Maria Soledad M. Santos Law Office

10/02/2026

Full opinion here, originally published by the Supreme Court Public Information Office:

https://sc.judiciary.gov.ph/?p=160444

10/02/2026

My name my only legacy❤️

During the Testimonial Dinner of the San Sebastian College - Recoletos College of Law, Atty. Edwin Carillo delivered an inspirational message and shared some tips to the new lawyers of the said institution.

10/12/2025

15/11/2025

The Past IBP Zambales Chapter Presidents

12/08/2025

RISA -TORRE for 2028? why not?

28/05/2025

If a young professional dies, lost earning capacity is considered in calculating damages. -SC

RATIONALE

The law allows recovery of actual damages for loss of earning capacity in consideration of the heirs of the deceased or those who are legally entitled to support from the deceased. The damages do not pertain to the full amount of foregone earnings, "but of the support they received or would have received from [the deceased] had he not died in consequence of the negligence [or fault] of [the tortfeasor or the accused]."

This form of actual damages quantifies the loss of the deceased’s family in terms of financial support they will receive from the deceased. A widow does not only grieve for the loss of her husband; she also has to worry about finding an additional source of livelihood. The condition is often worsened when the deceased is the sole breadwinner of the family and the family is already experiencing difficulties making ends meet. While this might not always be the case, the law devised the concept of actual damages in the form of loss of earning capacity to ensure that a part of the family’s loss is mitigated.

HOW TO COMPUTE and HOW TO PROVE...

Read more: (Civil Law section)

Legal Services | Personal Blog | Laws/ Jurisprudence

28/05/2025

Psychological Damage ⚖️

28/05/2025

Corporate Secretaries take note

Ready, set, file! 📄

The deadline of Annual Financial Statements (AFS) submission has started for corporations with SEC registration numbers ending in 3 and 4.

Rewatch our eFAST tutorial video at bit.ly/eFASTguide for a step-by-step guide on how to submit reports.

Don't forget to submit until May 30!

28/05/2025

I was deeply honored to be the Keynote Speaker at the 8th Senior High School Commencement Exercises of COMTECH Computer and
Business College .

14/02/2025

The (SC) has reiterated that a notice to cancel a contract to sell real estate must be notarized under Republic Act No. 6552, popularly known as the Maceda Law.

In a Decision written by Associate Justice Antonio T. Kho, Jr., the SC’s Second Division upheld the validity of contracts to sell between State Investment Trust, Inc. (SITI) and spouses Carlos and Victoria Baculo (Spouses Baculo) after SITI failed to meet the Maceda Law’s cancellation requirements.

The Maceda Law’s purpose is to protect real estate buyers on installment payments against one-sided conditions in contracts.

SITI owned two parcels of land, which it offered to sell to Spouses Baculo through two contracts to sell. When the latter failed to complete payments, SITI sent letters demanding payment and, later, declaring the contracts to sell cancelled. The Spouses Baculo refused to vacate the property, leading Siti to file an ejectment case.

The SC ruled that while a seller may cancel a contract to sell under the Maceda Law on its own without going to court, it must still comply with Section 4 of the law, which requires: (1) a 60-day grace period for the buyer to settle overdue installments; (2) a notarized notice of cancellation from the seller; and (3) cancellation only after 30 days from the buyer’s receipt of the notarized notice.

In this case, the SC found that SITI’s letters were not notarized, and it failed to provide the required 60-day grace period, giving only five days to settle the balance.

Read the full text of the Press Release at
https://sc.judiciary.gov.ph/sc-notarized-notice-required-to-cancel-real-estate-contract-under-maceda-law/.

Read the full text of the Decision at https://sc.judiciary.gov.ph/237934-state-investment-trust-inc-vs-carlos-baculo/.

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

29/01/2025

The (SC) has ruled that foreign currency deposit accounts are exempt from estate tax under Republic Act No. 6426 (RA 6426), also known as the 𝘍𝘰𝘳𝘦𝘪𝘨𝘯 𝘊𝘶𝘳𝘳𝘦𝘯𝘤𝘺 𝘋𝘦𝘱𝘰𝘴𝘪𝘵 𝘈𝘤𝘵 𝘰𝘧 𝘵𝘩𝘦 𝘗𝘩𝘪𝘭𝘪𝘱𝘱𝘪𝘯𝘦𝘴.

In a Decision penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division upheld the claim for an estate tax refund filed by the estate of Charles Marvin Romig (Charles), an American national who was a resident of Puerto Galera, Oriental Mindoro.

Charles passed away in 2011 without leaving a will. His sole heir, Maricel Narciso Romig (Maricel), transferred ownership of his properties to herself, including a dollar deposit account, through an Affidavit of Self-Adjudication.

Maricel initially excluded the dollar deposit account from the estate tax computation but later paid an additional PHP 4.56 million to cover it. Subsequently, she sought a refund, arguing that foreign currency deposit accounts are exempt from estate tax under Section 6 of RA 6426.

The Commission on Internal Revenue denied her claim, asserting that the tax exemption over dollar deposit accounts was revoked by the 1997 𝘕𝘢𝘵𝘪𝘰𝘯𝘢𝘭 𝘐𝘯𝘵𝘦𝘳𝘯𝘢𝘭 𝘙𝘦𝘷𝘦𝘯𝘶𝘦 𝘊𝘰𝘥𝘦 (NIRC). However, the Court of Tax Appeals (CTA) ruled in Maricel’s favor.

Affirming the CTA, the SC emphasized that the NIRC, a general tax law, did not expressly repeal the specific tax exemption granted by RA 6426, a special law. The Court clarified that a general law cannot override or revoke a special law without a clear and explicit repeal provision.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-foreign-deposit-accounts-exempt-from-estate-tax/

Read the full text of the Decision at https://sc.judiciary.gov.ph/262092-commissioner-of-internal-revenue-vs-estate-of-mr-charles-marvin-romig-represented-by-its-sole-heir-mrs-maricel-narciso-romig/

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