Atty. Carol Q Solatorio

12/08/2026

The Oral Arguments in the present case of Baluyot vs. Baluyot (GR No. 257575) pending before the Supreme Court En Banc are over. The issue is whether or not it is time to abandon the rule that foreign divorce of two Filipinos abroad is not recognizable in the Philippines. I advocated for its abandonment.

As amicus curiae, I am satisfied with my arguments and, modesty aside, I believe that, after four hearings, I responded to the queries of the Justices appropriately.

The present "public policy" rule is this: Under the second paragraph of Article 26 of the Family Code, only mixed-marriage ( Filipino and Foreigner) is entitled to obtain a foreign divorce filed by either the Filipino or the Foreigner. The divorce can be recognized in the Philippines via a petition fo recognition of foreign judgment. However, foreign divorce obtained where the parties are both Filipinos are not recognizable in the Philippines and any petition for recognition of foreign judgment filed in the Philippines will be automatically dismissed.

These are some of my strongest points which I articulated during the oral arguments:

FIRST. The Present "Public Policy" borders on racism against Filipinos. . It is racist because it makes our national identity a legal liability. It suggests that the law and public policy treat the foreigner as a superior race and the Filipino the inferior one BECAUSE our very law and public policy make the foreigner the bestower of rights of Filipinos. In Tagalog, I illustrated this to the SC by saying something like this , "kung banyaga ako at may ka-rival akong pilipinong nangliligaw sa Filipina, kaya kong sabihin sa Filipina: ako ang saguitn mo kasi binigyan ako ng kapangyarihan ng batas ng Pilipinas na bigyan ka ng karapatan divorce ako. Kung yung Pilipino ang sasagutin mo, walang ganyang karapatan ang mabibigay sa iyo."

SECOND. The law and present public policy are xenocentric because they give importance to the foreigner. Simply, to be given the right to file divorce, the key for the Filipino is to be married to a foreigner. Why is it that the magic formula to get a divorce in order to be liberated from an abusive spouse is to marry a foreigner?

THIRD. At the very least, present public policy mirrors a colonial-mentality because for a Filipino to be given greater rights, he/she must associate himself/herself with a foreigner just like during the time when we were colonized by Spain.

FOURTH. They are against the equal protection of the constitution.They effectively create a legal caste system. One set of Filipinos are benefited by the law and the other not so. One is permitted and one is barred. And the distinction simply depends on the nationality/race of who the Filipino married. When nationality creates a substantial distinction, that is undue discrimination.

FIFTH. To maintain the present so-called public policy suggests that , on this particular issue, marriage in the Philippines is not based on the sanctity of marriage but on race or nationality. If you are married to a foreigner and you get a divorce, it is moral. If you are a Filipino and you get a divorce from a Filipino spouse, it is immoral.

SIXTH. To maintain the present public policy is to say that , in the Philippines, marriage is the only institution that the law allows abuse and cruelty against another in the name of permanence.

SEVENTH. The outmoded public policy enunciated in 1939 and 1964 is anachronistic. I specifically stated in the arguments: "If public policy is to be frozen in its first articulation (1939 and 1964) and still applied in the 21st century, we will then be governed by norms of a society that no longer exist. Public policy is ratio temporis. It must also evolve."

There are other strong arguments ( such as misapplication of Article 15 of the Civil Code on the nationality rule) I made which I am very satisfied. I will talk about the others at some other time.

I hope the present Supreme Court will abandon the outmoded public policy presently being implemented lest ,by maintaing the rule, this particular Supreme Court might be perceptively known as a racist and xenocentric Supreme Court.

11/08/2026

The has ruled that employees who are illegally dismissed are entitled not only to full backwages but also to the remittance of their Social Security System (SSS) contributions.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division held that an employer’s obligation to remit SSS contributions continues during the period covered by an employee’s illegal dismissal.

The case involved four employees of Lopez Sugar Corporation (LSC) who were illegally dismissed. LSC was ordered to reinstate them to their former positions and pay them full backwages. After the ruling became final, the employees asked LSC to remit their SSS contributions for the period covered by their backwages so they could qualify for retirement benefits.

LSC refused, arguing that under the 𝘚𝘰𝘤𝘪𝘢𝘭 𝘚𝘦𝘤𝘶𝘳𝘪𝘵𝘺 𝘈𝘤𝘵 𝘰𝘧 1997, its obligation to pay SSS contributions ended upon the employees’ separation from employment, regardless of whether their dismissal was legal or illegal.

The Social Security Commission (SSC) rejected LSC’s position and ordered it to pay the contributions. The SSC ruled that because the employees were illegally dismissed, the employer-employee relationship was deemed to have continued during the period they were prevented from working.

Holding that LSC remained obligated to remit the employees’ SSS contributions for the period covered by their backwages, the SC stated that under Article 294 of the 𝘓𝘢𝘣𝘰𝘳 𝘊𝘰𝘥𝘦, illegally dismissed employees are entitled to full backwages and other benefits.

The SC explained that such employees are considered to have remained employed during the period covered by their backwages and are therefore entitled to the rights and benefits that would have accrued during that period.

Since LSC failed to remit the illegally dismissed employees’ social security contributions, the SC held that LSC is liable to pay a penalty thereon of three percent per month, reckoned from the date they became due until full payment.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=170676.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165713.

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

10/08/2026

The white knight who spent three months as the subject of grapevine speculation about rescuing ABS-CBN just confirmed the deal, and it is not the deal anyone was speculating about.

On Monday, August 10, Ramon S. Ang acquired a 25.68 percent stake in Lopez Inc., the private company that sits at the very top of the Lopez Group's ownership structure, two levels above First Philippine Holdings, with Lopez Holdings sitting in between as FPH's immediate parent. The seller was Crème Investment Corporation, the holding vehicle representing the family branch descended from Eugenio "Geny" Lopez Jr. and led by Eugenio "Gabby" Lopez III, the former ABS-CBN chairman. Ang is making the investment in his personal capacity through a wholly owned holding company rather than through San Miguel Corporation, where he remains chairman and CEO, and he is expected to brief SMC's board on the transaction at its next meeting on August 13. The price and financial terms have not been disclosed.

The reason this deal deserves more careful reading than the headline gives it is that it inverts the narrative most coverage, including our own earlier analysis of the ABS-CBN rescue speculation, had been building around for months. When Ang and Manuel Pangilinan appeared together at MVP's July 12 birthday celebration and laughed off questions about a rescue package, the operating assumption across Philippine business media was that any Ang involvement would come as fresh capital rescuing ABS-CBN specifically, most likely with the Gabby Lopez camp, which had been the faction publicly pushing for outside capital infusion against Piki Lopez's resistance. What actually happened is that Gabby's own branch of the family sold out of the parent holding company entirely. Ang did not join Gabby's side of the fight. He bought Gabby's chips off the table.

This matters enormously for understanding what kind of transaction this actually is. We detailed extensively in our earlier coverage that the Lopez family civil war has run between two camps: Gabby Lopez's branch, which had been arguing that the family must use its own capital, including a proposed 2 billion peso infusion, to keep ABS-CBN operating, and Federico "Piki" Lopez's branch, which resisted that infusion and was subsequently removed as Lopez Holdings chairman and CEO in a move he is now contesting in court. Gabby's public position throughout 2026 was pro-rescue and pro-capital-infusion. His own statement following the sale, that "this dispute has not been good for any of us," reads less like a strategic victory and more like an exit born of exhaustion with a fight that had already cost the family its unity and was actively grinding down the value of the businesses everyone was fighting over.

Crème's 25.68 percent stake in Lopez Inc. carried two board seats, currently occupied by Gabby and his brother Rafael Lopez. The sale does not automatically hand Ang those seats or any operational control; what changes hands is the equity position, and how board representation, voting rights, and influence over Lopez Inc.'s downstream holdings actually shift is a governance question that will play out over the weeks ahead rather than settle instantly on the disclosure date. What is already visible is one immediate consequence: Roberta "Berta" Lopez-Feliciano, the Crème-affiliated director who represented the Geny Lopez branch on the board of First Philippine Holdings, resigned from that board the same day, disclosed under Item No. 4 of an SEC Form 17-C. Her seat is now vacant on an FPH board that, as Rappler's reporting notes, has not faced its own shareholders in 2026 amid the ongoing family dispute. One resignation is a governance detail. It is also the first visible domino from a transaction whose downstream effects on First Philippine Holdings, First Gen, Rockwell Land, and ultimately ABS-CBN Corp itself have not yet been mapped.

The asset base that sits beneath Lopez Inc. is the reason this transaction is significant regardless of how the ABS-CBN question specifically resolves. Through its ownership chain, Lopez Inc. controls First Philippine Holdings, which controls First Gen and Energy Development Corporation, the LNG and geothermal power generation businesses we have covered as central to Philippine baseload electricity supply. It controls Rockwell Land, a premium Metro Manila property developer. It controls ABS-CBN Corp, the media company whose financial distress we detailed in depth just weeks ago, including its 747 million peso equity base against a 4.717 billion peso net loss and its urgent bank loan refinancing. And the family separately retains a 3.94 percent minority stake in Meralco, connecting this transaction, even at a minority level, to the single most important utility stock we have covered extensively this year. A 25.68 percent stake in the parent that sits above all of these holdings is not an ABS-CBN investment with extra steps. It is a foothold across one of the largest privately controlled conglomerates in the Philippines, with power generation, property, media, and utility exposure bundled into a single ownership stake.

Ang's own pattern of behavior toward Philippine media, documented across more than a decade, is the context that makes this deal read as something other than opportunistic. Reporting confirms Ang has pursued ownership positions in Philippine media repeatedly and unsuccessfully: a chase for GMA Network that did not close, rumored involvement behind a cable news channel, and a Philippine Daily Inquirer negotiation that reportedly reached the stage of active price haggling before falling apart. None of those closed. This is also not Ang's first proximity to a Lopez-controlled asset. In October 2008, San Miguel Corporation, under Ang's early diversification push beyond food and beer, acquired the government's 27 percent stake in Meralco, a transaction that put Ang directly into a Lopez-adjacent utility position eighteen years before this week's deal. The throughline across both transactions is a demonstrated, sustained appetite for exactly the kind of infrastructure, energy, and media assets that sit inside the Lopez conglomerate, pursued patiently over multiple attempts and multiple decades rather than opportunistically in a single moment.

What this transaction is not, at least not yet, is a confirmed ABS-CBN rescue. Ang told InsiderPH directly that the deal is limited to Crème's shares specifically, and when asked whether he was in talks to acquire other family branches' holdings, his answer was two words: "not for sale." That leaves the majority bloc, the branch that opposed Piki's capital infusion resistance and ultimately voted to remove him, still in control of Lopez Inc. going forward, now alongside a 25.68 percent outside shareholder whose ultimate intentions toward the media, energy, and property assets beneath that holding company have not been disclosed beyond the transaction itself. The Lopez majority's own public position, that ABS-CBN will "survive and grow" amid the family power struggle, has not changed as a result of this sale. What has changed is that one of the two warring factions has cashed out entirely, and the buyer who cashed them out is a man who has spent close to two decades trying and failing to acquire exactly this kind of asset.

The most precise way to describe what happened this week is this: Ramon Ang did not rescue ABS-CBN. He bought a quarter of the company that owns the company that owns ABS-CBN, from the family faction that wanted to rescue it and no longer controls enough of the empire to do so alone. Whether that positions him to eventually engineer the rescue everyone has been speculating about since July, through influence rather than through a direct capital infusion, or whether it simply makes him a large minority shareholder in a conglomerate still controlled by the majority Lopez bloc, is the question that Ang's August 13 board briefing at San Miguel and whatever follows it will begin to answer.

Not financial advice. Always do your own due diligence.

10/08/2026

10/08/2026

Do lease obligations pass on to heirs and successors-in-interest?

In Sui Man Hui Chan vs. Court of Appeals, G.R. No. 147999 (February 27, 2004), the Supreme Court ruled that a lease is not essentially personal in nature, so its rights and obligations generally pass to the parties’ heirs and successors-in-interest.

In this case, a lessor sued the lessee’s successors for unpaid rentals, realty taxes, and damages arising from a hotel building lease. The lease expressly bound the parties’ heirs and successors-in-interest.

After the deaths of the original parties, their respective successors continued the lease and business operations. However, the tenants allegedly failed to pay rentals and realty taxes before eventually vacating the premises.

The lessor demanded payment of the accumulated obligations. The tenants argued that they were not parties to the original lease and that any claim should instead be filed against the original lessee’s estate.

The trial court and the Court of Appeals (CA) rejected the contention, finding that their continued occupation and dealings with the lessor showed their recognition of and participation in the lease.

The SC likewise held that they were real parties-in-interest even though they were not signatories to the original lease contract.

Since the lease expressly bound the parties’ heirs and successors, its rights and obligations remained binding after the original parties’ deaths, subject to exceptions based on the nature of the obligation, the contract, or the law.

The SC also clarified that the unpaid rentals at issue accrued only after the original lessee’s death and therefore could not be charged against his estate.

Disclaimer: This material is for informational purposes only and may omit important details. Please read the full court decision and seek legal advice before acting on this information.

Duran & Duran-Schulze Law is a civil law firm in Metro Manila, Philippines specializing in contract drafting and comprehensive legal review. For drafting and review of lease contracts, email us at [email protected].

09/08/2026

I had the same experience although different facts and circumstances.

I filed a criminal case against this foreigner and I will set this case as an example to all other foreigners to not abuse that limited rights you have in our country against all filipinos.

There are remedies against undesirable aliens to be initiated before the office of the Bureau of Immigration.

A Cebu woman’s viral account of an argument with an alleged foreign permanent resident inside a café has sparked discussions about public etiquette, cultural differences, and how locals are treated in their own country.

In an Aug. 4 Facebook post, Honey Kate shared a six-minute video recounting what she described as an “intense, unexpected argument with a stranger” at Starbucks Ayala Center Cebu.

Honey said she was calling her boyfriend about their upcoming Palawan trip when she realized her headphones were not working, prompting her to use speakerphone.

She said a man approached her and told her, “Well, this is not your living room or your office to be talking that loud.”

Honey said she told him that the café was a public place, but the exchange escalated when the man allegedly told her, “Well, you can’t just do whatever you want.”

She then replied, “This is my country. I can do whatever I want,” to which the man allegedly answered, “This is also my country. I have a permanent resident card and I bring money to this country.”

She admitted she worried that the confrontation could become “physical,” but said she also did not want to back down. She told the man that he could leave, but he later spoke with the branch manager before returning, she said.

As the argument continued, another customer alerted the manager and security guard to intervene. Honey said the manager explained to the man that she was allowed to take a phone call because “this is a public cafe.”

Honey clarified that her post was “not to hate against foreigners,” but was instead “specifically about the entitled ones.” She acknowledged that speakerphone calls in cafés may be considered disruptive in some cultures, but said Filipino public spaces are generally more social.

The post drew mixed reactions. Some users praised Honey Kate for standing her ground, with one commenter writing, “Glad to hear you're ok after that ordeal, your bravery is inspiring and it's great to see you standing up for what's right.” Another said, “We should never ever feel intimidated in our own country! They already do that to us in other countries.”

Others, meanwhile, said speakerphone use and loud conversations in public spaces can also be considered inconsiderate regardless of nationality. One commenter wrote, “To be honest, I find it shameful to talk loudly in a public place because conversation for me should be private. However him talking to you that he brings in money is a bs.”

Similar frustrations are also familiar among Filipinos, particularly in Metro Manila, where some commuters have criticized loud calls, videos played aloud, and phone use without earphones in public spaces.

Still, several users argued that concerns over public etiquette do not justify talking down to locals or using money and residency status as a way to assert authority.

Honey maintained that being a foreign resident should come with an effort to understand and respect the community one lives in.

“Being a permanent resident, understanding and respecting the culture should be your first and foremost responsibility,” she said. “Bringing money to the Philippines does not give you the right to talk down to locals or act like you own the place.”

Honey ended her video by encouraging Filipinos to know their rights: “Our weapon is to really stand our grounds, know our rights, film for safety if needed. And most importantly, we need to be supporting each other.”

(✍️: Nikko Miguel Garcia)

09/08/2026

𝐔𝐬𝐚𝐩𝐚𝐧𝐠 𝐈𝐥𝐞𝐠𝐚𝐥 #41 – “𝐈𝐧𝐭𝐫𝐢𝐠𝐮𝐢𝐧𝐠 𝐀𝐠𝐚𝐢𝐧𝐬𝐭 𝐇𝐨𝐧𝐨𝐫”

Minsan, isang tsismis lang ang kailangan pwede nang masira ang pangalan ng isang tao. Pero alam mo bang may krimen na tinatawag na 𝐈𝐧𝐭𝐫𝐢𝐠𝐮𝐢𝐧𝐠 𝐀𝐠𝐚𝐢𝐧𝐬𝐭 𝐇𝐨𝐧𝐨𝐫?

Nagkakaroon ng krimeng ito kapag 𝐧𝐚𝐠𝐩𝐚𝐤𝐚𝐥𝐚𝐭 𝐤𝐚 𝐧𝐠 𝐭𝐬𝐢𝐬𝐦𝐢𝐬 𝐨 𝐢𝐧𝐭𝐫𝐢𝐠𝐚 𝐧𝐚 𝐚𝐧𝐠 𝐩𝐚𝐧𝐠𝐮𝐧𝐚𝐡𝐢𝐧𝐠 𝐥𝐚𝐲𝐮𝐧𝐢𝐧 𝐚𝐲 𝐬𝐢𝐫𝐚𝐢𝐧 𝐚𝐧𝐠 𝐝𝐚𝐧𝐠𝐚𝐥 𝐨 𝐫𝐞𝐩𝐮𝐭𝐚𝐬𝐲𝐨𝐧 𝐧𝐠 𝐢𝐛𝐚𝐧𝐠 𝐭𝐚𝐨, kahit hindi mo naman alam kung totoo o saan nanggaling ang balita.

𝗛𝗮𝗹𝗶𝗺𝗯𝗮𝘄𝗮:

Sinabi mo sa mga kapitbahay: "Mare, balitang balita na kabit ni ganito si ganyan." Hindi mo naman alam kung saan nanggaling ang balita. Inuulit mo lang ang narinig mo.

Kapag ang layunin ng pagpapakalat ng tsismis ay sirain ang reputasyon ng tao, maaari kang managot sa 𝐈𝐧𝐭𝐫𝐢𝐠𝐮𝐢𝐧𝐠 𝐀𝐠𝐚𝐢𝐧𝐬𝐭 𝐇𝐨𝐧𝐨𝐫.

𝗔𝗻𝗼 𝗮𝗻𝗴 𝗽𝗮𝗿𝘂𝘀𝗮?

Pagkakakulong mula 1 𝐡𝐚𝐧𝐠𝐠𝐚𝐧𝐠 30 𝐚𝐫𝐚𝐰, o 𝐦𝐮𝐥𝐭𝐚 𝐧𝐚 𝐡𝐢𝐧𝐝𝐢 𝐥𝐚𝐥𝐚𝐦𝐩𝐚𝐬 𝐬𝐚 ₱20,000, o pareho, depende sa ipapataw ng korte.

Hindi lahat ng tsismis ay simpleng kuwentuhan lang. Kapag ang intriga ay ginagamit para siraan ang pangalan ng iba, maaari itong maging usaping kriminal.

Follow Usapang Ilegal para mas maging legal ang kaalaman!

08/08/2026

The (SC) has clarified that a Precautionary Hold Departure Order (PHDO) may be issued only in cases involving crimes punishable by a minimum penalty of at least six years and one day of imprisonment, or when the respondent is a foreigner, regardless of the penalty.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SC’s Third Division ruled that a PHDO cannot be maintained when the crime under investigation does not meet these requirements.

The case arose from a complaint for 𝘦𝘴𝘵𝘢𝘧𝘢 under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 and violation of 𝘉𝘢𝘵𝘢𝘴 𝘗𝘢𝘮𝘣𝘢𝘯𝘴𝘢 𝘉𝘭𝘨. 22 (BP 22) filed against petitioner Faustine Feliz Abad (Abad) in connection with her purchase of airline tickets from respondent GHT Travel and Tours (GHT).

The City Prosecutor found probable cause to charge Abad with two counts of violation of BP 22, but found insufficient evidence to charge her with 𝘦𝘴𝘵𝘢𝘧𝘢. Two Informations for BP 22 were then filed before the Metropolitan Trial Court of Manila.

The prosecution also sought a PHDO against Abad with the Regional Trial Court (RTC), claiming that she was a flight risk. The RTC granted the request.

Abad later sought to have the PHDO lifted. The RTC denied her request, noting, among others, that GHT had appealed the dismissal of the 𝘦𝘴𝘵𝘢𝘧𝘢 charge to the Secretary of Justice and that Abad was a permanent resident of the United States.

Ruling that the PHDO should have been lifted, the SC cited the Rule on PHDO that it issued on August 7, 2018, which provides that a PHDO may be issued while a criminal complaint is undergoing preliminary investigation when the crime involved carries a minimum penalty of at least six years and one day of imprisonment. It may also be issued against a foreigner regardless of the penalty.

The SC explained that the 𝘦𝘴𝘵𝘢𝘧𝘢 charge, which could have carried a penalty exceeding six years and one day, was dismissed for lack of probable cause. The only charges filed against Abad were two counts of BP 22 violations, each punishable by imprisonment of 30 days to one year.

Thus, the BP 22 charges did not meet the penalty requirement for the issuance of a PHDO.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=170320.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=165691.

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

07/08/2026

Ever had a bank or e-wallet just... go silent on you? 😤 You don't have to just wait around. The BSP has a formal process for reporting unresponsive banks and e-wallets — chatbot, SMS, email, even snail mail. Read the full guide at the link 👇

07/08/2026

CALL FOR COMMENTS

Pursuant to the applicable Rules of the Supreme Court governing the accreditation of publishers authorized to publish Court Notices and Orders, the IBP NEGROS ORIENTAL CHAPTER invites comments from the members regarding the applications for renewal of accreditation of the following newspaper publishers:

Dumaguete Star Informer
Metropost
The Negros Chronicle

You may view the applications and their annexes at the IBP Office in person from August 7-10, 2026, during office hours.

Should you wish to submit a Comment, please do so through the Google Forms link provided (https://forms.gle/CLCBYRQrg1v8UCT3A) on or before August 10, 2026, to enable the IBP NEGOR Chapter Officers to consolidate and transmit all comments prior to the scheduled hearing.

The hearing on the applications for renewal of accreditation is set on August 11, 2026, at 9:00 A.M.

Your cooperation and participation in this process are greatly appreciated.