April 2025
62decisions- 01G.R. 273446Angelita a. Antonino v. Banco de Oro Universal Bank, Inc. Banco de Oro Universal Bank, Inc. Vs. Remedios a. Antonino and Angelita a. AntoninoA bank that cannot show proof it paid out a depositor's time deposits, while the depositors still hold the original certificates, must pay them, plus damages for failing to use the high care expected of banks.
- 02G.R. 259662Antonio Azurin, Jr. and Rafael Azurin v. Carlito ChuaA co-owner who knew of the sale of another co-owner's share and waited more than six years to act loses the right to buy it back, even if no written notice of the sale was ever given.
- 03G.R. 275978Domiciano and Anselma Herezo v. Ernesto MaquilingA co-owner can sell a specific part of shared land if the part does not exceed the co-owner's share and the other co-owners never objected, so that buyer gets a valid title.
- 04G.R. 257086Wilfrido* C. Wijangco, Represented by His Son, Andrew C. Wijangco v. Ucpb General Insurance Co., IncAn insurer that sits on a claim for more than 90 days without pointing out missing documents cannot later refuse to pay because the documents were incomplete, and a car that is recovered after being stolen at gunpoint does not cancel the insurance claim.
- 05G.R. 267998Eloisa Maliwat-Melad v. Amancio Reyes Melad and Republic of the PhilippinesA wife could not get her marriage declared void just by claiming that the person who married them was not the judge named in the marriage certificate, because she did not prove it.
- 06G.R. 228741Ronel Caridaoan y Calipio,• v. People of the PhilippinesA man who left his live-in partner for another woman was acquitted of psychological violence because the prosecution did not prove he deliberately meant to cause her mental anguish.
- 07G.R. 272590Marita S. Cabas v. Bernardita Vargas Feranil Vda. de PenaverdeA sick, elderly woman's will cannot be thrown out just because she was old, ill, sedated, or left everything to her helper, unless someone proves she did not understand what she was doing.
- 08G.R. 274959People of the Philippines v. Ryan de Castro y SerranoA man who offered three women for sex to undercover agents for PHP 500.00 each was convicted of qualified trafficking in persons and sentenced to life imprisonment.
- 09G.R. 249407Commissioner of Customs and Commissioner of Internal Revenue v. Air Philippines Corporation (Apc) Commissioner of Customs and Commissioner of Internal Revenue Vs. Philippine Airlines, IncAirlines that paid excise tax on imported jet fuel can claim a refund from the Bureau of Internal Revenue and the Court of Tax Appeals, not the Bureau of Customs, and the airlines proved they were exempt under their franchises.
- 10G.R. 260219& 260231 Datu Pax Ali S. Mangudadatu v. the Commission on Elections, Sharifa Akeel Mangudadatu, Azel v. Mangudadatu, and Bai Ali a. UntongA sitting mayor who files to run for governor of another province cannot claim to live in that province while still serving as mayor, and the Court ruled that if a winner is removed, the vice-governor takes over, not the runner-up.
- 11G.R. 260708People of the Philippines v. Abc260708The Court refused to overturn a rape conviction involving a minor and set clearer names and minimum damages for the different kinds of rape.
- 12G.R. 269921Spouses Noel M. Agullo and Leny Agullo, and Josephine Bermejo v. Lea Victa – Espinosa, Represented by Aurora a. VictaA landowner who has been dispossessed can file a case to recover possession in the regular court even before one year has passed, as long as the complaint does not allege force, intimidation, threat, strategy or stealth.
- 13G.R. 275800Elroy John M. Hagedorn v. House of Representatives of the Philippines, Hon. Ferdinand Martin G. Romualdez, in His Capacity as Speaker of the House of Representatives, Hon. Reginald S. Velasco, in His Capacity as Secretary General of the House of Representatives, and Hon. Maximo y. Dalog, Jr., in His Capacity as Chairperson of the Committee on Suffrage and Electoral Reforms of the House of RepresentativesWhen a House seat becomes vacant at least a year before its term ends, the Commission on Elections (COMELEC) must call and hold a special election on its own, without waiting for the House to issue a resolution.
- 14G.R. 257761Atty. Melita Go and Wayne Go v. Saint Jude Catholic School Manila, Inc., Fr. Marcelino Nicasio, Svd, Fatima de Guzman, and Spouses Eugene Lee and Joanne LeeA winning party who was already awarded attorney's fees as damages cannot also claim lawyers' appearance fees as costs of suit, because costs are limited to the small amounts fixed in the Rules of Court.
- 15G.R. 207118Republic of the Philippines and the City of Baguio v. the Association of Barangay Councils, Represented by Its President, Rufino M. PanaganBarangays may hold "Bingo sa Barangay" to raise money for barangay projects without getting a permit from PAGCOR or any other national or local office, because the Local Government Code and the PAGCOR charter both allow it.
- 16A.C. 13646Judge Janice R. Yulo-Antero v. Atty. William F. Delos SantosA lawyer who lied to jail officials to get his client released, and who ignored the Integrated Bar's orders, was fined PHP 300,000.00 even though he had already been disbarred in another case.
- 17G.R. 278582Ma. Gladys Cruz-Sta. Rita, Lorna T. Dy, Alexander P. Japon, Marina del Rosario, Monica R. Legaspi, Marciana B. Guinto, and National Power Corporation Recipient-Beneficiaries v. Commission on AuditThe National Power Corporation could not use its funds to buy private group health and life insurance for its employees, and the officers who approved it and the employees who benefited must return the money, except officers who only certified that funds were available.
- 18G.R. 254957-58Lily C. Lopez v. Lolito S. Lopez, Ma.* Rachel** Nicolette C. Lopez, Barbara O. Villas, Benedicto L. Villafuerte, Ma. Luisa I. Paras, Ruel S. Villacorta, Teresita C. Fernando, and Ispecialist Development Corporation Lolito S. Lopez, Mario S. Lopez, Andresito S. Lopez, Barbara O. Villas, Benedicto L. Villafuerte, Ma. Luisa I. Paras, Ruel S. Villacorta, Teresita C. Fernando, Lc Lopez Resources, Inc., and Conqueror International, IncOn reconsideration, the Court upheld the February 2019 shareholders' meetings and board elections of three family corporations, because the people excluded were not proven shareholders and the disputed share purchase could still be ratified.
- 19G.R. 273189People of the Philippines v. Cesar Oliman, Elias Raypan @ Ely, Ricardo Oliman y Enriquez @ Karding, Kenneth Deita y Belarmino, Analy Dequillo y Literal, Gary Gubatan y Baliscot, Marife de Jesus y Evangelista, and Gerry Enriquez y Sunga; Marife de Jesus y EvangelistaA search warrant that gives only an address shared by several houses is too vague to be valid, so the drugs found in the search cannot be used as evidence.
- 20G.R. 255266Republic of the Philippines v. Eduardo ManahanTo get title to land from the State through long possession, the applicant must prove the land was declared alienable and disposable (open to private ownership), and a CENRO certification and a surveyor's plan note are not enough without proper proof.
- 21G.R. 272507Department of Education, Represented by Dr. Estela Carino, in Her Capacity as Oic-Regional Director of Region II v. Princess Joama Marcosa a. CaledaA government office cannot refuse to leave private land just because the land is used for public purposes, unless the owner agreed to the use or sat on the right to object.
- 22G.R. 272461Vidya Dasi Mesina Ang v. Hon. Zarah R. Sanchez-Fernandez, Presiding Judge, Regional Trial Court of Dagupan City, Branch 15-Fc, Dakila Wesley S. Nabua, Sheriff IV, and Eric AbreauIn a custody fight over a child born outside marriage, the child's best interests come first, and the Court left her with her father instead of her mother because of the risk of sexual abuse in the mother's home.
- 23G.R. 255520Commissioner of Internal Revenue v. Stradcom CorporationThe BIR cannot seize a taxpayer's bank account to collect income tax that no assessment has been issued for and that the taxpayer's own return did not declare as due.
- 24G.R. 264870Xxx264870,* v. People of the PhilippinesCheating on a spouse, by itself, is not automatically a crime of violence against a woman under the Anti-VAWC law, and a husband was acquitted after his wife said she had not suffered the anguish the law requires.
- 25G.R. 188034Poro Point Management Corporation v. Bulk Handler'S Inc. Bases Conversion and Development Authority,* Vs. Bulk Handler'S Inc. Bases Conversion and Development Authority Vs. Bulk Handler'S Inc., Emmanuel P. Moran, Jr.,** Juanita U. Tan, Renato P. Venturina, and Poro Point Industrial Corporation Poro Point Management Corporation and Bases Conversion and Development Authority Vs. Bulk Handler'S Inc., Emmanuel P. Moran, Jr., Juanita U. Tan, Renato P. Venturina, and Poro Point Industrial CorporationUsing the wrong way to challenge a trial court's judgment does not stop the deadline from running, so a party that waits too long loses the chance to appeal, even in a large government joint-venture dispute.
- 26G.R. 221065Philippine Airlines, Inc. v. Romeo N. Ahmee, Millardo M. Aviñante, Represented by His Heirs, Margarita, Mario, Maita, Melanie and Millardo (Jr.), All Surnamed Aviñante, Danilo K. Bautista, Benjamin G. Blando, Jr., Ramon a. Belmonte, Filemon C. Cajator, Levi Patrick Cardenas, Catherine Marie a. Castillo, Ruben S. Castillo, Jr., Donald B. Cosip, Benjamin C. Delfin, Raul E. Diaz, Giovanni G.a. Diño, Jr., Ramon Claro J. Enriquez, Joseph Dc. Evangelista, Teodefrozo B. Flores, Manuel F. Foronda, Cesar S. Francia, Enrique L. Gaona, Jose T. Gil, Jr., Represented by His Heirs, Cecilia, Joe Henri, and James Paul Gil, Ma. Aurora C. Gloria, Estrellito F. Gutierrez, Reynaldo G. Iliscupides, Roberto T. Jabier, Emmanuel Ma. C. Justo, Eduardo E. Kilayko, Patrick C. Kimpo, Jorge S. Lacson, Ismael C. Lapus, Exequiel a. Lofranco, Potenciano M. Malilay, Geronimo Lawrence S. Mapeso, Maximo Vicente L. Matias, Jesus S. Medina, D' Artagnan E. Mercano, Rafael B. Misa, Alfredo M. Moises, Nicolas N. Montenegro, Arturo E. Perlada, Gabriel J. Piamonte, Edwin Benedict E. Pineda, Noel P. Porcuna, Ruben a. Pulma, Melvin B. Punzalan, Dante E. Rillorta, Carlos R. Terol, Represented by His Heirs, Ma. Cristina, Marie Caryl, Mari Christianne, Marie Charlene and Carlos Joseph Terol, Eduardo Sc Torio, Roberto P. Uson, and Bernardo M. Villegas Romeo N. Ahmee, Millardo M. Aviñante, Represented by His Heirs, Margarita, Mario, Maita, Melanie,. and Millardo (Jr.), All Surnamed Aviñante, Danilo K. Bautista, Benjamin G. Blando, Jr., Ramon a. Belmonte, Filemon C. Cajator, Levi Patrick Cardenas, Catherine Marie a. Castillo, Ruben S. Castillo, Jr., Donald B. Cosip, Benjamin C. Delfin, Raul E. Diaz, Giovanni G.a. Diño, Jr., Ramon Claro J. Enriquez, Joseph Dc. Evangelista, Teodefrozo B. Flores, Manuel F. Foronda, Cesar S. Francia, Enrique L. Gaona, Jose T. Gil, Jr., Represented by His Heirs, Cecilia, Joe Henri, and James Paul, All Surnamed Gil, Ma. Aurora C. Gloria, Estrellito F. Gutierrez, Reynaldo G. Iliscupides, Roberto T. Jabier, Emmanuel Ma. C. Justo, Eduardo E. Kilayko, Patrick C. Kimpo, Jorge S. Lacson, Ismael C. Lapus,* Exequiel a. Lofranco, Potenciano M. Malilay, Geronimo Lawrence S. Mapeso, Maximo Vicente L. Matias, Jesus S. Medina, D' Artagnan E. Mercano, Rafael B. Misa, Alfredo M. Moises, Nicolas N. Montenegro, Arturo E. Perlada, Gabriel J. Piamonte, Edwin Benedict E. Pineda, Noel P. Porcuna, Ruben a. Pulma, Melvin B. Punzalan, Dante E. Rillorta, Carlos R. Terol, Represented by His Heirs, Ma. Cristina, Marie Caryl, Marie Christianne, Marie Charlene and Carlos Joseph, All Surnamed Terol, Eduardo Sc. Torio, Roberto P. Uson, and Bernardo M. Villegas Vs. Philippine Airlines, IncAn employer that pays salaries through bank crediting must show that the bank received its payroll or advisory, and only then must the employees prove their accounts were not credited.
- 27G.R. 272300Reynaldo San Pedro* and Other Persons Acting in His Behalf v. Spouses Angelito Trinidad*** and Consuelo TrinidadWhen a regional trial court takes over and decides a case that a lower court wrongly tried, it is still acting as an appeals court, so the next appeal must be a petition for review and not a simple notice of appeal.
- 28G.R. 265570People of the Philippines v. Aron Akil y GuamalonA person cannot be convicted of carnapping when the owner never saw the thief's face, the police arranged a suggestive one-on-one identification, and the supposed confession was made without a lawyer.
- 29G.R. 266494Roger Galon Longno v. Skanfil Maritime Services, Inc., and Crown Shipmanagement, IncA seafarer whose back injury kept him unable to work for more than 240 days is treated as totally and permanently disabled, even if the third doctor gave only a partial disability grade.
- 30A.M. RTJ-25-092Edralyn Pangilinan v. Hon. Lelu P. Contreras, Presiding Judge, Regional Trial Court of Virac, Catanduanes, Branch 43A judge who carefully issued a search warrant is not liable for delay, but she was fined for barging into a congressional hearing to blame someone and for holding a press conference without going through the Court's channels.
- 31G.R. 265454Adan de Guzman Hisanza,* v. Bright Maritime Corporation, Navios Shipmanagement, Inc., Desiree P. Sillar, Georgios Stefanou, Natividad B. Ebron, Clarissa C. Mendoza, Rhodora S. Taboada, Konstantina Stefanou, and Webena D. DabucoIf the company doctor never gives a final and definite assessment within the treatment period, a seafarer is treated as totally and permanently disabled by law, and an interim rating does not count.
- 32G.R. 267833People of the Philippines v. Argie Bolagot y Pineda @ "Archie" and Rolly Batilaran y Toledo @ "Samantha"People who find customers for children and take a cut of the money are guilty of child abuse and qualified trafficking, even if the children went along willingly or the police set up a sting.
- 33G.R. 269362Heirs of Spouses Adriano Salise and Natividad Pagudar, Represented by Ranilo Salise, Heirs of Spouses Teodoro Virtudazo and Necitas Salise, Represented by Edison Virtudazo, Jerome Diolanto, Heirs of Spouses Eulalio Damasing, Sr. and Potenciana Labial, Represented by Eulalio Damasing, Jr., Heirs of Francisco Babayson and Simplicia Babayson, Represented by Niel M. Caduan,* Spouses Rufino Butihin and Cecilia Gagno, Heirs of Epetacio Pamisa, Sr. and Vegilia Virtudazo, Represented by Danilo Pamisa,** Franklin Pamisa, Sr., Heirs of Delfin Saarenas, Represented by Jaylon L. Ramos, Louis Philip L. Ramos,*** Felipe Virtudazo, Jr., Heirs of Angel Barbosa and Florencia Salise, Represented by Sarah B. Prigo,**** Felix Wabe, Serapen Surigao,***** Heirs of Reynaldo Salucot, Represented by Maximo S. Salucot, Jr., Larry Pamisa, Represented by Franklin B. Pamisa, Jr., Hegenio Paug, Marcelo Manique and Cecilia Carbon, Heirs of Enrique Carbon and Erlinda Somo, Represented by Guillermo P. Carbon, Maximo Borres, Heirs of Wilfredo Juanillo and Minda Villarmia, Represented by Minda Juanillo, Felix Requilme and Cerina Salvo, and the Heirs of Spouses Hilario Bacabis and Retificacion Dablo, Represented by Cynthia Marian Adoracion B. Mana-a v. Ricardo a. Gacula, Represented by His Attorney-in-Fact, Geoffrey GaculaFarmer-beneficiaries who did not appeal a DAR Secretary's order exempting land from agrarian reform lost the chance to challenge it, but their land titles cannot be cancelled until a separate, proper cancellation case is filed.
- 34G.R. 251180Jaime T. Dee, for Himself and as Attorney-in-Fact of Roberto v. Mabasa, Juanita M. Go,*** Leona Tan, Silvino v. Mabasa, Jr., Nancy Isabel Ong, Quintin Romeo v. Mabasa,**** Evelyn M. Sto. Domingo, Alexander Mabasa, Rita Huibonhua Mabasa, Lily M. Coseip, and Gloria Lim Vs. Union Bank of the PhilippinesA court can appoint a receiver to wind up a company whose corporate life has ended, even without a separate liquidation case, and an outsider like a debtor bank cannot intervene without a direct and immediate legal interest.
- 35G.R. 276735People of the Philippines v. Joseph Atanacio y Pagunaling and Jon Magno y LagamoTwo men convicted of selling and possessing shabu were acquitted because the police did not mark the seized drugs right away and the lab custody trail was incomplete.
- 36G.R. 262831Gianni de Munari v. Thelma Gagui Asprec Also Known as Thelma de Munari, Thelma Picotto and Thelma Centeno and the Civil Registrar GeneralPhilippine courts can hear a case to nullify a bigamous marriage between a foreigner and a Filipino even if the wedding was abroad, and the foreign husband or wife has the right to file it.
- 37G.R. 268461Republic Philippines, of the v. St. Augustine Realty and Development CorporationIf a land title was rebuilt administratively and nobody claimed any interest for two years, the owner can have the warning note on the title removed without publishing and posting notices.
- 38A.M. 2024-05-SCRe: Negligence and Inefficiency in the Performance of Duties of Ms. Eleonor S. Benbinuto, Administrative Officer II, Administrative Division, Philippine Judicial AcademyA court employee who keeps neglecting her work and ignoring her superiors' orders, even after being punished before, can be dismissed from the judiciary.
- 39A.C. 14062(Formerly Cbd Case No. 08-2188) Manuel H. Reyes v. Atty. Diosdado C. Sebrio, JrA lawyer who took a client's money for government paperwork, boasted of connections, never accounted for the money and did not repay a loan was found guilty of gross misconduct, and was fined and ordered to return PHP 870,000.00.
- 40G.R. 254543Vivien M. Cadungog , Substituted by Her Heirs, Vienne Andrea Kim Cadungog and Bien Andreu Cadungog, as Represented by Elena Camay and Jose Mari Cadungog,* v. Sung Ha JungA criminal court that acquits a condominium developer cannot also order her to settle contract claims with the buyer, and that part of the judgment is void because only the housing regulator can hear such claims.
- 41A.C. 14128(Formerly Cbd Case No. 19-6086) Wilma L. Zamora v. Atty. Makilito B. MahinayA lawyer who shops for a friendlier judge, files repeated motions to remove judges, and accuses opposing lawyers of plotting to kill him in a pleading can be suspended and fined.
- 42G.R. 251736Paolo Landayan Aragones v. Alltech Biotechnology Corporation, Octavio Eckhardt, and Matthew SmithA job offer that is accepted creates a binding employment contract, so an employer cannot simply cancel it before the start date without a valid, proven reason.
- 43G.R. 256343Benedicto Batara Ocampo and Daisy Garcia-Ocampo v. Noblesa Batara-Sapad and Ernesto C. BataraA verbal sale of land that has already been carried out, with the buyer in possession and holding the title, can be proven by testimony and can defeat the registered owner's heirs, but the buyer must still pay the unpaid balance with interest.
- 44G.R. 267541Grand Exploit Builder Development, Inc. v. Hoegaarden Realty CorporationCourts may re-examine the facts of a construction arbitration award only when there is real proof that the arbitrators were corrupt or biased, and merely disagreeing with the award is not enough.
- 45G.R. 271261Melco Resorts Leisure (Php) Corporation v. Commissioner of Internal RevenueA casino operator could not get back PHP 81,119,005.84 in VAT its suppliers charged it, because that money counted as part of the price it paid, but its refund claim was filed on time.
- 46G.R. 238383Janice L. Teologo and Jennifer Delos Santos,* v. People of the PhilippinesStore managers who withheld their crew's share of service charges committed ordinary theft, not qualified theft, because the money was taken from the employees and not from the employer who trusted the managers.
- 47G.R. 268308Elpidio Que v. Philippine Heart Center, Dr. Avelino P. Aventura, and First Associated Medical Distribution Co., IncA doctor who explained the risks of a new heart procedure and followed accepted medical practice is not liable when the patient dies of a risk that comes with the procedure.
- 48A.M. P-19-4001(Formerly Oca Ipi No. 19-4951-P) Almyra D. Yap, Librarian, Regional Trial Court, Angeles City, Pampanga v. Nida Gonzales, Legal Researcher, Branch 56, Same CourtA court employee who signs and notarizes an affidavit in another person's name without that person's consent is dismissed from the service.
- 49G.R. 258563People of the Philippines v. Ulysses Palconit ConsebidoA criminal case for failing to file a tax return can be dismissed for being filed too late, because the five-year period starts from the missed deadline when the BIR could easily have found out.
- 50G.R. 267315James Duavit y Villacarlos v. People of the PhilippinesA teacher who used his authority as class adviser to sexually touch a 15-year-old student was convicted, and the victim's lack of resistance did not make his story less believable.
- 51G.R. 261784Daniel T. So , Substituted by His Heirs, Namely: Jesusa H. So; Danalaine H. So; and Darrien Derrick H. So v. Food Fest Land, IncA winning party who filed for execution on time and was then delayed by court errors and the other side's objections can still enforce the judgment by motion, because the delay does not count against the five-year deadline.
- 52G.R. 252606People of the Philippines v. XxxA man who arranged for two 14-year-old girls to be paid for sex with other men was convicted of qualified trafficking in persons and sentenced to life imprisonment on each count.
- 53G.R. 268254Quezon City Government v. Rainier L. MadridRoads and open spaces in a private subdivision do not become city property just because a city ordinance requires developers to turn them over; the developer must actually transfer them, for example by a valid donation.
- 54G.R. 269981William Golangco Construction Corporation v. Philippine Commercial and International Bank (Now Banco de Oro Unibank, Inc.)A company that has been dissolved can still have its judgment award collected, and its stockholders can step in to do so, with interest running until the award is fully paid.
- 55G.R. 263794Commissioner of Internal Revenue v. Marily Development CorporationThe tax court cannot cancel a tax assessment for lack of a Letter of Authority when nobody raised that issue, and a taxpayer who claims the time to assess has run out must prove it with its own filing dates.
- 56G.R. 269598Rizalino B. Abella, Teodoro C. Abella, and Romilda S. Amago v. Atty. Sergio C. Sumayod, Jane a. Pica, Annaliza Yu, and Petron Corp., IncA court handling a will's probate may rule that a part of the will is invalid when the testator gave away property she did not own, but it cannot strike down her own share in co-owned property just because others said she was not the owner.
- 57G.R. 273438Department of Transportation (Dotr) and Department of Information and Communications Technology (Dict) v. Digital Telecommunications Philippines, Inc. (Digitel)The government cannot appeal a court order to execute a final arbitration award, and it cannot refuse to hand over facilities that a private company already paid for by claiming they are exempt government property.
- 58G.R. 256021Rural Bank of San Mateo Isabela, Inc., Represented by Katrina Marie Pilapil in Her Capacity as Chief Operating Officer v. Myrvin a. Ramales and Josie a. Ramales Alvarez-Ramales School Foundation, Inc., Represented by Marjorie de Guzman Vs. Rural Bank of San Mateo, (Isabela) IncA bank that loses a motion to dismiss must challenge it by certiorari, not an appeal, but it still lost here, and a school that could not prove its own title to land could not stop the bank's writ of possession.
- 59G.R. 270948Department of Finance-Revenue Integrity Protection Service (Dof-Rips), Represented by Joel M. Apolonio and Johnny S. Lassin v. Office of the Ombudsman and Rafael Mendoza Merencilla (Sg-24), Chief Customs Control Officer, Bureau of Customs, Rainier R. Merencilla, Rupert R. Merencilla, Riane R. Merencilla, and Ryan R. MerencillaA new Ombudsman may review and reverse an earlier Ombudsman's decision to file a forfeiture case, and a complainant cannot use the right to speedy disposition of cases to force that case forward.
- 60G.R. 262376People of the Philippines v. Xxx262376 and Yyy262376Parents who used their young children and a niece for live online sexual shows for foreign viewers were convicted of qualified trafficking, child abuse and child pornography, and their attack on the search of their home failed.
- 61G.R. 265302People of the Philippines v. Cicl Xxx265302A teenager who committed rape of a very young child can be held criminally responsible if he acted with discernment, but because he was a minor his penalty is lowered, and since the death penalty no longer exists, the lowering is counted from reclusion perpetua.
- 62A.C. 14378(Formerly Cbd Case No. 23-6847) Roan Amor Dator-Miles v. Atty. Vanessa Joyce I. MongeA lawyer who tricked a friend into a sham investment and left her paying a school loan she had co-signed was disbarred, because lawyers must be honest even in their private dealings.