ABINA LAW Firm CPA Lawyer

15/08/2026

⚖️ABINA LAW Firm proudly joins the Gun Expo this Ibalong Festival. See you there! 🇵🇭

05/08/2026

19/07/2026

Upholding the right to free speech, the (SC) has dismissed petitions for indirect contempt arising from public statements critical of its 2025 decision in 𝘋𝘶𝘵𝘦𝘳𝘵𝘦 𝘷. 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘙𝘦𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘢𝘵𝘪𝘷𝘦𝘴, which declared the fourth impeachment complaint against Vice President Sara Duterte unconstitutional.

In a Decision penned by Senior Associate Justice Marvic M.V.F. Leonen, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 dismissed the consolidated petitions against political analyst Richard J. Heydarian, Representative Percival Cendaña, and Presidential Adviser for Poverty Alleviation Secretary Lorenzo “Larry” G. Gadon (respondents).

After the release of the decision in 𝘋𝘶𝘵𝘦𝘳𝘵𝘦 𝘷. 𝘏𝘰𝘶𝘴𝘦 𝘰𝘧 𝘙𝘦𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘢𝘵𝘪𝘷𝘦𝘴, Heydarian posted on X and Facebook that former President Rodrigo “𝘋𝘶𝘵𝘦𝘳𝘵𝘦 𝘩𝘢𝘥 𝘢𝘱𝘱𝘰𝘪𝘯𝘵𝘦𝘥 𝘢𝘴 𝘮𝘢𝘯𝘺 𝘢𝘴 13 𝘰𝘶𝘵 𝘰𝘧 𝘵𝘩𝘦 15 𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘶𝘳𝘵 𝘫𝘶𝘴𝘵𝘪𝘤𝘦𝘴 𝘣𝘺 2022” while Rep. Cendaña posted a video on Facebook claiming that the Supreme Court disregarded the Constitution, its own decision and the principle of separation of powers, calling it “𝘚𝘶𝘱𝘳𝘦𝘮𝘦 𝘊𝘰𝘥𝘥𝘭𝘦𝘳 𝘰𝘧 𝘵𝘩𝘦 𝘗𝘩𝘪𝘭𝘪𝘱𝘱𝘪𝘯𝘦𝘴.” Sec. Gadon, for his part, referred to the SC in media interviews as “𝘵𝘶𝘵𝘢 𝘯𝘨 𝘮𝘨𝘢 𝘋𝘶𝘵𝘦𝘳𝘵𝘦.”

These statements prompted Attys. Mark Kristopher G. Tolentino, Rolex Suplico, and Ferdinand S. Topacio to file petitions asking the SC to cite the respondents for indirect contempt. They claimed that the statements questioned the SC’s independence, undermined its decisions, and weakened public trust in the Judiciary.

The SC, however, found that the statements did not amount to indirect contempt.

Rule 71, Section 3 of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵 punishes conduct that degrades the courts or damages their reputation. There must be a clear showing that the speaker intended to impede or obstruct the administration of justice.

While contempt proceedings help protect judicial independence and public confidence in the Judiciary, the SC emphasized that courts must also respect and uphold the freedoms of speech, expression, and the press.

The SC explained that political speech, which includes statements about government actions, public officials, and matters of public concern, enjoys the highest level of constitutional protection. It is not automatically punishable even if it is harsh or inaccurate.

Applying the stricter incitement test, the SC said political speech may be restricted only if it is intended and likely to cause imminent lawless action. In making this determination, courts look beyond the literal meaning of the words and consider their performative aspect: the speaker’s intent, the context in which the speech was made, and its likely effect.

Under this standard, a person may be held liable for contempt only if the speech advocates lawless conduct that threatens the administration of justice.

Applying these principles, the SC found that the respondents’ statements were political speech relating to the impeachment case of Vice President Duterte, a matter of significant public interest involving public accountability.

The SC found Heydarian’s post a fair comment on a matter of public interest and, when read together with his other posts, did not show bad faith, malice, or disrespect toward the SC. While the statement may have reflected bias, it remained protected speech.

As for Rep. Cendaña’s remarks, the SC said although they were accusatory, they only showed his disappointment with the ruling and were not meant to interfere with the administration of justice. The SC considered his statements as expressions of opinion and an understandable reaction to an unfavorable decision.

Finally, the SC found that while Sec. Gadon’s remark was disrespectful, it did not amount to contempt because it was not intended to interfere with court proceedings or influence any pending case. Instead, it was an expression of opinion on an issue that was widely debated by both supporters and critics of the SC’s decision.

Respondents were reminded, however, to encourage thoughtful and constructive public discussion of Judiciary’s decision, to show greater respect, restraint and care in publicly criticizing the Judiciary, and to express their criticisms with civility and fairness.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=169021

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168894

Read the Separate Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/e-01742-e-01747-separate-opinion-justice-alfredo-benjamin-s-caguioa/

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

31/05/2026

𝗕𝗜𝗥 𝗟𝗔𝗨𝗡𝗖𝗛𝗘𝗦 “𝗘𝗔𝗦𝗘 𝗢𝗙 𝗖𝗟𝗢𝗦𝗜𝗡𝗚 𝗕𝗨𝗦𝗜𝗡𝗘𝗦𝗦” 𝗚𝗨𝗜𝗗𝗘𝗟𝗜𝗡𝗘𝗦 𝗙𝗢𝗥 𝗧𝗔𝗫 𝗥𝗘𝗚𝗜𝗦𝗧𝗥𝗔𝗧𝗜𝗢𝗡 𝗖𝗔𝗡𝗖𝗘𝗟𝗟𝗔𝗧𝗜𝗢𝗡; 𝗧𝗔𝗫 𝗖𝗟𝗘𝗔𝗥𝗔𝗡𝗖𝗘 𝗥𝗘𝗟𝗘𝗔𝗦𝗘𝗗 𝗔𝗦 𝗙𝗔𝗦𝗧 𝗔𝗦 𝗧𝗛𝗥𝗘𝗘 𝗗𝗔𝗬𝗦

The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 47-2026 on May 19, 2026, prescribing new guidelines to simplify the process for closing businesses and cancelling tax registration, as part of the implementation of Republic Act No. 11976, otherwise known as the “Ease of Paying Taxes Act.”

“This is our ‘Ease of Closing Business’ reform,” Commissioner Charlito Martin R. Mendoza said. “In line with President Ferdinand R. Marcos Jr.’s directive to make government services faster, better, and more responsive, and Finance Secretary Frederick D. Go’s push to make tax administration more investor-friendly and business-friendly, the BIR is making it easier for taxpayers who have already ceased operations to properly close their business and cancel their registration.”

“From improving the ease of doing business and the ease of paying taxes, this reform completes the BIR’s support for businesses through every stage of the business life cycle. If we make it easier to start and operate a business, then the government must also make it easier to properly close BIR registration once operations have already ceased,” he added.

Under RMC No. 47-2026, taxpayers who have already ceased operations may now apply for the closure or cancellation of their registration, either manually or electronically, through the Revenue District Office where their head office or branch is registered.

The Circular simplifies and standardizes documentary requirements. Together with the application form and the surrender of original BIR registration documents and permits previously issued to the business, taxpayers will only be required to submit two other document sets for closure: the list of ending inventory of goods and supplies, including capital goods for VAT-registered taxpayers, and the unused invoices, supplementary documents, and other unutilized accounting forms, together with their inventory.

Under the new guidelines, penalties for non-filing of tax returns shall no longer accrue once the taxpayer submits the complete documentary requirements for the closure or cancellation of registration. To prevent the further accumulation of open cases, the taxpayer’s registered form types shall likewise be placed under “deregistered” status upon submission of the complete requirements. Filing an application for the closure or cancellation of registration, however, does not preclude the Bureau from conducting an audit to determine any outstanding tax liabilities.

In addition, micro taxpayers shall not be subject to mandatory audit for closure and/or cancellation of business registration. Hence, tax clearances will be issued within three (3) working days from submission of complete documentary requirements for those with no open cases or outstanding liabilities. For micro taxpayers with open cases, tax clearance will be issued within three (3) working days from the submission of the complete documentary requirements and the payment of outstanding liabilities, including penalties.

Commissioner Mendoza encouraged taxpayers who have already ceased operations to avail themselves of the streamlined process to avoid the continued accumulation of penalties and to properly update their registration records with the Bureau.

Read the full RMC here:https://bir-cdn.bir.gov.ph/BIR/pdf/RMC%20No.%2047-2026.pdf

18/04/2026

14/04/2026

14/04/2026

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11/04/2026

4 DAYS LEFT!

Pay as you file!

With the deadline fast approaching, the BIR is reminding taxpayers to pay their exact 2025 Annual Income Tax on the day of filing their Return.

Deadline: on or before April 15, 2026.