.

The Abays discovered that a title over the property had been issued in the Youngs’ name. This prompted them to file a complaint before the Regional Trial Court (RTC) to cancel the title.

The Gallardos challenged this, arguing that the documents the Abays presented referred to a different lot, Lot No. 6036-B, and not the lot they were occupying, which was Lot No. 7. While both lots were located in the same area, they were separate properties and were not beside each other. The Youngs supported the Gallardos’ position and maintained that they were buyers in good faith.

The RTC ruled in favor of the Abays which ruling was reversed by the Court of Appeals (CA). The CA held that the documents presented by the Abays showed that they purchased Lot No. 6036-B and not Lot No. 7, which they claimed to own and possess.

The SC disagreed and reiterated its pronouncements in previous cases upholding the validity of the sale and allowing the correction of a contract to reflect the parties’ true agreement in instances where the deed of sale failed to accurately describe the land intended by the parties.

The SC stressed that a person buys property based on what they see on the ground, such as its boundaries, landmarks, and improvements, and not by its technical lot number. Ordinary buyers cannot be expected to identify property based only on survey descriptions or legal documents.

Under the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦, a written document may be corrected when, because of a mistake, it does not express the parties’ actual agreement.

The SC explained that a contract may be reformed or corrected if: (1) the parties agreed on the transaction; (2) the written document does not express their true agreement; and (3) the error was caused by a mistake, fraud, accident, or unfair conduct.

In this case, all these requirements were present.

Thus, the Court declared deemed reformed the Deeds of Sale and Extrajudicial Settlement and Sale by changing the designation of the property sold from “Lot No. 6036-B” to “Lot 7” and the Abays as absolute owners of such property.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=169523

Read the full text of the Decision at https://sc.judiciary.gov.ph/266298-spouses-genera-and-felipe-abay-sr-et-al-vs-spouses-jacinto-s-young-et-al/

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

24/07/2026

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20/07/2026

The (SC) has ruled that the infliction of psychological violence, if done through Facebook, is considered done through information and communications technology, which warrants the imposition of a higher penalty pursuant to Section 6 of RA 10175 or the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012.

In a Resolution penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed with modification its October 22, 2025 Decision (assailed Decision), which upheld the conviction of an individual (###) for committing psychological violence under Section 5(i) of Republic Act (RA) No. 9262, or the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 𝘈𝘤𝘵 𝘰𝘧 2004 (Anti-VAWC Act) against his ex-girlfriend (AAA) by posting derogatory statements about her on Facebook.

The SC, however, resolved to raise the penalty by one degree, considering that the offense was committed through Facebook, as adequately alleged in the Information and established during trial.

AAA filed the VAWC case against her former partner ### after he posted a statement on Facebook calling her a dirty woman and an animal, and threatening to box her when he sees her. He repeated the insults in the comments to the post, which was public.

During trial, AAA presented screenshots of the Facebook post and testified that she had created for ### the Facebook account which made the post. Her two siblings testified that the account was ###’s and that they received messages from him through the same account.

Despite ###’s denial, the SC, in its assailed Decision, affirmed the decisions of the Family Court and the Court of Appeals (CA) convicting ###, stressing that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender. The SC also upheld the penalty imposed by the CA, consisting of imprisonment for six months and one day to eight years and one day, a fine of PHP 100,000, and psychological counseling or psychiatric treatment.

Resolving ###’s Motion for Reconsideration, the SC held that ###’s authorship of the Facebook post was established beyond reasonable doubt, using the guideposts it established in its assailed Decision:

𝟏. 𝐀𝐝𝐦𝐢𝐬𝐬𝐢𝐨𝐧 𝐨𝐟 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩;
𝟐. 𝐁𝐞𝐢𝐧𝐠 𝐬𝐞𝐞𝐧 𝐚𝐜𝐜𝐞𝐬𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐨𝐫 𝐜𝐨𝐦𝐩𝐨𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐩𝐨𝐬𝐭;
𝟑. 𝐂𝐨𝐧𝐭𝐚𝐢𝐧𝐢𝐧𝐠 𝐢𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐤𝐧𝐨𝐰𝐧 𝐨𝐧𝐥𝐲 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫 𝐨𝐫 𝐚 𝐟𝐞𝐰 𝐩𝐞𝐨𝐩𝐥𝐞;
𝟒. 𝐋𝐚𝐧𝐠𝐮𝐚𝐠𝐞 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫’𝐬 𝐜𝐡𝐚𝐫𝐚𝐜𝐭𝐞𝐫𝐢𝐬𝐭𝐢𝐜𝐬;
𝟓. 𝐑𝐞𝐜𝐨𝐫𝐝𝐬 𝐟𝐫𝐨𝐦 𝐭𝐡𝐞 𝐢𝐧𝐭𝐞𝐫𝐧𝐞𝐭 𝐬𝐞𝐫𝐯𝐢𝐜𝐞 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐫, 𝐭𝐞𝐥𝐞𝐜𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬 𝐜𝐨𝐦𝐩𝐚𝐧𝐲, 𝐨𝐫 𝐬𝐨𝐜𝐢𝐚𝐥 𝐦𝐞𝐝𝐢𝐚 𝐬𝐢𝐭𝐞, 𝐚𝐧𝐝 𝐫𝐞𝐬𝐮𝐥𝐭𝐬 𝐟𝐫𝐨𝐦 𝐝𝐞𝐯𝐢𝐜𝐞 𝐟𝐨𝐫𝐞𝐧𝐬𝐢𝐜 𝐚𝐧𝐚𝐥𝐲𝐬𝐢𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐠𝐞𝐨𝐥𝐨𝐜𝐚𝐭𝐢𝐨𝐧 𝐟𝐞𝐚𝐭𝐮𝐫𝐞𝐬, 𝐚𝐧𝐝 𝐨𝐭𝐡𝐞𝐫 𝐚𝐭𝐭𝐫𝐢𝐛𝐮𝐭𝐞𝐬 𝐥𝐢𝐧𝐤𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫;
𝟔. 𝐀𝐜𝐭𝐬 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐩𝐫𝐞𝐯𝐢𝐨𝐮𝐬 𝐩𝐨𝐬𝐭𝐬; 𝐨𝐫
𝟕. 𝐎𝐭𝐡𝐞𝐫 𝐢𝐧𝐬𝐭𝐚𝐧𝐜𝐞𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩, 𝐚𝐜𝐜𝐞𝐬𝐬, 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩.

The authorship of the Facebook post and all the elements of psychological violence having been established, the SC said Section 6 of the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012 applies, which mandates the imposition of a penalty higher by one degree for crimes and offenses committed using ICT. The use of ICT can enable offenders to evade liability, reach more victims, or cause greater harm.

Citing the definition of ICT, the Court ruled that social media platforms, such as Facebook, qualify as ICT systems because they allow users to generate, send, receive, store, and process electronic data messages through computers, mobile phones, or similar electronic devices.

In this case, the Information alleged that ### made the Facebook post using his "Facebook Messenger Account… which was set to public view." The SC ruled that this statement constitutes a sufficient allegation of the use of ICT as a qualifying circumstance. Even if the term "ICT" was not stated, the Information adequately informed ### that he is being charged of inflicting psychological violence upon AAA through Facebook, which falls under the contemplation of an ICT system.

The allegation was established by the prosecution during trial.

Thus, the Court increased the penalty by one degree from six months and one day to eight years and one day to imprisonment of six years and one day to 14 years, eight months, and one day, but retained the fined PHP 100,000. He was likewise ordered to undergo psychological counseling or psychiatric treatment.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=168987

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168968

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

The (SC) has ruled that the infliction of psychological violence, if done through Facebook, is considered done through information and communications technology, which warrants the imposition of a higher penalty pursuant to Section 6 of RA 10175 or the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012.

In a Resolution penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed with modification its October 22, 2025 Decision (assailed Decision), which upheld the conviction of an individual (###) for committing psychological violence under Section 5(i) of Republic Act (RA) No. 9262, or the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 𝘈𝘤𝘵 𝘰𝘧 2004 (Anti-VAWC Act) against his ex-girlfriend (AAA) by posting derogatory statements about her on Facebook.

The SC, however, resolved to raise the penalty by one degree, considering that the offense was committed through Facebook, as adequately alleged in the Information and established during trial.

AAA filed the VAWC case against her former partner ### after he posted a statement on Facebook calling her a dirty woman and an animal, and threatening to box her when he sees her. He repeated the insults in the comments to the post, which was public.

During trial, AAA presented screenshots of the Facebook post and testified that she had created for ### the Facebook account which made the post. Her two siblings testified that the account was ###’s and that they received messages from him through the same account.

Despite ###’s denial, the SC, in its assailed Decision, affirmed the decisions of the Family Court and the Court of Appeals (CA) convicting ###, stressing that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender. The SC also upheld the penalty imposed by the CA, consisting of imprisonment for six months and one day to eight years and one day, a fine of PHP 100,000, and psychological counseling or psychiatric treatment.

Resolving ###’s Motion for Reconsideration, the SC held that ###’s authorship of the Facebook post was established beyond reasonable doubt, using the guideposts it established in its assailed Decision:

𝟏. 𝐀𝐝𝐦𝐢𝐬𝐬𝐢𝐨𝐧 𝐨𝐟 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩;
𝟐. 𝐁𝐞𝐢𝐧𝐠 𝐬𝐞𝐞𝐧 𝐚𝐜𝐜𝐞𝐬𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐨𝐫 𝐜𝐨𝐦𝐩𝐨𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐩𝐨𝐬𝐭;
𝟑. 𝐂𝐨𝐧𝐭𝐚𝐢𝐧𝐢𝐧𝐠 𝐢𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐤𝐧𝐨𝐰𝐧 𝐨𝐧𝐥𝐲 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫 𝐨𝐫 𝐚 𝐟𝐞𝐰 𝐩𝐞𝐨𝐩𝐥𝐞;
𝟒. 𝐋𝐚𝐧𝐠𝐮𝐚𝐠𝐞 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫’𝐬 𝐜𝐡𝐚𝐫𝐚𝐜𝐭𝐞𝐫𝐢𝐬𝐭𝐢𝐜𝐬;
𝟓. 𝐑𝐞𝐜𝐨𝐫𝐝𝐬 𝐟𝐫𝐨𝐦 𝐭𝐡𝐞 𝐢𝐧𝐭𝐞𝐫𝐧𝐞𝐭 𝐬𝐞𝐫𝐯𝐢𝐜𝐞 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐫, 𝐭𝐞𝐥𝐞𝐜𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬 𝐜𝐨𝐦𝐩𝐚𝐧𝐲, 𝐨𝐫 𝐬𝐨𝐜𝐢𝐚𝐥 𝐦𝐞𝐝𝐢𝐚 𝐬𝐢𝐭𝐞, 𝐚𝐧𝐝 𝐫𝐞𝐬𝐮𝐥𝐭𝐬 𝐟𝐫𝐨𝐦 𝐝𝐞𝐯𝐢𝐜𝐞 𝐟𝐨𝐫𝐞𝐧𝐬𝐢𝐜 𝐚𝐧𝐚𝐥𝐲𝐬𝐢𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐠𝐞𝐨𝐥𝐨𝐜𝐚𝐭𝐢𝐨𝐧 𝐟𝐞𝐚𝐭𝐮𝐫𝐞𝐬, 𝐚𝐧𝐝 𝐨𝐭𝐡𝐞𝐫 𝐚𝐭𝐭𝐫𝐢𝐛𝐮𝐭𝐞𝐬 𝐥𝐢𝐧𝐤𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫;
𝟔. 𝐀𝐜𝐭𝐬 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐩𝐫𝐞𝐯𝐢𝐨𝐮𝐬 𝐩𝐨𝐬𝐭𝐬; 𝐨𝐫
𝟕. 𝐎𝐭𝐡𝐞𝐫 𝐢𝐧𝐬𝐭𝐚𝐧𝐜𝐞𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩, 𝐚𝐜𝐜𝐞𝐬𝐬, 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩.

The authorship of the Facebook post and all the elements of psychological violence having been established, the SC said Section 6 of the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012 applies, which mandates the imposition of a penalty higher by one degree for crimes and offenses committed using ICT. The use of ICT can enable offenders to evade liability, reach more victims, or cause greater harm.

Citing the definition of ICT, the Court ruled that social media platforms, such as Facebook, qualify as ICT systems because they allow users to generate, send, receive, store, and process electronic data messages through computers, mobile phones, or similar electronic devices.

In this case, the Information alleged that ### made the Facebook post using his "Facebook Messenger Account… which was set to public view." The SC ruled that this statement constitutes a sufficient allegation of the use of ICT as a qualifying circumstance. Even if the term "ICT" was not stated, the Information adequately informed ### that he is being charged of inflicting psychological violence upon AAA through Facebook, which falls under the contemplation of an ICT system.

The allegation was established by the prosecution during trial.

Thus, the Court increased the penalty by one degree from six months and one day to eight years and one day to imprisonment of six years and one day to 14 years, eight months, and one day, but retained the fined PHP 100,000. He was likewise ordered to undergo psychological counseling or psychiatric treatment.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=168987

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168968

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

09/07/2026

The (SC) has ruled that a duplicate or photocopy of original documents, whether in paper or electronic form, can be admitted as evidence in court, provided there is no genuine question regarding the original’s authenticity or fairness in using the copy.

In a Decision written by Chief Justice Alexander G. Gesmundo, the SC’s First Division upheld the conviction of Ybo Lastimosa (Lastimosa) for the murder of Ildefonso Vega, Jr. (Vega) in a case involving the use of a photocopy of Vega’s death certificate as key evidence.

Witnesses testified during trial that Lastimosa shot Vega in the head outside a cockpit in Cebu City. Vega’s wife also testified that Vega was already dead when she found him at the hospital. To support her testimony, the prosecution presented a photocopy of Vega’s death certificate, which confirmed that he died from gunshot wounds.

Convicted by the trial court of homicide and by the Court of Appeals of murder, Lastimosa argued before the SC that the prosecution failed to prove that the crime was committed because the original death certificate was not presented. He claimed that a photocopy, without comparison to the original for authentication, should not have been admitted as evidence.

The SC affirmed the Court of Appeals, sentencing Lastimoso to reclusion perpetua and ordered him to pay PHP 275,000 in civil indemnity and damages. It explained that under Rule 130, Section 4(c) of the 2019 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘌𝘷𝘪𝘥𝘦𝘯𝘤𝘦, a duplicate is admissible as the original unless there is a genuine question about the original’s authenticity or it would be unfair to use the duplicate.

This rule applies to both paper-based and electronic documents, reflecting the modern reality where duplicates are often as reliable as originals.

However, the SC emphasized that while a photocopy may be admissible, its weight or value depends on how well it corroborates or supports other available evidence.

In this case, the photocopy of the death certificate, combined with the testimonies of Vega’s wife and other eyewitnesses, sufficiently established that Vega died from gunshot wounds and that Lastimosa was responsible.

Read the full text of the Press Release at
https://tinyurl.com/36r9m76u.

Read the full text of the Decision at https://tinyurl.com/mwe35fhe.

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

The (SC) has ruled that a duplicate or photocopy of original documents, whether in paper or electronic form, can be admitted as evidence in court, provided there is no genuine question regarding the original’s authenticity or fairness in using the copy.

In a Decision written by Chief Justice Alexander G. Gesmundo, the SC’s First Division upheld the conviction of Ybo Lastimosa (Lastimosa) for the murder of Ildefonso Vega, Jr. (Vega) in a case involving the use of a photocopy of Vega’s death certificate as key evidence.

Witnesses testified during trial that Lastimosa shot Vega in the head outside a cockpit in Cebu City. Vega’s wife also testified that Vega was already dead when she found him at the hospital. To support her testimony, the prosecution presented a photocopy of Vega’s death certificate, which confirmed that he died from gunshot wounds.

Convicted by the trial court of homicide and by the Court of Appeals of murder, Lastimosa argued before the SC that the prosecution failed to prove that the crime was committed because the original death certificate was not presented. He claimed that a photocopy, without comparison to the original for authentication, should not have been admitted as evidence.

The SC affirmed the Court of Appeals, sentencing Lastimoso to reclusion perpetua and ordered him to pay PHP 275,000 in civil indemnity and damages. It explained that under Rule 130, Section 4(c) of the 2019 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘌𝘷𝘪𝘥𝘦𝘯𝘤𝘦, a duplicate is admissible as the original unless there is a genuine question about the original’s authenticity or it would be unfair to use the duplicate.

This rule applies to both paper-based and electronic documents, reflecting the modern reality where duplicates are often as reliable as originals.

However, the SC emphasized that while a photocopy may be admissible, its weight or value depends on how well it corroborates or supports other available evidence.

In this case, the photocopy of the death certificate, combined with the testimonies of Vega’s wife and other eyewitnesses, sufficiently established that Vega died from gunshot wounds and that Lastimosa was responsible.

Read the full text of the Press Release at
https://tinyurl.com/36r9m76u.

Read the full text of the Decision at https://tinyurl.com/mwe35fhe.

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

07/07/2026

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Whether you need legal consultation, notarization, preparation of legal documents, or other legal services, our team is ready to assist you with professionalism, integrity, and confidentiality.

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07/07/2026

Pinagtibay ng ang konstitusyonalidad ng Republic Act No. (RA) 12079 na nagbibigay ng value-added tax (VAT) refund sa ilang lokal na produkto na binili ng mga dayuhang turista na hindi residente ng Pilipinas.
Sa Desisyong isinulat ni Associate Justice Amy C. Lazaro-Javier, isinantabi ng En Banc ng Korte Suprema ang petisyong inihain ni John Barry T. Tayam na kumukuwestiyon sa bisa ng naturang batas. Sa pamamagitan ng RA No. 12079, idinagdag ang Section 112-A sa National Internal Revenue Code of 1997 na nagtatatag ng sistema ng VAT refund para sa mga dayuhang turistang hindi residente na bumibili ng mga kalakal sa Pilipinas.
Ang VAT refund ay para sa mga produktong binili sa mga tindahang may kaukulang akreditasyon at inilabas sa Pilipinas sa loob ng 60 araw mula sa petsa ng pagbili. Dapat hindi bababa sa PHP 3,000 ang halaga ng mga produktong binili sa bawat transaksiyon at ayon sa seksiyon 5 ng implementing rules and regulations ng batas, limitado lang ito sa mga kalakal na para sa personal na paggamit.
Sinabi ni Tayam na lumalabag ang batas sa konstitusiyonal na garantiya ng equal protection dahil nililimitahan nito ang VAT refund sa mga dayuhang turista at hindi ito ipinagkakaloob sa mga mamamayan at residente ng Pilipinas.
Sa pagsantabi ng petisyon, sinabi ng Korte Suprema na ang equal protection ay hindi nangangahulugang magkakatulad na pagtrato sa lahat ng tao. Pinahihintulutan ng Konstitusyon ang magkaibang pagtrato sa mga grupong tunay na magkaiba ang kalagayan basta’t makatwiran ang pagkakaiba at may kaugnayan ito sa layunin ng batas.
Sinabi ng Korte na wastong ibinubukod ng RA No. 12079 ang mga dayuhang turista sa mga mamamayan at residente ng Pilipinas. May tuwirang kaugnayan sa layunin ng batas na itaguyod ang turismo at hikayatin ang mga dayuhang bisita na bumili ng mga lokal na produkto ang nasabing klasipikasyon. Walang diskriminasyon laban sa mga Pilipino. Sa halip, nagbibigay lamang ito ng tiyak na insentibo sa mga dayuhang turista bilang bahagi ng pagsisikap ng pamahalaan na palakasin ang industriya ng turismo.
Ayon pa sa Korte, umaayon ang sistema ng VAT refund sa pangunahing tuntunin ng VAT na binubuwisan ang mga produkto sa lugar kung saan ginagamit o kinokonsumo ang mga ito. Dahil inaatasan ng batas ang mga dayuhang turista na ilabas sa Pilipinas ang mga produktong kanilang binili sa loob ng 60 araw, itinuturing na ikokonsumo ang mga ito sa ibang bansa at maaari silang maging kuwalipikado para sa VAT refund. Pero kung kinonsumo ang mga produkto sa Pilipinas, mananatili silang saklaw ng Philippine VAT.
Dagdag pa ng Korte Suprema, ang mga programang nagkakaloob ng VAT refund ay matagal nang ginagawa sa ibang bahagi ng mundo.
Basahin ang press release sa https://sc.judiciary.gov.ph/?p=168521
Basahin ang Desisyon sa https://sc.judiciary.gov.ph/?p=168497
Basahin ang Separate Concurring and Dissenting Opinion ni Senior Associate Justice Marvic M.V.F. Leonen sa https://sc.judiciary.gov.ph/?p=168502
Basahin ang Concurring Opinion ni Associate Justice Maria Filomena D. Singh sa https://sc.judiciary.gov.ph/?p=168507
Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.

Pinagtibay ng ang konstitusyonalidad ng Republic Act No. (RA) 12079 na nagbibigay ng value-added tax (VAT) refund sa ilang lokal na produkto na binili ng mga dayuhang turista na hindi residente ng Pilipinas.

Sa Desisyong isinulat ni Associate Justice Amy C. Lazaro-Javier, isinantabi ng En Banc ng Korte Suprema ang petisyong inihain ni John Barry T. Tayam na kumukuwestiyon sa bisa ng naturang batas. Sa pamamagitan ng RA No. 12079, idinagdag ang Section 112-A sa National Internal Revenue Code of 1997 na nagtatatag ng sistema ng VAT refund para sa mga dayuhang turistang hindi residente na bumibili ng mga kalakal sa Pilipinas.

Ang VAT refund ay para sa mga produktong binili sa mga tindahang may kaukulang akreditasyon at inilabas sa Pilipinas sa loob ng 60 araw mula sa petsa ng pagbili. Dapat hindi bababa sa PHP 3,000 ang halaga ng mga produktong binili sa bawat transaksiyon at ayon sa seksiyon 5 ng implementing rules and regulations ng batas, limitado lang ito sa mga kalakal na para sa personal na paggamit.

Sinabi ni Tayam na lumalabag ang batas sa konstitusiyonal na garantiya ng equal protection dahil nililimitahan nito ang VAT refund sa mga dayuhang turista at hindi ito ipinagkakaloob sa mga mamamayan at residente ng Pilipinas.

Sa pagsantabi ng petisyon, sinabi ng Korte Suprema na ang equal protection ay hindi nangangahulugang magkakatulad na pagtrato sa lahat ng tao. Pinahihintulutan ng Konstitusyon ang magkaibang pagtrato sa mga grupong tunay na magkaiba ang kalagayan basta’t makatwiran ang pagkakaiba at may kaugnayan ito sa layunin ng batas.

Sinabi ng Korte na wastong ibinubukod ng RA No. 12079 ang mga dayuhang turista sa mga mamamayan at residente ng Pilipinas. May tuwirang kaugnayan sa layunin ng batas na itaguyod ang turismo at hikayatin ang mga dayuhang bisita na bumili ng mga lokal na produkto ang nasabing klasipikasyon. Walang diskriminasyon laban sa mga Pilipino. Sa halip, nagbibigay lamang ito ng tiyak na insentibo sa mga dayuhang turista bilang bahagi ng pagsisikap ng pamahalaan na palakasin ang industriya ng turismo.

Ayon pa sa Korte, umaayon ang sistema ng VAT refund sa pangunahing tuntunin ng VAT na binubuwisan ang mga produkto sa lugar kung saan ginagamit o kinokonsumo ang mga ito. Dahil inaatasan ng batas ang mga dayuhang turista na ilabas sa Pilipinas ang mga produktong kanilang binili sa loob ng 60 araw, itinuturing na ikokonsumo ang mga ito sa ibang bansa at maaari silang maging kuwalipikado para sa VAT refund. Pero kung kinonsumo ang mga produkto sa Pilipinas, mananatili silang saklaw ng Philippine VAT.

Dagdag pa ng Korte Suprema, ang mga programang nagkakaloob ng VAT refund ay matagal nang ginagawa sa ibang bahagi ng mundo.

Basahin ang press release sa https://sc.judiciary.gov.ph/?p=168521

Basahin ang Desisyon sa https://sc.judiciary.gov.ph/?p=168497

Basahin ang Separate Concurring and Dissenting Opinion ni Senior Associate Justice Marvic M.V.F. Leonen sa https://sc.judiciary.gov.ph/?p=168502

Basahin ang Concurring Opinion ni Associate Justice Maria Filomena D. Singh sa https://sc.judiciary.gov.ph/?p=168507

Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.