When the time is right, I, the Lord, will make it happen (Isaiah 60:22) #MostValuableLawyer ๐คโ๏ธ Here to inspire ๐น
Joined February 2019
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CJ Panganiban hopefully humbled our dear Senators. Truth, Justice and Fairness.
Thank you po Your Honor, Chief Justice Panganiban.
YOU TELL THEM! Sana matauhan na yung makakapal ang mukha dyan
#VPonTrial
#ImpeachmentTrial
๊ทธ๋ ์ด์ค ๐ป retweeted
"What do our people expect from you? It's not legalism, it's not judicial conduct. It is justice for our people ... Ang hinahanap po ng ating bayan ay hustisya mula sa senado."
goosebumps kay CJ Panganiban talaga diretsahan ๐๐ป๐ญ sana matamaan yung ibang senator-judges dyan na hustisya ang pinaglalaban dito at hindi pansariling interes lang ng isang tao ๐๐ป
#VPonTrial
๊ทธ๋ ์ด์ค ๐ป retweeted
The #SupremeCourtPH ๐๐ฏ ๐๐ข๐ฏ๐ค, during its session on August 26, 2026, unanimously declared that Article II, Section 26 of the Constitution requires Congress to enact a law prohibiting political dynasties, holding that Congressโ failure to do so for 39 years constitutes grave abuse of discretion.
The Court directed Congress to comply with its mandatory constitutional duty to enact an anti-political dynasty law at the earliest opportunity, define political dynasties, and determine the scope of the prohibition.
In a Decision penned by Associate Justice Ramon Paul L. Hernando, the Court ๐๐ฏ ๐๐ข๐ฏ๐ค granted the consolidated petitions in G.R. Nos. 263934, 272370, and 279201 for certiorari and mandamus. The petitions challenged Congressโ prolonged failure to pass a law defining and prohibiting political dynasties.
The Court strongly urged Congress to heed its constitutional duty with utmost urgency, as it declared that the latter has โthe MANDATORY CONSTITUTIONAL DUTY to enact the law on the constitutional prohibition against political dynasties as expressly provided for in Article II, Section 26 of the Constitution.โ
It stated that the Congress โMUST HENCEFORTH AND WITH UTMOST URGENCY ENACT THE APPROPRIATE ANTI-POLITICAL DYNASTY LAW AT THE EARLIEST OPPORTUNITY.โ
Article II, Section 26 of the Constitution provides that โThe State shall guarantee equal access to opportunities for public service, and prohibit political dynasties as may be defined by law.โ
The Court held that this provision is not merely an aspiration but a constitutional command. The use of the word โshallโ makes clear that the State has a mandatory duty both to guarantee equal access to public service and to prohibit political dynasties.
The Court also held that the phrase โas may be defined by lawโ does not give Congress the choice whether to prohibit political dynasties. Rather, it gives Congress the authority to define what constitutes a political dynasty and determine the scope of the prohibition.
The Court further said that Congressโ prolonged failure to enact an anti-political dynasty law constitutes grave abuse of discretion.
The Court took judicial notice of the numerous anti-political dynasty bills filed but left unacted upon since the ratification of the 1987 Constitution. It also considered studies on the prevalence of political dynasties and their relationship with socioeconomic conditions in the country.
The Court noted that political dynasties have remained widespread and have extended even into the party-list system. Despite changes in the composition of Congress over the years, no comprehensive anti-political dynasty law has been enacted, implying either a lack of interest, avoidance for convenience, or service of self-interest.
Although the Constitution does not set a deadline for Congress to enact the law, the Court held that this does not allow Congress to postpone its constitutional duty indefinitely. The Court found that 39 years is beyond a reasonable period to carry out the constitutional command. Congressโ continued inaction therefore constitutes a continuing violation of its constitutional duty.
Read the full text of the Press Briefer at: sc.judiciary.gov.ph/?p=17324โฆ.
Read the full text of the Decision at: sc.judiciary.gov.ph/?p=17319โฆ.
Read Senior Associate Justice Marvic M.V.F. Leonenโs Concurring Opinion at: sc.judiciary.gov.ph/?p=17319โฆ.
Read Associate Justice Henri Jean Paul B. Inting Concurring Opinion at: sc.judiciary.gov.ph/?p=17320โฆ.
Read Associate Justice Rodil V. Zalamedaโs Separate Opinion at: sc.judiciary.gov.ph/?p=17320โฆ.
Read Associate Justice Japar B. Dimaampaoโs Separate Concurring Opinion at: sc.judiciary.gov.ph/?p=17321โฆ.
Read Associate Justice Maria Filomena D. Singhโs Separate Opinion at: sc.judiciary.gov.ph/?p=17322โฆ
Read Associate Justice Raul B. Villanuevaโs Separate Concurring Opinion at: sc.judiciary.gov.ph/?p=17323โฆ.
Copying of this content is subject to the SC PIOโs Credit Attribution Policy: sc.judiciary.gov.ph/credit-aโฆ.
Something worth remembering:
Criminal law: cyber libel, estafa, BP 22, grave threats, probation, community service, wheel of conspiracy.
Remedial Law: Rule 26 applicability to impeachment proceedings (vs criminal - not applicable), double jeopardy, right to speedy disposition
What is the diff between electronic document & ephemeral electronic communication?
What are their modes of authentication?
Can an ephemeral electronic communication transform into an electronic document?
#AweSamBar2026
A criminal case for estafa is pending before the RTC. Considering that it involves millions, private complaint (PC) suffered sleepless nights. Feeling anxious, PC started stalking the FB of the accused. To her delight, she saw the accused renting out a condo. #AweSamBar2026
PC immediately filed for preliminary attachment fearing that the accused will eventually sell the condo. TC denied the application. PC argued that she complied with all the requisites for issuing the writ and even attached the original lease contract . Is her argument tenable?
Question number 5 in Criminal law. Preliminary attachment Rule 127. โ๏ธ #AweSamBar2026
๊ทธ๋ ์ด์ค ๐ป retweeted
PRACTICE OF LAW, IN RE: SOCIAL MEDIA POSTS OF EDGAR S. DIZON
In a recently decided case, the Supreme Court ruled that the conduct of bar review coaching sessions and the authorship of bar review materials constitute the practice of law.
In support of its conclusion, the Court cited the 1991 case of Cayetano v. Monsod, where the Court defined the practice of law as:
โany activity, in or out of court, which requires the application of law, legal procedure, knowledge, training and experience.โ
It is submitted, however, that this definition has been modifiedโor, at the very least, qualifiedโby the definition of the practice of law under the Code of Professional Responsibility and Accountability (CPRA), which provides:
โThe practice of law is the rendition of legal service or performance of acts or the application of law, legal principles, and judgment, in or out of court, with regard to the circumstances or objectives of a person or a cause, and pursuant to a lawyer-client relationship or other engagement governed by the CPRA.โ
Therefore, the mere fact that an activity involves the application of law, legal principles, knowledge, training, or experience should not, by itself, be sufficient to constitute the practice of law. The definition expressly contemplates that such rendition of legal services or performance of acts must be โpursuant to a lawyer-client relationship or other engagement governed by the CPRA.โ
Is the conduct of bar review coaching sessions and the authorship of bar review materials an engagement governed by the CPRA?
If the answer is in the negative, then it may be argued that these activities, notwithstanding their substantial use of legal knowledge and training, do not fall within the present CPRA definition of the practice of law.
Ongoing yung investigation nila bakit sila nakaalis ng Pilipinas?
Relevant questions:
When do you file a hold departure order?
Where do you file a HDO?
#AweSamBar2026
Something to ponder on. The question might confuse or trick you into thinking that the SC have no power over a person who is not a member of the Bar. #AweSamBar2026
His name was stricken of the list of bar passers.
The #SupremeCourtPH (SC) has found a bar review coach guilty of indirect contempt for spreading false information about the 2023 Bar Examinations on Facebook after stating that the said exams would be checked by means of artificial intelligence (AI).
In a ๐๐ฆ๐ณ ๐๐ถ๐ณ๐ช๐ข๐ฎ Decision, the SC ๐๐ฏ ๐๐ข๐ฏ๐ค found Edgar S. Dizon, administrator of the Facebook group Bar Law for Dummies, liable for indirect contempt. The Court fined him PHP 30,000 and ordered the removal of his name from the list of 2016 Bar passers.
On September 21, 2023, a post from the Facebook group and the account ๐๐ด๐ช๐ฅ๐ฌ๐ฆ๐ฏ๐ถ ๐๐ช๐ป๐ฐ๐ฏ claimed that the 2023 Bar Examinations would be โ๐ด๐ฐ๐ณ๐ต๐ฆ๐ฅ, ๐ค๐ฉ๐ฆ๐ค๐ฌ๐ฆ๐ฅ, ๐ข๐ฏ๐ฅ ๐ค๐ฐ๐ณ๐ณ๐ฆ๐ค๐ต๐ฆ๐ฅ ๐ฃ๐บ ๐ฎ๐ฆ๐ข๐ฏ๐ด ๐ฐ๐ง ๐ข๐ณ๐ต๐ช๐ง๐ช๐ค๐ช๐ข๐ญ ๐ช๐ฏ๐ต๐ฆ๐ญ๐ญ๐ช๐จ๐ฆ๐ฏ๐ค๐ฆ (๐๐).โ It also stated:
โ๐๐๐๐๐ ๐ ๐๐๐๐๐ ๐๐๐๐ ๐ ๐๐ ๐ฐ๐ณ ๐๐.
๐ ๐ข๐ฏ ๐ข๐ฏ๐จ ๐ถ๐ฏ๐ข๐ฏ๐จ ๐ฉ๐ข๐ฉ๐ข๐ฏ๐ข๐ฑ๐ช๐ฏ ๐ฏ๐จ ๐๐ ๐๐ฉ๐ฆ๐ค๐ฌ๐ช๐ฏ๐จ ๐ต๐ฐ ๐ด๐ฐ๐ณ๐ต ๐ฐ๐ถ๐ต ๐ต๐ฉ๐ฆ ๐ค๐ฐ๐ณ๐ณ๐ฆ๐ค๐ต ๐ข๐ฏ๐ด๐ธ๐ฆ๐ณ๐ด.โ
As a result, the Office of the 2023 Bar Chair (BCO), headed by Associate Justice Ramon Paul L. Hernando, had to investigate the source of the post and determine its impact on the examinations. It also issued an advisory clarifying that the examinations would be checked by four human examiners for each subject, all of whom are experts in their respective fields.
But instead of removing the post, Dizon threatened to sue the Court and demanded a public apology โwithin 24 hoursโ, in a media interview. He also sent several emails to the SCโs Judiciary Public Assistance Section, claiming that the advisory had a chilling effect on him. He denied spreading misinformation and asked the Court to issue a statement correcting the advisory.
After being directed by the SC to explain why he should not be cited for indirect contempt for interfering with the conduct of the 2023 Bar Examinations, Dizon admitted owning the Facebook account but denied claiming that AI would check the examinations, arguing that he used the words โTO HELPโ in his post.
The SC was not convinced and held him liable under Rule 71, Section 3 of the ๐๐ถ๐ญ๐ฆ๐ด ๐ฐ๐ง ๐๐ฐ๐ถ๐ณ๐ต, which punishes unlawful interference with court processes outside a courtroom, conduct that degrades the courts or undermines public confidence in the administration of justice, and unauthorized practice of law, as indirect contempt.
The SC held that Dizonโs post unlawfully interfered with the conduct of the 2023 Bar Examinations and undermined the integrity of both the exams and the SC, which exercises supervision over the legal profession. It caused confusion and alarm, forcing bar officials to divert their limited time and resources to tracing the source of the post, coordinating with government agencies, issuing clarifications, and responding to numerous inquiries.
The SC further noted Dizonโs lack of remorse. Instead of acknowledging the harm caused by his post, he demanded an apology from the Court, threatened legal action, refused to take down the post, and sought a statement retracting the advisory.
The Court likewise warned Dizon from engaging in the unauthorized practice of law when he conducted bar review coaching sessions and authored several bar review materials used in the ๐๐ข๐ณ ๐๐ข๐ธ ๐ง๐ฐ๐ณ ๐๐ถ๐ฎ๐ฎ๐ช๐ฆ๐ด training program. Dizon acknowledged that while he had passed the 2016 Bar Examinations, he had not taken the lawyerโs oath, which is one of the requirements to practice law, because of pending criminal cases.
In his Separate Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that Dizon must be punished for undermining the integrity of the Bar examinations. However, he also emphasized the need to balance the Courtโs power to punish for contempt with the constitutional right to free speech, including legitimate criticism of the courts.
Read the full text of the press release at sc.judiciary.gov.ph/?p=17295โฆ
Read the full text of the Decision at sc.judiciary.gov.ph/4734-in-โฆ
Read the Separate Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at sc.judiciary.gov.ph/4734-sepโฆ
Copying of this content is subject to the SC PIOโs Credit Attribution Policy: sc.judiciary.gov.ph/credit-aโฆ
Another q, can the SC disbar a bar passer?
You can easily answer yes/no but what legal basis are you going to cite?
Can the Supreme Court cite a Bar passer for Indirect contempt for false AI claims? #AweSamBar2026
Why do we sometimes forget the doctrines we just memorized or had difficulty recalling it? Because we just memorize without understanding or analyzing the concepts. So I always remind my mentees to understand first before memorizing.
And @atty_cheldiokno was able eloquently explain why Rule 26 is applicable to impeachment proceedings. He explained the difference v. criminal proceedings not merely by stating the sui generis nature of impeachment process. Kudos sir!
Remember that every point counts so don't forget Legal Ethics and Forms. ๐ค #AweSamBar2026