Marcial-Rapilo Law and Accounting Firm

Marcial-Rapilo Law and Accounting Firm CPA | Lawyer | Notary Public โš–๏ธ๐Ÿ’ป๐Ÿ“š
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06/04/2026

๐Ÿต ๐—ฑ๐—ฎ๐˜†๐˜€ ๐—น๐—ฒ๐—ณ๐˜ before the April 15, 2026 Annual Income Tax filing and payment deadline.

This is a daily reminder from the BIR to taxpayers to pay your exact 2025 Annual Income Tax on the day of filing your return. Today's guide is on the ๐—•๐—œ๐—ฅ ๐—™๐—ผ๐—ฟ๐—บ๐˜€ & ๐—ง๐—ฎ๐˜… ๐—ฅ๐—ฒ๐˜๐˜‚๐—ฟ๐—ป ๐—™๐—ถ๐—น๐—ถ๐—ป๐—ด ๐—™๐—ฎ๐—ฐ๐—ถ๐—น๐—ถ๐˜๐—ถ๐—ฒ๐˜€ ๐˜๐—ผ ๐—ฏ๐—ฒ ๐˜‚๐˜€๐—ฒ๐—ฑ ๐—ฏ๐˜† ๐—–๐—ผ๐—ฟ๐—ฝ๐—ผ๐—ฟ๐—ฎ๐˜๐—ถ๐—ผ๐—ป๐˜€, ๐—ฃ๐—ฎ๐—ฟ๐˜๐—ป๐—ฒ๐—ฟ๐˜€๐—ต๐—ถ๐—ฝ๐˜€ & ๐—ข๐˜๐—ต๐—ฒ๐—ฟ ๐—ก๐—ผ๐—ป-๐—œ๐—ป๐—ฑ๐—ถ๐˜ƒ๐—ถ๐—ฑ๐˜‚๐—ฎ๐—น ๐—ง๐—ฎ๐˜…๐—ฝ๐—ฎ๐˜†๐—ฒ๐—ฟ๐˜€.

Avoid the rush - file and pay now!

10/12/2025

We have loose docstamps available at Marcial-Rapilo Law and Accounting Firm. Limited stocks only. Thank you!

01/12/2025

Announcement ๐Ÿ“ฃ

Office reopens tomorrow, December 2, 2025.

To God be the glory!

09/07/2025
28/05/2025
08/05/2025

LAST DAY for filing the 1st QUARTER Income Tax Returns and payment of Income Tax Due thereon by Individual Taxpayers.

05/05/2025

The (SC) has reiterated that courts are not bound by parental custody agreements when these do not serve the childโ€™s best interest.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SCโ€™s Second Division granted the petition filed by Jeffrey Rosacay Empuerto and his parents challenging a Court of Appeals ruling which upheld the validity of a compromise agreement between Jeffrey and Sheena Cabrillos, the mother of his child.

The SC sent the case back to the Family Court for determination of parental custody. It also gave custody to petitioners Jeffrey and his parents, who have actual care of the child, while the case remains pending.

Jeffrey and Sheena had a child in 2013. The couple eventually separated, with Sheena moving with their child to her parentsโ€™ home, and with Jeffrey exercising custody over the latter during long vacations.

In 2020, the childโ€™s visit to Jeffrey was extended due to the COVID-19 lockdown, with Jeffrey refusing to return the child to Sheena even after restrictions were lifted. Sheena thus filed a complaint with the police and a petition for the issuance of a writ of habeas corpus with the Family Court.

The Family Court issued the writ and terminated the case. It adopted in an order the agreement between Jeffrey and Sheena that the latter would have custody of the child by July 2021. The Court of Appeals upheld this agreement as a provisional custody arrangement.

Petitioners then argued before the SC that the mere agreement between the parents before trial cannot determine the issue of a childโ€™s custody.

Ruling in petitionersโ€™ favor, the SC stressed that a petition for habeas corpus in custody cases is meant to determine who has rightful custody, not merely to secure a childโ€™s appearance in court.

Trial courts must consider the totality of circumstances and grant custody only if:

- the petitioner has a legal right to custody;
- the child is being kept from them by the other party; and
- being with the petitioner is in the best interest of the child.

In this case, the SC found that the Family Court failed to evaluate these factors, relying solely on the parentsโ€™ agreement without conducting a case study or assessing parental fitness. It added that compromise agreements between parents as to a childโ€™s custody are frowned upon. Courts should not simply approve custody agreements but must ensure that the childโ€™s rights and welfare are protected.

Read the full text of the Press Release at https://tinyurl.com/3p6v2cc2.

Read the full text of the Decision at https://tinyurl.com/52yna5zv.

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

24/04/2025
24/04/2025

How to Revert to Your Maiden Name Under the New Philippine Passport Act

The New Philippine Passport Act (RA 11983) now allows Filipino women who changed their surname after marriage to revert to their maiden name in their passport. This change makes it easier for women to update their records.

Who May Apply?

You can revert to your maiden name if:
1. You voluntarily choose to do so (but only once).
2. Your spouse has passed away.
3. Your marriage has been annulled, declared void, or legally ended (including foreign divorces recognized by Philippine courts).

What Documents Do You Need?

For Voluntary Reversion (not due to separation):
โ€ข PSA-issued Birth Certificate
โ€ข PSA-issued Marriage Certificate
โ€ข Affidavit of Explanation (stating youโ€™re requesting the change, indicating that you have not done it before)
โ€ข Current passport and a valid ID showing your maiden name

If your spouse passed away:
โ€ข PSA-issued Death Certificate of your spouse
โ€ข PSA-issued Birth Certificate
โ€ข Current passport

If your marriage was nullified/annulled or legally ended:
โ€ข PSA-issued Marriage Certificate, including Advisory on Marriage (with annotation about annulment/nullity or divorce)
โ€ข PSA-issued Birth Certificate
โ€ข Current passport

How to Apply?

1. Gather the required documents based on your situation.
2. Fill out and notarize the Affidavit of Explanation (if applying voluntarily).
3. Schedule an appointment at the DFA or a Philippine Consulate/Embassy.
4. Submit your documents and pay the required fees.

Things to Remember

โ€ข If you voluntarily revert to your maiden name (not due to separation), you can only do it once.
โ€ข Make sure all your IDs and legal documents match your maiden name after the change.
โ€ข The DFA may ask for additional documents depending on your case.

21/04/2025

The (SC) has ruled that land buyers must verify ownership by checking the certificate of title and reviewing the records in the Registry of Deeds to avoid fraudulent transactions.

In a Decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the Courtโ€™s Third Division upheld the rulings of the Regional Trial Court and Court of Appeals which voided the land titles of a married couple who failed to conduct due diligence when they bought the properties from someone who acquired her titles through fraud.

Orencio and Eloisa Manalese purchased two parcels of land from Carina Pinpin, who presented certificates of title in her name and claimed to have bought the properties from the original owners, the late Narciso and Ofelia Ferreras.

However, the administrator of the Ferreras estate, alleged that Pinpin fraudulently obtained duplicate titles by submitting a false affidavit of loss and a forged deed of sale. Pinpin then used these to sell the properties to Spouses Manalese a year later.

The Supreme Court upheld the lower courtsโ€™ findings, stressing that buyers must check both the certificate of title and the Registry of Deeds records before purchasing land. Relying solely on a certificate of title is insufficient, especially if there are signs of fraud or irregularity.

In this case, the Spouses Manelese failed to investigate despite multiple warning signs, making them liable for not exercising due diligence. Several key documents were already on record, including the affidavit of loss procured by Pinpin, the issuance of another set of duplicate titles, a second affidavit of loss by a certain Zenaida Ferreras, and the nearly simultaneous registrations of these three annotations on the titles.

Said the Court: โ€œSince petitioners did not inquire into the register, and even without such inquiry, they are nonetheless constructively notified of every registration affecting the said subject properties, they cannot feign ignorance of such
registrations.โ€

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-land-buyers-must-check-both-title-and-registry-of-deeds-records/.

Read the full text of the Decision at https://tinyurl.com/3njh86mk.

Read the Separate Concurring Opinion of Associate Justice Henri Jean Paul B. Inting at https://tinyurl.com/3k2p236k.

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

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San Fabian
2433

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Thursday 7am - 7pm
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