Mendoza Palacao Condat Law Office - MPC Law

29/08/2026

The (SC) has reiterated that once a job offer is accepted, an employer-employee relationship is already formed. Employers cannot just claim redundancy to justify terminating workers – they must present clear proof that a valid redundancy program is in place.

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division found that Alltech Biotechnology (Alltech) illegally dismissed Paolo Landayan Aragones (Aragones) for failing to prove there was redundancy in the company.

Alltech had offered Aragones the position of Swine Technical Manager - Pacific, with a monthly salary of PHP 140,000. He accepted the offer and resigned from his previous job.

Before Aragones’ start date, however, Alltech informed him that the position had been abolished due to a global restructuring. Alltech offered him the amount of PHP 140,000 as goodwill payment. Aragones then filed a complaint for illegal dismissal.

The SC ruled that the employment contract was perfected as soon as Aragones signed the job offer. The delay in his start date merely postponed the obligations of Aragones to report for work, and of Alltech to pay his salary.

However, the SC emphasized that employers must provide solid evidence to justify terminating an employee due to redundancy, which Alltech failed to provide.

Alltech only submitted an affidavit from its Vice President stating that the company decided to shift from regional to local support to better respond to its customers’ needs.

The SC found the statement vague and unsupported by other documents. It did not explain how or why certain positions like Aragones’ were removed. It thus ordered Alltech to pay Aragones backwages and separation pay.

Read the full text of the Press Release at https://tinyurl.com/38vp842u.

Read the full text of the Decision at https://tinyurl.com/2tfywuhu.

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

22/08/2026

The has ruled that employees who are illegally dismissed are entitled not only to full backwages but also to the remittance of their Social Security System (SSS) contributions.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division held that an employer’s obligation to remit SSS contributions continues during the period covered by an employee’s illegal dismissal.

The case involved four employees of Lopez Sugar Corporation (LSC) who were illegally dismissed. LSC was ordered to reinstate them to their former positions and pay them full backwages. After the ruling became final, the employees asked LSC to remit their SSS contributions for the period covered by their backwages so they could qualify for retirement benefits.

LSC refused, arguing that under the 𝘚𝘰𝘤𝘪𝘢𝘭 𝘚𝘦𝘤𝘶𝘳𝘪𝘵𝘺 𝘈𝘤𝘵 𝘰𝘧 1997, its obligation to pay SSS contributions ended upon the employees’ separation from employment, regardless of whether their dismissal was legal or illegal.

The Social Security Commission (SSC) rejected LSC’s position and ordered it to pay the contributions. The SSC ruled that because the employees were illegally dismissed, the employer-employee relationship was deemed to have continued during the period they were prevented from working.

Holding that LSC remained obligated to remit the employees’ SSS contributions for the period covered by their backwages, the SC stated that under Article 294 of the 𝘓𝘢𝘣𝘰𝘳 𝘊𝘰𝘥𝘦, illegally dismissed employees are entitled to full backwages and other benefits.

The SC explained that such employees are considered to have remained employed during the period covered by their backwages and are therefore entitled to the rights and benefits that would have accrued during that period.

Since LSC failed to remit the illegally dismissed employees’ social security contributions, the SC held that LSC is liable to pay a penalty thereon of three percent per month, reckoned from the date they became due until full payment.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=170676.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165713.

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

17/08/2026

The has acquitted a woman of bigamy, ruling that a prior marriage that was void from the beginning (𝘷𝘰𝘪𝘥 𝘢𝘣 𝘪𝘯𝘪𝘵𝘪𝘰) may be raised as a defense even without a prior judicial declaration of nullity.

In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division reversed the ruling of the Regional Trial Court (RTC) Pampanga and the Court of Appeals (CA), which had found Ma. Fe Imelda Lapira guilty of bigamy.

Lapira faced a bigamy charge under Article 349 of the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 for marrying Jimmy Fariscal while still married to Takahiko Sato as evidenced by a marriage certificate from the Office of the Civil Registrar General.

During trial, Lapira argued that her marriage to Sato was void because no ceremony took place and no marriage license had been issued, both of which were required for validity. The Local Civil Registrar confirmed that there was no record of the application for a marriage license for Lapira and Sato.

In acquitting Lapira, the SC applied its ruling in the 2021 case of 𝘗𝘶𝘭𝘪𝘥𝘰 𝘷. 𝘗𝘦𝘰𝘱𝘭𝘦, which held that an accused in a bigamy case may directly argue that a previous marriage is void as a defense, even without a prior court declaration.

The SC explained that one of the essential elements of bigamy is the existence of a valid prior marriage. If the first marriage was void from the beginning, that element is absent.

In this case, the certification from the Local Civil Registrar sufficiently proved that no marriage license was issued to Lapira and Sato. This certification was enough to counter the presumption of the marriage certificate’s validity.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=171178.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165698.

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

11/08/2026

So eto na nga…

Navideohan ka na nag-jaywalking, tapos ginawang "educational content" at ipinost sa personal account nang walang consent. Ang sabi ng nag-upload, nasa public place naman daw kaya wala nang privacy at di na kelangan ng consent.

Totoo ba na kapag nasa pampublikong lugar, wala nang privacy at pwede nang i-record at i-post sa social media?

Hmm... answer in the comment section 👇

09/08/2026

MAN GETS 14 YEARS IN PRISON OVER FACEBOOK POSTS; SC EN BANC RULES VAWC COMMITTED THROUGH ICT CARRIES A HIGHER PENALTY

The case arose from a criminal complaint filed by a woman against her former boyfriend and the father of her child. According to the records, the accused publicly posted insulting and threatening statements on Facebook, calling the victim degrading names and inviting others to identify her. The victim testified that the public post caused her fear, anxiety, humiliation, sleeplessness, and emotional distress.

The Court held that when psychological violence under Republic Act No. 9262, or the Anti-Violence Against Women and Their Children Act, is committed through Facebook or similar social media platforms, Section 6 of Republic Act No. 10175, or the Cybercrime Prevention Act of 2012, applies, increasing the prescribed penalty by one degree, provided that the use of ICT is properly alleged in the Information and proved during trial.

30/07/2026

30/07/2026

The (SC) has ruled that the infliction of psychological violence, if done through Facebook, is considered done through information and communications technology, which warrants the imposition of a higher penalty pursuant to Section 6 of RA 10175 or the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012.

In a Resolution penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed with modification its October 22, 2025 Decision (assailed Decision), which upheld the conviction of an individual (###) for committing psychological violence under Section 5(i) of Republic Act (RA) No. 9262, or the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 𝘈𝘤𝘵 𝘰𝘧 2004 (Anti-VAWC Act) against his ex-girlfriend (AAA) by posting derogatory statements about her on Facebook.

The SC, however, resolved to raise the penalty by one degree, considering that the offense was committed through Facebook, as adequately alleged in the Information and established during trial.

AAA filed the VAWC case against her former partner ### after he posted a statement on Facebook calling her a dirty woman and an animal, and threatening to box her when he sees her. He repeated the insults in the comments to the post, which was public.

During trial, AAA presented screenshots of the Facebook post and testified that she had created for ### the Facebook account which made the post. Her two siblings testified that the account was ###’s and that they received messages from him through the same account.

Despite ###’s denial, the SC, in its assailed Decision, affirmed the decisions of the Family Court and the Court of Appeals (CA) convicting ###, stressing that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender. The SC also upheld the penalty imposed by the CA, consisting of imprisonment for six months and one day to eight years and one day, a fine of PHP 100,000, and psychological counseling or psychiatric treatment.

Resolving ###’s Motion for Reconsideration, the SC held that ###’s authorship of the Facebook post was established beyond reasonable doubt, using the guideposts it established in its assailed Decision:

𝟏. 𝐀𝐝𝐦𝐢𝐬𝐬𝐢𝐨𝐧 𝐨𝐟 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩;
𝟐. 𝐁𝐞𝐢𝐧𝐠 𝐬𝐞𝐞𝐧 𝐚𝐜𝐜𝐞𝐬𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐨𝐫 𝐜𝐨𝐦𝐩𝐨𝐬𝐢𝐧𝐠 𝐭𝐡𝐞 𝐩𝐨𝐬𝐭;
𝟑. 𝐂𝐨𝐧𝐭𝐚𝐢𝐧𝐢𝐧𝐠 𝐢𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐤𝐧𝐨𝐰𝐧 𝐨𝐧𝐥𝐲 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫 𝐨𝐫 𝐚 𝐟𝐞𝐰 𝐩𝐞𝐨𝐩𝐥𝐞;
𝟒. 𝐋𝐚𝐧𝐠𝐮𝐚𝐠𝐞 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫’𝐬 𝐜𝐡𝐚𝐫𝐚𝐜𝐭𝐞𝐫𝐢𝐬𝐭𝐢𝐜𝐬;
𝟓. 𝐑𝐞𝐜𝐨𝐫𝐝𝐬 𝐟𝐫𝐨𝐦 𝐭𝐡𝐞 𝐢𝐧𝐭𝐞𝐫𝐧𝐞𝐭 𝐬𝐞𝐫𝐯𝐢𝐜𝐞 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐫, 𝐭𝐞𝐥𝐞𝐜𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬 𝐜𝐨𝐦𝐩𝐚𝐧𝐲, 𝐨𝐫 𝐬𝐨𝐜𝐢𝐚𝐥 𝐦𝐞𝐝𝐢𝐚 𝐬𝐢𝐭𝐞, 𝐚𝐧𝐝 𝐫𝐞𝐬𝐮𝐥𝐭𝐬 𝐟𝐫𝐨𝐦 𝐝𝐞𝐯𝐢𝐜𝐞 𝐟𝐨𝐫𝐞𝐧𝐬𝐢𝐜 𝐚𝐧𝐚𝐥𝐲𝐬𝐢𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐠𝐞𝐨𝐥𝐨𝐜𝐚𝐭𝐢𝐨𝐧 𝐟𝐞𝐚𝐭𝐮𝐫𝐞𝐬, 𝐚𝐧𝐝 𝐨𝐭𝐡𝐞𝐫 𝐚𝐭𝐭𝐫𝐢𝐛𝐮𝐭𝐞𝐬 𝐥𝐢𝐧𝐤𝐢𝐧𝐠 𝐭𝐡𝐞 𝐚𝐜𝐜𝐨𝐮𝐧𝐭 𝐭𝐨 𝐭𝐡𝐞 𝐨𝐟𝐟𝐞𝐧𝐝𝐞𝐫;
𝟔. 𝐀𝐜𝐭𝐬 𝐜𝐨𝐧𝐬𝐢𝐬𝐭𝐞𝐧𝐭 𝐰𝐢𝐭𝐡 𝐩𝐫𝐞𝐯𝐢𝐨𝐮𝐬 𝐩𝐨𝐬𝐭𝐬; 𝐨𝐫
𝟕. 𝐎𝐭𝐡𝐞𝐫 𝐢𝐧𝐬𝐭𝐚𝐧𝐜𝐞𝐬 𝐬𝐡𝐨𝐰𝐢𝐧𝐠 𝐨𝐰𝐧𝐞𝐫𝐬𝐡𝐢𝐩, 𝐚𝐜𝐜𝐞𝐬𝐬, 𝐨𝐫 𝐚𝐮𝐭𝐡𝐨𝐫𝐬𝐡𝐢𝐩.

The authorship of the Facebook post and all the elements of psychological violence having been established, the SC said Section 6 of the 𝘊𝘺𝘣𝘦𝘳𝘤𝘳𝘪𝘮𝘦 𝘗𝘳𝘦𝘷𝘦𝘯𝘵𝘪𝘰𝘯 𝘈𝘤𝘵 𝘰𝘧 2012 applies, which mandates the imposition of a penalty higher by one degree for crimes and offenses committed using ICT. The use of ICT can enable offenders to evade liability, reach more victims, or cause greater harm.

Citing the definition of ICT, the Court ruled that social media platforms, such as Facebook, qualify as ICT systems because they allow users to generate, send, receive, store, and process electronic data messages through computers, mobile phones, or similar electronic devices.

In this case, the Information alleged that ### made the Facebook post using his "Facebook Messenger Account… which was set to public view." The SC ruled that this statement constitutes a sufficient allegation of the use of ICT as a qualifying circumstance. Even if the term "ICT" was not stated, the Information adequately informed ### that he is being charged of inflicting psychological violence upon AAA through Facebook, which falls under the contemplation of an ICT system.

The allegation was established by the prosecution during trial.

Thus, the Court increased the penalty by one degree from six months and one day to eight years and one day to imprisonment of six years and one day to 14 years, eight months, and one day, but retained the fined PHP 100,000. He was likewise ordered to undergo psychological counseling or psychiatric treatment.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=168987

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168968

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

24/07/2026

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

23/07/2026

SC WARNS: IRREGULAR NOTARIZATION HAS SERIOUS LEGAL CONSEQUENCES

"Registration of the notarized document in the notarial registry is basic requirement in the notarial process. The notarial registry is a record of the notary public's official acts. Acknowledged documents and instruments recorded in it are considered public documents. A document or instrument which does not appear in the notarial records or without a copy of it therein, suggests that the document or instrument was not really notarized. Without registration, a document or instrument while signed by the Notary Public cannot be treated as duly notarized. It cannot be treated as a public document and as such, is not entitled to the presumption of regularity. The document or instrument does not have for its benefit that which is due to public documents, that is that genuineness and due ex*****on need not be proved. Irregular notarization reduces the evidentiary value of a document to a private document which requires proof of its due ex*****on and authenticity to be admissible as evidence."

— GAERLAN, J.

SC, First Division
G.R. No. 228999, April 28, 2021

Read the full text in the comments section.