GV Law Office & Notary Public

03/11/2025

Public Advisory

31/10/2025

To our valued clients, as we commemorate Undas and honor our departed loved ones, our office will be closed on October 31 to November 2.

We will resume regular operations on Monday, November 3, 2025.

Thank you.

31/10/2025

The 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session yesterday, October 28, 2025, resolved to direct the Office of the Court Administrator (OCA) to monitor the filing of cases involving corruption in infrastructure projects before the Regional Trial Courts.

Once such cases are filed, the Supreme Court will designate special courts to exclusively hear and decide corruption-related cases arising from infrastructure projects.

In line with this initiative, the Supreme Court continues to implement reforms under the Strategic Plan for Judicial Innovations 2022-2027, including the development of eCourt PH and other digitalization projects aimed at enhancing efficiency, transparency, and accountability in the Judiciary. These reforms cover all court levels: the trial courts, the Court of Appeals, the Sandiganbayan, the Court of Tax Appeals, and the Supreme Court.

Read the full text of the Press Briefer at

The full text of the Resolution in A.M. No. 25-10-24-SC will be uploaded to the SC website once available.

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

31/10/2025

Inaprubahan ng En Banc ng ang Mga Tuntunin sa Filipino Sign Language (FSL) sa Hudikatura o Rules on Filipino Sign Language (FSL) Interpreting in the Judiciary, isang makasaysayang hakbang na nagtataguyod sa paggamit ng FSL sa mga paglilitis sa hukuman para matiyak ang pantay na akses sa katarungan para sa komunidad ng mga bingi o d/Deaf.

Isinakatuparan ng FSL Rules ang Republic Act No. 11106 o ang Filipino Sign Language Act at pinagtibay ang pangako ng Estado sa ilalim ng United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) na tiyakin ang ganap na pakikilahok ng mga bingi o d/Deaf na Pilipino sa mga prosesong hudisyal.

Inihanda ng Technical Working Group na pinamunuan ni Associate Justice Japar B. Dimaampao at binubuo ng mga kinatawan mula sa Office of the Court Administrator (OCA), mga kinatawan ng mga hukuman sa unang antas at appellate courts, ang Komisyon sa Wikang Filipino, mga organisasyon ng mga bingi, at mga grupo ng interpreter, pinahusay ang FSL Rules sa pamamagitan ng malawakang pagpupulong, konsultasyon sa mga stakeholder, at writeshop na isinagawa noong unang bahagi ng taong ito.

Kabilang sa mga pangunahing probisyon ng FSL Rules ang obligadong pagtalaga ng mga kwalipikado at kinikilalang FSL interpreter sa lahat ng paglilitis sa hukuman na kinasasangkutan ng mga bingi o d/Deaf na partido o testigo, para matiyak ang ganap at pantay na akses sa katarungan.

Itinatakda rin ng FSL Rules ang mga pamantayang etikal at propesyonal na gagabay sa mga court interpreter sa pagtupad ng kanilang tungkulin, kasama ang mga malinaw na pamamaraan para sa pagkilala at pagbabayad sa mga interpreter.

Pinahihintulutan din ng FSL Rules ang parehong on-site at remote interpreting, na may mga itinakdang mekanismo para mapanatili ang katumpakan, pagiging kompidensiyal, at pagiging maaasahan ng mga interpretasyon sa lahat ng paraan ng pagsasagawa nito.

Basahin ang buong teksto ng press briefer sa https://sc.judiciary.gov.ph/press-briefer-october-29-2025/.

Ang buong teksto ng FSL Rules ay ia-upload sa website ng Korte Suprema kapag ito ay available na.

Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.

19/08/2025

26/06/2025

THE COURT CANNOT FORCE A SPOUSE TO STAY IN A LOVELESS MARRIAGE—SUPREME COURT

| The Supreme Court (SC) has ruled that a spouse’s “inability to love or emotionally connect with their partner,“ if rooted in a genuine personality disorder, could be deemed as evidence to prove psychological incapacity in marital obligations.

In a 16-page decision penned by Senior Associate Justice Marvic Leonen, the SC's Second Division granted the petition of Ronald Boado to annul his marriage to his wife, Florence Galvez-Boado, on the ground of his psychological incapacity.

Their love story started when they met in 1999. Roughly three years later, or in 2002, they decided to settle down and marry each other. Florence and Ronald decided not to live together immediately, as Ronald worked in Saudi Arabia.

During Ronald's brief vacation in 2004, they held a church wedding, after which the husband returned abroad. A year later, he came back to the Philippines, which served as their opportunity to live together. Ronald and Florence were blessed with two children: a son in 2007 and a daughter in 2012. As the years passed by, their relationship began to turn sour due to frequent misunderstandings and periods of separation.

In 2016, Ronald filed a petition for nullification of marriage on the ground of his psychological incapacity. He attached a psychologist's diagnosis, which showed that he had passive-aggressive personality disorder—an illness marked by emotional detachment and difficulty maintaining close relationships.

Initially the Regional Trial Court granted the petition, saying the petitioner had sufficiently proven psychological incapacity in a legal sense, but the said ruling was later reversed by the Court of Appeals. This prompted Ronald to elevate the case before the Supreme Court.

In reinstating the RTC's ruling and deciding in favor of Ronald, the high court said his psychological incapacity had been sufficiently proven. It cited Article 36 of the Family Code, which states that a marriage may be declared void if one or both spouses are psychologically incapable of fulfilling essential marital obligations—even if such incapacity manifested only after the wedding.

The SC found that Ronald's incapacity was deeply rooted in his personal character and had existed before the marriage. It emphasized that psychological incapacity may not be immediately visible and may surface only later in the relationship.

It added that Ronald's inability to emotionally connect stemmed from an upbringing marked by strictness and emotional immaturity from his parents. While he could provide for his family financially, he struggled to meet his wife’s emotional needs, including basic companionship.

“Loving one’s spouse is an important, if not the most important, essential marital obligation,” the Supreme Court said.

The SC ruled to grant Ronald's petition because of his inability as a husband to love his wife, which was caused by his psychological condition, adding that the court cannot force him to stay in a loveless marriage.

23/06/2025

The (SC) has reiterated that a co-owner must give written notice to the other co-owners before selling their share of a property. However, if the other co-owners already knew about the sale and failed to exercise their right to buy the share within 30 days, the written notice is no longer required.

In a Decision written by Chief Justice Alexander G. Gesmundo, the SC’s First Division denied the petition filed by siblings Antonio Azurin, Jr. (Antonio) and Rafael Azurin (Rafael) to buy back a parcel of land registered in the name of Carlito Chua (Chua).

Antonio and Rafael were in possession of a parcel of land which they co-owned with their aunt Adelaida. Adelaida later sold to Chua her portion, which was officially registered in Chua’s name after it was surveyed and divided.

Years later, Antonio and Rafael attempted to buy back the land from Chua by filing a complaint for legal redemption before the trial court. Both the trial court and the Court of Appeals denied the complaint, on the ground that the case was filed years after the sale and well beyond the 30-day period allowed by the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦.

Antonio and Rafael appealed to the SC, but the SC denied their appeal.

The SC said that under the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦, a co-owner intending to sell their share to a third party must notify the other co-owners in writing about the sale. The other co-owners then have 30 days from receipt of the written notice to redeem or buy back the portion sold. If they fail to do so within the period, they lose the right to redeem the sold portion.

The SC, however, added that the requirement of written notice can be waived if (1) unusual circumstances have made the co-owners aware of the sale, and (2) the co-owners did not take action or were negligent in their right to redeem the property, a situation referred to in law as laches.

In this case, the SC found that Antonio and Rafael were aware of the sale. They were in actual possession of the land and, therefore, were informed about the survey conducted on it. Additionally, they received Chua’s legal complaint to recover possession.

However, they waited more than six years before trying to redeem the property.

Read the full text of the Press Release at https://tinyurl.com/68yxczhw.

Read the full text of the Decision at https://tinyurl.com/35tpwuye.

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

22/06/2025

From Senior Associate Justice Marvic Leonen: “I disagree that Pax Ali should be replaced by the elected vice governor. I maintain that the position should go to the duly elected candidate who: (i) is eligible for the position; and (ii) obtained the highest number of votes. Where the candidate with the most votes was ineligible from the beginning, only the qualified candidates are considered for the position. The qualified eligible candidate who obtained the highest number of votes is the true winner. This is why the position must necessarily go to the "second placer." Though they obtained the second highest number of votes in relation to the unqualified or disqualified candidate, the second placer is more accurately described as the first placer among the qualified candidates. The Court must be mindful that the person who ran and won for vice governor was elected as vice governor, not governor. Thus, to keep the intent of the electorate, the legitimacy of the other votes cast in the election of governor should still be upheld.”

This was emphasized by the Senior Associate Justice as he introduced his dissenting opinion to the recent landmark ruling of the Supreme Court where it abandoned the second-placer rule and held that there is no legal basis for proclaiming the second-placer in elections when the winning local elective official is disqualified or ineligible.

21/06/2025

12/06/2025

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04/06/2025

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