Aton Law

Aton Law Lawyer and Notary Public Also, Aton Law Office offers Retainership options, establishing an ongoing partnership to address your evolving legal needs.
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Aton Law Office is your trusted legal partner and a newly established law office located at Basak, Lapu-Lapu City, Cebu, near Mactan Doctors Hospital (beside Alma Fruit Stand). Aton Law Office specializes in legal services, such as Notarization, Legal Consultation, Affidavits, Special Power of Attorney, Deed of Sale Document, Demand Letters, Certified True Copy, Contract Preparation, and Review. B

eyond these, we extend a range of other legal services, ensuring that Aton Law Office is your one-stop destination for comprehensive legal support. Visit us today and experience the professional excellence of Aton Law.

Thank you so much our dear clients. We truly appreciate it.โค๏ธ
29/05/2026

Thank you so much our dear clients. We truly appreciate it.โค๏ธ

๐˜ผ๐˜ฟ๐™‘๐™„๐™Ž๐™Š๐™๐™” ๐Ÿ“ข๐Ÿ“ข๐Ÿ“ขAton Law Office will be closed this coming May 30, 2026 (Saturday) to give way for our Summer Outing. โœจ๐Ÿ๏ธ๐ŸŒŠWe...
26/05/2026

๐˜ผ๐˜ฟ๐™‘๐™„๐™Ž๐™Š๐™๐™” ๐Ÿ“ข๐Ÿ“ข๐Ÿ“ข

Aton Law Office will be closed this coming May 30, 2026 (Saturday) to give way for our Summer Outing. โœจ๐Ÿ๏ธ๐ŸŒŠ

We will resume our regular office hours on June 1, 2026 (Monday) from 8:00 AM to 5:00 PM.

Thank you! ๐ŸŒด๐Ÿ–๏ธ

20/05/2026

๐—•๐—œ๐—ฅ ๐—Ÿ๐—”๐—จ๐—ก๐—–๐—›๐—˜๐—ฆ โ€œ๐—˜๐—”๐—ฆ๐—˜ ๐—ข๐—™ ๐—–๐—Ÿ๐—ข๐—ฆ๐—œ๐—ก๐—š ๐—•๐—จ๐—ฆ๐—œ๐—ก๐—˜๐—ฆ๐—ฆโ€ ๐—š๐—จ๐—œ๐——๐—˜๐—Ÿ๐—œ๐—ก๐—˜๐—ฆ ๐—™๐—ข๐—ฅ ๐—ง๐—”๐—ซ ๐—ฅ๐—˜๐—š๐—œ๐—ฆ๐—ง๐—ฅ๐—”๐—ง๐—œ๐—ข๐—ก ๐—–๐—”๐—ก๐—–๐—˜๐—Ÿ๐—Ÿ๐—”๐—ง๐—œ๐—ข๐—ก; ๐—ง๐—”๐—ซ ๐—–๐—Ÿ๐—˜๐—”๐—ฅ๐—”๐—ก๐—–๐—˜ ๐—ฅ๐—˜๐—Ÿ๐—˜๐—”๐—ฆ๐—˜๐—— ๐—”๐—ฆ ๐—™๐—”๐—ฆ๐—ง ๐—”๐—ฆ ๐—ง๐—›๐—ฅ๐—˜๐—˜ ๐——๐—”๐—ฌ๐—ฆ

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 โ€œEase of Paying Taxes Act.โ€

โ€œThis is our โ€˜Ease of Closing Businessโ€™ reform,โ€ Commissioner Charlito Martin R. Mendoza said. โ€œIn line with President Ferdinand R. Marcos Jr.โ€™s directive to make government services faster, better, and more responsive, and Finance Secretary Frederick D. Goโ€™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.โ€

โ€œFrom improving the ease of doing business and the ease of paying taxes, this reform completes the BIRโ€™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,โ€ 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 taxpayerโ€™s registered form types shall likewise be placed under โ€œderegisteredโ€ 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

15/05/2026

The has ruled that non-verbal threatening gestures with criminal intent may be considered grave threats under the ๐˜™๐˜ฆ๐˜ท๐˜ช๐˜ด๐˜ฆ๐˜ฅ ๐˜—๐˜ฆ๐˜ฏ๐˜ข๐˜ญ ๐˜Š๐˜ฐ๐˜ฅ๐˜ฆ (๐˜™๐˜—๐˜Š).

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SCโ€™s Third Division acquitted Gregory Israel of grave threats after finding no criminal intent in his gesture of pretending to shoot and behead two individuals.

But it clarified that the crime of grave threats may be committed through non-verbal gestures and not only through spoken or written words.

Israel, who claimed to be a Belgian architect allowed to practice his profession in the Philippines, was hired by Belgian business partners Christine Helena Amanda Navez and Olivier Edmund Denonville for the construction of their building. After Israel refused to correct the construction defects in the said building, Navez and Denonville filed a case for damages against him.

Sometime in 2017, while Navez and Denonville were on their way home from the airport, they nearly collided with Israelโ€™s motorcycle. The latter then allegedly made two overt gestures: pointing his fingers at Navezโ€™s head as if pulling a gun trigger and drawing his fingers across his neck as if threatening to behead Navez.

Israel was convicted of grave threats. When his conviction was affirmed by the Court of Appeals, he sought relief from the SC, arguing that he had no criminal intent when he performed the acts, and that Article 282 of the ๐˜™๐˜—๐˜Š does not cover pure non-verbal gestures.

The SC acquitted Israel after finding that criminal intent was not proven. But it disagreed with his other argument, ruling that non-verbal gestures may be considered grave threats.

To convict for grave threats, the ๐˜™๐˜—๐˜Š requires two elements: the ๐—ฎ๐—ฐ๐˜๐˜‚๐—ฎ๐—น ๐˜€๐—ฝ๐—ฒ๐—ฎ๐—ธ๐—ถ๐—ป๐—ด ๐—ผ๐—ฟ ๐˜‚๐˜๐˜๐—ฒ๐—ฟ๐—ถ๐—ป๐—ด ๐—ผ๐—ณ ๐˜๐—ต๐—ฒ ๐˜๐—ต๐—ฟ๐—ฒ๐—ฎ๐˜๐˜€ and the ๐—ถ๐—ป๐˜๐—ฒ๐—ป๐˜ ๐˜๐—ผ ๐—ถ๐—ป๐˜๐—ถ๐—บ๐—ถ๐—ฑ๐—ฎ๐˜๐—ฒ.

The SC held that Article 282 of the ๐˜™๐˜—๐˜Š does not differentiate between threats conveyed verbally and those expressed through non-verbal gestures. What matters is the communication of a threat intended to intimidate.

Although the second paragraph of the provision specifies that threats can be conveyed orally or in writing, it does not exclude threats conveyed through non-verbal means. Therefore, threats can be either verbal or non-verbal.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=166072.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164941.

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

๐™ƒ๐™Š๐™‡๐™„๐˜ฟ๐˜ผ๐™” ๐˜ผ๐˜ฟ๐™‘๐™„๐™Ž๐™Š๐™๐™” ๐Ÿ“ข๐Ÿ“ข๐Ÿ“ขIn line with the 48th ASEAN Summit holiday, our law office will remain open and ready to assist you ...
05/05/2026

๐™ƒ๐™Š๐™‡๐™„๐˜ฟ๐˜ผ๐™” ๐˜ผ๐˜ฟ๐™‘๐™„๐™Ž๐™Š๐™๐™” ๐Ÿ“ข๐Ÿ“ข๐Ÿ“ข

In line with the 48th ASEAN Summit holiday, our law office will remain open and ready to assist you with any legal concerns.

Our office is located at Basak, Lapu-Lapu City, Cebu near Mactan Doctors Hospital (in front of 7/11 and Biano's Pizza)

Regular office hours:
Monday-Saturday: 8:00 AM - 5:00 PM
Sunday: By appointment

Feel free to drop by or contact us at 09761275412 or [email protected].

Celebrating 2 years of Aton LawโœจGrateful for our clientsโ€™ trust and our teamโ€™s unwavering dedication. Hereโ€™s to many mor...
15/01/2026

Celebrating 2 years of Aton Lawโœจ

Grateful for our clientsโ€™ trust and our teamโ€™s unwavering dedication. Hereโ€™s to many more years of service and excellence.๐Ÿฅฐโœจ

We would like to express our thanks to our clients for the thoughtful Christmas presents. We truly appreciate it.โค๏ธLooki...
09/01/2026

We would like to express our thanks to our clients for the thoughtful Christmas presents. We truly appreciate it.โค๏ธ

Looking forward to serve you best. โœจ

19/12/2025

The (SC) has admonished Marikina City Regional Trial Court Judge Rey P. Inciong for his conduct during a parking-related incident involving a Public Attorneyโ€™s Office (PAO) lawyer, Atty. Ivanheck U. Gatdula. A video of the incident was later shared on social media.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC En Banc found that Judge Inciong acted improperly when he publicly scolded Atty. Gatdula and demanded a public apology.

Judge Inciong was heard uttering demeaning remarks at Atty. Gatdula after the latter briefly parked his vehicle blocking an access ramp for persons with disabilities and a pedestrian pathway while he logged his attendance to avoid being marked late. Atty. Gatdula immediately apologized several times.

Despite this, Judge Inciong demanded a public apology from Atty. Gatdula. The judge later went to the PAO office, where he again insisted on the apology and lost his temper.

Atty. Gatdula and his supervisor said the judgeโ€™s remarks and actions were intimidating and unnecessary, especially since an apology had already been made. They also said that a public apology was no longer required.

The Office of the Court Administrator ordered Judge Inciong to explain his actions and initially recommended that he be reprimanded and sternly warned.

The matter was referred to the Judicial Integrity Board, which recommended that he be found guilty of the light offense of vulgar and unbecoming conduct under Canon VI, Section 35(b) of the Code of Professional Responsibility and Accountability (CPRA).

In admonishing Judge Inciong, the Supreme Court recognized his intention to enforce order in the hall of justice but emphasized that this did not justify harsh language or aggressive behavior.

Citing Canons II (on Integrity) and IV (on Propriety) of the CPRA, the SC reminded judges that even when faced with improper conduct, they must still act with restraint and maintain the dignity of their office. Public confidence in the Judiciary, the SC said, depends on how judges behave.

The SC stressed that judges may exercise their right to free speech and expression, but they must do so within the limits of decency.

The SC observed that Judge Inciongโ€™s conduct was his first offense and that he has maintained a clean record in public service since 1999. While the SC found him free from administrative liability, it issued a warning that future similar behavior will face more serious consequences.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=157802

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=157776

Read the Dissenting Opinion of Associate Justice Japar B. Dimaampao at https://sc.judiciary.gov.ph/?p=157789

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

19/12/2025

The has clarified that the proper term for the crime under Article 266-A(1)(a) of the ๐˜™๐˜ฆ๐˜ท๐˜ช๐˜ด๐˜ฆ๐˜ฅ ๐˜—๐˜ฆ๐˜ฏ๐˜ข๐˜ญ ๐˜Š๐˜ฐ๐˜ฅ๐˜ฆ (๐˜™๐˜—๐˜Š) is ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ and not ๐˜ด๐˜ช๐˜ฎ๐˜ฑ๐˜ญ๐˜ฆ ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SCโ€™s Third Division affirmed a manโ€™s conviction for ra**ng a 13-year-old girl, sentencing him to a maximum of 40 years in prison.

The accused was found guilty by the Regional Trial Court and the Court of Appeals of ๐˜ด๐˜ช๐˜ฎ๐˜ฑ๐˜ญ๐˜ฆ ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ.

Under Article 266-A(1)(a) of the RPC, ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ is committed when a man has sexual in*******se with a woman through force, threat, or intimidation.

The SC affirmed his conviction and also took the opportunity to clarify that the crime should be referred to as ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ instead of ๐˜ด๐˜ช๐˜ฎ๐˜ฑ๐˜ญ๐˜ฆ ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ:

โ€œAfter all, there is nothing โ€˜simpleโ€™ about R**e and referring to it in such a manner downplays its severity and desensitizes the public to the harm it inflicts,โ€ said the SC.

While ๐˜ณ๐˜ข๐˜ฑ๐˜ฆ was initially classified as a crime against chastity under Article 335 of the RPC, Republic Act No. 8353, or the ๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜™๐˜ข๐˜ฑ๐˜ฆ ๐˜“๐˜ข๐˜ธ ๐˜ฐ๐˜ง 1997, reclassified it as a crime against persons.

Crimes against chastity, such as adultery and seduction, are generally private crimes which focus on protecting the victimโ€™s honor.

On the other hand, crimes against persons, such as homicide, murder, and physical injuries, aim to protect individualsโ€™ bodily integrity and well-being.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=157708.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=157708.

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

06/08/2025

The invalidated a sale of two parcels of land because the buyer knew that the seller was not the real owner.

In a Decision written by Associate Justice Maria Filomena D. Singh, the SCโ€™s Third Division cancelled the sale made by Bayani S. Cerilla (Cerilla) to Edward C. Ciacho (Ciacho). The SC found that Ciacho knew the sold properties did not belong to Cerilla.

The properties were inherited by Adolfo De Guia which were about to be foreclosed due to unpaid debt. De Guia asked Cerilla to pay off the mortgage. They signed a deed of sale, and land titles were transferred to Cerillaโ€™s name.

After a few months, another agreement was signed to re-sell the properties to De Guia. The latter filed adverse claim on the titles.

Cerilla and De Guia entered into a subsequent agreement where Cerilla would buy the properties for PHP 15 Million but only after De Guia ejects the illegal settlers from the properties.

As De Guia failed to remove the illegal settlers, Cerilla had to undertake the same but was not successful in doing so. As a result, Cerilla incurred expenses for ejectment which caused him to obtain a loan from a bank and from Ciacho.

Ciacho agreed to lend Cerilla with the properties as collateral. Because Cerilla could not pay the loan, Ciacho asked him to sign a deed of sale on the properties but with a request from Cerilla not to register the same.

De Guia learned that Ciacho registered the properties under his name. Thus, he filed a case with the RTC to invalidate the sale. After finding in favor of De Guia, the case was appealed to the Court of Appeals.

Both RTC and CA found that Cerilla had no authority to sell the properties as he was just a mere โ€œaccommodation partyโ€ to avoid foreclosure of the properties but was not the real owner.

The Court agreed with the RTC and CA finding that there was no real intention to transfer ownership from De Guia to Cerilla. Even after the land titles were transferred under his name, Cerilla did not act as if he owned the lands.

Under the Civil Code, for a sale to be valid, the parties must agree to the sale. The partiesโ€™ actions during and after the agreement can serve as basis to determine their intent. The seller must also be the owner of the property or has authority to sell.

Here, the re-sale of the properties from Cerilla to De Guia within a short period of time coupled with the fact that Cerilla asked Ciacho not to register the properties under his name, indicate that there was no intention on the part of De Guia to transfer ownership of the properties.

The Court added that Ciacho cannot claim to be an innocent buyer because he was aware of facts that should have raised doubts about Cerillaโ€™s ownership. He knew of the earlier sale between De Guia and Cerilla and the formerโ€™s claim as annotated on the titles.

Read the full text of the press release at https://sc.judiciary.gov.ph/sc-no-valid-sale-if-buyer-knows-seller-is-not-true-owner/

Read the full text of the Decision https://sc.judiciary.gov.ph/259051-edward-c-ciacho-vs-spouses-adolfo-t-de-guia-and-fe-alma-v-de-guia-et-al/

Read the Separate Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/259051-separate-concurring-opinion-justice-alfredo-benjamin-s-caguioa/

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

Address

Basak
Lapu-Lapu City
6015

Opening Hours

Monday 8am - 5pm
Tuesday 8am - 5pm
Wednesday 8am - 5pm
Thursday 8am - 5pm
Friday 8am - 5pm
Saturday 8am - 5pm

Telephone

+639761275412

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