Atty. Errol J. Dobrea, ECE

19/09/2026

Extension of the six-month probationary period

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

11/09/2026

06/09/2026

https://www.facebook.com/share/p/1baKb3ZM8H/

22/04/2026

24 likes. "Highlights of the Regional Consultations on the Unified Legal Aid Service (ULAS) Rules."

08/04/2026

Sa sesyon ng En Banc ng ngayong Miyerkules, ika-8 ng Abril 2026, naglabas ito ng writ of kalikasan laban sa Halrey Construction, Inc. at iba pang mga taong kumikilos para sa kanila, dahil sa pagsasagawa ng ilegal na quarrying sa loob ng Angat River-Bustos Dam Forest Reserve sa Banaban, Angat, Bulacan.

Sa ponencia ni Associate Justice Amy C. Lazaro-Javier, pinagbigyan ng Korte Suprema ang hiling ni petitioner Narciso A. De Leon para sa isang pansamantalang environmental protection order na nag-uutos sa mga respondent na agad itigil ang quarrying, paghuhukay, pagkuha ng lupa, o katulad na mga gawain sa loob ng watershed area. Ipinagbabawal din sa kanila ang paggawa ng anumang kilos na maaaring magdulot ng karagdagang pinsala sa kapaligiran.

Sa pag-isyu ng writ, inilapat ng Korte Suprema ang precautionary principle batay sa mga teknikal na natuklasan na nagpapakita na malaki ang naidulot ng mga gawain ng mga respondent sa pagtaas sa surface runoff, erosion, at sedimentation sa loob ng watershed system. Ayon sa mga ulat, sinira ng mga gawaing ito ang mga pananim, halaman, at mga punong namumunga na nagsisilbing tirahan ng mga hayop.

Binigyang-pansin din ng Korte Suprema na ang pagbabago sa likas na anyo ng kahit isang bahagi lamang ng isang protektadong forest reserve ay nagbabanta sa katatagan ng watershed ng Angat River-Bustos Dam at nagdudulot ng malubhang panganib sa buhay, kalusugan, at ari-arian ng mga naninirahan sa ilang lalawigan.

Idineklara bilang protektadong kagubatan ang Angat River-Bustos Dam Forest Reserve sa ilalim ng Proclamation No. 573.

Basahin ang press briefer sa https://sc.judiciary.gov.ph/?p=162980.

Sumunod sa Credit Attribution Policy ng SC PIO: https://sc.judiciary.gov.ph/credit-attribution-policy/.

28/03/2026

📣 𝗡𝗢𝗧𝗜𝗖𝗘: 𝗔𝗹𝗹 𝗰𝗼𝗺𝗽𝗹𝗮𝗶𝗻𝘁𝘀 𝗺𝘂𝘀𝘁 𝗯𝗲 𝗳𝗶𝗹𝗲𝗱 𝘁𝗵𝗿𝗼𝘂𝗴𝗵 𝘁𝗵𝗲 𝗶𝗠𝗲𝘀𝘀𝗮𝗴𝗲 𝗣𝗼𝗿𝘁𝗮𝗹 𝘀𝘁𝗮𝗿𝘁𝗶𝗻𝗴 𝟭 𝗔𝗽𝗿𝗶𝗹 𝟮𝟬𝟮𝟲

The Securities and Exchange Commission (SEC) informs the public that starting 1 April 2026, all complaints handled by the Enforcement and Investor Protection Department (EIPD) must be submitted through the SEC iMessage portal.

This system helps prevent duplicate submissions, reduces fraudulent or malicious complaints, and allows better tracking of case status and communication with complainants.

Submit your complaint at: https://imessage.sec.gov.ph

For assistance, visit www.sec.gov.ph or call 1-4SEC (1-4732).

🔗 Read the notice here: https://www.sec.gov.ph/notices-2026/public-notice-eipd-sec-imessage/

17/03/2026

▶️Special Rules for Micro & Small Individual Business Taxpayers◀️

✅ May use any of the individual AITR forms (1701-MS, 1701, or 1701A) regardless of what is written on their COR (Form 2303).
1701-MS – still manual only (not yet in eFPS or eBIRForms).
✅ Download from BIR website or request from RDO → print 3 copies.
✅ Payment: over-the-counter at any AAB.
✅ They may choose to file electronically using 1701 or 1701A (minimum fields only – see Annex “D”).
✅ Once 1701/1701A is electronically filed & paid, no need to file 1701-MS manually.
✅ No penalty for wrong venue or for using 1701-MS.
✅ No need to update COR to add “1701-MS”.

16/03/2026

The enactment of Republic Act No. 12010, also known as the Anti-Financial Account Scamming Act (“AFASA”), is a radical step forward in this country’s commitment to protecting consumers, deterring fraudsters, and fostering a more inclusive and resilient financial system. The implementing regulations, Bangko Sentral ng Pilipinas (BSP) Circular Nos. 1213, 1214, and 1215, Series of 2025, provide a comprehensive framework for the exercise of the BSP’s mandates and translate AFASA’s aspirations into actionable rules and policies for BSP-supervised institutions (“BSIs”), consumers, and the public. These rules work in tandem to (1) prevent, detect, and delay fraudulent transactions, (2) enhance the ability of fraud victims and BSIs to trace, hold, verify, and recover disputed funds, and (3) provide an expedited procedure for accessing and sharing financial account information for law enforcement purposes.

END OF SMS OTPs

LOOK: The Bangko Sentral ng Pilipinas will require banks in the Philippines to phase out SMS OTPs (One-Time Passwords) starting from June 30 in accordance with the implementation of the Anti-Financial Account Scamming Act (AFASA).

This measure, which seeks to prevent phishing, SIM-swapping, and text-hijacking scams, mandates that banks implement more advanced authentication methods, including biometrics, in-app OTPs or push notifications, behavioral biometrics (such as typing patterns or device movements), and silent authentication through telecommunications networks. | 📸: Digital Banks/ Facebook via Rajzaiken Anda, INQUIRER.net trainee

Story soon on business.inquirer.net.

04/03/2026

Source: The Manila Times

Payment in coins exceeding P2,000.00 is not allowed