Mansion Law Office

05/09/2026

The (SC) has clarified the rules on serving notices of dishonor in cases involving Batas Pambansa Blg. 22 (BP 22) or the 𝘈𝘯𝘵𝘪-𝘉𝘰𝘶𝘯𝘤𝘪𝘯𝘨 𝘊𝘩𝘦𝘤𝘬 𝘓𝘢𝘸. The SC formally recognized electronic service as a valid mode of serving notice of dishonor, while requiring safeguards to ensure that service can be reliably proven in court.

In a Decision penned by Associate Justice Samuel H. Gaerlan, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 affirmed the conviction of spouses Arnel and Marivic Carlos for six counts of violating BP 22.

The spouses issued six checks to respondent Tire Star, Inc. as payment for car tires. All six checks were dishonored by the bank as the account they were drawn from had been closed.

The prosecution presented evidence that Tire Star’s messenger personally attempted to serve the notice of dishonor at the spouses’ office, and that the spouses refused to receive it, instructed an employee instead to sign for it.

The spouses then claimed before the SC that they should be acquitted because they were not properly served with a notice of dishonor.

The SC rejected the spouses’ argument, emphasizing that an accused cannot defeat a BP 22 prosecution simply by denying receipt of the notice or refusing to accept it. Otherwise, issuers could easily evade liability by avoiding service.

To promote uniformity and reduce disputes, the SC clarified the acceptable modes of serving notices of dishonor.

𝗣𝗲𝗿𝘀𝗼𝗻𝗮𝗹 𝘀𝗲𝗿𝘃𝗶𝗰𝗲 remains the preferred mode. The notice may be delivered directly to the issuer or, in the case of a business, to an authorized representative. If the issuer cannot be served at the office, the notice may be left at the issuer’s residence with an adult resident between 8:00 A.M. and 6:00 P.M.

The person serving the notice must execute an affidavit stating when, where, and how service was made. When practicable, service should be documented through photographs or video recordings, subject to proper authentication in court.

If personal service is not practicable, the notice of dishonor may be sent by 𝗿𝗲𝗴𝗶𝘀𝘁𝗲𝗿𝗲𝗱 𝗺𝗮𝗶𝗹, or where registry service is unavailable, by 𝗼𝗿𝗱𝗶𝗻𝗮𝗿𝘆 𝗺𝗮𝗶𝗹. The person serving the notice must likewise execute an affidavit explaining why personal service could not be made and attach the supporting postal documents.

The SC also recognized 𝗲𝗹𝗲𝗰𝘁𝗿𝗼𝗻𝗶𝗰 𝘀𝗲𝗿𝘃𝗶𝗰𝗲, ruling that a notice of dishonor may now be served through email as a primary mode of service when the issuer previously provided their email address. Electronic service may likewise be used through platforms such as 𝘝𝘪𝘣𝘦𝘳, 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 𝘔𝘦𝘴𝘴𝘦𝘯𝘨𝘦𝘳, or similar applications, provided it can be verified that the electronic account belongs to the issuer.

Electronic service may also be used when the issuer refuses to receive the notice, avoids service, or when personal service is otherwise impracticable. In such cases, the electronic notice must be sent within 24 hours after the final unsuccessful attempt at personal service and must state the dates and details of those failed attempts.

The sender must also execute an affidavit and preserve supporting evidence, such as screenshots, messages, delivery or read receipts, or chat histories., stressing that a simple denial of receipt is not enough to invalidate electronic service.

In all instances, to successfully dispute service, the issuer must show that it was physically impossible to have received the notice at the time and place it was served.

The spouses were fined a total of PHP 609,972.58 for the six BP 22 violations, with subsidiary imprisonment in case of nonpayment. They were also ordered to pay Tire Star the same amount, plus interest.

In his Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that electronic service should not merely be a substitute but a primary mode of service consistent with contemporary means of communication and the Judiciary’s ongoing digital reforms.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=172159.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=171528.

Read the Concurring Opinion of Senior Associate Justice Leonen at https://sc.judiciary.gov.ph/?p=171527.

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

05/09/2026

04/07/2026

Thank you for your trust, Ma’am. We look forward to assisting you again.

02/07/2026

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.

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

27/06/2026

Another set of titles delivered. Thank you for your trust, clients! 💕

13/06/2026

11/05/2026

Bago bumili ng lupa, mas mabuting kumuha muna ng electronic copy ng titulo mula sa Registry of Deeds.

Makakatulong ito upang masigurong tunay ang titulo at malinis ang record ng property bago ituloy ang transaksyon.

In, 𝐒𝐩𝐨𝐮𝐬𝐞𝐬 𝐌𝐚𝐧𝐚𝐥𝐞𝐬𝐞 𝐯. 𝐓𝐡𝐞 𝐄𝐬𝐭𝐚𝐭𝐞 𝐨𝐟 𝐭𝐡𝐞 𝐋𝐚𝐭𝐞 𝐒𝐩𝐨𝐮𝐬𝐞𝐬 𝐅𝐞𝐫𝐫𝐞𝐫𝐚𝐬, 𝐆.𝐑. 𝐍𝐨. 𝟐𝟓𝟒𝟎𝟒𝟔, 𝐍𝐨𝐯𝐞𝐦𝐛𝐞𝐫 𝟐𝟓, 𝟐𝟎𝟐𝟒, the Supreme Court affirmed the rulings of the lower courts declaring the sale and subsequent transfers of two parcels of land in Sta. Teresita, Angeles City, null and void. The properties were originally owned by Spouses Narciso and Ofelia Ferreras, who died in 2005 and 1992, respectively. Despite their passing, a Deed of Absolute Sale dated 2009 was allegedly executed in favor of Carina Pinpin, who then sold the properties to Spouses Orencio and Eloisa Manalese and their son, Aries, in 2010. The petitioners argued they were innocent purchasers for value, citing clean titles and lack of visible claims.

Nonetheless, the Court found that they failed to exercise the required level of diligence, especially in light of the obvious impossibility of a valid sale executed by deceased persons. The Court held that the petitioners were not buyers in good faith and upheld the annulment of their titles.

09/05/2026

Today, our clients successfully received their title, marking another completed transaction.
Thank you, for your trust in our service.

For any inquiries regarding the transfer of land titles, feel free to message us or visit us at ATLAS Law Office, Tuguegarao City from Monday to Thursday, or at Mansion Law Office, Lasam every Friday and Saturday.