Atty. Winna Oroncillo-Tan, CPA

14/06/2026

14/06/2026

Honored to welcome the members of the IBP–Northern Samar Chapter for a Nationwide Synchronized Tree-Planting at Barangay Rebong, Las Navas, Northern Samar. A meaningful day of service, stewardship, and shared commitment to a greener future. 🌱🌳

10/06/2026

Happy Wednesday!

Time may pass quickly, but we are never powerless in how we use it. Each day is an opportunity to choose purpose, direction, and meaningful action.

May this midweek reminder inspire us to take charge of our time, our choices, and the path we are building.

14/02/2026

WHEN MARRIAGE HAS NO INTIMACY — IS IT STILL VALID? ✨

Not all love stories end with “happily ever after.” Some end in court — and sometimes, the issue is not betrayal or abandonment, but the absence of intimacy itself.

⚖️ Chi Ming Tsoi v. Court of Appeals

FACTS:
In this case, a couple married, lived together… but their marriage was never consummated. The wife claimed her husband persistently refused marital relations despite her efforts to build a normal marital life.

Later, she filed a petition to declare the marriage void under Article 36 of the Family Code, arguing psychological incapacity.

ISSUE:
Can refusal to engage in marital intimacy make a marriage legally void?

RULING:
YES — under certain circumstances.

The Court held that marriage involves essential marital obligations, including mutual love, respect, and intimacy. Persistent refusal to perform these obligations, when rooted in psychological incapacity, may render a marriage void from the beginning.

KEY TAKEAWAY: 💡

Psychological incapacity is not mere unwillingness or incompatibility. It must involve:

✔️ A serious psychological condition
✔️ Existing at the time of marriage
✔️ Rendering a spouse truly incapable of fulfilling essential marital duties.

This case reminds us that:

Marriage is more than ceremony — it is a partnership requiring emotional, psychological, and physical commitment.

Law recognizes that absence of genuine marital union may reflect deeper incapacity, not just personal choice.

Love is not only about romance — it carries responsibility, respect, and shared human connection.

HAPPY VALENTINES DAY! ❤️

13/02/2026

10/02/2026

𝗚𝘂𝗶𝗱𝗲𝗹𝗶𝗻𝗲𝘀 𝗼𝗻 𝘁𝗵𝗲 𝗣𝗿𝗼𝗰𝗲𝘀𝘀𝗶𝗻𝗴 𝗮𝗻𝗱 𝗜𝘀𝘀𝘂𝗮𝗻𝗰𝗲 𝗼𝗳 𝘁𝗵𝗲 𝗘𝗹𝗲𝗰𝘁𝗿𝗼𝗻𝗶𝗰 𝗖𝗲𝗿𝘁𝗶𝗳𝗶𝗰𝗮𝘁𝗲 𝗔𝘂𝘁𝗵𝗼𝗿𝗶𝘇𝗶𝗻𝗴 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻 (𝗲𝗖𝗔𝗥) 𝗳𝗼𝗿 𝗢𝗻𝗲-𝗧𝗶𝗺𝗲 𝗧𝗿𝗮𝗻𝘀𝗮𝗰𝘁𝗶𝗼𝗻𝘀 (𝗢𝗡𝗘𝗧𝗧)
RMC #56-2024, RMC #133-2024, and OM #20-2025

With the passage of the Ease of Paying Taxes (EOPT) Act, taxpayers can now file returns and pay taxes at any Authorized Agent Bank (AAB) or Revenue Collection Office (RCO). However, while payment is flexible, the jurisdiction for processing the eCAR remains specific to the type of transaction.

📌 Sale of Real Property: The RDO with jurisdiction over the location of the property.

📌 Sale of Personal Property: The RDO with jurisdiction over the seller's registration OR the RDO of the seller's residence.
📌 Donations (Individual): The RDO with jurisdiction over the residence of the donor.
📌 Donations (Non-Individual): The RDO where the donor-corporation is registered.

Note: If the address on the submitted documents (e.g., Deed of Donation/Sale, Barangay Certificate) differs from the address in the BIR’s system (ITS/IRIS), the residential address in the BIR system prevails.

The taxpayer, however, may process the eCAR at the RDO having jurisdiction over their actual and current residence, provided that the residence information in the BIR system is updated to reflect the current address. The Client Support Section of the RDO with jurisdiction over the current address shall initiate the transfer or update of the registration information.

📌 Estate Tax: The RDO with jurisdiction over the TIN of the Estate.
Note: If the decedent had a registered business, it is the RDO of that business. If not, it is the RDO where the heirs intend to apply for the eCAR.

06/02/2026

What is the crime committed — ESTAFA or QUALIFIED THEFT? ✨

Many people confuse estafa with qualified theft, especially in cases involving money or trust. The key difference lies in how possession of the property was given and whether fraud was involved.

⚖️ ESTAFA is committed when a person voluntarily gives money or property because of deceit or fraud.

WHAT IS JURIDICAL POSSESSION IN ESTAFA?

It means money or property is legally entrusted to a person — meaning they are given authority to control or use it for a specific purpose or condition, not just hold it physically.

📌 Example: Someone borrows ₱200,000 claiming it will be used for a business that does not exist, then disappears after receiving the money.

Because the money was given due to deception, the crime may be estafa.

⚖️ QUALIFIED THEFT is committed when a person takes money or property without the owner’s consent, usually abusing trust or a special relationship (employee, helper, agent, etc.)

WHAT IS MATERIAL POSSESSION IN QUALIFIED THEFT?

It means ONLY PHYSICAL CUSTODY of money or property is given; legal control remains with the owner. (Taga-hawak lang.)

The person is allowed to hold or handle the property but does NOT have legal authority to control or use it.

📌 Example: A collection agent keeps the cash collected from clients instead of remitting it to the employer.

Since the agent only had custody, keeping the money may constitute qualified theft.

💡Simple takeaway:

✔ If voluntarily GIVEN because of DECEPTION — likely Estafa.

✔ If TAKEN WITHOUT CONSENT despite trust — likely Qualified Theft.

⚠️ Disclaimer: This is general legal information for educational purposes only and does not constitute legal advice. Each case depends on its specific facts and applicable law.

01/02/2026

MONEY DEBT SURVIVES, BUT HEIRS ARE LIABLE ONLY UP TO THE AMOUNT OF INHERITANCE RECEIVED. ✨

Under the Civil Code, money debts survive death, but they are charged against the ESTATE, not the heirs’ own pockets.

What is an “ESTATE”?

In simple terms, the estate is everything the deceased left behind — like land, house, savings, vehicles, or other property. Ito ang mga ari-arian na naiwan ng yumao. At ito ang gagamitin pambayad ng kanyang mga utang.

Heirs may pay but only up to what they inherit —
No inheritance? No payment.
May minana? Hanggang doon lang.

Key takeaway:

The debt is still valid — but it is charged against the ESTATE of the deceased, not automatically against the heirs.

⚠️ Disclaimer: This post is for general information only and is not a legal advice.

30/01/2026

CIVIL STATUS IS A MATTER OF FACT AND LAW — not a personal choice. ✨

Once a woman is validly married, her civil status automatically changes from “single” to “married” by operation of law. This is true regardless of:

• whether she continues using her maiden name
• whether her IDs have been updated yet
• whether she lives with her spouse or not

Key takeaway:
💡 Marriage changes civil status, not a woman’s name.

That distinction matters—especially in official records and sworn documents.

The Personal Data Sheet (CSC Form No. 212) is a sworn document. It requires the declarant to state true and correct personal circumstances as of the date of accomplishment. And Civil status of a person is not discretionary.

Disclaimer:
This post is for general information only and is not legal advice. Application of the law may vary depending on specific facts and applicable rules. ⚖️

27/01/2026

As they say, Excess is no accident when it is engineered. 😅

A landmark social media addiction trial in which top tech executives are expected to testify begins on Tuesday in California.

Read more about the case: https://bbc.in/4k3A1p8