ASG Law

Tag: false statement

  • Perjury and Venue: Where the False Statement Truly Matters

    The Supreme Court clarified that in perjury cases, the venue for filing charges is not where the false statement was sworn, but where the statement was used or filed. This ruling emphasizes that the intent to deceive and the impact of the false statement on a judicial proceeding are key to determining jurisdiction. It ensures that perjury cases are tried where the false statement has legal significance, safeguarding the integrity of court proceedings and protecting individuals from malicious prosecution in inappropriate venues.

    Ilusorio vs. Bildner: When a Notary Isn’t Enough – Finding the Right Court for Perjury

    This case stems from a dispute within Lakeridge Development Corp. (LDC) involving Erlinda K. Ilusorio and several other individuals (Ma. Erlinda Bildner, Lily Raqueño, Sylvia K. Ilusorio, Ma. Cristina A. Ilusorio, and Aurora I. Montemayor). The heart of the matter involves perjury charges filed by Erlinda K. Ilusorio against the respondents. These charges arose from petitions the respondents filed on behalf of LDC seeking new owner’s duplicate copies of property titles. The critical point of contention is whether these petitions contained false statements about the loss of the original titles.

    The informations filed against the respondents allege that they committed perjury by falsely claiming the titles were lost, when, according to Erlinda, she possessed them. These petitions were filed in the Regional Trial Courts of Makati and Tagaytay, but the perjury charges were brought in the Metropolitan Trial Court (MeTC) of Pasig City because the petitions were notarized there. The central legal question revolves around whether Pasig City was the proper venue for the perjury charges, given that the petitions were filed and intended to have legal effect in Makati and Tagaytay.

    The MeTC initially sided with Erlinda, arguing that as the alleged offenses were committed in Pasig City, it had the venue or territorial jurisdiction over these cases. However, the MeTC later reversed its decision, quashing the informations based on the argument that the statements made in the petitions were privileged. This decision was upheld by the Regional Trial Court (RTC) of Pasig City, which relied on cases involving libel and pleadings to justify the quashing of the perjury charges. Erlinda then appealed to the Supreme Court, challenging the lower courts’ reliance on the privilege doctrine.

    The Supreme Court addressed the procedural question raised by respondents, stating that the present petition is indeed a review on certiorari under Rule 45 of the Rules of Court, not a special civil action for certiorari under Rule 65, meaning that there was no violation of the principle of hierarchy of courts. Shifting to the substance of the case, the Court ultimately ruled that the venue for the perjury charges was improperly laid in Pasig City. The Court emphasized that perjury occurs where the false statement is made with the intent to deceive and where it has a legal effect.

    The Revised Penal Code defines perjury as follows:

    Article 183, Revised Penal Code:

    False Testimony in other cases and perjury in solemn affirmations. – The penalty of arresto mayor in its maximum period to prision correccional in its minimum period shall be imposed upon any person who, knowingly making untruthful statements and not being included in the provisions of the next preceding articles, shall testify under oath, or make an affidavit, upon any material matter before a competent person authorized to administer an oath in cases in which the law so requires.

    Applying this definition, the Court found that while the petitions were notarized in Pasig, the alleged false statements were material to the proceedings in Makati and Tagaytay. The Court clarified that the critical element of perjury is the deliberate making of untruthful statements on a material matter before a competent person. Therefore, the venue should be where the impact of that false statement is felt – where it is presented and relied upon in a legal proceeding.

    The court supported its venue ruling citing United States v. Cañet, noting that the core of perjury is “the intentional giving of false evidence” as a means of an affidavit or other signed and sworn instrument. Ultimately, the Court held that it was in Makati and Tagaytay, where the petitions were filed, that the intent to assert an alleged falsehood became manifest and where the untruthful statement finds relevance in the issuing of duplicate copies of property titles. The act of notarization in Pasig, while necessary for the petitions’ validity, was not the location where the perjury occurred for purposes of establishing criminal jurisdiction.

    FAQs

    What was the key issue in this case? The key issue was determining the proper venue for filing perjury charges against respondents who allegedly made false statements in petitions filed in Makati and Tagaytay. The charges were filed in Pasig City where the documents were notarized.
    What is perjury? Perjury involves knowingly making untruthful statements under oath or in an affidavit on a material matter, before a competent authority, in cases where the law requires such statements. It’s a crime against the administration of justice.
    Why did the Supreme Court rule against Pasig City as the venue? The Supreme Court determined that Pasig City was not the proper venue because the material false statements were intended to have legal effect in Makati and Tagaytay where the petitions were filed, not where they were notarized.
    Where should the perjury charges have been filed? The perjury charges should have been filed in Makati City and Tagaytay City, where the petitions containing the alleged false statements were filed and were intended to influence judicial proceedings.
    What is the significance of venue in criminal cases? Venue is jurisdictional in criminal cases, meaning the case must be instituted and tried in the municipality or territory where the offense was committed. Improper venue can lead to dismissal of the case due to lack of jurisdiction.
    What is the main takeaway of this ruling? The main takeaway is that in perjury cases, the venue is where the false statement has its intended and actual legal impact, not necessarily where the statement was sworn or notarized.
    How did the Court distinguish this case from previous rulings about privileged statements? The Court clarified that previous rulings on privileged statements in libel cases do not automatically apply to perjury cases. The Court held that Flordelis and Aquino cases, invoked by the lower courts to claim absolute privilege, are not applicable as respondents’ petitions are required by law to be under oath.
    What are the elements of perjury? The elements of perjury are: (a) making a statement under oath or an affidavit on a material matter; (b) doing so before a competent officer; (c) willfully asserting a falsehood; and (d) the sworn statement is required by law or for a legal purpose.

    In conclusion, the Supreme Court’s decision in Ilusorio v. Bildner provides clear guidance on determining the proper venue in perjury cases. This case reinforces that the location where a false statement is notarized is not determinative of jurisdiction; rather, it is where the statement is presented and has a material legal effect that matters. Understanding this distinction is crucial for both prosecutors and defendants in perjury cases.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Erlinda K. Ilusorio v. Ma. Erlinda I. Bildner, G.R. Nos. 173935-38, December 23, 2008

  • Perjury Requires Proof of Deliberate Falsehood: Honest Mistakes Are Not Enough

    The Supreme Court ruled that a person cannot be convicted of perjury if their false statement was the result of an honest mistake or a bona fide belief in its truth. The court emphasized that perjury requires a willful and corrupt assertion of a falsehood, meaning the person must have intentionally made a false statement with the knowledge that it was untrue. This decision protects individuals from perjury charges when discrepancies arise from genuine errors or sincerely held beliefs, ensuring that the legal system does not unduly punish unintentional misstatements.

    Compromise or Contradiction: Can a Signed Agreement Trigger a Perjury Charge?

    This case revolves around a dispute between Criste B. Villanueva (RCP) and Horst-Kessler Von Sprengeisen (HTC) concerning an anti-dumping case. They entered into a compromise agreement, but later, HTC sought to nullify the agreement, alleging fraud by RCP. This led to Villanueva filing a perjury complaint against Von Sprengeisen based on statements made in an affidavit supporting HTC’s motion. The central legal question is whether Von Sprengeisen’s statements constituted perjury, specifically focusing on the element of whether the statements were a willful and deliberate assertion of falsehood.

    The heart of the matter involves allegations of perjury against private respondent Von Sprengeisen, stemming from statements he made in an Urgent Motion to Set Aside and/or Vacate Judgment and its supporting Affidavit of Merit. The petitioner, Villanueva, asserted that Von Sprengeisen made false statements regarding the circumstances surrounding the compromise agreement between RCP and HTC, particularly the insertion of the phrase “based on the findings of the BIS.” Villanueva argued that Von Sprengeisen knew these statements were false and that they were made with the intent to deceive the Tariff Commission. The Secretary of Justice, however, reversed the City Prosecutor’s finding of probable cause for perjury, a decision affirmed by the Court of Appeals.

    The Supreme Court agreed with the lower courts, emphasizing that perjury requires a willful and deliberate assertion of a falsehood. The Court referred to Article 183 of the Revised Penal Code which defines perjury and set out the elements required to be proven to secure a conviction. In its analysis, the Court highlighted that a simple false statement is insufficient for perjury; the assertion must be intentional, malicious, and with the knowledge that it is untrue. The absence of malice or an honest mistake in making the statement negates the element of willfulness, thereby precluding a conviction for perjury.

    Building on this principle, the Court scrutinized the specific statements made by Von Sprengeisen. One key point of contention was who initiated the meeting between the parties. While Von Sprengeisen stated that Villanueva invited him, the Court found this discrepancy immaterial. The fact that the parties met and agreed to discuss the case was the more pertinent aspect, rendering the initiator’s identity inconsequential. This exemplifies the necessity of demonstrating the materiality of the false statement to the issue at hand.

    A further examination centered on the claim that Villanueva surreptitiously inserted the phrase “based on the findings of the Bureau of Import Services (BIS)” into the final compromise agreement. The Court noted that while Borgonia, and not Villanueva, may have been the individual who physically inserted the phrase, Villanueva, as Senior Vice President and Assistant General Manager, bore the responsibility for the agreement’s content. However, the Court also considered evidence suggesting that the parties had initially agreed to set aside the BIS report. Von Sprengiensen was given an early draft before the finalized version.

    Given this context, the Court reasoned that Von Sprengeisen’s belief that he was deceived into signing the final agreement was not entirely without basis. The crucial point here is that perjury cannot be established if the person making the statement genuinely believed it to be true, even if that belief is mistaken. The Court was not convinced that the petitioner adequately proved the private respondent acted in bad faith. Essentially, honest mistakes, inadvertent errors, and bona fide beliefs do not meet the threshold for perjury.

    Moreover, the Court highlighted that a perjury conviction cannot rest solely on contradictory statements made by the accused. The prosecution must present independent evidence to prove which statement is false. In this case, Villanueva failed to provide sufficient evidence beyond Von Sprengeisen’s statements to demonstrate the falsity of his claims. The absence of such corroborating evidence further undermined the perjury charge. The court emphasizes it’s need to “throw every fence” around a person charged with perjury to protect people lodging complaints.

    FAQs

    What was the key issue in this case? The key issue was whether the statements made by Von Sprengeisen in his affidavit and motion constituted perjury, specifically focusing on whether the statements were a willful and deliberate assertion of falsehood.
    What are the elements of perjury? The elements of perjury are: (1) a statement under oath or an affidavit on a material matter; (2) made before a competent officer authorized to administer oaths; (3) a willful and deliberate assertion of a falsehood; and (4) the sworn statement is required by law or made for a legal purpose.
    What does “willful” mean in the context of perjury? “Willful” means the statement was made intentionally, with evil intent, and with the consciousness that the statement was false. It implies that the person making the statement knew it was untrue and intended for it to be received as true.
    Can a person be convicted of perjury if they made an honest mistake? No, a person cannot be convicted of perjury if the false statement was the result of an honest mistake or a bona fide belief in its truth. The element of willfulness is absent in such cases.
    What kind of evidence is required to prove perjury? The prosecution must prove which of the two contradictory statements is false. To prove, they must show it through evidence outside of the contradicting statement itself.
    Is a contradictory statement sufficient to prove perjury? No, a perjury conviction cannot be sustained merely upon the contradictory sworn statements of the accused. There must be corroborating evidence to prove which statement is false.
    What does “material matter” mean in a perjury case? A “material matter” is the main fact subject of the inquiry, or any circumstance which tends to prove that fact, or any fact or circumstance which tends to corroborate or strengthen the testimony related to the subject of the inquiry.
    Why did the Supreme Court deny Villanueva’s petition? The Supreme Court denied Villanueva’s petition because it found that Von Sprengeisen’s statements did not constitute a willful and deliberate assertion of falsehood. The Court was not convinced that Von Sprengeisen acted with malice or knowledge of the falsity of his statements.

    In summary, the Supreme Court’s decision reinforces that perjury requires more than just a false statement; it demands proof of a deliberate and malicious intent to deceive. This ruling serves to protect individuals from unwarranted perjury charges when their statements are the result of genuine mistakes or honestly held beliefs. This case underscores the high burden of proof required to sustain a perjury conviction, safeguarding individuals from potential abuses of the legal system.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: CRISTE B. VILLANUEVA v. THE HON. SECRETARY OF JUSTICE AND HORST-KESSLER VON SPRENGEISEN, G.R. No. 162187, November 18, 2005

  • Perjury and Jurisdiction: Where Does the Crime Truly Occur?

    The Supreme Court ruled that the location where a false statement is made in an affidavit, not where the affidavit is later sent, determines the court’s jurisdiction for a perjury case. This means that if a person makes a false statement in an affidavit in one city, but the affidavit is used in legal proceedings in another city, the perjury case must be filed in the city where the affidavit was originally made. This decision ensures that cases are tried where the act of giving false evidence initially took place, protecting the integrity of local proceedings and averting judicial anarchy.

    The Case of the Disputed Streamers: Unraveling Jurisdictional Boundaries in Perjury Cases

    This case revolves around the question of which court has jurisdiction over a perjury case when an allegedly false affidavit is submitted in one location but then forwarded to another for further investigation. Emilio Villarosa and Jude Thaddeus Sayson were rivals in a barangay captain election. Following the election, a complaint was filed against Sayson and other winning barangay councilors for violating the Omnibus Election Code by prematurely posting campaign streamers. The councilors submitted counter-affidavits denying these allegations to the Election Officer in Bacolod City. These affidavits were later forwarded to the Commission on Elections (COMELEC) in Manila for preliminary investigation, prompting Villarosa to file a perjury case in Bacolod City, arguing that the counter-affidavits contained false statements.

    The Regional Trial Court (RTC) quashed the informations for perjury, asserting that jurisdiction lay with the Manila court since the affidavits were sent to COMELEC there. The central question is: Should the perjury case be tried in Bacolod, where the affidavits were initially filed, or in Manila, where they were used for preliminary investigation? This issue highlights the complexities of determining jurisdiction in cases where documents cross jurisdictional lines. The Supreme Court tackled this precise issue to determine which court had jurisdiction.

    The Supreme Court emphasized that the location where the essential elements of the crime occurred determines jurisdiction. According to Section 15, Rule 110 of the Rules on Criminal Procedure, a criminal action should be instituted and tried in the court of the municipality or province where the offense was committed or where any of its essential ingredients took place. Here, the operative act constituting the crime of perjury, if proven, occurred in Bacolod City where the counter-affidavits were executed and originally submitted to the Office of the Election Officer.

    The Court distinguished this case from United States v. Cañet, clarifying that the critical act is not merely the making of the affidavit but the intentional giving of false evidence in a specific court proceeding. The lis mota, or the cause of the action, in perjury is the deliberate or intentional giving of false evidence in the court where such evidence is material. Thus, jurisdiction rests where the false statements were made and submitted, not where the document was subsequently processed.

    The Supreme Court also warned against the potential for judicial chaos if all perjury cases related to election offenses had to be filed in Manila, the seat of the COMELEC Law Department. Such a rule would unduly burden the Manila courts and create significant logistical and financial challenges for litigants across the country. The court noted that the intent of the lawmakers was to have offenses adjudicated in local jurisdictions, close to where evidence and witnesses are available, thereby facilitating a more efficient and accessible system of justice.

    Moreover, the Court underscored the purpose of perjury laws: to prevent the corrupt assertion of falsehoods under oath that could undermine the integrity of judicial proceedings. In this case, the alleged untruthful statements became material during the proceeding in the Office of the Election Officer in Bacolod City, where it was determined whether the private respondents had violated the Omnibus Election Code.

    Ultimately, the Supreme Court held that the Municipal Trial Court in Cities (MTCC) of Bacolod City has jurisdiction over the perjury case. The Court found that the RTC committed grave abuse of discretion in ruling otherwise. This decision reaffirms the principle that the location of the operative acts of the crime, rather than the subsequent location of the documents, determines jurisdiction in perjury cases.

    FAQs

    What was the key issue in this case? The central issue was determining which court had jurisdiction over a perjury case: the court where the false affidavit was originally submitted or the court where it was later forwarded for preliminary investigation.
    What is perjury? Perjury is the act of knowingly making false statements under oath or affirmation in a legal proceeding. It undermines the integrity of the judicial process by introducing false evidence.
    Where should a perjury case be filed? A perjury case should be filed in the jurisdiction where the false statement was originally made and submitted, as this is where the essential elements of the crime occur.
    What was the court’s ruling in this case? The Supreme Court ruled that the Municipal Trial Court in Cities (MTCC) of Bacolod City had jurisdiction over the perjury case, reversing the RTC’s decision.
    Why did the court choose Bacolod City as the venue? The court selected Bacolod City because the counter-affidavits containing the alleged false statements were originally filed with the Election Officer there, where the alleged violation of the Omnibus Election Code took place.
    How does this case differ from United States v. Cañet? Unlike Cañet, this case focused on whether jurisdiction should be where the affidavit was submitted versus where it was forwarded for investigation, not where it was made versus where it was filed in court.
    What could happen if all perjury cases related to election offenses were filed in Manila? The Supreme Court cautioned that such a rule would overwhelm Manila courts and create undue burden for litigants from across the country, hindering the pursuit of justice.
    What is the ‘lis mota‘ in perjury cases? The ‘lis mota‘ refers to the cause of action in a perjury case, specifically the deliberate or intentional giving of false evidence in the court where such evidence is material.

    This decision clarifies an important aspect of jurisdictional rules in perjury cases, affirming that the location where false statements are made is the appropriate venue for trial. It protects the integrity of local proceedings by ensuring that such cases are addressed in the jurisdictions directly affected by the false statements.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Villarosa v. Magallanes, G.R. No. 139841, April 29, 2003

  • Upholding Procedural Integrity: Raffling of Cases and Judicial Accountability

    The Supreme Court’s decision in Atty. Nescito C. Hilario and Ma. Meriem A. Ursua v. Hon. Julian C. Ocampo III underscores the importance of adhering to established procedures for the raffling of cases and the accountability of judges in ensuring the accuracy of their pronouncements. The Court found Judge Ocampo administratively liable for failing to comply with the prescribed procedure for case raffling and for making a false statement in an order. This ruling reinforces the principle that judges must uphold the integrity of the judicial process by strictly following procedural rules and maintaining the accuracy of court records.

    When Shortcuts Lead to Sanctions: Questioning Judicial Discretion

    The case arose from an administrative complaint filed by Atty. Nescito C. Hilario and Ma. Meriem A. Ursua against Judge Julian C. Ocampo III of the Municipal Trial Court (MTC) of Naga City. The complainants alleged grave abuse of authority, dishonesty, gross ignorance of the law, bias, and knowingly rendering an unjust order. These charges stemmed from Judge Ocampo’s handling of Criminal Case Nos. 78500-78512, involving violations of Batas Pambansa Bilang 22 (Bouncing Checks Act) against Ursua. The central issue revolved around Judge Ocampo’s decision to assign all thirteen criminal cases to his own sala without a formal motion for consolidation and his subsequent misstatement in a court order regarding the issuance of an arrest warrant.

    The Office of the Court Administrator (OCA) investigated the complaint and found merit in the allegations concerning the unauthorized procedure for raffling cases and the false statement made by the judge. Specifically, the OCA noted that Judge Ocampo violated Supreme Court Circular No. 7 of 1974, which mandates that cases in stations with multiple branches must be assigned through a raffle system. The circular explicitly states:

    “All cases filed with the Court in stations or groupings where there are two or more branches shall be assigned or distributed to the different branches by raffle. No case may be assigned to any branch without being raffled.“

    Judge Ocampo defended his actions by claiming that his method of assigning related cases to the branch with the lowest docket number was a more prudent approach. However, the Supreme Court rejected this justification, emphasizing that judges must adhere to established rules and procedures to ensure the orderly administration of justice. The Court elucidated that “rules of procedure have been formulated and promulgated by this Court to ensure the speedy and efficient administration of justice. Failure to abide by these rules undermines the wisdom behind them and diminishes respect for the rule of law.” Furthermore, it was mentioned that Judges are expected to be knowledgeable about Supreme Court rules and circulars and should ensure compliance in their jurisdictions.

    In addition to the procedural violation, the Court also addressed the false statement made by Judge Ocampo in his September 22, 1997 Order. In the order, the judge stated that a warrant of arrest had been issued against Ursua, when in fact, no such warrant was ever issued. Judge Ocampo attempted to explain this discrepancy by arguing that Ursua had already posted bail in advance, rendering the issuance of a warrant unnecessary. However, the Court found this explanation untenable, citing Rule 114, Section 1 of the Rules of Court, which defines bail as “the security given for the release of a person in custody of the law.”

    The Court emphasized that “bail requires that a person must first be arrested or deprived of liberty before it can be availed of”. While the posting of bail is considered submission to the court’s jurisdiction, it implies that the accused is already under detention or in the custody of law. Therefore, the judge’s statement was deemed false and misleading, warranting administrative sanction. However, the Court dismissed the charges of bias and partiality, knowingly rendering an unjust order, and gross ignorance of the law, finding insufficient evidence to support these claims. The Supreme Court clarified that “mere suspicion that a judge is partial to one of the parties is not enough to show that the former favors the latter”.

    The High Court acknowledges that administrative liability for ignorance of the law and/or knowingly rendering an unjust judgment does not arise simply because a judge issued an order that may be deemed erroneous. A judge cannot be held administratively accountable for every mistake; sanctions are only necessary when a judge acts fraudulently or with gross ignorance. The Supreme Court concluded that Judge Ocampo’s actions warranted disciplinary action. He was fined P5,000 for failing to comply with the prescribed procedure for raffling cases and for falsely stating in his Order that an arrest warrant had been issued. The other charges were dismissed for lack of merit.

    This ruling serves as a reminder to judges of their duty to adhere to established procedures and maintain the integrity of court records. It underscores the importance of impartiality and fairness in the administration of justice and the need for judges to be vigilant in ensuring the accuracy of their pronouncements. By holding Judge Ocampo accountable for his actions, the Supreme Court reaffirmed its commitment to upholding the rule of law and preserving public trust in the judiciary.

    FAQs

    What was the key issue in this case? The key issue was whether Judge Ocampo violated administrative rules by failing to follow the prescribed procedure for raffling cases and by making a false statement in a court order. The Supreme Court addressed whether these actions warranted administrative sanctions.
    What is the prescribed procedure for raffling cases? Supreme Court Circular No. 7 of 1974 mandates that all cases in stations with multiple branches must be assigned through a raffle system. This ensures impartiality and prevents cases from being arbitrarily assigned to a specific judge.
    Why was Judge Ocampo found liable for making a false statement? Judge Ocampo falsely stated in an order that an arrest warrant had been issued, even though no such warrant existed. The Court found this statement misleading and a violation of judicial ethics.
    What is the significance of bail in relation to an arrest warrant? Bail is security given for the release of a person in custody of the law. It presupposes that the accused has been arrested or is under detention, making the issuance of an arrest warrant a prerequisite for bail.
    Were the charges of bias and partiality against Judge Ocampo upheld? No, the charges of bias and partiality were dismissed due to insufficient evidence. The Court emphasized that mere suspicion is not enough to prove bias; concrete evidence is required.
    Can a judge be held liable for every erroneous order? No, a judge is not administratively accountable for every erroneous order. Liability arises only when a judge acts fraudulently, with gross ignorance, or with malicious intent.
    What was the penalty imposed on Judge Ocampo? Judge Ocampo was fined P5,000 for failing to comply with the raffling procedure and for making a false statement in his order. He was also sternly warned against similar future actions.
    What is the remedy for a party prejudiced by a judge’s order? If a party is prejudiced by a judge’s order, the proper remedy is to seek recourse through the appropriate reviewing court, such as filing a petition for certiorari, rather than resorting to an administrative complaint.

    This case highlights the judiciary’s dedication to maintaining ethical standards and procedural integrity within the courts. The Supreme Court’s decision serves as a guide for judges to remain vigilant in upholding the rule of law, ensuring public trust in the justice system. By adhering to established rules and procedures, judges can avoid administrative sanctions and contribute to the fair and impartial administration of justice.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Atty. Nescito C. Hilario and Ma. Meriem A. Ursua, vs. Hon. Julian C. Ocampo III, A.M. No. MTJ-00-1305, December 03, 2001