K. L. Delgado - Law Office & Notary Public

09/10/2026

The (SC) has ruled that probate courts, which settle a deceased person’s estate, may require banks to explain withdrawals from the deceased person’s accounts to determine whether the funds are part of the estate.

In a Decision penned by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division upheld the Regional Trial Court’s (RTC) order requiring Union Bank of the Philippines (UnionBank) to explain withdrawals from the accounts of the late Ignacio T. Arroyo and submit related email exchanges.

During the settlement of Arroyo’s estate, the estate administrators discovered that money had been withdrawn from his UnionBank accounts after his death without the heirs’ knowledge.

The RTC, upon motion of the heirs, required UnionBank to explain the withdrawals and submit additional records, including emails exchanged between bank officers and a certain Atty. Fe. This was upheld by the Court of Appeals.

UnionBank challenged the ruling before the SC, arguing that the RTC had exceeded its authority as a probate court. The bank claimed that the withdrawals were made under a survivorship agreement and were used, among others, to settle Arroyo’s existing obligations. It also argued that any attempt to recover the funds should be brought in a separate civil case.

In upholding the RTC, the SC explained that while probate courts have limited powers, they may provisionally determine whether property belongs to a deceased person’s estate. Under Rule 87 of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵, they may also require persons suspected of concealing or taking estate property to answer questions and account for it.

In this case, the bank accounts were admittedly in Arroyo’s name. The RTC merely sought to determine how much money was in the accounts when he died and whether the funds should be included in the estate.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=174678

Read the full text of the Decision at https://sc.judiciary.gov.ph/e-02776-union-bank-of-the-philippines-vs-bernardina-arroyo-tantoco-and-alicia-rita-m-arroyo/

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

09/10/2026

07/10/2026

CONGRATULATIONS!

The UPHSL College of Law community proudly celebrates the hard-earned appointment of:

Justice Leilani Marie N. Dacanay-Grimares
Former Faculty Member,
UPHSL College of Law.

Newly appointed Associate Justice of the Court of Appeals.

Your dedication and excellence continue to inspire us all. We are incredibly proud of your success!

07/10/2026

LOOK: President Ferdinand R. Marcos Jr. has appointed Allan Batarra Gepty, Leilani Marie N. Dacanay-Grimares, and Pia Cristina B. Bersamin-Embuscado as Associate Justices of the Court of Appeals.

Their appointments reinforce the judiciary and support the administration of justice in the country.

06/10/2026

01/10/2026

30/09/2026

The has ruled that waiving rights to inherited property may be considered a valid donation when it shows intent to donate and meets the legal requirements for a donation.

In a Decision written by Associate Justice Jhosep Y. Lopez, the SC’s Second Division denied the consolidated petitions filed by Felix G. Cruz and affirmed the Court of Appeals’ (CA) rulings upholding the transfer of two inherited properties by Luis and Rosita Cruz to their sons, Robin and Osias.

The case involved two parcels of land left by Judy Cruz, who died single and without a will. She was survived by her parents, Luis and Rosita, and five siblings, including Felix, Robin, and Osias.

After Judy’s death, Luis and Rosita executed separate notarized 𝘞𝘢𝘪𝘷𝘦𝘳𝘴 𝘰𝘧 𝘙𝘪𝘨𝘩𝘵𝘴 over the properties in favor of Robin and Osias, who later executed an 𝘌𝘹𝘵𝘳𝘢𝘫𝘶𝘥𝘪𝘤𝘪𝘢𝘭 𝘗𝘢𝘳𝘵𝘪𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘚𝘦𝘵𝘵𝘭𝘦𝘮𝘦𝘯𝘵 𝘰𝘧 𝘌𝘴𝘵𝘢𝘵𝘦 and registered the properties in their names.

Felix and his two other siblings, Doris and Henry, also executed waivers giving up any interest in the properties. Felix, who was the family lawyer, prepared these documents.

After their mother died, Felix sought to nullify the transfer of the properties and cancel the titles of Robin and Osias. Felix argued that the transfer was invalid and that the properties should have remained part of their mother’s estate, to which he was entitled to inherit as one of the heirs.

The SC upheld the ruling of the trial court and the CA dismissing Felix’s complaint and holding that the Waivers of Rights executed by Luis and Rosita constituted valid donations in favor of Robin and Osias.

The SC explained that when Judy died, ownership of her properties immediately passed to her parents as her legal heirs. Luis and Rosita therefore had the right to dispose of the properties.

Although the documents they executed were called 𝘞𝘢𝘪𝘷𝘦𝘳𝘴 𝘰𝘧 𝘙𝘪𝘨𝘩𝘵𝘴, the SC found that Luis and Rosita intended to donate the properties to Robin and Osias.

Under Article 749 of the 𝘊𝘪𝘷𝘪𝘭 𝘊𝘰𝘥𝘦, a valid donation of real property requires: (1) a decrease in the donor’s property; (2) a corresponding increase in the donee’s property; (3) intent to donate; (4) ex*****on of the donation in a public document; and (5) acceptance by the donee. If the acceptance is in a separate document, the donor must be informed.

These requirements were met in this case. Luis and Rosita gave up their ownership of the properties in favor of Robin and Osias through notarized documents that expressly authorized the transfer. Robin and Osias, in turn, accepted the donation by executing the 𝘌𝘹𝘵𝘳𝘢𝘫𝘶𝘥𝘪𝘤𝘪𝘢𝘭 𝘗𝘢𝘳𝘵𝘪𝘵𝘪𝘰𝘯 𝘢𝘯𝘥 𝘚𝘦𝘵𝘵𝘭𝘦𝘮𝘦𝘯𝘵 and registering the properties in their names. Their actions were made known to Luis and Rosita.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=174097.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168026.

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

27/09/2026

Presiding Judge Janice L. Andrade-Udarbe of the Regional Trial Court, Branch 57, Lucena City, Quezon, and Acting Presiding Judge of Pasig City RTC Branch 161, discusses the use of online chat logs and videos as evidence vis-à-vis the right to privacy in 𝐄𝐩𝐢𝐬𝐨𝐝𝐞 𝟏𝟑𝟔: 𝐂𝐡𝐚𝐭 𝐋𝐨𝐠𝐬 𝐚𝐬 𝐄𝐯𝐢𝐝𝐞𝐧𝐜𝐞 𝐢𝐧 𝐂𝐨𝐮𝐫𝐭. Judge Andrade-Udarbe is also a Professorial Lecturer at the Philippine Judicial Academy, an MCLE Lecturer, a law professor, Bar reviewer, and author of law books.

• 𝘏𝘰𝘸 𝘤𝘢𝘯 𝘥𝘪𝘨𝘪𝘵𝘢𝘭 𝘦𝘷𝘪𝘥𝘦𝘯𝘤𝘦 𝘣𝘦 𝘶𝘴𝘦𝘥 𝘪𝘯 𝘢 𝘤𝘳𝘪𝘮𝘪𝘯𝘢𝘭 𝘤𝘢𝘴𝘦 𝘸𝘪𝘵𝘩𝘰𝘶𝘵 𝘷𝘪𝘰𝘭𝘢𝘵𝘪𝘯𝘨 𝘢 𝘱𝘦𝘳𝘴𝘰𝘯'𝘴 𝘳𝘪𝘨𝘩𝘵 𝘵𝘰 𝘱𝘳𝘪𝘷𝘢𝘤𝘺?

• 𝘞𝘩𝘢𝘵 𝘴𝘵𝘦𝘱𝘴 𝘴𝘩𝘰𝘶𝘭𝘥 𝘭𝘢𝘸 𝘦𝘯𝘧𝘰𝘳𝘤𝘦𝘳𝘴 𝘵𝘢𝘬𝘦 𝘵𝘰 𝘦𝘯𝘴𝘶𝘳𝘦 𝘵𝘩𝘢𝘵 𝘰𝘯𝘭𝘪𝘯𝘦 𝘤𝘩𝘢𝘵𝘴, 𝘷𝘪𝘥𝘦𝘰 𝘴𝘵𝘳𝘦𝘢𝘮𝘴, 𝘢𝘯𝘥 𝘰𝘵𝘩𝘦𝘳 𝘧𝘰𝘳𝘮𝘴 𝘰𝘧 𝘥𝘪𝘨𝘪𝘵𝘢𝘭 𝘦𝘷𝘪𝘥𝘦𝘯𝘤𝘦 𝘢𝘳𝘦 𝘱𝘳𝘰𝘱𝘦𝘳𝘭𝘺 𝘢𝘶𝘵𝘩𝘦𝘯𝘵𝘪𝘤𝘢𝘵𝘦𝘥 𝘢𝘯𝘥 𝘢𝘥𝘮𝘪𝘴𝘴𝘪𝘣𝘭𝘦 𝘪𝘯 𝘤𝘰𝘶𝘳𝘵?

This week's podcast is available on Spotify, Apple Podcasts, YouTube, Facebook, and the website.

LISTEN to the FULL episode of this Podcast on

Spotify: https://open.spotify.com/episode/3HuDktLKbdJjycBCQG6vSB?si=hIhZEJDFSVWyHePsaXNSjQ

Apple Podcasts: https://podcasts.apple.com/ph/podcast/supreme-court-ph-podcast/id1852172756?i=1000791593771

Facebook: https://www.facebook.com/share/v/1EJib6T4j3/

YouTube: https://youtu.be/Y6SNhYJA8Bo

SC website: http://sc.judiciary.gov.ph/podcasts/

24/09/2026

Newly uploaded pleading in current cases involving public interest:

G.R. No. E-08529 (Victor D. Rodriguez v. The Senate of the Philippines sitting as the Senate Impeachment Tribunal, et al.)

- Petition for Certiorari and Prohibitionhttps://sc.judiciary.gov.ph/wp-content/uploads/2026/09/PETITION-Victor-D.-Rodriguez-vs.-The-Senate-of-the-Philippines_Red.pdf

Copies of recent pleadings and orders in cases involving public interest are regularly uploaded to the Current Cases page of the website. SCAN the QR Code for the latest uploads.