26/08/2026
⚖️New Jurisprudence on BP 22 case.
In G.R. No. 277047, Carlos v. People (April 15, 2026), the Supreme Court clarified and standardized the modes of service of the Notice of Dishonor in B.P. Blg. 22 cases.
📌 Three recognized modes:
1️⃣ Personal Service — the primary mode.
2️⃣ Registered Mail — when personal service is not practicable, subject to the requirements on mailing and authentication.
3️⃣ Electronic Means — email or messaging applications may be used as a primary or substituted mode, provided the electronic contact is properly attributed and reasonably verified.
🔎 Important: An Affidavit of Service is now mandatory regardless of the mode used. Supporting evidence must properly establish the fact and circumstances of service.
The Court also emphasized that mere denial of receipt is not enough to defeat affirmative evidence of service.
Source: https://sc.judiciary.gov.ph/277047-arnel-carlos-and-marivic-carlos-vs-people-of-the-philippines-and-tire-star-inc/
