Atty. GM Madrigal

The (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session today, July 1, 2025, issued a writ of 𝘬𝘢𝘭𝘪𝘬𝘢𝘴𝘢𝘯 in a case which seeks to stop the construction of the Samal Island-Davao City Connector Bridge Project against the following respondents:

- Department of Public Works and Highways;
- Department of Environment and Natural Resources;
- Samal Island Protected Landscape and Seascape Protected Area Management Board; and
- China Road and Bridge Corporation

Petitioners Carmela Marie Santos, Mark Peñalver, and Sustainable Davao Movement claim that the Project will cause actual, serious, and irreversible damage to coral reefs in Paradise Reef, Samal Island, and Hizon Marine Protected Area in Davao City.

The SC required the respondents to file a verified return on the petition within 10 days from service of the writ.

The SC also referred the prayer for a temporary environmental protection order to the Court of Appeals–Cagayan de Oro station for action.

Read the Press Briefer at https://sc.judiciary.gov.ph/press-briefer-july-1-2025/

Read the Petition athttps://sc.judiciary.gov.ph/wp-content/uploads/2025/07/Petition-for-Writ-of-Kalikasan.pdf

The has reiterated that a victim’s admission of being in a relationship with her abuser does not imply consent to s*x. Clear and convincing evidence of consent is still required.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC’s Second Division affirmed the conviction of accused Jhopet Hernandez Toralde for r**e of a 14-year old girl.

In 2017, Toralde showed up at the victim’s house unannounced and forced her to have s*x, threatening to show her family a video of them kissing if she refused. Out of fear, the victim gave in. She then reported the incident to the police.

During trial, the defense claimed that Toralde did not force the victim to have s*xual in*******se as he and the victim were in a romantic relationship—a defense known as the “𝘀𝘄𝗲𝗲𝘁𝗵𝗲𝗮𝗿𝘁 𝘁𝗵𝗲𝗼𝗿𝘆.”

The SC, however, rejected Toralde’s sweetheart defense and declared him guilty of r**e under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦, citing that all elements of the crime were present, including the use of threats and intimidation to force s*xual in*******se.

The SC rejected Toralde’s sweetheart defense, affirming that being in a relationship does not grant the right to force s*x. The SC stressed that proving a romantic relationship is not enough—there must be clear evidence of consent.

Toralde was sentenced to suffer the penalty of 𝘳𝘦𝘤𝘭𝘶𝘴𝘪𝘰𝘯 𝘱𝘦𝘳𝘱𝘦𝘵𝘶𝘢, or a maximum of 40 years in prison, and ordered to pay the victim PHP 225,000 in damages.

Read the full text of the Press Release at https://tinyurl.com/nvpvv9fm.

Read the full text of the Decision at https://tinyurl.com/6tzma4tx

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

The (SC) has held a school civilly liable for negligence after a bullying incident led to the assault of a student during class.

In a Decision written by Associate Justice Mario V. Lopez, the SC’s Second Division found that Mother Goose Special School System, Inc. (Mother Goose School) failed to address a punching incident involving three grade school students inside one of its classrooms.

When the victim’s parents raised the matter with the school, their complaints were ignored, prompting them to file formal requests for investigation. Mother Goose School ultimately concluded the incident was mere "teasing" or "rough play" and took no disciplinary action.

Dissatisfied, the parents filed a complaint for damages against the school, the teachers, and the other students’ fathers.

Ordering Mother Goose School to pay the victim’s parents PHP 650,000 in damages and attorney’s fees, the SC agreed with the trial court and the Court of Appeals that Mother Goose School was grossly negligent in handling the punching incident.

The SC emphasized that schools have a contractual obligation to ensure a safe learning environment. It also reiterated that schools must maintain peace and order within their premises, and even outside campus during school activities. They may avoid liability only upon proof they exercised due diligence.

The SC found Mother Goose School negligent for its lack of proper protocols, failure to inform the victim’s parents promptly, and inaccuracies in its investigation.

Read the full text of the Press Release at https://tinyurl.com/m86ufzwa.

Read the full text of the Decision at https://tinyurl.com/mparp5dp.

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

The (SC) has ruled that security guards cannot be held criminally liable for illegal possession of a firearm if they reasonably believe that the firearm issued by their agency is licensed.

In a Decision written by Associate Justice Ricardo R. Rosario, the SC’s First Division acquitted a security guard charged with unlawful possession of a firearm under Republic Act No. (RA) 10591 or the 𝘊𝘰𝘮𝘱𝘳𝘦𝘩𝘦𝘯𝘴𝘪𝘷𝘦 𝘍𝘪𝘳𝘦𝘢𝘳𝘮𝘴 𝘢𝘯𝘥 𝘈𝘮𝘮𝘶𝘯𝘪𝘵𝘪𝘰𝘯 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯 𝘈𝘤𝘵.

The case stemmed from the arrest of a security guard by a police officer who saw him carrying a firearm issued by his security agency. The police officer noticed that the guard was not wearing his prescribed uniform and asked for the firearm’s license. When the guard failed to present one, he was arrested.

While both the trial court and the Court of Appeals found the accused guilty of unlawful possession of fi****ms and ammunition, the SC reversed the conviction.

It ruled that under the 1983 𝘐𝘮𝘱𝘭𝘦𝘮𝘦𝘯𝘵𝘪𝘯𝘨 𝘙𝘶𝘭𝘦𝘴 𝘢𝘯𝘥 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯𝘴 (𝘐𝘙𝘙) 𝘰𝘧 𝘗𝘋 𝘕𝘰. 1866, private security agency guards can carry fi****ms on work premises so long as authorized by a Duty Detail Order (DDO). The 2018 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘐𝘙𝘙 𝘰𝘧 𝘙𝘈 10591 confirms that the DDO serves as the authority for security personnel to carry their issued firearm within the assigned location and period.

The issuance of a DDO assumes the presence of a valid license for the fi****ms listed in the order.

Read the full text of the Press Release at https://tinyurl.com/mpse8pzk.

Read the full text of the Decision at https://tinyurl.com/y4aym6e2.

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

The (SC) has ruled that lawyers cannot be held liable for notarial violations unless there is clear evidence that they knowingly permitted the misuse of their notarial commission.

In a Decision written by Associate Justice Ricardo R. Rosario, the SC’s First Division dismissed the administrative complaint against Attys. Delfin Agcaoili, Jr., Editha Talaboc, and Mark Oliveros (respondents) due to lack of proof that they allowed the unauthorized use of their notarial signatures, notarial seals, and notarial registers for a fee.

The complaint stemmed from the alleged notarization of documents related to criminal cases filed before the Office of the Ombudsman concerning the Malampaya Fund issue. The documents were supposedly notarized using the respondents’ signatures, notarial seals, and registers – allegedly forged by Ben Hur Luy.

The 𝘕𝘰𝘵𝘢𝘳𝘪𝘢𝘭 𝘗𝘳𝘢𝘤𝘵𝘪𝘤𝘦 𝘙𝘶𝘭𝘦𝘴 prohibits notaries from notarizing documents if the signatory is not present and properly identified. The Ombudsman claimed that the respondents allowed others to misuse their notarial registers, stamps, and seals in exchange for money and recommended disciplinary action.

However, the SC held that there was no concrete proof that the respondents willingly allowed the misuse of their notarial registers, stamps, and seals.

It noted several missing elements in the documents, including details such as respondents’ notarial commission serial numbers, office addresses, Integrated Bar of the Philippines chapters, and Professional Tax Receipt numbers. It also found irregularities in the notarial certificates regarding the validity of their notarial commissions.

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

Read the full text of the Decision at https://tinyurl.com/4dtxmphe.

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

The (SC) has ruled that a teacher may be held liable to pay damages for harm caused by a student under their supervision if they did not exercise due diligence in preventing the incident.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division upheld the liability of Gil Apolinario (Apolinario), the principal of Brgy. Palale Elementary School in Sta. Margarita, Samar, for damages arising from the death of Francisco De Los Santos (De Los Santos).

The incident involved a 15-year-old student who, under Apolinario’s instruction, cut down a banana plant near the school and on the side of a highway. The plant fell and struck De Los Santos, who was passing by on a motorcycle, leading to his death. De Los Santos’ family then filed a complaint for damages against Apolinario.

Ruling that Apolinario, as the teacher-in-charge, is vicariously liable for damages, the SC held that teachers and school heads are responsible for students’ actions while under their supervision. Even outside school hours, educators must exercise due diligence when assigning tasks to students.

Ordering Apolinario to pay De Los Santos’ heirs PHP 355,000 in damages and litigation expenses, the SC
said that under the Civil Code, a person who causes harm to another due to fault or negligence must pay for the damage done.

This obligation also applies, following the principle of vicarious liability, to teachers-in-charge and school heads who are primarily responsible for their students’ actions while under their supervision unless they can show that they took proper precautions.

Read the full text of the Press Release at
https://tinyurl.com/3dwnztb4.

Read the full text of the Decision at https://tinyurl.com/a6p8nxjf.

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

𝗖𝗮𝗻 𝘁𝗵𝗲 𝗣𝗵𝗶𝗹𝗶𝗽𝗽𝗶𝗻𝗲 𝗦𝘂𝗽𝗿𝗲𝗺𝗲 𝗖𝗼𝘂𝗿𝘁 𝗶𝗻𝘁𝗲𝗿𝘃𝗲𝗻𝗲 (𝗲.𝗴., 𝗶𝘀𝘀𝘂𝗲 𝗮 𝗧𝗥𝗢) 𝘁𝗼 𝗽𝗿𝗲𝘃𝗲𝗻𝘁 𝗗𝘂𝘁𝗲𝗿𝘁𝗲’𝘀 𝗮𝗿𝗿𝗲𝘀𝘁 𝗼𝗿 𝘀𝘂𝗿𝗿𝗲𝗻𝗱𝗲𝗿 𝗼𝗻 𝗮𝗻 𝗜𝗖𝗖 𝘄𝗮𝗿𝗿𝗮𝗻𝘁? 𝗪𝗵𝗮𝘁 𝗶𝗳 𝘁𝗵𝗲 𝗣𝗵𝗶𝗹𝗶𝗽𝗽𝗶𝗻𝗲 𝗴𝗼𝘃𝗲𝗿𝗻𝗺𝗲𝗻𝘁 𝗶𝘁𝘀𝗲𝗹𝗳 𝗮𝗴𝗿𝗲𝗲𝘀 𝘁𝗼 𝗰𝗼𝗼𝗽𝗲𝗿𝗮𝘁𝗲, 𝗰𝗮𝗻 𝘁𝗵𝗲 𝗦𝘂𝗽𝗿𝗲𝗺𝗲 𝗖𝗼𝘂𝗿𝘁 𝘀𝘁𝗶𝗹𝗹 𝘀𝘁𝗲𝗽 𝗶𝗻?

By Dean Ralph Sarmiento


Yes, the Philippine Supreme Court can intervene to prevent former President Duterte's arrest or surrender to the International Criminal Court (ICC) if it finds that such actions violate Philippine law or the Constitution. The Court's power of judicial review allows it to determine the legality of executive actions, including cooperation with the ICC.

𝗝𝘂𝗱𝗶𝗰𝗶𝗮𝗹 𝗥𝗲𝘃𝗶𝗲𝘄 𝗮𝗻𝗱 𝗧𝗥𝗢

The Supreme Court has the authority to issue a Temporary Restraining Order (TRO) to prevent irreparable harm while it deliberates on the merits of a case. In BAYAN MUNA v. ROMULO, G.R. No. 159618 (2011), the Court emphasized its power to review executive agreements and actions for compliance with domestic law and constitutional principles. Similarly, in PANGILINAN v. CAYETANO, G.R. No. 238875 (2021), the Court clarified that it retains jurisdiction to resolve justiciable controversies, even in matters involving foreign affairs, provided that constitutional rights or domestic laws are implicated.

In this case, Duterte's petition for a TRO would likely argue that the government's cooperation with the ICC violates his constitutional rights, particularly his right to due process and protection against unlawful arrest and detention. The Court could issue a TRO if it finds prima facie evidence of a legal violation or a risk of irreparable harm.

𝗘𝗳𝗳𝗲𝗰𝘁 𝗼𝗳 𝘁𝗵𝗲 𝗥𝗼𝗺𝗲 𝗦𝘁𝗮𝘁𝘂𝘁𝗲 𝗪𝗶𝘁𝗵𝗱𝗿𝗮𝘄𝗮𝗹

The Philippines' withdrawal from the Rome Statute, which took effect in 2019, does not absolve the country of obligations incurred while it was a State Party. Article 127 of the Rome Statute explicitly states that withdrawal does not affect the ICC's jurisdiction over crimes committed during the period of membership. This principle was acknowledged in PANGILINAN v. CAYETANO, G.R. No. 238875 (2021), where the Court noted that withdrawal from a treaty does not extinguish liabilities for acts committed before the withdrawal took effect.

Thus, the Supreme Court would need to determine whether the ICC's ongoing investigation and warrant for Duterte's arrest are valid consequences of obligations incurred while the Rome Statute was in force.

𝗔𝗽𝗽𝗹𝗶𝗰𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗼𝗳 𝗥𝗲𝗽𝘂𝗯𝗹𝗶𝗰 𝗔𝗰𝘁 𝗡𝗼. 𝟵𝟴𝟱𝟭

Republic Act No. 9851, also known as the Philippine Act on Crimes Against International Humanitarian Law, Genocide, and Other Crimes Against Humanity, provides a domestic legal framework for prosecuting international crimes. Section 17 of the law recognizes the principle of complementarity, which allows the ICC to exercise jurisdiction only when the Philippines is unwilling or unable to prosecute such crimes domestically.

If the government cooperates with the ICC, it implicitly acknowledges that domestic mechanisms are insufficient to address the alleged crimes. However, Duterte could argue that RA 9851 does not authorize the surrender of Philippine citizens to the ICC, particularly after the Rome Statute withdrawal. The Supreme Court would need to interpret RA 9851 in light of the Constitution and the country's treaty obligations.

𝗣𝗿𝗲𝘀𝗶𝗱𝗲𝗻𝘁𝗶𝗮𝗹 𝗜𝗺𝗺𝘂𝗻𝗶𝘁𝘆 𝗮𝗻𝗱 𝗙𝘂𝗻𝗱𝗮𝗺𝗲𝗻𝘁𝗮𝗹 𝗥𝗶𝗴𝗵𝘁𝘀

While Duterte is no longer immune from suit as a former President (De Lima v. Duterte G.R. No. 227635 (2019)), he retains the right to challenge actions that infringe on his constitutional rights. The Supreme Court has consistently upheld the protection of individual liberties, even in cases involving international obligations. For example, in BAYAN MUNA v. ROMULO, G.R. No. 159618 (2011), the Court emphasized that executive actions must comply with domestic law and constitutional safeguards.

𝗝𝘂𝗱𝗶𝗰𝗶𝗮𝗹 𝗥𝗼𝗹𝗲 𝗶𝗻 𝗥𝗲𝘀𝗼𝗹𝘃𝗶𝗻𝗴 𝗖𝗹𝗮𝘀𝗵𝗲𝘀 𝗕𝗲𝘁𝘄𝗲𝗲𝗻 𝗕𝗿𝗮𝗻𝗰𝗵𝗲𝘀

The judiciary serves as the final arbiter in disputes between the executive and individuals, particularly when constitutional rights are at stake. Even if the government consents to ICC cooperation, the Supreme Court retains the power to review the legality of such actions. As noted in PANGILINAN v. CAYETANO, G.R. No. 238875 (2021), the Court's role is to ensure that executive actions comply with the Constitution and domestic laws.

The has ruled that a person does not need a documented history of mental illness to claim legal insanity as a defense.

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division acquitted an accused in a homicide case due to insanity and ordered her confinement at the National Center for Mental Health (NCMH) for treatment.

The accused was charged with murder after her father found her naked, covered in blood, and chanting religious phrases over her best friend’s lifeless body. She claimed she attacked her best friend after she saw her grow horns and transform into a demon. She also reported hearing the Virgin Mary’s voice instructing her to place a cross into the victim’s heart, among other commands.

In acquitting the accused, the SC found that she showed enough evidence of insanity at the time of the crime. It clarified that proving legal insanity only requires evidence that the accused was deprived of intelligence either before, during, or immediately after the crime.

The SC stressed that while prior medical records can be relevant, they are not required to prove that the accused’s medical condition led to the crime. Therefore, the absence of documented psychiatric history should not be taken against the accused claiming legal insanity.

Read the full text of the Press Release at
https://sc.judiciary.gov.ph/sc-past-psychiatric-records-not-required-to-prove-legal-insanity/.

Read the full text of the Decision at
https://sc.judiciary.gov.ph/244692-2/.

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

The (SC) has reiterated that a notice to cancel a contract to sell real estate must be notarized under Republic Act No. 6552, popularly known as the Maceda Law.

In a Decision written by Associate Justice Antonio T. Kho, Jr., the SC’s Second Division upheld the validity of contracts to sell between State Investment Trust, Inc. (SITI) and spouses Carlos and Victoria Baculo (Spouses Baculo) after SITI failed to meet the Maceda Law’s cancellation requirements.

The Maceda Law’s purpose is to protect real estate buyers on installment payments against one-sided conditions in contracts.

SITI owned two parcels of land, which it offered to sell to Spouses Baculo through two contracts to sell. When the latter failed to complete payments, SITI sent letters demanding payment and, later, declaring the contracts to sell cancelled. The Spouses Baculo refused to vacate the property, leading Siti to file an ejectment case.

The SC ruled that while a seller may cancel a contract to sell under the Maceda Law on its own without going to court, it must still comply with Section 4 of the law, which requires: (1) a 60-day grace period for the buyer to settle overdue installments; (2) a notarized notice of cancellation from the seller; and (3) cancellation only after 30 days from the buyer’s receipt of the notarized notice.

In this case, the SC found that SITI’s letters were not notarized, and it failed to provide the required 60-day grace period, giving only five days to settle the balance.

Read the full text of the Press Release at
https://sc.judiciary.gov.ph/sc-notarized-notice-required-to-cancel-real-estate-contract-under-maceda-law/.

Read the full text of the Decision at https://sc.judiciary.gov.ph/237934-state-investment-trust-inc-vs-carlos-baculo/.

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

The (SC) has reiterated that a contract of sale of goods is completed by a mere agreement between the parties, even without a written document.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division directed Marcelina Villanueva (Villanueva) to pay Coca-Cola Bottlers Phils., Inc. (Coca-Cola) over PHP 600,000 for unpaid products delivered under their dealership agreement.

Coca-Cola sued Villanueva to collect payment for Coca-Cola products her business received but failed to pay for. It claimed it had a dealership agreement with Villanueva, who was operating under the name Vedge Trading.

Villanueva denied knowledge of the dealership agreement, claiming it was her nephews who actually managed the business, and that they should be held liable instead.

Ruling that Villanueva is liable to Coca-Cola for the entire unpaid obligation, the Supreme Court stated that while no written contract was presented, the sale of goods was proven through other evidence, such as signed delivery invoices confirming the purchase, payment terms, and actual delivery of the products.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-contract-of-sale-of-goods-finalized-by-mere-agreement-of-parties/

Read the full text of the Decision at https://tinyurl.com/6bbav392

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