Jemuel Carlos Law Office

20/05/2026

Kasama ka hanggang sa pagtanda 😁.
Notarial Commission granted!

17/05/2026

The International Criminal Court's Jurisdiction is "complementary to national criminal jurisdiction."

16/05/2026

What makes a person a good spouse?
What makes a good marriage?
What reasons are sufficient to enter into, and to remain bound by, a marriage?
And when love has faded, is its absence ever, by itself, a sufficient reason to leave?

G.R. No. 249759, April 22, 2026.





Disclaimer: The image shown below is AI generated.

16/05/2026

FYI!

The has ruled that non-verbal threatening gestures with criminal intent may be considered grave threats under the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘗𝘦𝘯𝘢𝘭 𝘊𝘰𝘥𝘦 (𝘙𝘗𝘊).

In a Decision written by Associate Justice Alfredo Benjamin S. Caguioa, the SC’s Third Division acquitted Gregory Israel of grave threats after finding no criminal intent in his gesture of pretending to shoot and behead two individuals.

But it clarified that the crime of grave threats may be committed through non-verbal gestures and not only through spoken or written words.

Israel, who claimed to be a Belgian architect allowed to practice his profession in the Philippines, was hired by Belgian business partners Christine Helena Amanda Navez and Olivier Edmund Denonville for the construction of their building. After Israel refused to correct the construction defects in the said building, Navez and Denonville filed a case for damages against him.

Sometime in 2017, while Navez and Denonville were on their way home from the airport, they nearly collided with Israel’s motorcycle. The latter then allegedly made two overt gestures: pointing his fingers at Navez’s head as if pulling a gun trigger and drawing his fingers across his neck as if threatening to behead Navez.

Israel was convicted of grave threats. When his conviction was affirmed by the Court of Appeals, he sought relief from the SC, arguing that he had no criminal intent when he performed the acts, and that Article 282 of the 𝘙𝘗𝘊 does not cover pure non-verbal gestures.

The SC acquitted Israel after finding that criminal intent was not proven. But it disagreed with his other argument, ruling that non-verbal gestures may be considered grave threats.

To convict for grave threats, the 𝘙𝘗𝘊 requires two elements: the 𝗮𝗰𝘁𝘂𝗮𝗹 𝘀𝗽𝗲𝗮𝗸𝗶𝗻𝗴 𝗼𝗿 𝘂𝘁𝘁𝗲𝗿𝗶𝗻𝗴 𝗼𝗳 𝘁𝗵𝗲 𝘁𝗵𝗿𝗲𝗮𝘁𝘀 and the 𝗶𝗻𝘁𝗲𝗻𝘁 𝘁𝗼 𝗶𝗻𝘁𝗶𝗺𝗶𝗱𝗮𝘁𝗲.

The SC held that Article 282 of the 𝘙𝘗𝘊 does not differentiate between threats conveyed verbally and those expressed through non-verbal gestures. What matters is the communication of a threat intended to intimidate.

Although the second paragraph of the provision specifies that threats can be conveyed orally or in writing, it does not exclude threats conveyed through non-verbal means. Therefore, threats can be either verbal or non-verbal.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=166072.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=164941.

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

14/05/2026

Piliin mong maging mabuting tao.

13/05/2026

Naa pa ba pag-asa ning Pilipinas?

Murag dili naman ni "buhay ay langit sa piling mo."

12/05/2026

"Let us not become weary of doing good, for at the proper time we will reap a harvest if we do not give up."

Galatians 6:9

12/05/2026

"An accusation alone does not constitute proof of guilt."

B.M No. 4530

10/05/2026

It should be more than "Happy Mother's Day."

It should be I love you, I'm sorry, and thank you on a daily basis.

Love your mom no matter the celebration.

Happy mother's Day!