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26/12/2025

The has laid down guideposts for proving who owns or controls a social media account in criminal cases.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SCโ€™s First Division affirmed the conviction of an individual (###) for committing psychological violence under Section 5 (i) of the ๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜๐˜ช๐˜ฐ๐˜ญ๐˜ฆ๐˜ฏ๐˜ค๐˜ฆ ๐˜ˆ๐˜จ๐˜ข๐˜ช๐˜ฏ๐˜ด๐˜ต ๐˜ž๐˜ฐ๐˜ฎ๐˜ฆ๐˜ฏ ๐˜ข๐˜ฏ๐˜ฅ ๐˜›๐˜ฉ๐˜ฆ๐˜ช๐˜ณ ๐˜Š๐˜ฉ๐˜ช๐˜ญ๐˜ฅ๐˜ณ๐˜ฆ๐˜ฏ (๐˜ˆ๐˜ฏ๐˜ต๐˜ช-๐˜๐˜ˆ๐˜ž๐˜Š) ๐˜ˆ๐˜ค๐˜ต against his ex-girlfriend (AAA) by posting derogatory statements about her on ๐˜๐˜ข๐˜ค๐˜ฆ๐˜ฃ๐˜ฐ๐˜ฐ๐˜ฌ.

The SC sentenced ### to up to eight years in prison, imposed a PHP 100,000 fine, and ordered ### to undergo psychological counseling or psychiatric treatment.

The SC stressed that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender.

It explained that for crimes committed through social media, the basic features of the platform such as ๐˜๐˜ข๐˜ค๐˜ฆ๐˜ฃ๐˜ฐ๐˜ฐ๐˜ฌ, must be considered.

Noting that ๐˜๐˜ข๐˜ค๐˜ฆ๐˜ฃ๐˜ฐ๐˜ฐ๐˜ฌ is widely used in the Philippines, the SC held that a ๐˜๐˜ข๐˜ค๐˜ฆ๐˜ฃ๐˜ฐ๐˜ฐ๐˜ฌ account can easily be created by anyone claiming to be at least 13 years old with an email address or mobile number.

Once an account is created, the user can add friends, exchange private messages, and post statements, photos, or videos visible to others depending on the userโ€™s privacy settings. Fake or dummy accounts can easily spread, enabling disinformation, identity theft, or crimes.

Given this, the SC ruled that guideposts are necessary to establish who owns or controls a social media account. It said the following must be shown to prove ownership or access:

1. Admission of ownership or authorship;
2. Being seen accessing the account or composing the post;
3. Containing information known only to the offender or a few people;
4. Language consistent with the offenderโ€™s characteristics;
5. Records from the internet service provider, telecommunications company, or social media site, and results from device forensic analysis showing geolocation features, and other attributes linking the account to the offender;
6. Acts consistent with previous posts; or
7. Other instances showing ownership, access, or authorship.

Applying these, the SC found that several factors proved ### wrote the ๐˜๐˜ข๐˜ค๐˜ฆ๐˜ฃ๐˜ฐ๐˜ฐ๐˜ฌ post. The account name bore his full name, and the profile photo showed him with his child from his current live-in partner.

AAAโ€™s sister had also received messages from the same account for years.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=158535.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=158446.

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

19/11/2025
20/10/2025

The has reiterated that just compensation in land expropriation cases must be based on all relevant factors, not just market value.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SCโ€™s Third Division remanded to the Regional Trial Court (RTC) the case between the City Government of Pasay (Pasay LGU) and Arellano University (University) to reassess the amount of just compensation owed to the latter.

The University filed a complaint before the RTC in 2015, claiming that the Pasay LGU took its 805-sq. m. parcel of land in Barangay San Isidro and turned it into a public road, now known as Menlo Street, without going through proper expropriation proceedings or paying just compensation. The parties subsequently referred the matter to a board of commissioners composed of Pasay LGU officials.

The board used a base value of PHP200/sq. m. based on the 1978 General Revision of the City Assessorโ€™s Office, then added 6% annual interest from 1978, the year the street was discovered, up to 2017, resulting in a value of PHP2,060/sq. m.

The University disagreed and proposed a total compensation of PHP 5,793,664.63, arguing that the interest should be based on the rates published by the Bangko Sentral ng Pilipinas.

The RTC adopted the boardโ€™s base value but applied a different interest rate, ordering Pasay LGU to pay PHP 161,000 plus 12% annual interest from 1978 to 2018.

The CA remanded the case to the RTC, ruling that the RTC relied solely on the 1978 assessment and ignored other relevant factors.

The SC upheld the CA, finding that the RTCโ€™s decision was based on incomplete data.

Article III, Section 9 of the Constitution provides that private property cannot be taken for public use without just compensation. The SC emphasized that just compensation must be real, substantial, full, and ample, and that determining this amount is a matter for the courts to decide.

The SC clarified that although local government assessors provide appraisals, these are not controlling in expropriation cases. Such appraisals often cover broad areas and do not account for specific property differences. They rely on general descriptions and may be inaccurate. And while tax values can serve as a guideline, they cannot substitute for a comprehensive assessment of just compensation.

Thus, courts must use a โ€œtotality of circumstancesโ€ approach, considering all facts about the propertyโ€™s condition, surroundings, existing improvements, and capabilities. These include the zonal valuation of the Bureau of Internal Revenue, acquisition cost, tax declarations, size, shape, location, and the current value of similar properties.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=153762

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=153692

Read the Separate Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/?p=153737

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

19/10/2025

COMELEC CAN'T DISQUALIFY CANDIDATE ABSENT CONVICTION FROM COMPETENT COURTโ€”SUPREME COURT

| The Supreme Court (SC) has junked the petition for disqualification against Edgar Erice from running as congressman of Caloocan Cityโ€™s 2nd District in the May 2025 midterm elections, due to lack of prior conviction from court.

In a 17-page decision penned by Associate Justice Henri Jean Paul Inting, the SC En Banc overturned the decision of the Commission on Elections (Comelec), which had earlier declared Erice disqualified for allegedly violating the Omnibus Election Code (OEC).

To recall, the high court had earlier issued a temporary restraining order to halt Comelec from enforcing the disqualification of Erice while the case was under review.

The case stemmed from statements Erice made during media interviews in April 2024, where he claimed that the automated counting machines from Miru Systems (Miru) had never been used in any election worldwide.

He flagged the PHP18 billion contract between Comelec and Miru, saying that the bidding was rigged and that he had evidence of offshore accounts linked to Comelec officials, including Chairman George Erwin Garcia.

In disqualifying Erice, the poll body cited Section 261(z)(11) of the Omnibus Election Code, which prohibits spreading false or alarming information regarding ballot printing, election postponement, or the general conduct of elections when the statements are intended to disrupt the election process.

Erice countered this claim, emphasizing that there was no violation because the prohibition against spreading false or alarming information applies only to statements made during an actual election and within the vicinity of voting centers. He claimed his statements were protected under his right to free speech.

In deciding in favor of Erice, the SC clarified that under Section 1(c)(3)(viii) of Comelec Resolution No. 11046, a candidate can only be disqualified if a competent court has already found them guilty of violating the OEC or the Local Government Code in a separate proceeding.

The SC said under the OEC, Comelec has the authority to investigate election offenses, while the Regional Trial Courts have the power to decide if an offense was committed.

โ€œInstead of following the foregoing procedure, it appears that respondent Comelec decided to directly rule on whether petitioner Erice is guilty of violation of Section 26l(z)(1 l), an election offense, and after having done so, imposed the penalty of disqualification. This cannot be permitted,โ€ the Supreme Court said.

The highest bench noted that the poll body failed to observe the proper legal steps when it directly declared that Erice was guilty and then proceeded to disqualify him.

โ€œConsidering that respondent Comelec had no power in the first place to disqualify a candidate on the ground of violation of Section 26l(z)(l 1) of the Omnibus Election Code, the Court shall refrain from determining whether petitioner Erice violated this provision,โ€ the courtโ€™s ruling read.

โ€œTo reiterate, the determination of petitioner Ericeโ€™s guilt for this election offense should be made in the proper forum through an appropriate action,โ€ it added.

24/09/2025

The (SC) has reiterated that preventing employees from entering company premises and doing their jobs, without a valid reason, is considered illegal dismissal.

In a Decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SCโ€™s Second Division upheld the labor arbitersโ€™ ruling that 12 workers from Constant Packaging Corporation (Constant Packaging), a company that prints packaging materials, were illegally dismissed.

Constant Packaging hired the workers as sorters and packers on a ๐˜ฑ๐˜ข๐˜ฌ๐˜บ๐˜ข๐˜ธ basis (paid per output).

The workers later raised concerns about their below-minimum wage earnings, 12-hour work day, 7-day work week, non-remittance of their SSS, PhilHealth, and PAG-IBIG contributions, and delay in the release of their salaries. Constant Packaging responded by telling them to leave if they were unhappy with their working conditions.

The workers filed a complaint with the Department of Labor and Employment. Soon after, the company security guard prevented them from entering the company premises, leading the workers to file a complaint for illegal dismissal.

Ruling in favor of the workers, the SC clarified that an employee who is able and willing to work is considered illegally dismissed if they are prevented from entering the workplace without a valid or lawful reason.

In this case, the companyโ€™s security guard blocked the workers from entering the company premises without any valid reason. This action amounts to dismissal.

Moreover, as the workers were suddenly dismissed without following the required procedures, their dismissal was unlawful.

The SC thus ordered Constant Packaging to pay the workers separation pay, back wages, service incentive leave, and holiday pay.

However, since the workers were hired on a ๐˜ฑ๐˜ข๐˜ฌ๐˜บ๐˜ข๐˜ธ basis, the SC ruled that they are not entitled to 13th month pay.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/sc-preventing-employees-from-reporting-to-work-without-valid-reason-is-illegal-dismissal/.

Read the full text of the Decision at https://sc.judiciary.gov.ph?p=152126.

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

20/09/2025

SUPREME COURT AFFIRMS COA'S POWER TO RULE ON LEGALITY OF DISBURSEMENT OF GOV'T FUNDS

| The Supreme Court (SC) has affirmed the Commission on Audit (COA) notice of disallowance on the disbursement of Medical/Health Care Allowance (MHCA) to former officials of the Department of Agrarian Reform (DAR) but absolved its former secretary from liability to return the disallowed amount.

In a 13-page ruling penned by Associate Justice Antonio Kho, Jr., the SC En Banc partially granted the petition of former DAR Secretary Atty. Rene Villa and absolve him from solidary liability to return the disallowed P70.301 million given to former officials of DAR from 2001 to 2005 as their health care allowance.

The COA Audit Team issued notices of disallowances to DAR former officials, including Villa, on the disbursement of the MHCA pursuant to the collective negotiation agreement (CNA) entered into between DAR and the DAR Employees Foundation, Inc.

It found that the budget of the MHCA was charged to the Agrarian Reform Fund (ARF) or the Comprehensive Agrarian Reform Program (CARP) Fund, thereby violating Section 9 of Presidential Decree No. 4776, which required that trust funds shall only be available for the specific purpose.

In 2017, the COA proper affirmed the notice of disallowance, as it held that a special fund like the CARP fund should only be obligated for the purpose for which it was created and that is for payment of compensation to landowners and expenses involved in the implementation of support services.

The state auditor has ordered the approving/certifying officers, including Villa, to return the disallowed amounts. Subsequently, Villa filed a motion for reconsideration, but it was also dismissed, prompting him to elevate the case before the Supreme Court.

In partially granting Villa's petition, the high court cited the case of Amputuan vs. COA in absolving him from solidary liability. It emphasized that a mere signature in the CNA cannot be assumed to operate as an express or implied authority from the signatory thereof to release the MHCA arising from the agreement.

The SC stressed that there must be proof that Villa not only conspired with the persons who actually caused the disbursement of the MHCA but also acted with bad faith, malice, or gross negligenceโ€”all of which the COA Proper failed to adduce.

โ€œAbsent any proof to show petitioner's participation in the disbursement of the MHCA, the Court is hard-pressed to hold that petitioner should be absolved from solidary liability to return the disallowed amounts,โ€ the Supreme Court said.

While Villa was absolved from liability, the SC, however, affirmed the notice of disallowance on the disbursement of the funds, as it recognized that COA is constitutionally empowered to exercise its general auditing power to determine, prevent, and disallow illegal, unnecessary, excessive, extravagant, or unconscionable expenditures of government funds.

It emphasized that the audit power of the commission is provided under Article IX(D), Section 2 of the 1987 Constitution, as "among the constitutional mechanisms that [give] life to the check and balance system inherent in our form of government."

"The Court has generally sustained the COA's decisions or resolutions in deference to its expertise in the implementation of the laws it has been entrusted to enforce... It finds that the COA Proper did not gravely abuse its discretion in affirming the propriety of the disallowance relative to the grant of MHCA to the officials and employees of DAR,โ€ it added.

18/09/2025

| The Supreme Court (SC) ruled that being irresponsible in doing household chores and taking care of children may be considered evidence of psychological incapacity to comply with marital obligations, a ground for nullification of marriage.

In a 13-page decision authored by Associate Justice Samuel Gaerlan, the SC's Third Division has declared void from the beginning the marriage between Arnold Alfonso and Michelle Pamintuan-Alfonso on the ground of the latter's psychological incapacity as provided under Article 36 of the Family Code.

Arnold and Michelle were high school classmates. In 1997, or eight years after their graduation, they unexpectedly met. Since then, they have become close and regularly exchanged phone calls.

Despite being in a relationship with another man, Michelle often visited Arnold's apartment. Later on Michelle and Arnold spent the night at the latter's apartment, where the two engaged in unprotected sexual in*******se that resulted in Michelle's unexpected and unwanted pregnancy.

At first, Michelle was contemplating aborting the child, but Arnold convinced her otherwise and offered marriage. After the wedding, Michelle and Arnold resided at the parental house. They were blessed with three children.

A year later their relationship turned sour. Arnold noticed the changes in Michelle's behavior. Michelle would be verbally aggressive towards him, crying loudly to gain sympathy from their neighbors. She also refused to do household chores or care for their children, instead relying on her mother to fulfill her domestic responsibilities.

Arnold also observed that Michelle has a luxurious lifestyle, which caused her to obtain looming debts from various people. It reached the extent that Arnold's father paid Michelle's debt to save her from being sued.

Over time, Arnold felt Michelle's growing coldness towards him. Michelle disavowed fulfilling his sexual needs by making excuses that she is tired and not in the mood.

Sometime in 2010, Michelle informed Arnold that she had secured a job that required deployment to Bicol for one month. However, to his surprise, Arnold later learned that Michelle was having an affair with another man. Since then, Michelle has refused to communicate with him and their children.

This paved the way for Arnold to file a petition for nullification of their marriage on the ground of Michelle's psychological incapacity to fulfill her marital obligations.

Initially, the Regional Trial Court (RTC) granted the petition and nullified their marriage, but it was later reversed by the Court of Appeals. This prompted Arnold to elevate the case before the Supreme Court.

In granting Arnold's petition, the high court held that he was able to illustrate that the incapacity of Michelle was so grave or serious that it already impaired her from carrying out the required ordinary marital duties. It gave credence to the psychological report, which diagnosed Michelle with histrionic personality disorder and antisocial personality disorder.

The SC also emphasized that the incapacity of Michelle was incurable, as the pattern of persistent failure to assume her essential marital obligations was proven. It also took into account the instance where Michelle entered into an illicit affair with another man.

โ€œIn every marriage lies the vinculum jurisโ€”the juridical bond that unites the spouses in a legally and morally binding union governed by law. This vinculum juris imposes upon each spouse the essential marital obligations of mutual love, respect, fidelity, and support,โ€ the Supreme Court said.

โ€œThus, in the present case, we hold that Michelle's psychological incapacity existed prior to and during the celebration of the marriage; the vinculum juris is deemed never to have validly arisen,โ€ it added.

02/09/2025

The (SC) has reiterated the rules in determining the appropriate legal actions for recovery of possession and/or ownership of land and the corresponding prescriptive periods in filing them. These remedies are: ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ž๐™ฃ๐™ฉ๐™š๐™ง๐™™๐™ž๐™˜๐™ฉ๐™–๐™ก or ejectment, ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™–, and ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™–.

In a Decision written by Associate Justice Ricardo R. Rosario, the SC ๐™€๐™ฃ ๐˜ฝ๐™–๐™ฃ๐™˜ held that Lea Victa-Espinosa (Espinosa) correctly filed an ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– to recover possession of her land within a year from dispossession. It explained that ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– may be filed not only when the dispossession lasted for a year but also when it lasted for a year or less when there is no allegation that the deprivation is by force, intimidation, threat, strategy, or stealth.

The SC also ruled that Espinosaโ€™s action is not ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™– as she did not seek in her complaint the recovery of ownership of the land.

After purchasing the property, Espinosa found that Spouses Noel and Leny Agullo were occupying a part of it. When they refused to leave despite her demand, Espinosa filed a complaint for recovery of possession in the Regional Trial Court (RTC).

The RTC dismissed the complaint for being filed too early. It explained that Espinosa may still file forcible entry, an ejectment suit, within one year from the time she learned of the deprivation of physical possession of the land. Since an ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– can only be filed after that one-year period, RTC ruled that her complaint was premature.

The Court of Appeals reversed the RTCโ€™s decision, finding that Espinosaโ€™s complaint was not an ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– but an ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™–, as she sought to recover possession based on her ownership of the property.

In their Petition before the SC, Spouses Agullo sought to reinstate the ruling of the RTC dismissing the case and insisted that Espinosaโ€™s case was an ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– that was filed prematurely, as less than a year had passed since the alleged dispossession.

The Court denied the Petition but clarified that the action is not accion reivindicatoria but accion publiciana. It reiterated the actions available for recovery of possession and/or ownership of land:

โ€ข ๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ž๐™ฃ๐™ฉ๐™š๐™ง๐™™๐™ž๐™˜๐™ฉ๐™–๐™ก or a summary ejectment case;
โ€ข ๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™–; and
โ€ข ๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™–.

๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ž๐™ฃ๐™ฉ๐™š๐™ง๐™™๐™ž๐™˜๐™ฉ๐™–๐™ก or summary ejectment proceeding is filed to recover physical possession of land when the dispossession was due to force, intimidation, threat, strategy, or stealth and has not lasted for more than a year.

๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– is filed when the dispossession lasted for more than a year, or even for a year or less, if it is not due to force, intimidation, or similar means.

๐˜ผ๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™– is filed to recover both ownership and possession based on that ownership.

The Court explained that in ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™–, the issue is who has the better right to possess the land, without necessarily claiming ownership. In contrast, ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™– involves determining who owns the land, with possession granted to the rightful owner.

As what is sought in the complaint is recovery of possession and not ownership, and there is no allegation that Spouses Agullo disputed Espinosaโ€™s title, the action is ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– and not ๐™ง๐™š๐™ž๐™ซ๐™ž๐™ฃ๐™™๐™ž๐™˜๐™–๐™ฉ๐™ค๐™ง๐™ž๐™–.

The Court also held that contrary to the findings of the RTC, the action was not premature, because ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™– may be filed even within one year from dispossession if no force, intimidation, threat, strategy, or stealth was used. Since Espinosa did not claim that Spouses Agullo used any of these means, the action was correctly filed not as ejectment suit but ๐™–๐™˜๐™˜๐™ž๐™ค๐™ฃ ๐™ฅ๐™ช๐™—๐™ก๐™ž๐™˜๐™ž๐™–๐™ฃ๐™–.

The SC thus ordered the RTC to proceed to trial and decide the case.

Read the full text of the press release at https://tinyurl.com/y7nr9hzx

Read the full text of the Decision at https://tinyurl.com/38e2xzfa

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

27/08/2025

| The Supreme Court (SC) held that not all denials and alibis to the commission of a crime should be regarded as fabricated, most especially if the prosecution failed to discharge the burden of proof beyond reasonable doubt.

In a 25-page ruling penned by Associate Justice Japar Dimaampao, the SC's Third Division has acquitted Marvin Nuguid of murder for allegedly shooting Dutch national Wilhelmus Johannes Joseph Geertman to death on the grounds of reasonable doubt and for the failure of the prosecution to sufficiently establish his guilt.

Geertman was the executive director of Alay Bayan, Inc., a non-government organization engaged in disaster preparedness. Initially, Nuguid, along with three others, was indicted for murder and robbery stemming from an incident that happened in 2012. The victim, Geertman, was gunned down by two assailants who entered the Alay Bayan Inc. premises.

The unidentified men escaped by riding a motorcycle driven by a third man, parked just outside the compound. Geertman was immediately rushed to the hospital but was declared dead on arrival. It was only in 2014, or roughly two years after the incident, when the police searched Nuguid's house and arrested him for the crime.

The Regional Trial Court (RTC) acquitted Nuguid for robbery due to the prosecution's failure to prove his guilt beyond a reasonable doubt. But on the other hand, he was convicted for murder, giving great weight to the testimonies of prosecution witnesses. The said ruling was later upheld by the Court of Appeals, prompting the accused to elevate the case before the Supreme Court.

In acquitting Nuguid, the SC held that the lower courts committed reversible error in hastily convicting him based on questionable evidence. It noted the basic and immutable principle in criminal law that an accused individual cannot be convicted if there is reasonable doubt in his commission of a crime.

"Indeed, proof of guilt beyond reasonable doubt must be adduced by the prosecution; otherwise, the accused must be acquitted, even if, on the face of it, he or she appears to be most suspicious or even if there is no other possible or identifiable perpetrator [on] the records despite there having been a crime committed," the Supreme Court said.

It took into consideration the admission of some of the supposed witnesses who said that they did not personally witness the shooting of the victim and they cannot testify as to the real identity of the shooter.

Meanwhile, some supposed eyewitnesses also failed to give a concrete description of the assailant they purportedly saw and eventually acknowledged that they did not see who fired the gun that caused the death of Geertman.

The court found that the glaring inconsistencies in the testimonies of the witnesses, as well as in the evidence on record, are vital to the integrity of the case. It emphasized that the said inconsistencies were not based on minor details that greatly affect the credibility of the witnesses.

"The first duty of the prosecution is not to prove the crime but to prove the identity of the criminal, for even if the commission of the crime can be established, there can be no conviction without proof of identity of the criminal beyond a reasonable doubt," the Supreme Court said.

"The inconsistent statements inexorably lead this Court to conclude that the prosecution failed to discharge its burden of proving the guilt of Nuguid for the crime beyond a reasonable doubt. It is elementary that the prosecution must rely on the strength of its evidence and not on the weakness of that of the defense," it added.

The high court also underscored that while Nuguid relied on mere denials in asserting his innocence, and while these are the weakest evidence of all, it said not all alibis should be regarded as fabricated. Due to this acquittal, the court ordered the immediate release of the Nuguid from detention.

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