GAD Law Firm

20/05/2026

⚖️ 𝐆𝐀𝐃 𝐋𝐀𝐖 𝐈𝐍 𝐀𝐂𝐓𝐈𝐎𝐍

Earlier today, Atty. Gordon attended a Preliminary Investigation at the Office of the City Prosecutor (OCP) Pasig in connection with a Human Trafficking case.

𝑂𝑢𝑟 𝑓𝑖𝑟𝑚 𝑟𝑒𝑚𝑎𝑖𝑛𝑠 𝑐𝑜𝑚𝑚𝑖𝑡𝑡𝑒𝑑 𝑖𝑛 𝑝𝑟𝑜𝑚𝑜𝑡𝑖𝑛𝑔 𝑗𝑢𝑠𝑡𝑖𝑐𝑒, 𝑝𝑟𝑜𝑡𝑒𝑐𝑡𝑖𝑛𝑔 𝑟𝑖𝑔ℎ𝑡𝑠, 𝑎𝑛𝑑 𝑝𝑟𝑜𝑣𝑖𝑑𝑖𝑛𝑔 𝑑𝑒𝑑𝑖𝑐𝑎𝑡𝑒𝑑 𝑙𝑒𝑔𝑎𝑙 𝑠𝑒𝑟𝑣𝑖𝑐𝑒𝑠 𝑡𝑜 𝑜𝑢𝑟 𝑐𝑙𝑖𝑒𝑛𝑡𝑠.

14/05/2026

Ang Hukuman ay nag-wika!

Naglabas ang ng isang Desisyon sa wikang Filipino, na layong gawing mas malapit sa mga mamamayan, mas nauunawaan at mas nakatuon sa mga pangangailangan ng publiko ang katarungan.

Sa Desisyon sa kasong Velarde at Macasaet v. Kagagalang-Galang na Hukuman ng Pag-aapela sa Buwis na isinulat ni Associate Justice Maria Filomena D. Singh, nagpasya ang Ikatlong Dibisyon ng Korte na isantabi ang petisyong inihain nina Mel V. Velarde at Angeline L. Macasaet dahil naging 𝘮𝘰𝘰𝘵 na o wala nang saysay ang usapin.

Kinuwestiyon sa petisyon ang mga naging pagdinig ng Hukuman ng Pag-aapela sa Buwis o Court of Tax Appeals (CTA) kaugnay ng kasong kriminal na 𝘵𝘢𝘹 𝘦𝘷𝘢𝘴𝘪𝘰𝘯 na nag-ugat umano sa sadyang pagdeklara ng mas mababang halaga ng transaksiyong may kinalaman sa ari-arian (𝘶𝘯𝘥𝘦𝘳𝘷𝘢𝘭𝘶𝘢𝘵𝘪𝘰𝘯 𝘰𝘧 𝘢 𝘱𝘳𝘰𝘱𝘦𝘳𝘵𝘺 𝘵𝘳𝘢𝘯𝘴𝘢𝘤𝘵𝘪𝘰𝘯).

Naging 𝘮𝘰𝘰𝘵 ang kaso nang pagbigyan ng Court of Tax Appeals ang 𝘮𝘰𝘵𝘪𝘰𝘯 𝘧𝘰𝘳 𝘳𝘦𝘤𝘰𝘯𝘴𝘪𝘥𝘦𝘳𝘢𝘵𝘪𝘰𝘯 ng mga petisyoner sa pagtanggi nito sa kanilang 𝘥𝘦𝘮𝘶𝘳𝘳𝘦𝘳 𝘵𝘰 𝘦𝘷𝘪𝘥𝘦𝘯𝘤𝘦. Ibig sabihin, tuluyan nang isinantabi ang kasong kriminal. Dahil dito, nagpasya ang Korte Suprema na wala nang natitirang aktuwal na kontobersiyang kailangang resolbahin at hindi rin ito isa sa mga eksepsiyon sa doktrina ng 𝘮𝘰𝘰𝘵𝘯𝘦𝘴𝘴.

Sa paggamit ng wikang Filipino, mas naipapaintindi ng Korte Suprema sa mga mamamayan ang pangangatwiran sa mga desisyon nito. Mas madali kasing maintindihan ng publiko kung nakasulat ito sa wikang Filipino, bilang isa sa mga opisyal na wika ng bansa at wikang malawak na nauunawaan ng nakararami.

Kapag ang batas ay naipahahayag sa wikang ginagamit ng mga mamamayan, nakatutulong itong patatagin ang tiwala ng publiko at iparamdam sa kanilang bahagi sila ng sistema. Higit sa lahat, natutugunan ang pangako ng Saligang Batas na ang katarungan ay dapat madaling maabot at mapakinabangan ng lahat.

Basahin ang buong press release sa https://sc.judiciary.gov.ph/supreme-court-uses-filipino-decision-to-advance-access-to-justice/

Basahin ang buong Desisyon sa https://sc.judiciary.gov.ph/210480-mel-v-velarde-at-angeline-l-macasaet-vs-kagalang-galang-na-hukuman-ng-pag-aapela-sa-buwis-et-al/

Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.

23/04/2026

Thus sayeth the Court!

The 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session today, April 22,2026, acted on G.R. No. E-05860 (𝘗𝘢𝘯𝘵𝘢𝘭𝘦𝘰𝘯 𝘋. 𝘈𝘭𝘷𝘢𝘳𝘦𝘻, 𝘝𝘪𝘳𝘨𝘪𝘭𝘪𝘰 𝘙. 𝘎𝘢𝘳𝘤𝘪𝘢, 𝘑𝘶𝘢𝘯 𝘊. 𝘙𝘢ñ𝘢, 𝘢𝘯𝘥 𝘙𝘢𝘺𝘮𝘶𝘯𝘥𝘰 𝘓. 𝘑𝘶𝘯𝘪𝘢 𝘷. 𝘍𝘦𝘳𝘥𝘪𝘯𝘢𝘯𝘥 𝘙. 𝘔𝘢𝘳𝘤𝘰𝘴, 𝘑𝘳., 𝘢𝘯𝘥 𝘙𝘢𝘭𝘱𝘩 𝘎. 𝘙𝘦𝘤𝘵𝘰, 𝘪𝘯 𝘩𝘪𝘴 𝘤𝘢𝘱𝘢𝘤𝘪𝘵𝘺 𝘢𝘴 𝘈𝘤𝘵𝘪𝘯𝘨 𝘌𝘹𝘦𝘤𝘶𝘵𝘪𝘷𝘦 𝘚𝘦𝘤𝘳𝘦𝘵𝘢𝘳𝘺) by directing the respondents to comment on the petition for writ of 𝘮𝘢𝘯𝘥𝘢𝘮𝘶𝘴 filed by Pantaleon D. Alvarez and his co-petitioners.

The petition seeks the issuance of a writ of 𝘮𝘢𝘯𝘥𝘢𝘮𝘶𝘴 directing the President to submit himself to physical and mental examination, including a hair follicle drug test.

The petition also seeks to direct the President to disclose and publish the medical report indicating the results of the examination, including medical and clinical confirmation of his physical and medical fitness to discharge the powers and duties of the Presidency.

Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=163942.

A copy of the available pleadings may be downloaded from the Current Cases section of the Supreme Court website at https://sc.judiciary.gov.ph/public-pleadings/.

23/04/2026

HOW THE SUPREME COURT JUSTICES VOTED ON THE PRESCRIPTIVE PERIOD FOR CYBER LIBEL

G.R. No. 258524 (Berteni Cataluña Causing vs. People of the Philippines, et al.)

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.

The SC, by an 8-7 vote, held that the prescriptive period for cyber libel is governed by the same provision under the Revised Penal Code on written libel.

In this , see how the Justices voted 8-7 in favor of declaring a one-year prescriptive period for cyber libel.

For more, read the press release and full text of the Decision, and the opinions of the Justices:

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 Opinion 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

20/04/2026

Thus sayeth the Court!

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

17/04/2026

Thus sayeth the Court!

The (SC) has ruled that sounds incident to the operation of an educational institution, those arising from a school’s regular activities, are not considered a nuisance and cannot make the school liable for damages.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division granted the petition of Couples for Christ School of the Morning Star (School) and reversed the Court of Appeals’ (CA) ruling that awarded damages to residents of Saint Joseph Subdivision in Barangay Villa Kananga, Butuan City, where the school is located.

Wideline I. Malonda and others, who are residents of the Subdivision, claimed they were often exposed to loud noises from the School, such as drums and bugles being played, teachers speaking through microphones and megaphones, and students running, cheering and shouting during games played at the multipurpose center.

The residents claimed that these sounds, heard day and night, disturbed their sleep and peace at home.

In its defense, the School said it has been operating since 2012 with the necessary permits and clearances and that any noise comes only from regular classes. It added that the City Environment and Natural Resources Office conducted a test and found the noise to be within the allowed limits for residential areas. The School also claimed it took steps to reduce noise, such as building higher fences, planting trees, using small speakers, and limiting activities to 7:00 a.m. to 7:00 p.m. on weekdays.

The Regional Trial Court (RTC) dismissed the residents’ complaint, ruling that they failed to prove they were harmed by the noise. The RTC also found that the School did not intend to harm the residents and acted in good faith by taking steps to reduce the noise.

On appeal, the CA ruled in the residents’ favor, holding that the School’s noise, which came not only from classes but also from other social functions in the multi-purpose hall, was a nuisance that caused discomfort and annoyance to the residents.

The SC overturned the CA’s ruling. It held that academic noise, or sounds from legitimate school activities, is not a nuisance.

Nuisance includes any disturbance that interferes with a person, property or comfort and enjoyment of all citizens. The SC ruled that the determination of whether a noise is a nuisance requires more than just considering the location, environment, and its effect on residents.

Thus, for noise to be considered nuisance, the SC considered in the 𝘍𝘳𝘢𝘣𝘦𝘭𝘭𝘦 𝘗𝘳𝘰𝘱𝘦𝘳𝘵𝘪𝘦𝘴 𝘊𝘰𝘳𝘱. 𝘷. 𝘈𝘊 𝘌𝘯𝘵𝘦𝘳𝘱𝘳𝘪𝘴𝘦𝘴 𝘐𝘯𝘤. the:

1. reliability of the noise pollution tests conducted,
2. introduction by the defendant of measures or improvements to mitigate the noise,
3. allowable noise levels,
4. defendant’s intention (or lack thereof) to cause harm to the plaintiff,
5. number of complaining witnesses,
6. representativeness of the plaintiff, and
7. actions of the plaintiff to alleviate his or her plight.

Adopting the framework, the SC finds that the sounds emanating from the School arose from its ordinary operations as an educational institution, and that the respondents are hardly representative of the community.

The SC also ruled that the residents failed to prove that the noise was unreasonably disturbing and that it worsened their health conditions. The residents’ statements showed only minor discomforts, not serious harm.

The SC added that while location and environment are important in determining a nuisance, they must be weighed against whether the noise is normally expected from the activity involved. Here, the sounds complained of did not go beyond what could be reasonably expected from a school.

The SC emphasized that there is no nuisance if an ordinary person would not find the sound disturbing, even if someone else is unusually sensitive to it.

The SC explained:

“𝘓𝘪𝘷𝘪𝘯𝘨 𝘪𝘯 𝘢 𝘥𝘦𝘯𝘴𝘦𝘭𝘺 𝘱𝘰𝘱𝘶𝘭𝘢𝘵𝘦𝘥 𝘤𝘰𝘶𝘯𝘵𝘳𝘺 𝘴𝘶𝘤𝘩 𝘢𝘴 𝘵𝘩𝘦 𝘗𝘩𝘪𝘭𝘪𝘱𝘱𝘪𝘯𝘦𝘴, 𝘸𝘩𝘦𝘳𝘦 𝘩𝘰𝘶𝘴𝘦𝘴 𝘢𝘯𝘥 𝘣𝘶𝘴𝘪𝘯𝘦𝘴𝘴𝘦𝘴 𝘢𝘳𝘦 𝘴𝘪𝘵𝘶𝘢𝘵𝘦𝘥 𝘪𝘯 𝘤𝘭𝘰𝘴𝘦 𝘱𝘳𝘰𝘹𝘪𝘮𝘪𝘵𝘺, 𝘢𝘮𝘱𝘭𝘪𝘧𝘪𝘦𝘴 𝘱𝘦𝘰𝘱𝘭𝘦’𝘴 𝘴𝘦𝘯𝘴𝘪𝘵𝘪𝘷𝘪𝘵𝘺 𝘵𝘰 𝘯𝘰𝘪𝘴𝘦. 𝘏𝘰𝘸𝘦𝘷𝘦𝘳, 𝘯𝘰𝘵 𝘢𝘭𝘭 𝘬𝘪𝘯𝘥𝘴 𝘰𝘳 𝘭𝘦𝘷𝘦𝘭𝘴 𝘰𝘧 𝘯𝘰𝘪𝘴𝘦 𝘢𝘳𝘦 𝘢𝘤𝘵𝘪𝘰𝘯𝘢𝘣𝘭𝘦. 𝘗𝘢𝘳𝘵𝘪𝘤𝘶𝘭𝘢𝘳𝘭𝘺, 𝘵𝘩𝘦 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦 𝘳𝘦𝘨𝘢𝘳𝘥𝘴 𝘯𝘰𝘪𝘴𝘦 𝘢𝘴 𝘢 𝘯𝘶𝘪𝘴𝘢𝘯𝘤𝘦 𝘰𝘯𝘭𝘺 𝘸𝘩𝘦𝘯 𝘪𝘵 𝘳𝘦𝘢𝘤𝘩𝘦𝘴 𝘢𝘯 𝘪𝘯𝘵𝘦𝘯𝘴𝘪𝘵𝘺 𝘵𝘩𝘢𝘵 𝘪𝘯𝘫𝘶𝘳𝘦𝘴 𝘰𝘳 𝘦𝘯𝘥𝘢𝘯𝘨𝘦𝘳𝘴 𝘵𝘩𝘦 𝘩𝘦𝘢𝘭𝘵𝘩 𝘰𝘳 𝘴𝘢𝘧𝘦𝘵𝘺 𝘰𝘧 𝘰𝘵𝘩𝘦𝘳𝘴, 𝘰𝘳 𝘢𝘯𝘯𝘰𝘺𝘴 𝘰𝘳 𝘰𝘧𝘧𝘦𝘯𝘥𝘴 𝘵𝘩𝘦 𝘴𝘦𝘯𝘴𝘦𝘴.”

The SC also denied the claim for damages since the School did not intend to harm or annoy the residents and had taken steps to reduce the noise. There was no evidence that the school caused the noise willfully, with malice or bad faith.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=163502

Read the full text of the Decision https://sc.judiciary.gov.ph/?p=163486

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/278875-formerly-udk-no-18061-concurring-opinion-justice-alfredo-benjamin-s-caguioa/

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

16/04/2026

IS THERE A CRIME OF ROBBERY WITH MURDER?

I got several queries about this photo. This is a mug shot of a suspect who was allegedly caught and booked for the crime of "robbery with murder." The senders were asking if the caption on the mugshot is correct. In other words, they were asking if there is a crime of "robbery with murder."

The answer is in the negative.

In 1993, Congress passed RA 7659 (or the Death Penalty law) amending certain provisions of the RPC. At the same time, it introduced several crimes called "special complex crimes." Among the special complex crimes introduced by the said law is robbery with homicide under Article 294 (robbery with violence against, or intimidation of, person) of the RPC.

There is robbery with homicide when by reason or on the occasion of the robbery, homicide is committed. By jurisprudence, homicide is said to be committed by reason or in the occasion of robbery if it was committed to facilitate the robbery or the escape of the robber, to preserve the possession of the loot, to prevent discovery of the robbery, or to eliminate witnesses.

In this crime, homicide is to be understood in its generic sense - meaning, the killing is always denominated as homicide regardless of the circumstances, manner and relationship of the offender to the victim. For purposes of robbery with homicide, the word "homicide" includes murder, parricide and infanticide.

Moreover, the killing cannot be qualified by treachery. It is well-settled that treachery applies only in crimes against persons. It must be borne in mind that robbery with homicide is a crime against property. Treachery, however, is considered merely as generic aggravating circumstance.
(Photo not mine)

12/04/2026

Thus sayeth the Court!

The (SC) En Banc, during its session on Wednesday, April 8, 2026, through the ponencia of Associate Justice Antonio T. Kho, Jr, denied the petition for certiorari filed by Merson C. Calubag (Calubag), which challenged the Commission on Elections’ (COMELEC) Resolutions canceling his Certificate of Candidacy (COC) for Sangguniang Kabataan Chairperson of Barangay Magtangale, San Francisco, Surigao del Norte, during the 2023 Barangay and Sangguniang Kabataan Elections.

The COMELEC found that Calubag falsely stated a material fact in his COC when he declared he was not related within the second civil degree of consanguinity or affinity to any incumbent Sangguniang Barangay member of Barangay Magtangale, despite his mother being a member.

Section 10, or the “Anti-Dynasty clause” of Republic Act No. (RA) 10742 (Sangguniang Kabataan Reform Act of 2015) requires that a candidate for the position in the Sangguniang Kabataan must not be related within the second civil degree of consanguinity or affinity to any incumbent elected national office, or to any incumbent elected regional, provincial, city, municipal, or barangay official, in the locality where they seek to be elected.

The SC “recognized the legislative framework in RA 10742 for preventing the creation and expansion of political dynasties in the country as the Legislative’s answer to the constitutional call to define political dynasties, at least at the barangay and [Sangguniang Kabataan] levels.” It held that such “breathes life to the constitutionally enshrined policy of the sovereign to prohibit political dynasties.”

Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=163046

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