Ruben Bance Law

29/09/2026

“Sexual Violence Cases”



Lawyer

The has adopted the term "𝘷𝘪𝘤𝘵𝘪𝘮-𝘴𝘶𝘳𝘷𝘪𝘷𝘰𝘳" when referring to persons who have experienced sexual violence.

In a Decision written by Associate Justice Japar B. Dimaampao, the SC’s Third Division affirmed a man’s conviction for the r**e of a 12-year-old child.

The minor testified that while everyone was asleep, the accused, who was the common-law spouse of the minor’s mother, dragged the child outside the residence of her uncle, r**ed her, pointed a knife at her, and threatened to kill her if she told anyone about the incident.

She told her uncle and aunt that the accused had been sexually abusing her since she was nine years old. She did not report it earlier because she feared his threats.

The SC found all the elements of r**e present and the accused positively identified as the ra**st. In addition to the penalty of 𝘳𝘦𝘤𝘭𝘶𝘴𝘪𝘰𝘯 𝘱𝘦𝘳𝘱𝘦𝘵𝘶𝘢 or up to 40 years in prison, the SC ordered the man to pay the victim-survivor PHP 450,000 in civil indemnity and damages.

The SC clarified its terminology in cases involving sexual violence. Rather than using the term "𝘷𝘪𝘤𝘵𝘪𝘮," it adopted "𝘷𝘪𝘤𝘵𝘪𝘮-𝘴𝘶𝘳𝘷𝘪𝘷𝘰𝘳" to acknowledge both the harm caused by the crime and the strength victims show in enduring and recovering from such violence.

As part of the government’s efforts to provide comprehensive support for victim-survivors, the SC also directed the Department of Social Welfare and Development to refer the minor to the proper r**e crisis center for assistance.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=174013.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168013.

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

26/09/2026

The (SC) has ruled that the Presidential Commission on Good Government (PCGG) is not liable to pay interest or damages on funds it sequestered or took custody of. The PCGG’s duty is only to preserve the funds, not to make them grow.

In a Decision penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division denied the petition of Palm Avenue Holding Co., Inc. and Palm Avenue Realty Development Corporation (“Palm Companies”) seeking interest on funds sequestered from them.

The PCGG sequestered shares of stock in Benguet Corporation registered under the Palm Companies in 1986 as part of the government’s effort to recover alleged ill-gotten wealth. It did so based on a letter identifying Benjamin “Kokoy” Romualdez as the shares’ beneficial owner.

The shares later earned income and were partly sold. The PCGG placed the proceeds in an escrow account and a Comprehensive Agrarian Reform Program (CARP) account. The escrow funds earned over PHP 273 million in interest, while the CARP funds earned over PHP 4 million before being transferred to the CARP account. After their transfer to the CARP account, they stopped earning interest.

The Sandiganbayan later ordered the release of the funds, including the interest earned, to the Palm Companies pending its decision on whether the funds were ill-gotten.

Because the CARP account funds came without any interest, the Palm Companies moved to ask the Sandiganbayan to order the PCGG to pay interest at 12% per year, compounded until full payment. They argued that the PCGG should have kept the CARP funds in escrow instead of moving them.

The Sandiganbayan initially agreed and ordered the PCGG to pay 6% in interest but later reversed itself.

The SC affirmed the ruling of the Sandiganbayan as it denied for lack of merit the motion of the Palm Companies.

Under the law creating the PCGG, the Commission can sequester assets suspected to be ill-gotten while the courts are deciding whether they were unlawfully acquired. This prevents assets from being hidden, destroyed, or depleted while in government custody.

The SC explained that the PCGG’s role over sequestered property is limited to that of a caretaker, not an owner or manager. This duty is fulfilled when the sequestered assets are safeguarded, kept intact, and returned without loss, including any actual profits and interest earned while they were under sequestration.

The SC clarified that the PCGG has no duty to increase the value of the sequestered funds or generate profit for its owners. To impose this on the commission would unnecessarily burden the State’s resources and distract the PCGG from its main task of recovering ill-gotten wealth.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=173942.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=173926.

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

22/09/2026

“VAWC Law”

The has reiterated that what Republic Act No. 9262, or the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 𝘈𝘤𝘵 𝘰𝘧 2004, criminalizes is not marital infidelity by itself but the psychological violence that goes with it causing mental or emotional suffering to the wife.

In a Decision penned by Associate Justice Amy C. Lazaro-Javier, the SC’s Second Division affirmed the conviction of a husband for violation of Section 5(i) of the 𝘈𝘯𝘵𝘪-𝘝𝘈𝘞𝘊 𝘈𝘤𝘵, which penalizes the act of causing mental or emotional anguish, public ridicule or humiliation to a woman or her child.

Married in 1999, the husband and wife’s marital problems began in 2009, when the husband started coming home late and grew distant from his family. In January 2010, the husband sent his wife text messages saying he would no longer return home, wanted to start a new life alone, and intended to seek the nullity of their marriage. The wife later discovered that her husband was living with another woman.

The husband was charged with psychological violence before the Regional Trial Court. During trial, the wife claimed that her husband’s actions caused her severe mental and emotional suffering, and loss of self-esteem and dignity. She said she experienced depression and attempted to take her own life several times.

The psychologist who evaluated the wife found signs of depression, including feelings of inferiority, sleep problems, difficulty concentrating, and problems relating with others. The psychologist linked these emotional difficulties to the wife’s conflict with her husband and his abandonment of the family for another woman.

The SC affirmed in full the finding that the husband is guilty of psychological violence under the 𝘈𝘯𝘵𝘪-𝘝𝘈𝘞𝘊 𝘈𝘤𝘵, sentencing the husband to up to eight years in prison and ordering him to pay a PHP 100,000 fine and PHP 30,000 in moral damages to his wife. The SC also directed him to undergo mandatory psychological counseling or psychiatric treatment.

The SC explained that, depending on the circumstances, an extramarital relationship may or may not cause mental or emotional anguish to the wife. Infidelity may be one of the acts through which psychological violence is committed, but the resulting mental or emotional suffering must still be proven.

In this case, the SC held that the wife’s testimony, psychological evaluation, and other witness testimonies sufficiently proved that her husband’s acts caused her mental and emotional suffering.

Read the full text of the Press Release at: https://sc.judiciary.gov.ph/?p=173362.

Read the full text of the Decision: https://sc.judiciary.gov.ph/268619-###-vs-people-of-the-philippines/.

Read the Dissenting Opinion of Senior Associate Justice Marvic M.V.F. Leonen: https://sc.judiciary.gov.ph/?p=168031.

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

15/09/2026

“Election Liquor Ban”

The (SC) has ruled that appearing intoxicated, smelling of alcohol, or being found near empty liquor bottles is not, by itself, enough to establish a violation of the election liquor ban.

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division acquitted Mcgill Esquillo Omandam (Omandam), ruling that the prosecution failed to prove beyond reasonable doubt that he consumed alcohol during the prohibited period as stated under Section 261(dd)(1) of the Omnibus Election Code (OEC), or the “COMELEC liquor ban.”

Omandam was arrested on the eve of the elections after police responded to reports of rowdiness. Arresting officers said he appeared intoxicated, smelled of alcohol, spoke with a slurred voice, and moved groggily. The police also recovered two empty bottles of Tanduay Rhum near the scene.

The SC explained that the OEC prohibits the taking of intoxicating liquor during the election liquor ban, which covers the day before the election and election day. The prosecution has to prove that the accused actually consumed alcohol during that period.

In this case, however, none of the arresting officers saw Omandam drinking. The prosecution relied solely on circumstantial evidence.

While circumstantial evidence may support a conviction, the SC stressed that the circumstances taken together must prove guilt beyond reasonable doubt and rule out any reasonable explanation of innocence.

The SC found that the prosecution failed to meet this standard. It based its case solely on observations of Omandam’s appearance and other unsupported circumstances.

The SC noted that the offense is not typically committed in secret and could have been easily verified through readily available means, such as field sobriety, breath analyzer, or chemical tests. However, the police did not conduct any of these, nor did they take photographs or videos to document Omandam’s alleged intoxication.

Although two empty liquor bottles were recovered, the police did not examine them for fingerprints or conduct forensic tests to determine whether Omandam handled them.

The SC ruled that these omissions undermined the accuracy and fairness of the investigation. Taken together, they cast doubt on the reliability and sufficiency of the circumstantial evidence.

Read more at https://sc.judiciary.gov.ph/?p=173139

Read the Decision https://sc.judiciary.gov.ph/?p=173133

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

15/09/2026

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13/09/2026

11/09/2026

The (SC) has found a bar review coach guilty of indirect contempt for spreading false information about the 2023 Bar Examinations on Facebook after stating that the said exams would be checked by means of artificial intelligence (AI).

In a 𝘗𝘦𝘳 𝘊𝘶𝘳𝘪𝘢𝘮 Decision, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 found Edgar S. Dizon, administrator of the Facebook group Bar Law for Dummies, liable for indirect contempt. The Court fined him PHP 30,000 and ordered the removal of his name from the list of 2016 Bar passers.

On September 21, 2023, a post from the Facebook group and the account 𝘛𝘴𝘪𝘥𝘬𝘦𝘯𝘶 𝘋𝘪𝘻𝘰𝘯 claimed that the 2023 Bar Examinations would be “𝘴𝘰𝘳𝘵𝘦𝘥, 𝘤𝘩𝘦𝘤𝘬𝘦𝘥, 𝘢𝘯𝘥 𝘤𝘰𝘳𝘳𝘦𝘤𝘵𝘦𝘥 𝘣𝘺 𝘮𝘦𝘢𝘯𝘴 𝘰𝘧 𝘢𝘳𝘵𝘪𝘧𝘪𝘤𝘪𝘢𝘭 𝘪𝘯𝘵𝘦𝘭𝘭𝘪𝘨𝘦𝘯𝘤𝘦 (𝘈𝘐).” It also stated:

“𝘈𝘓𝘞𝘈𝘠𝘚 𝘚𝘛𝘈𝘙𝘛 𝘞𝘐𝘛𝘏 𝘠𝘌𝘚 𝘰𝘳 𝘕𝘖.
𝘠𝘢𝘯 𝘢𝘯𝘨 𝘶𝘯𝘢𝘯𝘨 𝘩𝘢𝘩𝘢𝘯𝘢𝘱𝘪𝘯 𝘯𝘨 𝘈𝘐 𝘊𝘩𝘦𝘤𝘬𝘪𝘯𝘨 𝘵𝘰 𝘴𝘰𝘳𝘵 𝘰𝘶𝘵 𝘵𝘩𝘦 𝘤𝘰𝘳𝘳𝘦𝘤𝘵 𝘢𝘯𝘴𝘸𝘦𝘳𝘴.”

As a result, the Office of the 2023 Bar Chair (BCO), headed by Associate Justice Ramon Paul L. Hernando, had to investigate the source of the post and determine its impact on the examinations. It also issued an advisory clarifying that the examinations would be checked by four human examiners for each subject, all of whom are experts in their respective fields.

But instead of removing the post, Dizon threatened to sue the Court and demanded a public apology “within 24 hours”, in a media interview. He also sent several emails to the SC’s Judiciary Public Assistance Section, claiming that the advisory had a chilling effect on him. He denied spreading misinformation and asked the Court to issue a statement correcting the advisory.

After being directed by the SC to explain why he should not be cited for indirect contempt for interfering with the conduct of the 2023 Bar Examinations, Dizon admitted owning the Facebook account but denied claiming that AI would check the examinations, arguing that he used the words “TO HELP” in his post.

The SC was not convinced and held him liable under Rule 71, Section 3 of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵, which punishes unlawful interference with court processes outside a courtroom, conduct that degrades the courts or undermines public confidence in the administration of justice, and unauthorized practice of law, as indirect contempt.

The SC held that Dizon’s post unlawfully interfered with the conduct of the 2023 Bar Examinations and undermined the integrity of both the exams and the SC, which exercises supervision over the legal profession. It caused confusion and alarm, forcing bar officials to divert their limited time and resources to tracing the source of the post, coordinating with government agencies, issuing clarifications, and responding to numerous inquiries.

The SC further noted Dizon’s lack of remorse. Instead of acknowledging the harm caused by his post, he demanded an apology from the Court, threatened legal action, refused to take down the post, and sought a statement retracting the advisory.

The Court likewise warned Dizon from engaging in the unauthorized practice of law when he conducted bar review coaching sessions and authored several bar review materials used in the 𝘉𝘢𝘳 𝘓𝘢𝘸 𝘧𝘰𝘳 𝘋𝘶𝘮𝘮𝘪𝘦𝘴 training program. Dizon acknowledged that while he had passed the 2016 Bar Examinations, he had not taken the lawyer’s oath, which is one of the requirements to practice law, because of pending criminal cases.

In his Separate Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that Dizon must be punished for undermining the integrity of the Bar examinations. However, he also emphasized the need to balance the Court’s power to punish for contempt with the constitutional right to free speech, including legitimate criticism of the courts.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=172950

Read the full text of the Decision at https://sc.judiciary.gov.ph/4734-in-re-social-media-posts-of-edgar-s-dizon/

Read the Separate Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/4734-separate-concurring-opinion-senior-associate-justice-marvic-m-v-f-leonen/

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

10/09/2026

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07/09/2026

06/09/2026

"Preparation can only take you so far.
After that, you gotta take a few leaps of faith"
-Michael Scofield, S1EP3 “Cell Test

Good Luck Bar Examinees!

𝐆𝐎𝐎𝐃 𝐋𝐔𝐂𝐊, 𝐁𝐀𝐑 𝐄𝐗𝐀𝐌𝐈𝐍𝐄𝐄𝐒!

Today marks Day 1 of the 2026 Bar Examinations.

The Integrated Bar of the Philippines extends its heartfelt encouragement and best wishes to all bar examinees as they begin this important journey. May your hard work, preparation, and perseverance guide you with confidence and clarity throughout the examinations.

Stay calm, stay focused, and give it your best.
The legal profession awaits you.

Good luck, future lawyers!