ADG Law Office

16/07/2026

Planning to purchase a land? 🏡 Don't skip your due diligence!💡

Before you sign a deed, ensure you remain a purchaser in good faith with the essential checks listed in the image below 👇🏼

12/07/2026

SUPREME COURT: CONTINUOUS COHABITATION REQUIRED FOR COMMON LAW PARTNERS TO QUALIFY FOR MARRIAGE LICENSE EXEMPTION

The Supreme Court (SC) has declared a marriage void from the beginning for lack of a valid marriage license, ruling that an Affidavit of Cohabitation containing false or fabricated statements has no legal force or effect and is considered a mere scrap of paper without legal effect.

In a 15-page decision penned by Associate Justice Henri Jean Paul Inting, the SC's Third Division has declared void ab initio the marriage between Boots Rodel Aguirre and Alma Aguirre due to absence of marriage license by executing a fraudulent Affidavit of Cohabitation

Boots and Alma were married on May 8, 2009, without securing a marriage license. Instead, they bypassed the license requirement by executing an Affidavit of Cohabitation under Article 34 of the Family Code, falsely swearing that they had continuously lived together as husband and wife for at least five years since December 2003.

However, Boots actually lived and worked in Israel from May 2006 to May 2009, returning only days before the wedding. In 2013, Boots filed a petition to declare their marriage void ab initio (from the beginning), admitting that the affidavit was fabricated to bypass the law.

The Regional Trial Court (RTC) and the Court of Appeals (CA) both declared the marriage null and void. The Republic, through the Office of the Solicitor General (OSG), appealed to the Supreme Court, arguing that Boots’ stay in Israel was merely a "temporary absence" that did not disrupt their cohabitation.

The high court affirmed the ruling of the CA and RTC as it held that the exceptions to the marriage license requirement must be strictly construed. It noted if the essential statements in an Affidavit of Cohabitation are false, the affidavit is considered a mere scrap of paper without legal effect.

The Court explained that lawmakers exempted qualified common-law couples from the marriage license requirement to protect them from the humiliation, shame, and embarrassment that could arise from the public posting of marriage license applicants' names, as stipulated under Article 34 of the Family Code.

But it underscored that the exemption applies only to couples who have lived together continuously as husband and wife for the period required by law. It clarified that intermittent cohabitation where the parties frequently separated, maintained separate residences, and did not publicly present themselves as husband and wife, does not qualify as a common-law union for purposes of the exemption.

The SC emphasized that while brief separations due to work or business do not necessarily interrupt an already established common-law relationship, the evidence showed that Boots and Alma never established an exclusive and regular common-law household before Boots left. As such, they failed to satisfy the legal requirements for exemption from obtaining a marriage license.

It added that because the essential matter in their sworn affidavit was a lie, the document was reduced to a "mere scrap of paper" with no legal force. Without a valid license or a truthful affidavit to exempt them, the marriage was legally non-existent from the start.

07/07/2026

The (SC) has ruled that a duplicate or photocopy of original documents, whether in paper or electronic form, can be admitted as evidence in court, provided there is no genuine question regarding the original’s authenticity or fairness in using the copy.

In a Decision written by Chief Justice Alexander G. Gesmundo, the SC’s First Division upheld the conviction of Ybo Lastimosa (Lastimosa) for the murder of Ildefonso Vega, Jr. (Vega) in a case involving the use of a photocopy of Vega’s death certificate as key evidence.

Witnesses testified during trial that Lastimosa shot Vega in the head outside a cockpit in Cebu City. Vega’s wife also testified that Vega was already dead when she found him at the hospital. To support her testimony, the prosecution presented a photocopy of Vega’s death certificate, which confirmed that he died from gunshot wounds.

Convicted by the trial court of homicide and by the Court of Appeals of murder, Lastimosa argued before the SC that the prosecution failed to prove that the crime was committed because the original death certificate was not presented. He claimed that a photocopy, without comparison to the original for authentication, should not have been admitted as evidence.

The SC affirmed the Court of Appeals, sentencing Lastimoso to reclusion perpetua and ordered him to pay PHP 275,000 in civil indemnity and damages. It explained that under Rule 130, Section 4(c) of the 2019 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘙𝘶𝘭𝘦𝘴 𝘰𝘯 𝘌𝘷𝘪𝘥𝘦𝘯𝘤𝘦, a duplicate is admissible as the original unless there is a genuine question about the original’s authenticity or it would be unfair to use the duplicate.

This rule applies to both paper-based and electronic documents, reflecting the modern reality where duplicates are often as reliable as originals.

However, the SC emphasized that while a photocopy may be admissible, its weight or value depends on how well it corroborates or supports other available evidence.

In this case, the photocopy of the death certificate, combined with the testimonies of Vega’s wife and other eyewitnesses, sufficiently established that Vega died from gunshot wounds and that Lastimosa was responsible.

Read the full text of the Press Release at
https://tinyurl.com/36r9m76u.

Read the full text of the Decision at https://tinyurl.com/mwe35fhe.

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

02/07/2026

PABATID | Ipinababatid sa lahat ng mga may-ari ng lupang di-natitinag (real property) na maaari pa ninyong samantalahin ang mga benepisyong ipinagkakaloob sa ilalim ng Real Property Valuation and Assessment Reform Act (RPVARA) hanggang Hulyo 5, 2026 na lamang.

Hinihikayat ang lahat ng mga taxpayers na magbayad ng kanilang Real Property Tax sa Office of the Provincial Treasurer, Capitol Compound, Puerto Princesa City, sa Hulyo 3–5, 2026 (Biyernes hanggang Linggo), mula 8:00 ng umaga hanggang 5:00 ng hapon, upang mapakinabangan ang mga benepisyo ng RPVARA at maisaayos ang kanilang obligasyon sa Real Property Tax sa loob ng itinakdang panahon.

Samantalahin ang pagkakataong ito at makiisa sa pagpapatupad ng RPVARA.

Provincial Treasurer's Office - PTO Palawan

02/07/2026