Atty. Dionaldo

02/07/2026

“In a petition for declaration of nullity of marriage, lack of objection (on the part of one spouse) is not the same as collusion.” -SC

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.

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22/05/2026

NOTICE TO THE PUBLIC

In light of recent reports of alleged cybersecurity incidents, the National Privacy Commission (NPC) reminds the public that unauthorized access, use, disclosure, sharing, or further dissemination of another person’s personal data may give rise to civil, administrative, or criminal liability under the Data Privacy Act of 2012 and other applicable laws, rules, and regulations.

Accordingly, the public is strongly advised to refrain from viewing, downloading, posting, sharing, or further disseminating files, databases, screenshots, or links purported or implied to have been obtained through unauthorized access, as these may contain personal data protected under the Data Privacy Act of 2012.

Read more below.

18/05/2026

“…factors that can lessen or increase penalties apply in cases of reckless imprudence resulting in HOMICIDE involving MOTOR vehicle.” - SC

The has clarified that the rules on modifying circumstances—factors that can lessen or increase penalties—apply in cases of reckless imprudence resulting in homicide involving a motor vehicle.

In a Decision written by Associate Justice Antonio T. Kho, Jr., the SC En Banc upheld Noli Z. Ilon’s (Ilon) conviction for reckless imprudence resulting in homicide, but reduced his sentence because he voluntarily surrendered to the police.

Under Article 365 of the Revised Penal Code (RPC), reckless imprudence is acting without intent to harm but still causing injury or death to another due to a clear lack of precaution. The SC emphasized that motorists are expected to drive at a reasonable speed suited to road and weather conditions, especially near intersections. In this case, Ilon admitted that he failed to slow down despite knowing he was approaching an intersection. He even increased his speed, leading him to hit the trisikad that caused Lee de la Cruz’s death.

The SC clarified that Ilon’s voluntary surrender should be appreciated as a mitigating circumstance that reduces his penalty. It explained that while Article 365 of the RPC generally allows trial courts to impose penalties without applying the rules on mitigating and aggravating circumstances under Article 64 of the RPC, this does not apply when reckless imprudence results in death involving a motor vehicle. In such cases, Article 64 must be followed.

The SC reviewed the amendments to Article 365—from Act No. 3992, or the Revised Motor Vehicle Law, passed in 1932, through Batas Pambansa Blg. 398 passed in 1983—and found that Congress consistently retained the clause excluding cases where death results from reckless imprudence involving motor vehicles from the usual discretion given to trial courts. This means that courts must apply Article 64 to determine the proper penalty.

The SC observed, however, an inconsistency: reckless imprudence resulting in homicide with the use of a motor vehicle may be mitigated, while those resulting in serious bodily injury or damage to property are left to the discretion of the trial courts. Finding this distinction unjust, the SC directed that copies of its Decision be furnished to the President, the Senate, and the House of Representatives, to alert its co-equal branches of this inconsistency and for possible legislative action.

Ilon was sentenced to up to two years and four months in prison and ordered to pay the heirs of de la Cruz PHP 629,883.45 in damages.

In his Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen noted that piecemeal amendments to the RPC have led to inconsistencies in criminal law. He called for the consolidation of all criminal provisions into a single, unified code to ensure fairness, clarity, and the orderly administration of justice.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=166162

Read the full text of the Decision at https://sc.judiciary.gov.ph/260538-noli-z-ilon-vs-people-of-the-philippines/

Read the full text of the Concurring Opinion at https://sc.judiciary.gov.ph/260538-concurring-opinion-senior-associate-justice-marvic-m-v-f-leonen/

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16/05/2026

21/04/2026

“CYBER LIBEL prescribes 1 year from discovery” - SC

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

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11/03/2026

The SC has upheld the validity of a DOJ circular that raised the standard of proof in preliminary investigations and inquest proceedings from probable cause to prima facie evidence with reasonable certainty of conviction.

The (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤 has upheld the validity of a Department of Justice (DOJ) circular that raised the standard of proof in preliminary investigations and inquest proceedings from probable cause to prima facie evidence with reasonable certainty of conviction.

In a Decision written by written by Associate Justice Japar B. Dimaampao, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 ruled that Department Circular No. 15, series of 2024 containing the 2024 𝘋𝘖𝘑-𝘕𝘢𝘵𝘪𝘰𝘯𝘢𝘭 𝘗𝘳𝘰𝘴𝘦𝘤𝘶𝘵𝘪𝘰𝘯 𝘚𝘦𝘳𝘷𝘪𝘤𝘦 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘗𝘳𝘦𝘭𝘪𝘮𝘪𝘯𝘢𝘳𝘺 𝘐𝘯𝘷𝘦𝘴𝘵𝘪𝘨𝘢𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘐𝘯𝘲𝘶𝘦𝘴𝘵 𝘗𝘳𝘰𝘤𝘦𝘦𝘥𝘪𝘯𝘨𝘴 (𝘋𝘖𝘑 𝘙𝘶𝘭𝘦𝘴), is a valid exercise of the DOJ’s authority over prosecutorial processes.

Under the DOJ Rules’ new standard of proof in preliminary investigations and inquest, prosecutors must ensure that the evidence to charge a person with a crime must sufficiently establish all the elements and consequently warrant a conviction.

Atty. Hazel L. Meking questioned the DOJ Rules before the SC, claiming that the DOJ encroached on the SC’s constitutional authority to promulgate rules of pleading, practice, and procedure in all courts. She argued that the DOJ Rules effectively revised Rule 112, Section 3(a) of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘳𝘪𝘮𝘪𝘯𝘢𝘭 𝘗𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦, which provides that the quantum of evidence in preliminary investigations is probable cause.

The SC dismissed her petition and reiterated its ruling in 𝘈.𝘔. 𝘕𝘰. 24-02-09-𝘚𝘊, which recognized the DOJ’s authority to promulgate its own rules on preliminary investigations and inquest proceedings.

The SC held that the DOJ Rules govern only the conduct of preliminary investigations and inquests by prosecutors, which are executive functions. These Rules, however, do not extend to judicial proceedings as the power to promulgate rules of procedure over them remains under the authority of the Supreme Court.

The SC noted it had already recognized preliminary investigation as the exclusive domain of prosecutors when it revised the Rules of Criminal Procedure in 2005.

In 2024, through 𝘈.𝘔. 𝘕𝘰. 24-02-09-𝘚𝘊, the SC also ordered the repeal of provisions in Rule 112 which are inconsistent with the DOJ Rules to harmonize them.

The SC’s constitutional rule-making authority over judicial proceedings remains supreme, as well as its power to correct grave abuse of discretion in any prosecutorial rule or action that violates constitutional rights.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=161871

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=161853

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=161858

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

23/02/2026

“ACQUITTAL VIA DEMURRER TO EVIDENCE IS FINAL AND UNAPPEALABLE” - SC

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.

19/01/2026

01/01/2026

“The Supreme Court has ordered a lending app operator to pay damages to a client for accessing her contact list and sending messages about her outstanding loan, actions that harm her reputation.”

SUPREME COURT FINES LENDING APP FOR UNAUTHORIZED CONTACT ACCESS; CRIMINAL PROSECUTION RECOMMENDED

The Supreme Court (SC) has ordered a lending app operator to pay damages to a client for accessing her contact list and sending messages about her outstanding loan, actions that harmed her reputation

In a 16-page ruling penned by Associate Justice Henri Jean Paul Inting, the SC's Third Division reversed the decision of the Court of Appeals (CA) that set aside the National Privacy Commission (NPC)’s recommendation to charge FCash Global Lending Inc. with violation of the Data Privacy Act of 2012 and to pay damages to complainant Grace Trimillos.

Court records revealed that Trimillos filed the complaints alleging that the lending app accessed her phone’s contacts list without her authority and sent everyone on the list messages about her loan.

She added this tarnished her reputation, as her co-workers and friends were told they were guarantors and would be forced to pay on her behalf if she did not settle her loan.

Trimillos presented screenshots of the text messages allegedly sent by FCash as evidence. When mediation failed, NPC directed FCash to file a responsive comment, which received no response.

The NPC then resolved the issue and ruled that Trimillo’s right to privacy was violated after it found that FCash gathered personal information in excess of what was necessary and processed it for purposes other than those stated in their own privacy policy.

It held that the unauthorized processing of personal information was done with malice, as the messages reveal FCash’s “unquestionable intention to shame Trimillos and jeopardize her reputation” until she settled her obligations.

The NPC awarded P15,000 in nominal damages to Trimillos and recommended to the Department of Justice the filing of criminal cases against FCash for malicious disclosure and processing of sensitive personal information for unauthorized purposes.

However, when the case was brought to the CA, it abandoned the NPC ruling, noting that Trimillos failed to have the screenshots authenticated by any of her supposed witnesses, violating the Rules on Electronic Evidence. This paved the way for Trimillos to elevate the case before the Supreme Court.

In ruling in her favor and reinstating the NPC ruling, the high court found FCash failed to timely object to the admissibility of the screenshots used as evidence in the complaint against it before the NPC.

It explained that because FCash raised the issue for the first time on appeal, it could no longer be used as a ground to reverse the NPC’s decision. The issue was deemed waived when the lending app failed to file its response during the proceedings before the NPC.

“While there had been a ground to question its admissibility, it is clear that FCash failed to make a timely objection on the presentation and offer of the screenshots,” the Supreme Court said.

It also cited a previous ruling that inadmissible evidence may be admitted if not challenged at the proper time, and such an issue may not be raised for the first time on appeal.

The highest bench underscored that Trimillos submitted the screenshots to the NPC before the discovery conference. Despite its availability for examination, FCash did not object to these when given an opportunity to comment, including its objection to the inadmissibility of evidence.

“At the risk of being repetitive, grounds for objections not raised at the proper time shall be considered waived. Thus, even on appeal, the CA may not consider any other ground of objection except those that were raised at the proper time,” it added.

26/12/2025

“The SC stressed that in criminial cases, the prosecution must not only prove the elements of the crime but also the identity of the offender.”

The has laid down guideposts for proving who owns or controls a social media account in criminal cases.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed the conviction of an individual (###) for committing psychological violence under Section 5 (i) of the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 (𝘈𝘯𝘵𝘪-𝘝𝘈𝘞𝘊) 𝘈𝘤𝘵 against his ex-girlfriend (AAA) by posting derogatory statements about her on 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬.

The SC sentenced ### to up to eight years in prison, imposed a PHP 100,000 fine, and ordered ### to undergo psychological counseling or psychiatric treatment.

The SC stressed that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender.

It explained that for crimes committed through social media, the basic features of the platform such as 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬, must be considered.

Noting that 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 is widely used in the Philippines, the SC held that a 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 account can easily be created by anyone claiming to be at least 13 years old with an email address or mobile number.

Once an account is created, the user can add friends, exchange private messages, and post statements, photos, or videos visible to others depending on the user’s privacy settings. Fake or dummy accounts can easily spread, enabling disinformation, identity theft, or crimes.

Given this, the SC ruled that guideposts are necessary to establish who owns or controls a social media account. It said the following must be shown to prove ownership or access:

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.

Applying these, the SC found that several factors proved ### wrote the 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 post. The account name bore his full name, and the profile photo showed him with his child from his current live-in partner.

AAA’s sister had also received messages from the same account for years.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=158535.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=158446.

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