Patriarcha v. Orfate
No confirmed citationJanuary 1, 1907
Study material, not legal advice. Written and checked by the PhilippineLaws team to the best of our knowledge; not reviewed by a lawyer. A digest is a summary — the full decision is the authority, so read it before you cite it.
Don't cite this from here. The docket on file (G.R. No. L-3624) could not be matched to any decision in the library, so it is not shown as a citation above. The case may well be real — find the reported citation before you use it.
Cited for
Proving Custom as a Fact
Why it matters
Established the foundational rule that a custom cannot be simply assumed or taken for granted — it must be proven as a fact in court, subject to the ordinary rules of evidence. Courts do not take judicial notice of local or indigenous customs; they must be established through testimony or documentary evidence.
Digest
No digest has been checked for this case yet. A draft is never shown — read the ruling itself, or write your own digest in the reader.