Atty. Francis Melville Villarin Tinio

26/02/2026

22/02/2026

ACQUITTAL VIA DEMURRER TO EVIDENCE IS FINAL AND UNAPPEALABLE—SUPREME COURT

The Supreme Court (SC) held that a judgment of acquittal via demurrer to evidence is final, unappealable, and immediately executory, noting that the State cannot appeal the same as it would violate the right of the accused against double jeopardy.

In a 10-page decision penned by Associate Justice Maria Filomena Singh, the SC's Third Division has affirmed the decision of the Metropolitan Trial Court (MeTC) granting the demurrer to evidence in favor of Dr. Jovith Royales, effectively dismissing the falsification of private document charges filed against him by Marilao Medical and Diagnostic Inc.

Dr. Royales is the owner of Best Care, a clinic not authorized to issue Reverse Transcription Polymerase Chain Reaction (RT-PCR) tests. The Marilao Medical and Diagnostic Inc. alleged that Dr. Royales falsely used its name to process and issue RT-PCR test results.

After the prosecution presented its evidence, Dr. Royales filed a demurrer to evidence. The Metropolitan Trial Court (MeTC) granted the demurrer and acquitted Dr. Royales. The MeTC found that the prosecution witnesses failed to identify the alleged falsified documents or prove that Dr. Royales ordered the falsification. While a scheme may have existed, there was no evidence directly linking Dr. Royales to it.

Marilao Medical filed a Petition for Certiorari (Rule 65) with the Regional Trial Court (RTC) assailing the acquittal. Notably, Marilao Medical obtained the conformity of the Office of the City Prosecutor (OCP) for this petition, but not the Office of the Solicitor General (OSG).

The RTC dismissed the petition. It ruled that the OCP’s conformity was insufficient because the criminal aspect of the case must be prosecuted on behalf of the State, and the RTC believed the OSG was the proper party to represent the State in such actions. This prompted Mqrilap Medical to file a direct recourse before the Supreme Court.

In affirming the MeTC’s acquittal of Dr. Royales, it noted that a judgment of acquittal is final and unappealable to protect the accused against double jeopardy. The only exception is a Rule 65 petition showing grave abuse of discretion—meaning the court acted in a capricious, whimsical, or arbitrary manner amounting to a denial of due process.

It noted that the MeTC correctly found that the prosecution failed to prove Dr. Royales' authorship or possession of the falsified documents. Being an officer/owner of the company (Best Care) does not create a presumption of authorship of falsified documents without evidence of actual possession or specific orders to falsify.

The SC also rejected Marilao Medical's assertion invoking presumption of authorship, which allows Dr. Royales, being the owner of Best Care, to possess and benefit from the documents. It noted that the presumption of authorship against a person in possession of a falsified document does not automatically apply to an officer of a company simply because the company produced the document.

Meanwhile, as to the procedural aspect, the SC held that the RTC erred in denying due course to the petition for certiorari on the ground that it bore the conformity of the City Prosecutor instead of the Solicitor General. It underscored that when a case is filed or pending in the RTC, including a Rule 65 petition, it is the provincial or city prosecutor, not the Solicitor General, who represents the state.

"Since Marilao Medical’s petition was filed before the RTC and had the express conformity of the Office of the City Prosecutor (OCP), the requirement for state representation was satisfied," the Supreme Court said.

10/02/2026

The (SC) has ruled that same-sex couples who live together may be recognized as co-owners of property under Article 148 of the 𝘍𝘢𝘮𝘪𝘭𝘺 𝘊𝘰𝘥𝘦, provided there is proof of actual contribution.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC’s Second Division granted a woman’s complaint for partition of property and recognized her as a co-owner of the house and lot she shared with her same-sex partner.

Article 148 of the 𝘍𝘢𝘮𝘪𝘭𝘺 𝘊𝘰𝘥𝘦 governs the property relations of couples who are living together but cannot legally marry, acknowledging co-ownership based on their actual contributions.

The two women lived together as a couple. A year into their relationship, they purchased a house and lot, and agreed to register the property in one partner’s name to facilitate banking transactions.

Upon separation, they agreed to sell the property and divide the proceeds equally. One partner signed an 𝘈𝘤𝘬𝘯𝘰𝘸𝘭𝘦𝘥𝘨𝘮𝘦𝘯𝘵 stating that the other had paid about 50% of the purchase and renovation costs.

However, she later refused to sell the property and denied that her former partner was a co-owner.

To protect her interest, the former partner annotated an adverse claim on the title and demanded partition of the property. When this failed, she filed a case for partition of real estate and damages, relying on the 𝘈𝘤𝘬𝘯𝘰𝘸𝘭𝘦𝘥𝘨𝘮𝘦𝘯𝘵 as proof of co-ownership.

The SC granted the complaint for partition of real estate, as it clarified the provisions in the 𝘍𝘢𝘮𝘪𝘭𝘺 𝘊𝘰𝘥𝘦 governing the property relations of unmarried couples living together.

Article 147 applies to unmarried couples who may legally marry. Property acquired during their cohabitation is presumed jointly owned.

Article 148, on the other hand, applies to couples who are not permitted to marry. Only properties obtained through actual contribution are considered common property.

Since the 𝘍𝘢𝘮𝘪𝘭𝘺 𝘊𝘰𝘥𝘦 only allows marriage between a man and a woman, the SC held that same-sex couples necessarily fall under Article 148.

Here, the SC found that the signed 𝘈𝘤𝘬𝘯𝘰𝘸𝘭𝘦𝘥𝘨𝘮𝘦𝘯𝘵, where one partner admitted that the other paid about half of the property costs, was a binding admission and sufficient proof of actual contribution. This established co-ownership.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=160462.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=160431.

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=160444.

Read the Concurrence of Associate Justice Amy C. Lazaro-Javier at https://sc.judiciary.gov.ph/?p=160439.

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

06/02/2026

DID YOU KNOW? When a Spouse Abandons the Conjugal Home, the Court May Grant Sole Administration of Marital Property |

“If a spouse without just cause abandons the other or fails to comply with his or her obligations to the family, the aggrieved spouse may petition the court for receivership, for judicial separation of property or for authority to be the sole administrator of the absolute community…” -Supreme Court

Read more in the comment section.

04/02/2026

The (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session on February 4, 2026, dismissed the petition filed by Jacinto V. Paras et al., questioning the constitutionality of Executive Order No. (EO) 94, Series of 2025, which created the Independent Commission for Infrastructure (ICI).

In a Resolution written by Associate Justice Samuel H. Gaerlan, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 ruled that the petition failed to meet the basic requirements for judicial review.

The ICI was created as an independent ad hoc fact-finding body to investigate alleged anomalies in government flood control projects nationwide.

The petitioners argued that EO 94 violates the equal protection clause, usurps the legislative power of Congress, reduces or takes away the powers and functions vested in the Office of the Ombudsman and the Commission on Audit by the Constitution, and violates the Constitutional provision that no money shall be paid out of the Treasury except in pursuance of an appropriation made by law.

The SC ruled that the petition violated the hierarchy of courts doctrine because it was filed directly with the SC. While direct recourse it is allowed in exceptional cases, the petition failed to cite any compelling reason to bypass the lower courts.

The SC also found that the petitioners did not show that an actual case or controversy exists, which requires a violation of a legally enforceable right. The petition did not show that their rights were violated, or that EO 94 adversely affected them.

The full text of the Resolution will be uploaded to the SC website once available.

Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=160242

Copying of this content is subject to the Supreme Court Public Information Office’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

04/02/2026

The Supreme Court (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤 has approved the 𝘈𝘮𝘦𝘯𝘥𝘮𝘦𝘯𝘵𝘴 𝘵𝘰 𝘵𝘩𝘦 𝘎𝘶𝘪𝘥𝘦𝘭𝘪𝘯𝘦𝘴 𝘰𝘯 𝘵𝘩𝘦 𝘊𝘰𝘯𝘥𝘶𝘤𝘵 𝘰𝘧 𝘝𝘪𝘥𝘦𝘰𝘤𝘰𝘯𝘧𝘦𝘳𝘦𝘯𝘤𝘪𝘯𝘨, further strengthening the rules on virtual court hearings and remote appearances of parties and witnesses.

In a Resolution dated November 4, 2025, in A.M. No. 24-11-02-SC, the SC introduced key reforms to expand access to videoconferencing, particularly for digitally disadvantaged individuals, and to enable wider participation by individuals abroad.

The 𝘈𝘮𝘦𝘯𝘥𝘦𝘥 𝘎𝘶𝘪𝘥𝘦𝘭𝘪𝘯𝘦𝘴 apply to videoconferencing before first- and second-level courts, the Court of Appeals, the Sandiganbayan, and the Court of Tax Appeals. It covers all actions and proceedings at any stage, including mediation, consultation, deliberation, and the promulgation of decisions and resolutions, when conducted through videoconference.

Courts are now directed to ensure access to videoconferencing for individuals who are digitally disadvantaged, including those in geographically or geopolitically marginalized areas. This may include deploying court personnel to provide temporary or mobile internet access.

Courts may also establish designated “access points” within judicial regions where litigants, witnesses, and other participants can use computers and videoconferencing equipment under court supervision.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=160150.

Read the full text of the 𝘈𝘮𝘦𝘯𝘥𝘮𝘦𝘯𝘵𝘴 𝘵𝘰 𝘵𝘩𝘦 𝘎𝘶𝘪𝘥𝘦𝘭𝘪𝘯𝘦𝘴 𝘰𝘯 𝘵𝘩𝘦 𝘊𝘰𝘯𝘥𝘶𝘤𝘵 𝘰𝘧 𝘝𝘪𝘥𝘦𝘰𝘤𝘰𝘯𝘧𝘦𝘳𝘦𝘯𝘤𝘪𝘯𝘨 at https://sc.judiciary.gov.ph/wp-content/uploads/2026/01/A.M-No.-24-11-02-SC_FINAL.pdf.

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