AM LAW FIRM Philippines

21/08/2026

21/08/2026

Installing or updating the latest eBIRForms Offline Package v 7.9.6.1?

Here is a simple step-by-step guide! From downloading and installing the package to properly locating and renaming your eBIRProfiles folder when needed.

📥 Download the eBIRForms Offline Package v 7.9.6.1 here: https://bir-cdn.bir.gov.ph/BIR/pdf/Offline_eBIRForms_Package_v7.9.6.1_setup.zip
Read the complete Job Aid - eBIRForms installation guide here:https://bir-cdn.bir.gov.ph/BIR/pdf/eBIRForms_Package_Installation%20User%20Guide.pdf

For assistance, visit BIR Revenue District Office No. 23A - North Nueva Ecija or message our official page.

Mainam Kung Maalam!

30/07/2026

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-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

09/07/2026

HOW TO APPLY FOR CLOSURE AND/OR CANCELLATION OF BUSINESS REGISTRATION THROUGH THE TRRA PORTAL

Planning to close or cancel your business registration? Follow our step-by-step guide to complete your application through the Taxpayer Registration-Related Application (TRRA) Portal.

📌 This guide covers:
✅ Documentary Requirements
✅ Selecting the Frontline Service
✅ Choosing the correct Revenue District Office (RDO)
✅ Email Submission of Application
✅ Submission of Hard Copy Documents

📄 Download BIR Form No. 1905:
https://bir-cdn.bir.gov.ph/BIR/pdf/1905%20October%202025%20ENCS%20Final.pdf

💻 Access the TRRA Portal:
https://web-services.bir.gov.ph/trraportal/

For inquiries and assistance, you may contact:
📞 (045) 491-5697

03/07/2026

The (SC) has ruled that a husband and wife’s mutual desire to end their marriage, by itself, is not enough to prove collusion in a petition for declaration of nullity of marriage. A lack of objection is not the same as collusion.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division ruled that there was no collusion between the spouses in a petition to declare their marriage void. “Collusion” means that the spouses secretly agreed to fake or misrepresent facts in order to nullify their marriage.

The SC voided the marriage due to the husband’s psychological incapacity.

The wife filed the petition before the Regional Trial Court (RTC) alleging that her husband was unable to fulfill his marital duties because of continued physical, psychological, and economic abuse, which she said began even before their marriage.

When the husband did not file his answer to the petition, the RTC directed the Provincial Prosecutor to investigate possible collusion between the spouses. The Associate Provincial Prosecutor reported that there was no collusion.

During trial, the wife presented several witnesses while the husband presented none. He also did not oppose the petition.

Despite this, the RTC dismissed the case, ruling that the evidence did not sufficiently prove psychological incapacity.

The RTC pointed out that the husband’s father admitted discussing his testimony with his son, and that the husband was willing to have the marriage dissolved.

Explaining that collusion is a secret agreement to defraud or obtain something illegal, the SC noted that although the RTC observed suspicious circumstances, these did not clearly prove that the spouses conspired to fake grounds to nullify their marriage.

The SC emphasized that a mutual desire to end the marriage does not automatically mean collusion. A spouse’s agreement or lack of objection is not the same as a secret scheme to mislead the court.

Without proof that the spouses faked evidence or suppressed valid defenses, collusion cannot be established.

It added that the husband’s failure to file an answer or present evidence does not, by itself, prove collusion.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=168319.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165664.

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

26/06/2026

Sharing for the information of our clients and the public. We encourage eligible taxpayers to join this webinar and learn more about the Tax Amnesty Abatement and Penalty Relief Program recently release by the BIR. 📌

📢 Got unpaid tax penalties? This is your chance to start fresh!
Join our webinar on RR No. 4-2026: Tax Amnesty Abatement and Penalty Relief Program and learn how eligible taxpayers can avail of penalty relief, settle tax liabilities, and improve tax compliance.
🗓️ July 3, 2026 | ⏰ 10:00 AM

Register, learn, and take the next step toward compliance.

Meeting chat link: https://tinyurl.com/RDO23AAbatement

Meeting ID: 618 014 2899
Passcode: RDO23A

Mainam na ang maalam!

20/06/2026

𝗜𝗖𝗬𝗠𝗜: 𝗠𝗮𝘆 𝗻𝗲𝗴𝗼𝘀𝘆𝗼 𝗸𝗮 𝗯𝗮𝗻𝗴 𝘁𝘂𝗺𝗶𝗴𝗶𝗹 𝗻𝗮 𝘀𝗮 𝗼𝗽𝗲𝗿𝗮𝘀𝘆𝗼𝗻?

Mas pinasimple at mas streamlined na ang proseso ng Closure and/or Cancellation of Business Registration sa ilalim ng RMC No. 47-2026.
Tingnan ang step-by-step guide para malaman ang mga requirements, filing options, at proseso ng Tax Clearance.

Basahin ang buong Circular: https://tinyurl.com/BIRRMC47-2026

20/06/2026

The Government Procurement Policy Board (GPPB) has approved GPPB Resolution No. 10-2026, providing the 𝗱𝗼𝗰𝘂𝗺𝗲𝗻𝘁𝗮𝗿𝘆 𝗿𝗲𝗾𝘂𝗶𝗿𝗲𝗺𝗲𝗻𝘁𝘀 and relevant guidelines for specific modes of procurement under Republic Act No. 12009, or the New Government Procurement Act.

This issuance helps Procuring Entities identify the required documents and apply the appropriate procedures for specific modes of procurement under the NGPA and its IRR.

📌 Date of Approval: February 3, 2026
📌 Date Published: June 19, 2026
📌 Date of Effectivity: July 4, 2026

Access the full resolution here:
🔗https://www.gppb.gov.ph/wp-content/uploads/2026/06/Approved_GPPB-Resolution-No.-10-2026-Documentary-Requirements.pdf

28/03/2026

The SupremeCourtPH (SC) has clarified that a complaint or petition may only be dismissed for failure to state a cause of action after an examination of the complaint or information itself, together with its annexes—strictly excluding the pleadings or submissions of other parties, reconciling conflicting rulings on the issue.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division ruled that the lower courts erred in dismissing a petition for quieting of title for supposedly failing to state a cause of action and in interchanging this concept with “dismissal for lack of cause of action.”

A cause of action is the act or omission by which a party violates a right of another, the three elements of which are:

1. a right in favor of the plaintiff by whatever means and under whatever law it arises or is created;

2. an obligation on the part of the named defendant to respect or not to violate such right; and

3. an act or omission on the part of the named defendant violative of the right of the plaintiff or constituting a breach of the obligation of defendant to the plaintiff which the latter may maintain an action for recovery of damages.

The case arose from a land dispute between the groups of Inocencio Taganile and Filomena Delos Santos Dolar.

Taganile’s group claims that it has occupied a portion of land along Dr. Sixto Antonio Avenue in Rosario, Pasig City, since 1970. After learning that the land had been registered in the name of Dolar’s group, they filed a petition before the Regional Trial Court (RTC) to challenge the title.

Dolar’s group, on the other hand, claims that Taganile’s group were mere lessees. They filed a motion to dismiss the petition, arguing that it did not state a cause of action because it lacked supporting documents.

The RTC dismissed the case after considering both the petition and the evidence presented by Dolar’s group. It ruled that the petition failed to state a cause of action because it did not include proof of the Taganile’s group’s claim to the land. The Court of Appeals (CA) affirmed this ruling.

The SC disagreed. It clarified the difference between failure to state a cause of action and lack of cause of action.

A cause of action exists when a legal right is violated. Courts cannot hear a civil case unless there is a cause of action. A case may be dismissed if the complaint does not state one, or if the party later fails to prove it with evidence. These are different grounds.

To determine whether a complaint fails to state a cause of action, the court looks only at what is written in the complaint and assumes the allegations are true. If, even assuming those facts are true, the court still cannot grant the relief asked for, it can dismiss the complaint on this ground.

In contrast, to determine whether a case lacks a cause of action, the court looks at the evidence presented.

The SC noted that confusion arose from past rulings that allowed courts, in some instances, to look beyond the complaint, such as when the allegations appear to be legally impossible or unfounded. This blurred the difference between failure to state a cause of action and lack of cause of action.

To settle the issue, the SC ruled that courts may dismiss a complaint for failure to state a cause of action only by examining the complaint and its attachments—nothing more. Courts must not consider other pleadings or submissions at this stage.

The SC explained:

“Once the trial court considers other pleadings submitted by the parties or evidence admitted during the proceedings, it is no longer determining a failure to state a cause of action, but rather the very existence of one. In doing so, the ground for dismissing the complaint or petition ceases to be ‘failure to state a cause of action’ and becomes ‘lack of cause of action.’”

Applying this rule, the SC found that the RTC and CA improperly relied on the submissions and evidence of Dolar’s group. They prematurely ruled on the existence of a cause of action without giving Taganile’s group the chance to present evidence.

The SC also found that, based on the allegations alone, the petition was able to establish a case for quieting of title, noting Taganile group’s claims of long-standing possession and houses built on the property since the 1970s.

The SC directed that the case be returned to the RTC to continue the proceedings and receive evidence on the parties’ claims.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=162612

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=162606

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

07/01/2026

𝗖𝗼𝗻𝗴𝗿𝗮𝘁𝘂𝗹𝗮𝘁𝗶𝗼𝗻𝘀 𝘁𝗼 𝗼𝘂𝗿 𝗻𝗲𝘄 𝗣𝗮𝗻𝘆𝗲𝗿𝗼𝘀 𝗮𝗻𝗱 𝗣𝗮𝗻𝘆𝗲𝗿𝗮𝘀!

𝗧𝗼 𝗚𝗢𝗗 𝗯𝗲 𝘁𝗵𝗲 𝗴𝗹𝗼𝗿𝘆!

- List of Successful Examinees