Tanate Law Office

12/08/2026

07/08/2026

📌 LOT FOR SALE
POBLACION, LEON, ILOILO

06/08/2026

🏡 CENTREVERDE PRIME LOT FOR SALE

✅ 150 SQ.M. PER LOT
✅ 2 LOTS AVAILABLE
✅ ₱14,000.00 PER SQ.M.
(existing Market Value - P15,000.00 per sq. m)
✅ DIRECT BUYER ONLY

CLEAR TITLE READY

📍 Prime Location – Pavia, Iloilo
⚠️ Buyer will shoulder ALL taxes, transfer fees, and other related expenses.
Serious direct buyers only.

PLZ PM us for more details!

30/07/2026

Meet the Team Behind Tanate Law Office.

Every successful case is built on teamwork. Meet the dedicated people who work tirelessly behind the scenes to ensure every client receives efficient, reliable, and compassionate legal service.

✨ Krisel
✨ Jai
✨ Dhandz
✨ Iryn

Beyond legal representation, our team also assists clients in the processing and transfer of land titles, business permit applications and renewals, and other legal documentation.

Together, we are committed to serving you with integrity, excellence, and professionalism.

30/07/2026

❌SOLD❌

🏙️✨ FOR SALE — READY FOR OCCUPANCY ✨

Own a beautifully furnished condo unit at St. Honoré, Megaworld Iloilo — perfect for professionals, investors, students, or starting families looking for comfort and convenience in the heart of the city.

📍 St. Honoré, Megaworld, Iloilo City
📐 27 SQ. METERS
🛋 Fully Furnished
🏢 7th Floor
🍽 Modern Kitchen with Appliances
🔐 Safe & Secure Community

💰 Selling Price: ₱4,500,000
📈 Market Value: ₱5,500,000

✅ Ready for Occupancy
✅ Low Down Payment
✅ Seller willing to wait for bank approval

Experience modern city living in one of Iloilo’s most prestigious communities.

📩 Message now for viewing and inquiries!

12/05/2026

🏙️✨ FOR SALE — READY FOR OCCUPANCY ✨

Own a beautifully furnished condo unit at St. Honoré, Megaworld Iloilo — perfect for professionals, investors, students, or starting families looking for comfort and convenience in the heart of the city.

📍 St. Honoré, Megaworld, Iloilo City
📐 27 SQ. METERS
🛋 Fully Furnished
🏢 7th Floor
🍽 Modern Kitchen with Appliances
🔐 Safe & Secure Community

💰 Selling Price: ₱4,500,000
📈 Market Value: ₱5,500,000

✅ Ready for Occupancy
✅ Low Down Payment
✅ Seller willing to wait for bank approval

Experience modern city living in one of Iloilo’s most prestigious communities.

📩 Message now for viewing and inquiries!

05/05/2026

23/04/2026

𝗔𝗣𝗥𝗜𝗟 𝟮𝟬𝟮𝟲 𝗖𝗔𝗦𝗘 𝗣𝗿𝗼𝗺𝘂𝗹𝗴𝗮𝘁𝗲𝗱 𝟮𝟬 𝗔𝘂𝗴𝘂𝘀𝘁 𝟮𝟬𝟮𝟱

𝘈 𝘫𝘶𝘥𝘨𝘮𝘦𝘯𝘵 𝘰𝘧 𝘢𝘤𝘲𝘶𝘪𝘵𝘵𝘢𝘭 𝘮𝘢𝘺 𝘣𝘦 𝘢𝘴𝘴𝘢𝘪𝘭𝘦𝘥 𝘣𝘺 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦 𝘪𝘯 𝘢 𝘱𝘦𝘵𝘪𝘵𝘪𝘰𝘯 𝘧𝘰𝘳 𝘤𝘦𝘳𝘵𝘪𝘰𝘳𝘢𝘳𝘪 𝘶𝘯𝘥𝘦𝘳 𝘙𝘶𝘭𝘦 65 𝘰𝘧 𝘵𝘩𝘦 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵 𝘸𝘪𝘵𝘩𝘰𝘶𝘵 𝘱𝘭𝘢𝘤𝘪𝘯𝘨 𝘵𝘩𝘦 𝘢𝘤𝘤𝘶𝘴𝘦𝘥 𝘪𝘯 𝘥𝘰𝘶𝘣𝘭𝘦 𝘫𝘦𝘰𝘱𝘢𝘳𝘥𝘺, 𝘱𝘳𝘰𝘷𝘪𝘥𝘦𝘥 𝘵𝘩𝘦 𝘚𝘵𝘢𝘵𝘦 𝘤𝘢𝘯 𝘦𝘴𝘵𝘢𝘣𝘭𝘪𝘴𝘩 𝘵𝘩𝘢𝘵 𝘵𝘩𝘦 𝘭𝘰𝘸𝘦𝘳 𝘤𝘰𝘶𝘳𝘵 𝘢𝘤𝘵𝘦𝘥 𝘸𝘪𝘵𝘩𝘰𝘶𝘵 𝘫𝘶𝘳𝘪𝘴𝘥𝘪𝘤𝘵𝘪𝘰𝘯 𝘰𝘳 𝘸𝘪𝘵𝘩 𝘨𝘳𝘢𝘷𝘦 𝘢𝘣𝘶𝘴𝘦 𝘰𝘧 𝘥𝘪𝘴𝘤𝘳𝘦𝘵𝘪𝘰𝘯 𝘢𝘮𝘰𝘶𝘯𝘵𝘪𝘯𝘨 𝘵𝘰 𝘦𝘹𝘤𝘦𝘴𝘴 𝘰𝘳 𝘭𝘢𝘤𝘬 𝘰𝘧 𝘫𝘶𝘳𝘪𝘴𝘥𝘪𝘤𝘵𝘪𝘰𝘯.

𝘔𝘢𝘳𝘪𝘵𝘢𝘭 𝘪𝘯𝘧𝘪𝘥𝘦𝘭𝘪𝘵𝘺 𝘪𝘴 𝘦𝘹𝘱𝘳𝘦𝘴𝘴𝘭𝘺 𝘳𝘦𝘤𝘰𝘨𝘯𝘪𝘻𝘦𝘥 𝘢𝘴 𝘢 𝘧𝘰𝘳𝘮 𝘰𝘧 𝘱𝘴𝘺𝘤𝘩𝘰𝘭𝘰𝘨𝘪𝘤𝘢𝘭 𝘷𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘶𝘯𝘥𝘦𝘳 𝘚𝘦𝘤𝘵𝘪𝘰𝘯 3(𝘤) 𝘪𝘯 𝘳𝘦𝘭𝘢𝘵𝘪𝘰𝘯 𝘵𝘰 𝘚𝘦𝘤𝘵𝘪𝘰𝘯 5(𝘪) 𝘰𝘧 𝘙.𝘈. 𝘕𝘰. 9262. 𝘐𝘯 𝘪𝘯𝘴𝘵𝘢𝘯𝘤𝘦𝘴 𝘰𝘧 𝘮𝘢𝘳𝘪𝘵𝘢𝘭 𝘪𝘯𝘧𝘪𝘥𝘦𝘭𝘪𝘵𝘺, 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.

𝘈 𝘥𝘦 𝘧𝘢𝘤𝘵𝘰 𝘴𝘦𝘱𝘢𝘳𝘢𝘵𝘪𝘰𝘯 (𝘴𝘦𝘱𝘢𝘳𝘢𝘵𝘪𝘰𝘯 𝘪𝘯 𝘧𝘢𝘤𝘵) 𝘥𝘰𝘦𝘴 𝘯𝘰𝘵 𝘴𝘦𝘷𝘦𝘳 𝘵𝘩𝘦 𝘮𝘢𝘳𝘳𝘪𝘢𝘨𝘦 𝘣𝘰𝘯𝘥𝘴.

𝘅𝘅𝘅 𝘃𝘀. 𝗣𝗘𝗢𝗣𝗟𝗘 𝗢𝗙 𝗧𝗛𝗘 𝗣𝗛𝗜𝗟𝗜𝗣𝗣𝗜𝗡𝗘𝗦 𝗮𝗻𝗱 𝗔𝗔𝗔
𝗚.𝗥. 𝗡𝗼. 𝟮𝟯𝟮𝟭𝟵𝟬, 𝗔𝘂𝗴𝘂𝘀𝘁 𝟮𝟬, 𝟮𝟬𝟮𝟱

𝐅𝐀𝐂𝐓𝐒:
### and AAA were married in 2005 and had a son in 2008. While AAA was pregnant, she noticed ### 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, ### dismissed it as a prank. The following day, ### left their conjugal home and never returned, only visiting their son on weekends.

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

AAA filed a criminal complaint against ### for psychological violence under Section 5(i) of Republic Act (R.A.) No. 9262 (Anti-Violence Against Women and Their Children Act of 2004).

The Regional Trial Court (RTC) acquitted ### based on reasonable doubt, reasoning that the complaint was filed belatedly (four years after the separation), ### 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 ###, ruling that the evidence clearly showed ###'s infidelity caused AAA's mental and emotional suffering. ### appealed to the Supreme Court, arguing that the CA's reversal of his acquittal violated his constitutional right against double jeopardy.

𝐈𝐒𝐒𝐔𝐄/𝐒:
𝙒𝙖𝙨 𝙓𝙓𝙓'𝙨 𝙧𝙞𝙜𝙝𝙩 𝙖𝙜𝙖𝙞𝙣𝙨𝙩 𝙙𝙤𝙪𝙗𝙡𝙚 𝙟𝙚𝙤𝙥𝙖𝙧𝙙𝙮 𝙫𝙞𝙤𝙡𝙖𝙩𝙚𝙙 𝙬𝙝𝙚𝙣 𝙩𝙝𝙚 𝙊𝙎𝙂 𝙛𝙞𝙡𝙚𝙙 𝙖 𝙥𝙚𝙩𝙞𝙩𝙞𝙤𝙣 𝙛𝙤𝙧 𝙘𝙚𝙧𝙩𝙞𝙤𝙧𝙖𝙧𝙞 𝙗𝙚𝙛𝙤𝙧𝙚 𝙩𝙝𝙚 𝘾𝘼 𝙩𝙤 𝙖𝙨𝙨𝙖𝙞𝙡 𝙩𝙝𝙚 𝙍𝙏𝘾'𝙨 𝙫𝙚𝙧𝙙𝙞𝙘𝙩 𝙤𝙛 𝙖𝙘𝙦𝙪𝙞𝙩𝙩𝙖𝙡?

𝙄𝙨 𝙓𝙓𝙓 𝙜𝙪𝙞𝙡𝙩𝙮 𝙗𝙚𝙮𝙤𝙣𝙙 𝙧𝙚𝙖𝙨𝙤𝙣𝙖𝙗𝙡𝙚 𝙙𝙤𝙪𝙗𝙩 𝙤𝙛 𝙥𝙨𝙮𝙘𝙝𝙤𝙡𝙤𝙜𝙞𝙘𝙖𝙡 𝙫𝙞𝙤𝙡𝙚𝙣𝙘𝙚 𝙪𝙣𝙙𝙚𝙧 𝙎𝙚𝙘𝙩𝙞𝙤𝙣 5(𝙞) 𝙤𝙛 𝙍.𝘼. 𝙉𝙤. 9262?

𝐑𝐔𝐋𝐈𝐍𝐆:
𝟏. 𝐎𝐧 𝐃𝐨𝐮𝐛𝐥𝐞 𝐉𝐞𝐨𝐩𝐚𝐫𝐝𝐲:
NO. The Supreme 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.

The RTC committed grave abuse of discretion by acting with an obstinate disregard of basic and established rules of law. The RTC erroneously ruled that marital infidelity committed after a de facto separation falls outside the scope of R.A. No. 9262. The Supreme Court emphasized that a mere de facto separation does not sever marriage bonds; thus, any extramarital affair maintained by a spouse still constitutes marital infidelity.

𝟐. 𝐎𝐧 𝐆𝐮𝐢𝐥𝐭 𝐮𝐧𝐝𝐞𝐫 𝐑.𝐀. 𝐍𝐨. 𝟗𝟐𝟔𝟐:
YES. The Supreme Court affirmed ###'s conviction. All the elements of Section 5(i) of R.A. No. 9262 were proven:

𝘛𝘩𝘦 𝘰𝘧𝘧𝘦𝘯𝘥𝘦𝘥 𝘱𝘢𝘳𝘵𝘺 𝘪𝘴 𝘢 𝘸𝘰𝘮𝘢𝘯/𝘸𝘪𝘧𝘦.
𝘚𝘩𝘦 𝘪𝘴 𝘵𝘩𝘦 𝘸𝘪𝘧𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘰𝘧𝘧𝘦𝘯𝘥𝘦𝘳.
𝘛𝘩𝘦 𝘰𝘧𝘧𝘦𝘯𝘥𝘦𝘳 𝘤𝘢𝘶𝘴𝘦𝘥 𝘮𝘦𝘯𝘵𝘢𝘭 𝘰𝘳 𝘦𝘮𝘰𝘵𝘪𝘰𝘯𝘢𝘭 𝘢𝘯𝘨𝘶𝘪𝘴𝘩.
𝘛𝘩𝘦 𝘢𝘯𝘨𝘶𝘪𝘴𝘩 𝘸𝘢𝘴 𝘤𝘢𝘶𝘴𝘦𝘥 𝘵𝘩𝘳𝘰𝘶𝘨𝘩 𝘢𝘤𝘵𝘴 𝘰𝘧 𝘱𝘶𝘣𝘭𝘪𝘤 𝘳𝘪𝘥𝘪𝘤𝘶𝘭𝘦, 𝘩𝘶𝘮𝘪𝘭𝘪𝘢𝘵𝘪𝘰𝘯, 𝘰𝘳 𝘴𝘪𝘮𝘪𝘭𝘢𝘳 𝘢𝘤𝘵𝘴 (𝘪𝘯 𝘵𝘩𝘪𝘴 𝘤𝘢𝘴𝘦, 𝘮𝘢𝘳𝘪𝘵𝘢𝘭 𝘪𝘯𝘧𝘪𝘥𝘦𝘭𝘪𝘵𝘺).
𝘛𝘩𝘦 𝘊𝘰𝘶𝘳𝘵 𝘩𝘦𝘭𝘥 𝘵𝘩𝘢𝘵 𝘟𝘟𝘟'𝘴 𝘢𝘤𝘵 𝘰𝘧 𝘭𝘦𝘢𝘷𝘪𝘯𝘨 𝘵𝘩𝘦 𝘤𝘰𝘯𝘫𝘶𝘨𝘢𝘭 𝘩𝘰𝘮𝘦, 𝘣𝘶𝘪𝘭𝘥𝘪𝘯𝘨 𝘢 𝘧𝘢𝘮𝘪𝘭𝘺 𝘸𝘪𝘵𝘩 𝘩𝘪𝘴 𝘮𝘪𝘴𝘵𝘳𝘦𝘴𝘴, 𝘢𝘯𝘥 𝘧𝘭𝘢𝘶𝘯𝘵𝘪𝘯𝘨 𝘵𝘩𝘦𝘮 𝘰𝘯 𝘴𝘰𝘤𝘪𝘢𝘭 𝘮𝘦𝘥𝘪𝘢 𝘤𝘢𝘶𝘴𝘦𝘥 𝘪𝘳𝘳𝘦𝘱𝘢𝘳𝘢𝘣𝘭𝘦 𝘮𝘦𝘯𝘵𝘢𝘭 𝘢𝘯𝘥 𝘦𝘮𝘰𝘵𝘪𝘰𝘯𝘢𝘭 𝘩𝘶𝘳𝘵 𝘵𝘰 𝘈𝘈𝘈, 𝘢𝘴 𝘤𝘰𝘳𝘳𝘰𝘣𝘰𝘳𝘢𝘵𝘦𝘥 𝘣𝘺 𝘩𝘦𝘳 𝘱𝘴𝘺𝘤𝘩𝘪𝘢𝘵𝘳𝘪𝘤 𝘦𝘷𝘢𝘭𝘶𝘢𝘵𝘪𝘰𝘯. 𝘛𝘩𝘦 𝘧𝘢𝘤𝘵 𝘵𝘩𝘢𝘵 𝘟𝘟𝘟 𝘱𝘳𝘰𝘷𝘪𝘥𝘦𝘥 𝘧𝘪𝘯𝘢𝘯𝘤𝘪𝘢𝘭 𝘴𝘶𝘱𝘱𝘰𝘳𝘵 𝘵𝘰 𝘩𝘪𝘴 𝘭𝘦𝘨𝘪𝘵𝘪𝘮𝘢𝘵𝘦 𝘴𝘰𝘯 𝘥𝘰𝘦𝘴 𝘯𝘰𝘵 𝘢𝘣𝘴𝘰𝘭𝘷𝘦 𝘩𝘪𝘮 𝘧𝘳𝘰𝘮 𝘵𝘩𝘦 𝘱𝘴𝘺𝘤𝘩𝘰𝘭𝘰𝘨𝘪𝘤𝘢𝘭 𝘷𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘩𝘦 𝘪𝘯𝘧𝘭𝘪𝘤𝘵𝘦𝘥 𝘵𝘩𝘳𝘰𝘶𝘨𝘩 𝘩𝘪𝘴 𝘪𝘯𝘧𝘪𝘥𝘦𝘭𝘪𝘵𝘺.

𝘼𝘾𝘾𝙊𝙍𝘿𝙄𝙉𝙂𝙇𝙔, 𝙩𝙝𝙚 𝙋𝙚𝙩𝙞𝙩𝙞𝙤𝙣 𝙞𝙨 𝘿𝙀𝙉𝙄𝙀𝘿. 𝙏𝙝𝙚 𝘿𝙚𝙘𝙞𝙨𝙞𝙤𝙣 𝙙𝙖𝙩𝙚𝙙 𝙈𝙖𝙧𝙘𝙝 30, 2017 𝙖𝙣𝙙 𝙍𝙚𝙨𝙤𝙡𝙪𝙩𝙞𝙤𝙣 𝙙𝙖𝙩𝙚𝙙 𝙅𝙪𝙣𝙚 6, 2017 𝙤𝙛 𝙩𝙝𝙚 𝘾𝙤𝙪𝙧𝙩 𝙤𝙛 𝘼𝙥𝙥𝙚𝙖𝙡𝙨 𝙞𝙣 𝘾𝘼-𝙂.𝙍. 𝙎𝙋 𝙉𝙤. 148784 𝙖𝙧𝙚 𝘼𝙁𝙁𝙄𝙍𝙈𝙀𝘿 𝙬𝙞𝙩𝙝 𝙈𝙊𝘿𝙄𝙁𝙄𝘾𝘼𝙏𝙄𝙊𝙉. 𝙓𝙓𝙓 𝙞𝙨 𝙂𝙐𝙄𝙇𝙏𝙔 𝙤𝙛 𝙫𝙞𝙤𝙡𝙖𝙩𝙞𝙤𝙣 𝙤𝙛 𝙎𝙚𝙘𝙩𝙞𝙤𝙣 5(𝙞) 𝙤𝙛 𝙍𝙚𝙥𝙪𝙗𝙡𝙞𝙘 𝘼𝙘𝙩 𝙉𝙤. 9262 𝙖𝙣𝙙 𝙞𝙨 𝙨𝙚𝙣𝙩𝙚𝙣𝙘𝙚𝙙 𝙩𝙤 𝙩𝙝𝙚 𝙞𝙣𝙙𝙚𝙩𝙚𝙧𝙢𝙞𝙣𝙖𝙩𝙚 𝙥𝙚𝙣𝙖𝙡𝙩𝙮 𝙤𝙛 𝙛𝙤𝙪𝙧 𝙮𝙚𝙖𝙧𝙨, 𝙩𝙬𝙤 𝙢𝙤𝙣𝙩𝙝𝙨, 𝙖𝙣𝙙 𝙤𝙣𝙚 𝙙𝙖𝙮 𝙤𝙛 𝙥𝙧𝙞𝙨𝙞𝙤𝙣 𝙘𝙤𝙧𝙧𝙚𝙘𝙘𝙞𝙤𝙣𝙖𝙡, 𝙖𝙨 𝙩𝙝𝙚 𝙢𝙞𝙣𝙞𝙢𝙪𝙢 𝙩𝙚𝙧𝙢, 𝙖𝙣𝙙 𝙚𝙞𝙜𝙝𝙩 𝙮𝙚𝙖𝙧𝙨 𝙖𝙣𝙙 𝙤𝙣𝙚 𝙙𝙖𝙮 𝙤𝙛 𝙥𝙧𝙞𝙨𝙞𝙤𝙣 𝙢𝙖𝙮𝙤𝙧, 𝙖𝙨 𝙩𝙝𝙚 𝙢𝙖𝙭𝙞𝙢𝙪𝙢 𝙩𝙚𝙧𝙢. 𝙃𝙚 𝙞𝙨 𝙖𝙡𝙨𝙤 𝙤𝙧𝙙𝙚𝙧𝙚𝙙 𝙩𝙤 𝙋𝘼𝙔 𝙖 𝙛𝙞𝙣𝙚 𝙤𝙛 𝙋𝙃𝙋 100,000.00 𝙖𝙣𝙙 𝙩𝙤 𝙪𝙣𝙙𝙚𝙧𝙜𝙤 𝙥𝙨𝙮𝙘𝙝𝙤𝙡𝙤𝙜𝙞𝙘𝙖𝙡 𝙘𝙤𝙪𝙣𝙨𝙚𝙡𝙞𝙣𝙜 𝙖𝙣𝙙 𝙩𝙤 𝙧𝙚𝙥𝙤𝙧𝙩 𝙝𝙞𝙨 𝙘𝙤𝙢𝙥𝙡𝙞𝙖𝙣𝙘𝙚 𝙩𝙝𝙚𝙧𝙚𝙬𝙞𝙩𝙝 𝙩𝙤 𝙩𝙝𝙚 𝘾𝙤𝙪𝙧𝙩, 𝙖𝙨 𝙨𝙚𝙩 𝙛𝙤𝙧𝙩𝙝 𝙞𝙣 𝙩𝙝𝙚 𝙡𝙖𝙨𝙩 𝙥𝙖𝙧𝙖𝙜𝙧𝙖𝙥𝙝 𝙤𝙛 𝙎𝙚𝙘𝙩𝙞𝙤𝙣 6 𝙤𝙛 𝙍𝙚𝙥𝙪𝙗𝙡𝙞𝙘 𝘼𝙘𝙩 𝙉𝙤. 9262.

FULL:
https://sc.judiciary.gov.ph/wp-content/uploads/2026/04/232190.pdf

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20/04/2026

The (SC) has affirmed its previous ruling that cyber libel prescribes one year from the time it is discovered, holding that “cyber libel” is not a new crime but a form of “libel” under Art. 355 of the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 that is committed through a computer system or other similar means.

In a Resolution written by Associate Justice Henri Jean Paul B. Inting, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 denied the separate motions for reconsideration filed by Berteni Cataluña Causing and the Office of the Solicitor General (OSG).

In December 2020, Cotabato Second District Representative Ferdinand L. Hernandez filed a cyber libel complaint with the prosecutor against Causing related to Facebook posts accusing Hernandez of pocketing over PHP 200 million in relief goods for Marawi victims. Hernandez stated he discovered the posts on February 4 and April 29, 2019.

Informations were filed before the Regional Trial Court (RTC) against Causing in May 2021. He filed a motion to quash the Informations, arguing that they were already time-barred under the RPC because more than one year had passed since the posts were uploaded.

The RTC denied the motion, ruling that cyber libel prescribes in 12 years under 𝘙𝘦𝘱𝘶𝘣𝘭𝘪𝘤 𝘈𝘤𝘵 𝘕𝘰. (𝘙𝘈) 10175 or the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵.

Causing appealed to the SC, which clarified that the prescriptive period for cyber libel is one year from the date of discovery, consistent with traditional libel under the RPC. The Court rejected Causing’s motion to quash the Informations due to insufficient proof that the offense had already prescribed, highlighting that he can present evidence during the trial at the RTC.

Both the OSG and Causing filed separate partial motions for reconsideration.

The OSG argued that the one-year prescriptive period for traditional libel under the RPC should not apply to cyber libel. Instead, it should be 15 years under the Cybercrime Prevention Act, as previously decided by the Supreme Court through an unsigned resolution in Tolentino v. People.

Causing, on the other hand, argued that the prescription for cyber libel should start from the publication date rather than from discovery. He contended that online posts are more widespread than traditional forms of publication. If the discovery rule is applied, cyber libel charges could be filed several years after the post was made, as long as the offended party discovered it later.

The SC rejected both arguments.

Under the RPC, written libel prescribes in one year. There is no law that excludes cyber libel from this one-year period, and Congress has consistently treated libel as having a shorter prescriptive period than other crimes, even when penalties are increased.

The SC reiterated that cyber libel is not a separate crime, but rather libel committed through a computer system. The fact that the Cybercrime Prevention Act imposes a higher penalty for cyber libel does not imply that its prescriptive period should be extended beyond that of traditional libel.

The SC added that when laws on the prescription of crimes are unclear, they must be interpreted in favor of the accused. Since the RPC sets a one-year prescriptive period for cyber libel, it prevails over the 15-year period set in the case of Tolentino v. People, which is an unsigned resolution.

The SC also affirmed that prescription begins upon discovery of the offense, not upon publication. The law clearly states that prescription runs from the time the crime is discovered by the offended party or the authorities.

Seven other Justices joined Justice Inting in the majority. They are:
• Chief Justice Alexander G. Gesmundo
• Senior Associate Justice Marvic M.V.F. Leonen
• Associate Justice Alfredo Benjamin S. Caguioa
• Associate Justice Rodil V. Zalameda
• Associate Justice Samuel H. Gaerlan
• Associate Justice Jose Midas P. Marquez
• Associate Justice Maria Filomena D. Singh

In his Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen argued that the one-year prescription period should apply only to libel cases against private individuals. He added that libel against public figures should be decriminalized, as punishing comments and criticisms directed at public officials discourages free and uninhibited discussion about how those in public office conduct themselves.

In his Concurring Opinion, Associate Justice Alfredo Benjamin S. Caguioa stressed that the prescriptive period for libel has always been fixed at one or two years, never at 10 or more years.

Meanwhile, six other Justices joined Associate Justice Antonio T. Kho, Jr. in his dissent:
• Associate Justice Ramon Paul L. Hernando
• Associate Justice Amy C. Lazaro-Javier
• Associate Justice Ricardo R. Rosario
• Associate Justice Jhosep Y. Lopez
• Associate Justice Japar B. Dimaampao
• Associate Justice Raul B. Villanueva

In his Concurring and Dissenting opinion, Justice Kho, Jr. agreed with the majority that unsigned resolutions do not lay down doctrines of law but disagreed on the prescriptive period for cyber libel. Since cyber libel is committed through computer systems and is punishable under the Cybercrime Prevention Act, it is a separate crime from libel and the one-year prescriptive period for libel does not apply.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=163671

Read the full text of the Resolution at https://sc.judiciary.gov.ph/?p=163636

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=163642

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/wp-admin/post.php?p=163650

Read the Concurring and Dissenting OpinionOpinion of Associate Justice Antonio T. Kho, Jr. at https://sc.judiciary.gov.ph/?p=163661

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