SM Baguec Law

17/07/2026

𝗕𝗜𝗥 𝗜𝗦𝗦𝗨𝗘𝗦 𝗙𝗔𝗤𝘀 𝗢𝗡 𝗧𝗛𝗘 𝗔𝗣𝗣𝗟𝗜𝗖𝗔𝗧𝗜𝗢𝗡 𝗙𝗢𝗥 𝗢𝗡𝗘𝗧𝗧 𝗖𝗢𝗠𝗣𝗨𝗧𝗔𝗧𝗜𝗢𝗡 𝗦𝗛𝗘𝗘𝗧 (𝗢𝗖𝗦) 𝗔𝗡𝗗 𝗘𝗟𝗘𝗖𝗧𝗥𝗢𝗡𝗜𝗖 𝗖𝗘𝗥𝗧𝗜𝗙𝗜𝗖𝗔𝗧𝗘 𝗔𝗨𝗧𝗛𝗢𝗥𝗜𝗭𝗜𝗡𝗚 𝗥𝗘𝗚𝗜𝗦𝗧𝗥𝗔𝗧𝗜𝗢𝗡 (𝗲𝗖𝗔𝗥)

Find the full text of the Circular here: https://tinyurl.com/RMC75-2026

𝗕𝗜𝗥 𝗜𝗦𝗦𝗨𝗘𝗦 𝗙𝗔𝗤𝘀 𝗢𝗡 𝗧𝗛𝗘 𝗔𝗣𝗣𝗟𝗜𝗖𝗔𝗧𝗜𝗢𝗡 𝗙𝗢𝗥 𝗢𝗡𝗘𝗧𝗧 𝗖𝗢𝗠𝗣𝗨𝗧𝗔𝗧𝗜𝗢𝗡 𝗦𝗛𝗘𝗘𝗧 (𝗢𝗖𝗦) 𝗔𝗡𝗗 𝗘𝗟𝗘𝗖𝗧𝗥𝗢𝗡𝗜𝗖 𝗖𝗘𝗥𝗧𝗜𝗙𝗜𝗖𝗔𝗧𝗘 𝗔𝗨𝗧𝗛𝗢𝗥𝗜𝗭𝗜𝗡𝗚 𝗥𝗘𝗚𝗜𝗦𝗧𝗥𝗔𝗧𝗜𝗢𝗡 (𝗲𝗖𝗔𝗥)

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 75-2026, providing Frequently Asked Questions (FAQs) to guide taxpayers and other stakeholders on the application, processing, and issuance of the One-Time Transaction (ONETT) Computation Sheet (OCS) and the Electronic Certificate Authorizing Registration (eCAR) for property transactions.

The Circular consolidates key policies and procedures covering ONETT transactions, including the applicable type of tax/es, filing and payment procedures, documentary requirements, processing offices, prescribed processing timelines, and other common concerns involving the transfer of real properties, shares of stock, donations, and estates. It also clarifies the requirements for the issuance, replacement, and validity of eCARs, as well as the application of relevant tax rules in various transaction scenarios.

The issuance aims to provide taxpayers with clearer guidance on ONETT transactions, promote uniform implementation of existing policies, and facilitate faster and more efficient processing of applications for OCS and eCAR.

For the full text of RMC No. 75-2026, visit the BIR website or access the Circular through this link: https://tinyurl.com/RMC75-2026

30/05/2026

Hey, Notaries of Baguio! 🤠 If you're newly commissioned and have already started notarizing this May 2026, keep in mind that you are required to submit your first notarial report on or before June 10, 2026. You'll want to make time for it, as the preparation of required attachments is quite matrabaho.😆

Check out this post from the RTC OCC of Baguio to see the templates - https://www.facebook.com/100089768833030/posts/𝑭𝒓𝒐𝒎-𝑹𝑻𝑪-𝑶𝑪𝑪-𝑩𝒂𝒈𝒖𝒊𝒐effective-june-21-2025-all-notaries-public-for-and-in-the-cit/666984449637177/

Kindly note that while the given template covers January to May 2025 (first compliance period since effectivity), we are currently required to report on a monthly basis. Also, we are only required to transmit scanned copies of ACKNOWLEDGED documents, so no need to scan jurats and others.

Lastly, to everyone, please take note of the new email address for sending notarial reports: [email protected]

Congratulations to our newly appointed notaries public! 🎉🎉
-

23/05/2026

May 22, 2026 in Bokod | Had a fulfilling experience volunteering at the Care and Share Outreach Program of the UC College of Arts and Sciences in Barangay Karao, Bokod, Benguet. It was a meaningful initiative bringing health services, counseling, government desks, and legal aid straight to the indigenous community.

Traveled 2.5 hours to spend the day at the Karao Elementary School with the warmest people. It was truly an amazing experience made more memorable by their generosity — they gave us each a whole tray of fresh large eggs from their farm and a jar of good chili! In this economy? 🥹 Oh we are happy.

Salamat po UC CAS for the opportunity to serve the people, and to Barangay Karao for welcoming us with open arms. Our hearts (and kitchens) are so full! 🤗❤️

14/05/2026

HOW TO APPLY FOR A NOTARIAL COMMISSION IN BAGUIO CITY?

I was recently commissioned as Notary Public for Baguio City. Due to the volume of messages I get from lawyer friends and new applicants, I came up with this simplified but not-so-brief guideline based on my personal experience for the reference of new petitioners in Baguio. I've also included access to sample forms and to the pertinent rules and guidelines.

Hope this helps!🌻

1️⃣ FIRST, choose a jurisdiction. You cannot be a notary public for multiple jurisdictions.

2️⃣ Secure a checklist of requirements from the RTC-OCC.

3️⃣ File your verified petition and wait for the raffling of publication. Take note of the schedule of the following: publication, submission of formal offer of evidence, and summary hearing.

4️⃣ Claim your copy of the newspaper plus other documents from the publisher after publication.

5️⃣ Submit your Formal Offer of Evidence to the OCC.
6️⃣ Attend the summary hearing and take the oath.
7️⃣ FINALLY, note all the compliance requirements.

The notarial commission is valid for two years - from the date of commission to December 31st of the immediately succeeding year. Renew before expiry.

-

07/05/2026

👩‍⚖️ FAKE NUMBERS HAVE REAL CONSEQUENCES. In a 2025 pronouncement, the Supreme Court disbarred a lawyer for falsifying his MCLE compliance, proving once again that integrity isn’t optional in the legal profession.

The Mandatory Continuing Legal Education (MCLE) is a mandatory three-year cycle designed to ensure that members of the Philippine Bar remain updated on the latest laws, jurisprudence, and ethical standards. This is most important to older lawyers; however, not even the newly admitted lawyers are exempted. The MCLE is similar to the Continuing Professional Development (CPD) required of other licensed professionals.

A lawyer’s MCLE compliance number must be explicitly stated in all pleadings filed before courts and quasi-judicial bodies, as well as in every document notarized by them. Failure to include this simple information may render one's pleadings a mere scrap of paper. But to falsify it would amount to a grossly immoral act of deceit that is unacceptable and a clear violation of the Code of Professional Responsibility and Accountability, and therefore a ground for disbarment as can be read in the case In re: Civil Case No. B-10581 Vs. Atty. Jose R. Hidalgo (A.C. No. 14311. October 7, 2025).
-

The has disbarred a lawyer for using a false Mandatory Continuing Legal Education (MCLE) compliance number in his pleadings.

In a 𝘗𝘦𝘳 𝘊𝘶𝘳𝘪𝘢𝘮 Decision, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 disbarred Atty. Jose R. Hidalgo (Atty. Hidalgo) for dishonest conduct in violation of the 𝘊𝘰𝘥𝘦 𝘰𝘧 𝘗𝘳𝘰𝘧𝘦𝘴𝘴𝘪𝘰𝘯𝘢𝘭 𝘙𝘦𝘴𝘱𝘰𝘯𝘴𝘪𝘣𝘪𝘭𝘪𝘵𝘺 𝘢𝘯𝘥 𝘈𝘤𝘤𝘰𝘶𝘯𝘵𝘢𝘣𝘪𝘭𝘪𝘵𝘺 (𝘊𝘗𝘙𝘈).

Atty. Hidalgo represented the defendant in a malicious prosecution case pending before Branch 153, Regional Trial Court, Biñan City. In the answer he filed for his client, Atty. Hidalgo included his MCLE compliance number, which is required for lawyers.

The plaintiff's lawyer filed a motion to expunge Atty. Hidalgo's answer from the records, claiming that he did not actually comply with the MCLE requirements. Attached to the motion was a Certification from the MCLE Office stating that Atty. Hidalgo had not complied from the first compliance period up to the present.

In ordering the disbarment of Atty. Hidalgo, the SC emphasized that Canon II of the 𝘊𝘗𝘙𝘈 requires lawyers to act with propriety and maintain the appearance of propriety in personal and professional dealings, observe honesty, respect and courtesy, and uphold the dignity of the legal profession consistent with the highest standards of ethical behavior.

Lawyers are also required under Canon III to uphold the Constitution, obey the laws of the land, and promote respect for laws and legal processes.

The SC held that Atty. Hidalgo violated these Canons, stating that his act of indicating false information in the pleadings he filed “constitutes bad faith and dishonesty, and shows blatant disrespect of the courts and its rules.”

The SC also fined Atty. Hidalgo PHP 35,000 for willful disobedience, a less serious offense, for ignoring the IBP's order when he did not submit an answer and a verified position paper.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=164745.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164728.

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

02/05/2026

🧏‍♀️Jae-oh arrives home to find his drunken, abusive father threatening his younger brother with a knife. He fights him off, but the father attacks him next, and in the struggle, Jae-oh accidentally stabs his father with the same knife. In the K-drama world, Jae-oh was sentenced to 3–5 years of imprisonment despite defending his brother and voluntarily surrendering. Would his fate be the same if this happened in the Philippines?

🎯NO. JAE-OH WOULD LIKELY BE ACQUITTED UNDER PHILIPPINE LAW BECAUSE HIS ACTIONS CONSTITUTE A VALID SELF-DEFENSE AND DEFENSE OF A RELATIVE.

Articles 11(1) and 11(2) of the Revised Penal Code provide that a person who acts in defense of themself or their rights, or of their brother's person or rights, incurs no criminal liability, provided there is (a) unlawful aggression; (b) reasonable necessity of the means used to prevent it; (c) a lack of sufficient provocation on the part of the person defending themself, and (d) in case the relative provoked the aggressor, the person defending had no part in it.

Here, the father’s act of threatening the younger brother with a knife and redirecting his aim at Jae-oh is a clear case of unlawful aggression, and Jae-oh's act of fighting him off, even if it resulted in death, is a rational response to that threat.

Consequently, since all elements of the justifying circumstance are present, Jae-oh is free from both criminal and civil liability.

-----

Article 11 of the Revised Penal Code provides a list of Justifying Circumstances, which if appreciated by the court would acquit the accused from the crime charged. The law tells us that there is no "criminal liability" in such cases because the act committed is actually lawful. It is based on the natual impulse for self-preservation that is innate to humans beings; hence, "lawful defense" is in fact an exercise of a right.

Art. 11(1): Self-Defense - "Anyone who acts in defense of his person or rights"
Elements (U-R-L):
(1) Unlawful Agression - a condition sine qua non (i.e. indispensable requirement). There can be no Reasonable Necessity or Lack of Provocation to speak of or without a right to defense, which only arises in the presence of an unlawful assault or threat to attack in an immediate and imminent manner. Oral threats, insults, shoving, and mere threatening stances do not constitute unlawful agression.

(2) Reasonable Necessity of the Means Employed to Prevent or Repel the Unlawful Aggression - Doctrine of Rational Equivalence applies.

(3) Lack of Sufficient Provocation on the part of the person defending himself - To discredit defense under Article 11, provocation must be sufficient, i.e. proportionate to the act of aggression and adequate to stir the agggressor to its commission. And it must also be the proximate and immediate to the aggression.

Art. 11(2): Defense of Relatives - "Anyone who acts in defense of the person or rights of his spouse, ascendants, descendants, or legitimate, natural, or adopted brothers or sisters or of his relatives by affinity in the same degrees, and those by consanguinity within the fourth civil degree..."
Elements (U-R-N):
(1) Unlawful Agression
(2) Reasonable Necessity of the Means Employed to Prevent or Repel it
(3) No Provocation on the part of the person defending their relative (in case the relative being defended provoked the aggressor in some way). This does not mean that provocation by the relative defended is necessary; provocation by such relative is immaterial. The law simply tells us that in case the relative defended provoked the aggressor, the defending relative must have had no part in it. Otherwise, the defense of relative has no merit.
* Note that when there is mutual aggression, such as when two people are fighting or about to fight, the relative of either party cannot jump into the scene and lethally strike the other party, for the subsequent death of the subdued party would be a clear case of homicide and not a defense of one's relative.


In both cases of defense, mistake of fact may be appreciated. Thus, a person validly defended themself when someone from behind them in a dark alley suddenly covers their mouth, and they executed a harsh blow to the attacker, even if that attacker turned out to be a prankster friend.

-----

Like and follow our page to stay tuned to more content like this.

13/04/2026

Grateful to the IBP Baguio-Benguet Chapter for allowing us inductees to take an extension of our Oath before Justice Amy C. Lazaro-Javier, our Bar Mom. I purposely wore the same attire from the February 6, 2026 Oath Taking and Roll Signing Ceremony for continuity. ☺️

Taken during the IBP Testimonial Dinner | April 10, 2026 | Newtown Plaza Hotel, Baguio City