Prada Röck & Associates Law Office

28/04/2026

𝗕𝗜𝗥 𝗖𝗟𝗔𝗥𝗜𝗙𝗜𝗘𝗦 𝗥𝗨𝗟𝗘𝗦 𝗢𝗡 𝗣𝗥𝗢𝗢𝗙 𝗢𝗙 𝗦𝗘𝗧𝗧𝗟𝗘𝗠𝗘𝗡𝗧, 𝗜𝗡𝗦𝗧𝗔𝗟𝗟𝗠𝗘𝗡𝗧 𝗣𝗔𝗬𝗠𝗘𝗡𝗧𝗦 𝗙𝗢𝗥 𝗔𝗩𝗔𝗜𝗟𝗠𝗘𝗡𝗧𝗦 𝗢𝗙 𝗘𝗦𝗧𝗔𝗧𝗘 𝗧𝗔𝗫 𝗔𝗠𝗡𝗘𝗦𝗧𝗬

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 33-2026 to clarify specific rules on filing and payment of estate tax under the Estate Tax Amnesty.

The Circular, posted on April 27, 2026, provides guidance on the submission of proof of settlement, treatment of undeclared estate properties, and installment payment arrangements for taxpayers who availed of the Estate Tax Amnesty.

On the submission of proof of estate settlement, the Circular states:

“There is no deadline to submit the proof of settlement of estate. Non-submission of such proof on or before the June 16, 2025 deadline for availing the Estate Tax Amnesty does not invalidate the application. However, it is important to note that the proof of settlement is required for the processing and issuance of the eCAR, which is necessary for the transfer of the estate’s assets.”

The Circular also addresses cases where additional estate properties are discovered after the filing of the Estate Tax Amnesty Return. It clarifies that properties not included in the original return are not covered by the Estate Tax Amnesty and shall be taxed under the applicable estate tax laws in effect at the time of the decedent’s death.

RMC No. 33-2026 further provides that installment payment may be allowed, subject to prior approval of the concerned Revenue District Officer. Payment may be made within two years from the statutory date of payment, without civil penalties and interest, provided that the first installment was paid on or before June 16, 2025.

Failure to pay any installment on time will result in the forfeiture of the amnesty availment. The estate will then be subject to the applicable estate tax laws at the time of the decedent’s death, including corresponding penalties.

“This Circular is meant to remove confusion for taxpayers who already availed of the Estate Tax Amnesty before the deadline and are now completing the settlement and transfer of estate properties,” Commissioner Charlito Martin R. Mendoza said.

22/04/2026

📍Find us at the Second Floor of R&E Space.

R&E SPACE

5.0 ⭐ · Coffee shop

12/04/2026

𝐇𝐎𝐖 𝐌𝐎𝐃𝐄𝐑𝐍 𝐏𝐇𝐈𝐒𝐇𝐈𝐍𝐆 𝐖𝐎𝐑𝐊𝐒

Scammers now use fake bank websites that secretly connect to your real bank account while you are logging in.

Here’s how it works in simple terms:

🔍 How the Scam Happens
1️⃣ Fake Website
You enter your username, password, and the first OTP (one-time password) on a fake site that looks like your bank.
2️⃣ Secret Relay
The scammer uses that OTP right away to log in to your real bank account.
3️⃣ Money Transfer
The scammer starts transferring money, which triggers another OTP.
4️⃣ Final Step
You enter the second OTP on the fake site — and the scammer uses it to complete the transfer and steal your money.

🛡️ How to Protect Yourself
✅ Always check the website link carefully before logging in.
✅ Do not click links from texts or emails.
✅ Do not panic if you see urgent warnings. Call your bank using their official phone number.
✅ Never share your OTP with anyone. Your bank will NEVER ask for your OTP.

📢 Remember:
If someone keeps asking for your OTP — STOP immediately.



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12/04/2026

Sexual assault survivors can now genetically identify perpetrators with a r**e kit developed by researchers from the University of the Philippines.

The kit contains the tools needed for health professionals to collect samples that can be used as admissible evidence in court. Apart from the tools, the kit also has forms that document patient narratives, consent, details of samples collected, and the chain of custody. This ensures that the integrity and validity of the sample will hold up in court.

In order to effectively collect evidence, patients are advised to visit a healthcare facility within 72 hours, as this is the timeframe for biological evidence to remain in the body.

University Research Associate Frederick Delfin started developing the kit in 2003, with the goal of genetically identifying the assaulter. Later, Dr. Maria Corazon A. De Ungria and her team continued to develop a prototype of a sexual assault investigation kit (SAIK).

It was only this year, after decades of testing, validating, and researching, that a more refined version of the kit is now available for public use. It is now rebranded as the SAI.Kit, which will be commercially released in partnership with Manila Healthtek Inc this year.

Report by Alyana Fabella

08/04/2026

Nakakaiyak talaga ma-wrong send… ng pera.😢📱

Narito ang puwede mong gawin kung aksidenteng nakapagpadala sa maling GCash number, kahit i-block ka pa ng nakatanggap ng pera.

Link to article in the comment section.

07/04/2026

Sending money to the wrong account can be costly, as digital payments are now faster and harder to reverse. While fund transfers through banks and e-wallets are processed in real time, regulators have released steps consumers can take to try to recover their money.

For the Bangko Sentral ng Pilipinas (BSP), users must immediately report erroneous transfers or disputed transactions to their bank or e-wallet provider as prompt action can improve the chances of tracing the transactions and recovering the funds.

Read the full story: https://www.gmanetwork.com/news/money/personalfinance/982807/money-sent-to-wrong-account-here-s-what-the-bsp-says/story/

07/04/2026

📰 Real Estate News: Cebu Property Values Set for “Reset” Ahead of 2027 Market Update

Property owners in Cebu may soon experience a major shift in real estate valuations as the province prepares to implement a new Schedule of Market Values (SMV).

This updated valuation, expected to take effect in 2027, will serve as the basis for computing real property taxes starting 2028.

The initiative aims to create a more uniform and transparent system in determining the value of land, buildings, and other improvements across Cebu.

According to the Provincial Assessor’s Office, the revised figures are backed by extensive studies to ensure that property values remain fair and reflective of current market conditions.

Under the proposal, property values will vary depending on location and classification, with highly urbanized and rapidly developing areas expected to command higher rates.

Meanwhile, more rural municipalities may see significantly lower base values compared to growth areas near Metro Cebu.

The move is seen as a step toward improving transparency in property assessment, which directly impacts taxation and investment decisions.

As Cebu’s real estate market continues to evolve, this “reset” could reshape how both buyers and investors evaluate property opportunities in the coming years.

Source: PhilStar/The Freeman (link on the comment section)

24/03/2026

KINAHANGLAN NA ANG ONLINE APPOINTMENT

LOOK: Starting Monday, March 23, clients in Cebu must secure an online appointment before proceeding to National ID registration sites, according to Philippine Statistics Authority (PSA) in Central Visayas.

Bookings can be made through the official website or via QR code. via Airam Limatog

📷 : PSA-7

24/03/2026

22/03/2026

Sandiganbayan Associate Justice Maria Theresa V. Mendoza-Arcega, who serves as Vice President of the International Association of Women Judges, discusses the application of Republic Act No. 9262 or the Anti-Violence Against Women and Their Children Act in le***an relationships in Episode 110: Does RA 9262 (Anti-Violence Against Women and Their Children Act) Extend to Le***an Relationships?

What is Republic Act No. 9262? Why was there a need for the Anti-VAWC Act, and what purpose does it serve? Which acts are considered abuse?

This week's podcast is available on Spotify, Apple Podcasts, YouTube, Facebook, and the website.

Spotify: https://open.spotify.com/episode/3t0HyurCfKb0fqGPOY82tx?si=jI1XEQ4ZQNqmVtvETeYIaQ

Apple Podcasts: https://podcasts.apple.com/ph/podcast/supreme-court-ph-podcast/id1852172756?i=1000756283334

YouTube: https://youtu.be/rvQvwHtH8Wo

Facebook: https://www.facebook.com/share/v/1CWPuvqbje/

SC website: http://sc.judiciary.gov.ph/podcasts/

19/03/2026

THREATENING, HUMILIATING MESSAGES CONSTITUTE HARASSMENT UNDER ANTI-VAWC LAW—SUPREME COURT

The Supreme Court (SC) ruled that sending humiliating text messages is harassment that constitutes psychological violence under the Anti-Violence Against Women and Their Children Act, or Republic Act 9262.

In a 15-page ruling authored by Associate Justice Ricardo Rosario, the SC's First Division affirmed the conviction of the accused Janito Sedenio, who sent a barrage of “humiliating and threatening” text messages to his former partner, for psychological violence under Section 5(h)(5) of RA 9262.

The case began in 2009 when Sedenio met the complainant. They eventually entered into a clandestine relationship because both were married to others. The couple managed a sugarcane plantation while the accused helped pay for the woman’s home.

In 2011, Sedenio discovered that the woman was having an affair with another man. The two eventually broke up. However, between February and August 2012, the accused began sending derogatory name-calling text messages, death threats against the woman and her mother, threats to burn the belongings of her new partner, and threats to expose their intimate photographs.

This prompted the woman to file a complaint against Sedenio. During the trial, the accused admitted to sending the messages, claiming he was “hurt” and “drunk” when he sent them.

In proving psychological violence, the woman testified that because of the text messages, she “experienced mental anguish, sleepless nights, and besmirched reputation.” She said she thinks her neighbors are laughing behind her back.

The Regional Trial Court (RTC) convicted the accused, prompting him to elevate the case before the Court of Appeals arguing that there was no proof that his messages caused mental anguish to his former partner because there was no psychological or medical report.

He added that the excerpts from the messages presented in court were handwritten and that the mobile phone involved was not admitted into evidence. But the appellate court did not give credence to his defense and affirmed the decision of the RTC.

The high court agreed with the ruling of the CA and RTC, saying Sedenio himself admitted sending hurtful messages to the woman. It emphasized that emotional pain or intoxication does not grant a person the right to harass a wife, partner, or former lover.

“Under Rule 129, Section 4 of the Rules of Court, a judicial admission cannot be contradicted unless made through palpable mistake or not actually made — neither of which [the accused] demonstrated,” the SC said.

It cited the leading case of Araza vs. People, which provides that "the victim’s credible testimony alone, without expert psychological evaluation, suffices to prove substantial emotional or psychological distress."

The highest bench meted out the penalty of up to 8 years and 1 day in prison and a fine and moral damages of P400,000 against Sedenio.

25/02/2026

❗️

The (SC) has reiterated that search made after a lawful arrest extends to the surroundings within the immediate control of the accused and evidence obtained during such search is admissible even if they are not within the “plain view” of the arresting officers.

In a Decision penned by Associate Justice Ricardo R. Rosario, the SC’s First Division upheld the conviction of Jeryl Bautista for illegal possession of dangerous drugs under Republic Act No. 9165, or the 𝘊𝘰𝘮𝘱𝘳𝘦𝘩𝘦𝘯𝘴𝘪𝘷𝘦 𝘋𝘢𝘯𝘨𝘦𝘳𝘰𝘶𝘴 𝘋𝘳𝘶𝘨𝘴 𝘈𝘤𝘵 𝘰𝘧 2002, as amended.

During a buy-bust operation, a police officer posed as a buyer and received from Bautista 𝘴𝘩𝘢𝘣𝘶 in exchange for PHP 500. After the officer made a pre-arranged signal, the rest of the arresting team rushed to the place of the transaction.

Bautista was arrested and a representative from the Department of Justice, and two barangay kagawads arrived shortly after.

Subsequently, the officer searched Bautista and found three more sachets of suspected 𝘴𝘩𝘢𝘣𝘶 hidden inside a cellphone charger. The officer also found a cellphone, screwdriver, weighing scale, and marked money. The police then marked the four sachets, prepared an inventory of the seized items, and took photographs.

Bautista argued that the additional sachets should not be admitted as evidence because they were not within the plain view of the police officers when seized during his arrest.

The Regional Trial Court and the Court of Appeals both convicted Bautista of illegal possession of 𝘴𝘩𝘢𝘣𝘶.

The SC upheld Bautista’s conviction and rejected his argument. It explained that the plain view doctrine is not the only justification for a warrantless search, as the search could be done to a person who has just been lawfully arrested.

Searches and seizures generally require a warrant. If police perform a search or seize property without a valid warrant, any evidence obtained cannot be used in court and is considered inadmissible. However, there are recognized exceptions to this rule.

One of these is the plain view doctrine, which allows police officers to seize evidence in plain sight when: (1) the officer has a lawful reason to be in the place where the item is seen, (2) the discovery of the item is unplanned or incidental, and (3) it is immediately obvious that the item is connected to a crime or is illegal.

Another recognized exception is a warrantless search incident to a lawful arrest. To be valid, it must meet these conditions: (1) the accused is lawfully arrested, (2) the arresting officers subsequently made a warrantless search, (3) the search is limited to the person of the accused and the area within the accused’s immediate control, and (4) the search is performed at the place of the arrest.

In this case, Bautista was arrested during a buy-bust operation. He was frisked as part of the arrest. While the sachets hidden inside his cellphone charger were not in the officers’ plain view, the SC held that the warrantless search remained valid because it was done as part of a lawful arrest and the search extended to those that are within the immediate control of the accused at the time of the arrest.

To convict a person of illegal possession of dangerous drugs, the prosecution must prove that the accused had the drug, that the possession was not authorized by law, and that it was done knowingly and freely.

The SC found that all these elements were present. The search revealed three additional sachets of 𝘴𝘩𝘢𝘣𝘶 hidden inside a cellphone charger. Bautista could not explain why he had the drugs nor show any authority allowing him to possess them. His act of hiding the sachets inside the charger also showed his intent to keep them.

Bautista was sentenced to a maximum of 16 years in prison and ordered to pay a fine of PHP 300,000.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=161226

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=161221

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