Bonifacio Dines Donato Law Office

12/03/2026

The (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤 has upheld the validity of a Department of Justice (DOJ) circular that raised the standard of proof in preliminary investigations and inquest proceedings from probable cause to prima facie evidence with reasonable certainty of conviction.

In a Decision written by written by Associate Justice Japar B. Dimaampao, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 ruled that Department Circular No. 15, series of 2024 containing the 2024 𝘋𝘖𝘑-𝘕𝘢𝘵𝘪𝘰𝘯𝘢𝘭 𝘗𝘳𝘰𝘴𝘦𝘤𝘶𝘵𝘪𝘰𝘯 𝘚𝘦𝘳𝘷𝘪𝘤𝘦 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘗𝘳𝘦𝘭𝘪𝘮𝘪𝘯𝘢𝘳𝘺 𝘐𝘯𝘷𝘦𝘴𝘵𝘪𝘨𝘢𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘐𝘯𝘲𝘶𝘦𝘴𝘵 𝘗𝘳𝘰𝘤𝘦𝘦𝘥𝘪𝘯𝘨𝘴 (𝘋𝘖𝘑 𝘙𝘶𝘭𝘦𝘴), is a valid exercise of the DOJ’s authority over prosecutorial processes.

Under the DOJ Rules’ new standard of proof in preliminary investigations and inquest, prosecutors must ensure that the evidence to charge a person with a crime must sufficiently establish all the elements and consequently warrant a conviction.

Atty. Hazel L. Meking questioned the DOJ Rules before the SC, claiming that the DOJ encroached on the SC’s constitutional authority to promulgate rules of pleading, practice, and procedure in all courts. She argued that the DOJ Rules effectively revised Rule 112, Section 3(a) of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘳𝘪𝘮𝘪𝘯𝘢𝘭 𝘗𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦, which provides that the quantum of evidence in preliminary investigations is probable cause.

The SC dismissed her petition and reiterated its ruling in 𝘈.𝘔. 𝘕𝘰. 24-02-09-𝘚𝘊, which recognized the DOJ’s authority to promulgate its own rules on preliminary investigations and inquest proceedings.

The SC held that the DOJ Rules govern only the conduct of preliminary investigations and inquests by prosecutors, which are executive functions. These Rules, however, do not extend to judicial proceedings as the power to promulgate rules of procedure over them remains under the authority of the Supreme Court.

The SC noted it had already recognized preliminary investigation as the exclusive domain of prosecutors when it revised the Rules of Criminal Procedure in 2005.

In 2024, through 𝘈.𝘔. 𝘕𝘰. 24-02-09-𝘚𝘊, the SC also ordered the repeal of provisions in Rule 112 which are inconsistent with the DOJ Rules to harmonize them.

The SC’s constitutional rule-making authority over judicial proceedings remains supreme, as well as its power to correct grave abuse of discretion in any prosecutorial rule or action that violates constitutional rights.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=161871

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=161853

Read the Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=161858

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

12/03/2026

Meet our lawyers!

Before becoming lawyers, they were students of different fields. From pre-law courses to law school and the bar, every journey is unique.

*There is actually no required undergraduate degree for law school. Lawyers come from different academic backgrounds.

08/03/2026

✨Happy International Women’s Day!

Celebrating the strength, grace, and power of women everywhere. Today, we honor the women who inspire, lead, and uplift others every day.🌸

To every woman making a difference, your strength and courage inspire the world! 🥂

03/03/2026

Atty. Jose Adrian M. Bonifacio delivers a lecture today for the MCLE (Mandatory Continuing Legal Education), sharing insights on the “Obscurities of Lawyering” before fellow members of the Bar at Hotel Supreme, Baguio City.

The MCLE is organized by the Integrated Bar of the Philippines – Baguio-Benguet Chapter covering 8th and 9th compliance.

27/02/2026

We welcome to the team our new associate - Atty. Jeanette Angayon. Enjoy the facinating world of law practice.

25/02/2026

Commemorating 40 years of the EDSA People Power Revolution.

A peaceful movement that showed the world the strength of unity, faith, and democracy.

May its lessons guide us today and tomorrow.

Remembering the spirit of EDSA and the voices that shaped our nation 🇵🇭

24/02/2026

23/02/2026

Today we honor the rich heritage, enduring legacy, and invaluable contributions of the Ibaloy people, the original stewards of this land we call home.

While the Proclamation formally celebrates the Ibaloys of Baguio City, our warmest greetings extend beyond the city’s borders, to all Ibaloys in Benguet, across the Cordillera Region, and to those residing in other parts of the nation and the world.

It is with pride that we share that both Atty. Lucille Arianne Donato and Atty. Kenjo Ernesto Bay-an are of Ibaloy descent and members of the Ibaloy communities of the province of Benguet, a meaningful reflection of office's deep cultural roots and enduring connection to the community it serves.

Onpalapalad kitejon emin! Happy Ibaloy day!

📸 In the photo is Lola Andrea Kimmayong in Poblacion, Itogon, Benguet. Photo by Melvin Carantes via Wikipedia licensed under CC BY-SA 4.0.

20/02/2026

28/01/2026

Baguio court convicts former insurance manager of estafa, orders ₱81.9M restitution

By Mia Magdalena Fokno
January 28, 2026

BAGUIO CITY, Philippines — (Third Update) A Regional Trial Court (RTC) in Baguio City has convicted Catherine Aquino Belleza, a Baguio-based former insurance manager identified in court records as having served as a regional unit head of AXA Philippines, of multiple counts of estafa after finding that she deceived several individuals into investing large sums of money in business ventures that were later found by the court to be non-existent.

In a 47-page decision dated January 27, 2026, the court found Belleza guilty beyond reasonable doubt of four counts of estafa under Article 315, paragraph 2(a) of the Revised Penal Code, as amended by Republic Act No. 10951.

The decision was penned by Presiding Judge Michael V. Francisco of the RTC in Baguio City.

The case

According to the court, Belleza repeatedly told investors that their money would be placed in legitimate, profit-generating businesses, which she claimed were connected to government-related projects involving Camp Crame, Manila-based financing operations, and mining activities. These ventures were presented as lawful, secure, and capable of generating steady returns.

These representations were made before and during each release of funds, often accompanied by assurances that the investments were safe, that collections were ongoing, and that returns were guaranteed. In the early stages, interest payments were made—something the court said reinforced the appearance of legitimacy and encouraged investors to release more money.

However, trial evidence showed that the supposed businesses did not exist. Instead, the funds were later found to have been diverted to casino-related financing, which the court described as undocumented, high-risk, and never disclosed to the complainants at the time they agreed to invest.

The court rejected Belleza’s claim that she had eventually disclosed the true nature of the transactions, ruling that later explanations cannot undo earlier deception that already caused investors to part with their money. It emphasized that estafa is not about a simple failure to pay, but about deceit employed from the very beginning to obtain money.

Testimony and AXA connection

In its ruling, the court cited the testimonies of complainants who said Belleza introduced herself to them as a manager and regional unit head for the Cordillera Administrative Region of AXA Philippines, a factor that contributed to their trust. One complainant testified that dealings with Belleza began in 2017, while another said transactions started in 2019.

Belleza, for her part, testified that she openly discussed casino financing with colleagues inside their AXA office, according to the decision.

Following the promulgation of the ruling, AXA Philippines, through company representatives, publicly dissociated itself from Belleza’s activities.

“Her fraudulent activities were conducted entirely in her personal capacity. The investment schemes mentioned in the court decision have absolutely no connection to AXA Philippines or its legitimate insurance business,” the company’s representatives told Rappler in an email Wednesday night.

“AXA Philippines was not a party to any of the legal proceedings and has no involvement whatsoever in Ms. Belleza’s criminal conduct,” the statement added. The company said Belleza was terminated from AXA in June 2021.

Reliance and damage

The court found that the complainants relied on Belleza’s representations because of her professional position, prior dealings, personal relationships, and her initial compliance in paying interest.

This reliance, the court said, was real and decisive. The complainants would not have released their money had they known it would be used for casino financing or other undisclosed purposes.

Because of this fraudulent inducement, the complainants suffered substantial financial losses, with large portions of their principal investments remaining unpaid despite repeated demands. The court clarified that partial interest payments do not erase criminal liability when the principal amount is not returned.

The ruling and penalties

The court ruled on each of the four estafa cases separately, imposing prison sentences and ordering restitution corresponding to the amount lost in each case:
• In one case, Belleza was sentenced to an indeterminate penalty of eight (8) years and one (1) day of prisión mayor as minimum to fifteen (15) years of reclusión temporal as maximum, and ordered to pay ₱19.2 million in actual damages.
• In another case, the court imposed an indeterminate sentence of ten (10) years of prisión mayor as minimum to twenty (20) years of reclusión temporal as maximum, with an order to pay ₱41.7 million in actual damages.
• In a third case, Belleza was sentenced to an indeterminate penalty of four (4) years and two (2) months of prisión correccional as minimum to eleven (11) years of prisión mayor as maximum, and ordered to pay ₱11.5 million in actual damages.
• In a fourth case, the court imposed an indeterminate sentence of four (4) years and two (2) months of prisión correccional as minimum to ten (10) years of prisión mayor as maximum, and ordered Belleza to pay ₱9.5 million in actual damages.

All monetary awards carry legal interest at the rate of six percent (6%) per annum, computed from the finality of the judgment until fully paid.

The court further ruled that Belleza is civilly liable under Article 100 of the Revised Penal Code, making the financial obligations separate from and in addition to the prison sentences.

The cases were actively prosecuted for the private complainants by Attys. Jose Adrian Bonifacio and Lucille Arianne Donato.

28/01/2026

✨7 years in the making ✨

Built with passion, strengthened by teamwork, and driven by purpose. Cheers to the journey and the years still to come.

From day one to year seven what a journey it’s been. Thank you for trusting, supporting, and growing with us.

08/01/2026

It is with immense pride and honor that we congratulate Atty. Jeanette M. Angayon for passing the 2025 Bar Examinations. She was our first legal secretary when the Bonifacio Dines Donato Law Office was established in tne year 2019. She juggled work and law studies for some time until finally getting the coveted dot when the Supreme Court announced the bar examination results yesterday. Cheers!