Encio Law Office

23/11/2025

𝗪𝗵𝘆 𝗣𝗮𝗴𝗲 𝗔𝗱𝗺𝗶𝗻𝘀 𝗼𝗳 𝗙𝗿𝗲𝗲𝗱𝗼𝗺 𝗪𝗮𝗹𝗹𝘀 𝗔𝗿𝗲 𝗔𝘂𝘁𝗼𝗺𝗮𝘁𝗶𝗰𝗮𝗹𝗹𝘆 𝗟𝗶𝗮𝗯𝗹𝗲 𝗳𝗼𝗿 𝗖𝘆𝗯𝗲𝗿 𝗟𝗶𝗯𝗲𝗹
A legal analysis by Dean Ralph Sarmiento

𝗪𝗵𝗮𝘁 𝗶𝘀 𝗰𝘆𝗯𝗲𝗿 𝗹𝗶𝗯𝗲𝗹 𝘂𝗻𝗱𝗲𝗿 𝗣𝗵𝗶𝗹𝗶𝗽𝗽𝗶𝗻𝗲 𝗹𝗮𝘄?

Cyber libel is defamation that is committed in online platforms. As defined in Section 4(c)(4) of 𝗥𝗲𝗽𝘂𝗯𝗹𝗶𝗰 𝗔𝗰𝘁 𝗡𝗼. 𝟭𝟬𝟭𝟳𝟱 or the 𝗖𝘆𝗯𝗲𝗿𝗰𝗿𝗶𝗺𝗲 𝗣𝗿𝗲𝘃𝗲𝗻𝘁𝗶𝗼𝗻 𝗔𝗰𝘁 𝗼𝗳 𝟮𝟬𝟭𝟮, it consists of the unlawful or prohibited acts of libel as defined in 𝗔𝗿𝘁𝗶𝗰𝗹𝗲 𝟯𝟱𝟱 𝗼𝗳 𝘁𝗵𝗲 𝗥𝗲𝘃𝗶𝘀𝗲𝗱 𝗣𝗲𝗻𝗮𝗹 𝗖𝗼𝗱𝗲 that are committed through a computer system or any other similar means which may be devised in the future.

Cyber libel is committed when someone publishes a defamatory statement about someone on the internet. The law holds the author, publisher, and anyone who takes an active role in the act of posting liable. The moment the defamatory statement is posted online and names or identifies a real person, cyber libel is consummated.

𝗪𝗵𝗮𝘁 𝗱𝗶𝗱 𝘁𝗵𝗲 𝗦𝘂𝗽𝗿𝗲𝗺𝗲 𝗖𝗼𝘂𝗿𝘁 𝗿𝘂𝗹𝗲 𝗶𝗻 𝗗𝗶𝘀𝗶𝗻𝗶 𝘃. 𝗦𝗲𝗰𝗿𝗲𝘁𝗮𝗿𝘆 𝗼𝗳 𝗝𝘂𝘀𝘁𝗶𝗰𝗲?

In 𝗗𝗶𝘀𝗶𝗻𝗶 𝘃. 𝗦𝗲𝗰𝗿𝗲𝘁𝗮𝗿𝘆 𝗼𝗳 𝗝𝘂𝘀𝘁𝗶𝗰𝗲 (G.R. No. 203335, February 11, 2014), the Court also held that 𝗺𝗲𝗿𝗲 𝗹𝗶𝗸𝗶𝗻𝗴, 𝘀𝗵𝗮𝗿𝗶𝗻𝗴, 𝗼𝗿 𝗿𝗲𝗮𝗰𝘁𝗶𝗻𝗴 𝗶𝘀 𝗻𝗼𝘁 𝗰𝘆𝗯𝗲𝗿 𝗹𝗶𝗯𝗲𝗹 unless the act is a deliberate republication done with malice. The ruling focused on personal criminal liability and clarified that passive administrators and platform owners are not treated as publishers. The Court held:

“The question is: are online postings such as "Liking" an openly defamatory statement, ‘Commenting’ on it, or ‘Sharing’ it with others, to be regarded as ‘aiding or abetting?’ In libel in the physical world, if Nestor places on the office bulletin board a small poster that says, ‘Armand is a thief!,’ he could certainly be charged with libel. If Roger, seeing the poster, writes on it, ‘I like this!,’ that could not be libel since he did not author the poster. If Arthur, passing by and noticing the poster, writes on it, ‘Correct!,’ would that be libel? No, for he merely expresses agreement with the statement on the poster. He still is not its author. Besides, it is not clear if aiding or abetting libel in the physical world is a crime.”

𝗪𝗵𝗮𝘁 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺𝘀 𝘄𝗮𝘀 𝘁𝗵𝗲 𝗦𝘂𝗽𝗿𝗲𝗺𝗲 𝗖𝗼𝘂𝗿𝘁 𝗹𝗼𝗼𝗸𝗶𝗻𝗴 𝗮𝘁 𝗶𝗻 𝟮𝟬𝟭𝟰?

In Disini, the Court held that 𝗰𝗿𝗶𝗺𝗶𝗻𝗮𝗹 𝗹𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁 𝗮𝘁𝘁𝗮𝗰𝗵 𝘁𝗼 𝗽𝗲𝗼𝗽𝗹𝗲 𝘄𝗵𝗼 𝗼𝗻𝗹𝘆 𝗵𝗼𝘀𝘁 𝘂𝘀𝗲𝗿 𝗰𝗼𝗻𝘁𝗲𝗻𝘁. The Court held:

“In the cyberworld, there are many actors: a) the blogger who originates the assailed statement; b) the blog service provider like Yahoo; c) the internet service provider like PLDT, Smart, Globe, or Sun; d) the internet café that may have provided the computer used for posting the blog; e) the person who makes a favorable comment on the blog; and f) the person who posts a link to the blog site…”

𝗙𝗿𝗲𝗲𝗱𝗼𝗺 𝘄𝗮𝗹𝗹𝘀 𝗱𝗼 𝗻𝗼𝘁 𝗺𝗲𝗿𝗲𝗹𝘆 𝗵𝗼𝘀𝘁 𝘂𝘀𝗲𝗿 𝗰𝗼𝗻𝘁𝗲𝗻𝘁. What the Court examined in Disini was the structure of Facebook groups, forums, and pages that existed in 2014. 𝗔𝘁 𝘁𝗵𝗮𝘁 𝘁𝗶𝗺𝗲, 𝘂𝘀𝗲𝗿𝘀 𝗽𝗼𝘀𝘁𝗲𝗱 𝗱𝗶𝗿𝗲𝗰𝘁𝗹𝘆 𝘂𝗻𝗱𝗲𝗿 𝘁𝗵𝗲𝗶𝗿 𝗼𝘄𝗻 𝗻𝗮𝗺𝗲𝘀. Page admins did not receive anonymous submissions. They did not act as editors. They did not select which statements to publish. The Court analyzed 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺𝘀 𝘁𝗵𝗮𝘁 𝗳𝘂𝗻𝗰𝘁𝗶𝗼𝗻𝗲𝗱 𝗮𝘀 𝗼𝗽𝗲𝗻 𝗳𝗼𝗿𝘂𝗺𝘀, 𝗻𝗼𝘁 𝗰𝘂𝗿𝗮𝘁𝗲𝗱 𝗽𝗮𝗴𝗲𝘀. That is the crucial distinction.

𝗛𝗼𝘄 𝗮𝗿𝗲 𝗺𝗼𝗱𝗲𝗿𝗻 𝗳𝗿𝗲𝗲𝗱𝗼𝗺 𝘄𝗮𝗹𝗹𝘀 𝗱𝗶𝗳𝗳𝗲𝗿𝗲𝗻𝘁?

Freedom walls as they exist today on Facebook work in a very different way. 𝗣𝗲𝗼𝗽𝗹𝗲 𝗱𝗼 𝗻𝗼𝘁 𝗽𝗼𝘀𝘁 𝗱𝗶𝗿𝗲𝗰𝘁𝗹𝘆. Their submissions are not posted automatically. People send the statements to the admins of freedom walls and it is the admins that post under the name of the freedom wall itself. The admins 𝘁𝘂𝗿𝗻 𝘁𝗵𝗲 𝘀𝘁𝗮𝘁𝗲𝗺𝗲𝗻𝘁𝘀 𝘁𝗵𝗲𝘆 𝗿𝗲𝗰𝗲𝗶𝘃𝗲 𝗶𝗻𝘁𝗼 𝗼𝗻𝗹𝗶𝗻𝗲 𝗽𝗼𝘀𝘁𝘀. Hence, every post is created by the 𝗱𝗲𝗹𝗶𝗯𝗲𝗿𝗮𝘁𝗲 𝗮𝗰𝘁𝗶𝗼𝗻 𝗼𝗳 𝘁𝗵𝗲 𝗮𝗱𝗺𝗶𝗻𝘀 𝘁𝗼 𝗽𝘂𝗯𝗹𝗶𝘀𝗵 the same on their platform.

𝗪𝗵𝘆 𝗮𝗿𝗲 𝗳𝗿𝗲𝗲𝗱𝗼𝗺 𝘄𝗮𝗹𝗹 𝗮𝗱𝗺𝗶𝗻𝘀 𝗮𝘂𝘁𝗼𝗺𝗮𝘁𝗶𝗰𝗮𝗹𝗹𝘆 𝗹𝗶𝗮𝗯𝗹𝗲 𝘄𝗵𝗲𝗻 𝘁𝗵𝗲𝘆 𝗽𝗼𝘀𝘁 𝗱𝗲𝗳𝗮𝗺𝗮𝘁𝗼𝗿𝘆 𝗰𝗼𝗻𝘁𝗲𝗻𝘁?

Page admins of freedom walls become automatically liable the moment they publish a defamatory post about a named or identifiable individual. They are 𝗻𝗼𝘁 𝘁𝗵𝗲 𝗽𝗮𝘀𝘀𝗶𝘃𝗲 𝗶𝗻𝘁𝗲𝗿𝗺𝗲𝗱𝗶𝗮𝗿𝗶𝗲𝘀 of the online forums contemplated by the Supreme Court in the 2014 Disini case. 𝗧𝗵𝗲𝘆 𝗮𝗿𝗲 𝘁𝗵𝗲 𝗼𝗻𝗲𝘀 𝘄𝗵𝗼 𝗰𝗹𝗶𝗰𝗸 “𝗽𝗼𝘀𝘁.” They 𝗽𝗲𝗿𝗳𝗼𝗿𝗺 𝘁𝗵𝗲 𝗮𝗰𝘁 𝗼𝗳 𝗽𝘂𝗯𝗹𝗶𝗰𝗮𝘁𝗶𝗼𝗻, which is the essential element of cyber libel.

Once the page admins of the freedom wall publish a defamatory post that names a real or identifiable person and harm that person’s reputation, they 𝗯𝗲𝗰𝗼𝗺𝗲 𝘁𝗵𝗲 𝗽𝘂𝗯𝗹𝗶𝘀𝗵𝗲𝗿 𝗼𝗳 𝘁𝗵𝗲 𝗱𝗲𝗳𝗮𝗺𝗮𝘁𝗼𝗿𝘆 𝗽𝗼𝘀𝘁. Note that the law also presumes malice because the content is defamatory.

𝗗𝗼𝗲𝘀 𝘁𝗵𝗶𝘀 𝗰𝗼𝗻𝘁𝗿𝗮𝗱𝗶𝗰𝘁 𝗗𝗶𝘀𝗶𝗻𝗶?

No, this follows the logic of the Supreme Court in Disini. Disini only protects intermediaries or passive admins of online forums or platforms who have nothing to do with the creation or publication of the defamatory post. 𝗙𝗿𝗲𝗲𝗱𝗼𝗺 𝘄𝗮𝗹𝗹 𝗮𝗱𝗺𝗶𝗻𝘀 𝗱𝗼 𝘁𝗵𝗲 𝗲𝘅𝗮𝗰𝘁 𝗼𝗽𝗽𝗼𝘀𝗶𝘁𝗲. They take part in the content. 𝗧𝗵𝗲𝘆 𝗮𝗿𝗲 𝘁𝗵𝗲 𝗼𝗻𝗲𝘀 𝘄𝗵𝗼 𝗽𝘂𝗯𝗹𝗶𝘀𝗵 𝗶𝘁 𝗳𝗼𝗿 𝗲𝘃𝗲𝗿𝘆𝗼𝗻𝗲 𝗼𝗻 𝘁𝗵𝗲 𝗶𝗻𝘁𝗲𝗿𝗻𝗲𝘁 𝘁𝗼 𝘀𝗲𝗲.

The Supreme Court in Disini never said that a person who chooses to publish defamatory content is free from liability simply because they run a page. Disini only protects those who do not participate in the content at all, that is, those who merely like, share, react, or comment on the ongoing discussion.

𝗪𝗶𝗹𝗹 𝘁𝗵𝗲 𝗮𝗱𝗺𝗶𝗻𝘀 𝗲𝘀𝗰𝗮𝗽𝗲 𝗰𝗿𝗶𝗺𝗶𝗻𝗮𝗹 𝗹𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗶𝗳 𝘁𝗵𝗲𝘆 𝘁𝗮𝗸𝗲 𝗱𝗼𝘄𝗻 𝘁𝗵𝗲 𝗽𝗼𝘀𝘁 𝗼𝗻𝗰𝗲 𝘀𝗼𝗺𝗲𝗼𝗻𝗲 𝗰𝗼𝗺𝗽𝗹𝗮𝗶𝗻𝘀?

No. 𝗖𝘆𝗯𝗲𝗿 𝗹𝗶𝗯𝗲𝗹 𝗶𝘀 𝗮𝗹𝗿𝗲𝗮𝗱𝘆 𝗰𝗼𝗻𝘀𝘂𝗺𝗺𝗮𝘁𝗲𝗱 as soon as a defamatory post that names a real or identifiable person is published by the freedom wall admins. 𝗧𝗮𝗸𝗶𝗻𝗴 𝗱𝗼𝘄𝗻 𝘁𝗵𝗲 𝗽𝗼𝘀𝘁 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁 𝗲𝗿𝗮𝘀𝗲 𝘁𝗵𝗲 𝗰𝗿𝗶𝗺𝗲 𝗼𝗿 𝘁𝗵𝗲 𝗵𝗮𝗿𝗺 𝗱𝗼𝗻𝗲. Criminal liability has already attached. At most, it can be used by the page admins to mitigate their criminal liability, but it does not undo the fact that the admins have already committed the act that consummates the crime of cyber libel.

𝗪𝗵𝗮𝘁 𝗮𝗯𝗼𝘂𝘁 𝗳𝗿𝗲𝗲𝗱𝗼𝗺 𝗼𝗳 𝗲𝘅𝗽𝗿𝗲𝘀𝘀𝗶𝗼𝗻?

Freedom of expression does not cover defamation, false allegations, or shaming of individuals without basis. Anonymous speech is allowed, but 𝗮𝗻𝗼𝗻𝘆𝗺𝗶𝘁𝘆 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁 𝗴𝗶𝘃𝗲 𝗶𝗺𝗺𝘂𝗻𝗶𝘁𝘆 𝘄𝗵𝗲𝗻 𝘁𝗵𝗲 𝗰𝗼𝗻𝘁𝗲𝗻𝘁 𝗮𝘁𝘁𝗮𝗰𝗸𝘀 𝘁𝗵𝗲 𝗿𝗲𝗽𝘂𝘁𝗮𝘁𝗶𝗼𝗻 𝗼𝗳 𝗮𝗻𝗼𝘁𝗵𝗲𝗿 𝗽𝗲𝗿𝘀𝗼𝗻. Freedom walls cannot claim free speech when they choose to publish statements that destroy names and reputations.

𝗔𝗿𝗲 𝗳𝗿𝗲𝗲𝗱𝗼𝗺 𝘄𝗮𝗹𝗹𝘀 𝗵𝗮𝗿𝗺𝗳𝘂𝗹?

No. Freedom walls can be helpful spaces for feedback and community issues. However, they become harmful the moment admins use their platform to destroy reputations.

14/11/2025

22/10/2025

Paalala mula sa IBP: Protektahan ang sarili laban sa pekeng abogado.

Verify before you trust.

17/10/2025

PENMANSHIP PROBLEM NO MORE: GOODBYE HANDWRITTEN BAR EXAMS

The Supreme Court (SC) has institutionalized the conduct of digitalized and regionalized Bar examinations as the standard mode for admission to the Philippine Bar.

In a resolution dated August 12, 2025, the SC En Banc approved the 2025 Proposed Amendments to Rule 138 of the Rules of Court on August 12, which mandates the permanent shift toward a modern, inclusive, and technology-driven testing format.

Under the amended rules, the Philippine Bar Exams shall be conducted regionally, digitally and annually in local testing centers across the Philippines as may be designated by the high court.

As to the schedule, the examinations will span three days in September at LTCs nationwide.

Subjects and Weights: The six core subjects are distributed over the three days with the following weights:

• Remedial Law, Legal and Judicial Ethics, with Practical Exercises: 25%

• Commercial and Taxation Laws: 20%

• Civil Law and Land Titles and Deeds: 20%

• Political and Public International Law: 15%

• Labor Law and Social Legislation: 10%

• Criminal Law: 10%

For the passing mark, examinees must obtain a general average of 75% in all subjects unless the SC sets a different rate.

The amended rule will take effect on November 3, 2025, following its complete publication in the Official Gazette or in two newspapers of general circulation in the Philippines.

26/08/2025

SLIGHT DELAY IN INVENTORY FATAL TO INTEGRITY OF DRUG EVIDENCE—SUPREME COURT

| The Supreme Court (SC) has acquitted two men accused of drug-related charges due to the failure of the arresting officers to immediately conduct an inventory of the evidence upon confiscation, emphasizing that it is fatal to the integrity of the chain of custody.

In a 20-page ruling penned by Associate Justice Maria Filomena Singh, the SC's Third Division granted the appeal of Joseph Atanacio and Jon Magno, who challenged their conviction by the Court of Appeals for violation of Sections 5 (selling of illegal drugs) and 11 (possession) of Republic Act No. (RA) 9165 of the Comprehensive Dangerous Drugs Act of 2002.

Atanacio and Magno were charged in 2020 for the sale and possession of methamphetamine hydrochloride, or shabu, following a buy-bust operation conducted by the Iloilo City Police Office (ICPO).

During the trial, the arresting officers admitted that the insulating witnesses: Rommel Bebita of the GMA Super Radyo (media) and Barangay Kagawad Michias Vergara (barangay official), arrived at the place of arrest around 10 minutes after the two accused were arrested.

Meanwhile, Atanacio and Magno denied the accusations by claiming that the shabu recovered from their possessions was planted.

The Regional Trial Court (RTC) found the accused guilty, which was subsequently affirmed by the Court of Appeals. The appellate court emphasized that the prosecution was able to provide all the facts necessary to establish adherence to the chain of custody rule, prompting Atanacio and Magno to elevate the case before the Supreme Court.

In granting Atanacio and Magno's appeal, the high court stressed the importance of complying with the chain of custody rule in drug cases. It found that the arresting officers breached the first chain by not conducting the inventory and marking of the seized dangerous drugs immediately upon confiscation.

During cross examination, the arresting officer claimed that he marked the seized items in the presence of the insulating witnesses, who arrived at the place of confiscation around 10 minutes after the arrest of Atanacio and Magno.

“In the present case, there is a glaring irregularity that seriously taints the integrity of the dangerous drugs confiscated from Atanacio and highlights the importance of marking the seized buy-bust items immediately upon confiscation,” the Supreme Court said.

“The Court agrees with Atanacio and Magno that the slightest delay in the marking of the seized dangerous drugs already created a nagging doubt as to the precautionary and safeguarding measures adopted by Pat. Mendez on the confiscated items, thus putting into question the integrity and evidentiary value of the items seized,” the Supreme Court added.

It also held that the arresting officer failed to establish the fourth link in the chain of custody due to the failure of the forensic chemist to narrate how she handled the drug specimens before, during, and after she conducted the laboratory examination, which is vital to the integrity of the evidence.

“Neither the prosecution nor the apprehending officers offered any justification for the non-compliance with the procedure required under Section 21 of Republic Act No. 9165, as amended by Republic Act No. 10640. This unjustified departure from the chain of custody rule casts doubt on the prosecution's evidence,” it said.

The SC cleared Atanacio and Magno and ordered their immediate release from detention.

11/05/2025

‼️ 𝗣𝗔𝗔𝗟𝗔𝗟𝗔: 𝗟𝗜𝗤𝗨𝗢𝗥 𝗕𝗔𝗡 ‼️

Bawal ang pagbenta, pagbigay, pag-alok, pagbili, paghatid, o pag-inom ng alak saanman sa Pilipinas sa 𝗠𝗮𝘆 𝟭𝟭, 𝟮𝟬𝟮𝟱 (𝗘𝘃𝗲 𝗼𝗳 𝗘𝗹𝗲𝗰𝘁𝗶𝗼𝗻 𝗗𝗮𝘆) 𝗮𝘁 𝗠𝗮𝘆 𝟭𝟮, 𝟮𝟬𝟮𝟱 (𝗘𝗹𝗲𝗰𝘁𝗶𝗼𝗻 𝗗𝗮𝘆).

08/05/2025

Persons NOT ALLOWED TO ENTER the polling place or within the 50-meter radius from the polling place:

1. Any officer or member of the AFP or PNP
2. Barangay tanods, security guards, special policemen, CAFGUs, or para-military forces
3. Armed or unarmed extra-legal police forces

EXCEPT for voting purposes

Source: Sec. 34, COMELEC Resolution 11076

07/05/2025

06/05/2025

Rights and duties of poll watchers under COMELEC Resolution No. 11076

Key points:

1. Dapat napuruko la hit desiganted seats for watchers an mga watchers. Bawal hira magnilibot-libot hit precinct samtang nabotos it mga botante.

2. Bawal mag-picture/video an poll watcher samtang na-shade an botante han iya balota ngan nagfi-feed han iya balota dida ha Automated Counting Machine (ACM), whether aadto hit sulod or gawas hit precinct an watcher. An ma-violate hini in pwede mapiriso hin 1-6 years.

3. Pwede la mag-picture/video an watcher kun tapos na bumotos an ngatanan na botante na assigned hiton na presinto. Pwede picturan/videohan an counting of votes, transmission and printing of election returns, and scanning of voter receipts.

For more information, please read the infographics below.

KNOW YOUR RIGHTS! VOTE WISELY!

05/05/2025

The (SC) has reiterated that courts are not bound by parental custody agreements when these do not serve the child’s best interest.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC’s Second Division granted the petition filed by Jeffrey Rosacay Empuerto and his parents challenging a Court of Appeals ruling which upheld the validity of a compromise agreement between Jeffrey and Sheena Cabrillos, the mother of his child.

The SC sent the case back to the Family Court for determination of parental custody. It also gave custody to petitioners Jeffrey and his parents, who have actual care of the child, while the case remains pending.

Jeffrey and Sheena had a child in 2013. The couple eventually separated, with Sheena moving with their child to her parents’ home, and with Jeffrey exercising custody over the latter during long vacations.

In 2020, the child’s visit to Jeffrey was extended due to the COVID-19 lockdown, with Jeffrey refusing to return the child to Sheena even after restrictions were lifted. Sheena thus filed a complaint with the police and a petition for the issuance of a writ of habeas corpus with the Family Court.

The Family Court issued the writ and terminated the case. It adopted in an order the agreement between Jeffrey and Sheena that the latter would have custody of the child by July 2021. The Court of Appeals upheld this agreement as a provisional custody arrangement.

Petitioners then argued before the SC that the mere agreement between the parents before trial cannot determine the issue of a child’s custody.

Ruling in petitioners’ favor, the SC stressed that a petition for habeas corpus in custody cases is meant to determine who has rightful custody, not merely to secure a child’s appearance in court.

Trial courts must consider the totality of circumstances and grant custody only if:

- the petitioner has a legal right to custody;
- the child is being kept from them by the other party; and
- being with the petitioner is in the best interest of the child.

In this case, the SC found that the Family Court failed to evaluate these factors, relying solely on the parents’ agreement without conducting a case study or assessing parental fitness. It added that compromise agreements between parents as to a child’s custody are frowned upon. Courts should not simply approve custody agreements but must ensure that the child’s rights and welfare are protected.

Read the full text of the Press Release at https://tinyurl.com/3p6v2cc2.

Read the full text of the Decision at https://tinyurl.com/52yna5zv.

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