A.M. No. MTJ-07-1674. June 7, 2017

[ A.M. No. MTJ-07-1674, June 07, 2017 ]

We resolve the matter which arose from this administrative case[1] filed by Remberto C. Kara-an,[2] Sr. (Kara-an) against Judge Francisco S. Lindo (Judge Lindo), Presiding Judge of Metropolitan Trial Court (MeTC), Branch 55, Judge Edison F. Quintin (Judge Quintin), Presiding Judge of MeTC, Branch 56 and Fe Brenda J. Travino (Travino), Clerk of Court of MeTC, Branch 55, all of Malabon City, for dishonesty, gross misconduct, gross ignorance of the laws, rules and procedures, violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), violation of Articles 171, 172, 206 and 220 of the Revised Penal Code, and violations of the Code of Judicial Conduct, Canons of Judicial Ethics and the Code of Professional Responsibility, in relation to Civil Case No. JL00-128 for damages entitled, "Remberto C. Kara-an v. Hector A. Villacorta, et al."

In a Report[3] dated March 2, 2007, Justice Romulo S. Quimbo (Justice Quimbo), the designated Hearing Officer, recommended that: (1) Judge Quintin be held guilty of delay in resolving a matter pending before him; (2) a fine of P1,000.00 be imposed on him; and (3) the complaint against Judge Lindo and Travino be dismissed.[4] Justice Quimbo also reported that in the course of his investigation, he found that Kara-an may have been holding himself out as a member of the Bar and that Civil Case No. JL00-128 may not be the only case where Kara-an was appearing. Justice Quimbo observed:
xxx A cursory look at his stationery (envelop) would lead one to suspect that he is actually practicing law. Considering that he is not a member of the bar, it is unfair that he is competing with legitimate members of the legal profession who have to pass the bar examinations, pay IBP dues and professional taxes, not to mention the mandatory continuing legal education. It is therefore recommended that the first level courts, particularly in the Metro Manila area be asked to report to the Court whether the present complainant has any other appearances in their salas.[5]
Thus, in our Resolution[6] dated April 19, 2007, we held:
WHEREFORE, respondent Judge Edison F. Quintin of Metropolitan Trial Court of Malabon, Branch 56, is hereby found guilty of GROSS INEFFICIENCY and FINED in the amount of three thousand pesos ([P]3,000.00). He is further ADMONISHED to be circumspect in the performance of his judicial functions. A repetition of the same or similar acts in the future will be dealt with more severely.

The complaint against Judge Francis[c]o S. Lindo[,] Presiding Judge of Metropolitan Trial Court of Malabon, Branch 55, and Fe Brenda J. Travino[,] Branch Clerk of Court of MeTC of Malabon, Branch 55 is DISMISSED for lack of merit. However, they are REMINDED of their duty to diligently supervise the preparation of their semestral docket inventories.

The First Level Courts of Metro Manila are hereby directed to report to the Court whether complainant Remberto C. Kara-an has any other appearances in their salas.

SO ORDERED.[7] (Emphasis supplied.)
On January 28, 2008, we issued a Resolution[8] reiterating our directive requiring the Presiding Judges of the first level courts of Metro Manila to inform the Court whether Kara-an has any other appearances in their salas.

Due to the failure of most first level court judges to comply with the Court's directive, the Office of the Court Administrator (OCA) on August 13, 2010, issued OCA Circular No. 110-2010[9] addressed to all Executive Judges of the first and second level courts in Metro Manila requiring them to submit to the Court, through the OCA, a complete and latest report on whether Kara-an is appearing in any case before them.

On August 14, 2013, we issued a Resolution[10] referring the letters and compliances of the judges of the first and second level courts of Metro Manila to the OCA for evaluation, report, and recommendation.The OCA submitted a Memorandum[11] dated January 14, 2014 summarizing the reports of the various judges of the first and second level courts, and identifying Kara-an's appearances either as plaintiff or attorney-in-fact:[12]

Regional Trial Court (RTC), Branch 125, Caloocan City
Civil Case No. 008 - Remberto C. Kara-an v. Carlos R. Cruz, et al.
Civil Case No. 016 - Remberto C. Kara-an v. Al-Amanah Islamic Investment Bank of the Philippines, et al. [13]
MeTC, Branch 52, Caloocan City
Crim. Case Nos. 237357-58 - People of the Philippines vManny Capellan[14]
RTC, Branch 132, Makati City
Civil Case No. 09-673 - Juvy P. Ciocon-Reer, Angelina P. Ciocon, Marivit P. Ciocon-Hernandez and Remberto C. Kara-an, Sr. v. Rita G. De Leon, Pedro Mayo and Victoria Villasor-Inong[15]
MeTC, Makati City
Civil Case No. 95046 -Juvy P. Ciocon-Reer, Angelina P. Ciocon, Marivit Ciocon-Hernandez and Remberto C Kara-an, Sr. v. Rita G. De Leon, Pedro Mayo and Victoria Villasor-Inong [16] 
RTC, Branch 74, Malabon City
Civil Case No. CV-079-MN - Bonifacia V. Salientes, et al. v. Ma. Theresa P. Oblipias, et al.,[17]
MeTC, Branch 55, Malabon City
Civil Case No. JL00-1120 - Bonifacio B. Sechico, et al. v. Orlando C. Casimiro, et al.[18]
MeTC, Branch 55, Malabon City
Civil Case No. JL00-1122 - Daicarl G. Delos Santos-Candido, Remar T. Candido, Daisy G. Delos Santos (Deceased) whose estate and legacy are represented herein by Remberto C. Kara-an, Sr. and Oscar D. Delos Santos v. Dominga Balbelo-Ocampo, her husband Edgar do Ocampo, John and Jane Does[19]
MeTC, Branch 55, Malabon City
Civil Case No. JL00-1087 - Bonifacia V. Salientes, assisted by her friend, Attorney-in-Fact, Assistant Administrator and General Manager Remberto C. Kara-an, Sr. vTeotimo Esco and his wife Maria Esco, et al.,[20]
MeTC, Malabon City
JL00-128 - Remberto C Kara-an, Sr. v. Hector A. Villacorta, Allan R. Canares, Ferdinand C. Palor, Rudiger G. Falcis II, Orlando C. Casimiro and John Does
JL00-1068 -Remberto C. Kara-an, Sr. v. The Hon. Judge Lubao of RTC, Branch 22, 11th Judicial Region, General Santos City[21] 
MeTC, Branch 37, Quezon City
Civil Case No. 36414 - A-l Financial Services, Inc. v. Sps. Enriqueta Baldesancho Santos, et al.[22] 
MeTC, Quezon City (orig. Branch 38)
Civil Case No. 38-40412 - Macrina Rama Samson vAntonion Tumacay, also known as Antonio Rosales[23] (re-raffled to Branch 36)

The OCA determined that Kara-an is illegally practicing law by assuming to be an attorney or an officer of the Court, and acting as such without authority, in violation of Section 3(e), Rule 71 of the Rules of Court. The OCA also emphasized that Kara-an was previously found to have committed the same offense in Ciocon-Reer v. Judge Lubao,[24]where he was held guilty of indirect contempt.[25]

Thus, the OCA concluded and recommended:
Complainant Kara-an litigated three (3) RTC and eight (8) MeTC civil cases. Records disclosed that he filed nine (9) MTJ administrative complaints, eight (8) of which were dismissed and one (1) respondent Judge fined with Php 3,000.00; five (5) RTJ administrative complaints which were also all dismissed. Complainant Kara-an's law practice in the trial courts constitutes eleven (11) counts of indirect contempt. Had this been an administrative case, the penalty to be imposed would be that of the most serious charge or count, with the rest considered as aggravating circumstances, but such is not the case and the eleven (11) counts would have to be compounded. For complainant Kara-an's blatant illegal practice of law, a fine of Php 25,000.00 for each count or Php 75,000.00 for three (3) counts committed in the RTC, and a fine of Php 4,000.00 for each count or Php 32,000.00 for eight (8) counts in the MeTC (a total fine of Php 107,000.00) would be appropriate. Incarceration is not an option considering complainant Kara-an's advanced age.

IN VIEW OF THE FOREGOING, it is respectfully recommended for the consideration of this Honorable Court that:

1) Remberto C. Kara-an, Sr. be found GUILTY of indirect contempt under Section 3 (e), Rule 71 of the Rules of Civil Procedure and accordingly FINED in the total amount of Php 107,000.00 broken down as follows: Php 75,000.00 for three (3) counts in the Regional Trial Courts and Php 32,000.00 for eight (8) counts in the Metropolitan Trial Courts; and

2) [H]e be DIRECTED to pay the fine before the Cash Division, Financial Management Office, Office of the Court Administrator, within thirty (30) days from receipt of the resolution; and

3) [I]n the event he fails to pay the fine within the thirty (30)-day period, the Docket and Clearance Division, Office of the Court Administrator, be DIRECTED to report said non-payment to the Court for its appropriate action. [26]
In a Resolution[27] dated November 9, 2015, we furnished Kara-an with a copy of the OCA Memorandum and required him to comment.

On January 6, 2016, Kara-an filed an Ex-Parte Urgent Motion to Admit Comment and Motion for Extension of Time to Plead.[28] From January 13, 2016 to April 11, 2016, Kara-an filed a total of nine pleadings[29] arguing against his liability for indirect contempt.

Kara-an insists that his appearances were made with the intention to faithfully obey the laws[30] and in accordance with Section 34, Rule 138 of the Rules of Court.[31] He points out that he intentionally did not indicate in the pleadings that he is a member of the Bar, or his Professional Tax Receipt (PTR), Attorney's Roll, or Mandatory Continuing Legal Education (MCLE) compliance numbers and that he was merely actually representing himself in his own case—not as a counsel nor a lawyer but as a party exercising his right of self-representation.[32]

In addition, Kara-an maintains that he was denied his right to due process for the following reasons: (1) the allegations in the OCA Memorandum dated January 14, 2014 are not supported by any evidence annexed or attached therein;[33] (2) he was not given notice as to when the OCA Memorandum was received, transmitted to and received by the Third Division of this Court;[34] (3) lack of preliminary investigation at the OCA's level;[35] (4) it was erroneous and presumptuous for the OCA to declare that he would give the same explanation as what he filed in A.M. OCA IPI No. 09-3210-RTJ;[36] (5) his right to a speedy disposition of his case was violated due to the belated issuance of the OCA Memorandum dated January 14, 2014;[37] (6) he is a victim of forum shopping since he was already held guilty of indirect contempt in A.M. OCA IPI No. 09-3210-RTJ;[38] and (7) the provisions of Rule 71 of the Rules of Court were not complied with.[39]

Kara-an also asserts that he is perplexed as to how he, as the complainant in an administrative case, had become the accused/respondent in the same case. According to Kara-an, since our Resolution dated April 19, 2007 is already final and executory, there is no more basis for the OCA Memorandum dated January 14, 2014 to recommend his liability for indirect contempt.[40]

Meanwhile, as the OCA emphasized, we already found, through a Resolution dated June 20, 2012 in docon-Reer v. Lubao,[41] Kara-an guilty of indirect contempt due to unauthorized practice of law in Civil Case No. 7819 entitled, "Juvy P. Ciocon-Reer, et al. v. Gaspar Mayo, et al.," before the RTC of General Santos City, Branch 22.[42]

The OCA recommended that Kara-an be sentenced to serve an imprisonment of 10 days at the Manila City Jail and pay a fine of P1,000.00. In consideration of Kara-an's old age and state of health, we however, removed the penalty of imprisonment but increased the fine to P10,000.00.

On February 3, 2016, due to Kara-an's failure to pay the P10,000.00 fine, we issued a Resolution increasing his fine to P15,000.00. We also held:
The Court's Resolution is not to be construed as a mere request from the Court and it should not be complied with partially, inadequately, or selectively. The Court will not tolerate Karaan's temerity and disrespect to the Court and its processes by not paying the fine imposed on him in the Court's 20 June 2012 Resolution. However, while the OCA recommended that Karaan be sentenced to one-month imprisonment at the Manila City Jail, the Court is giving Karaan one last chance to comply with the Court's 20 June 2012 Resolution but the Court is increasing the fine imposed on him to P15,000. Again, the Court takes into account Karaan's old age. This will be the last time that the Court is giving him such consideration, and the Court will not hesitate to impose more serious sanctions against him should he again defy this Court.[44] (Citation omitted.)
On March 1, 2016, Kara-an deposited with the Court three Philippine National Bank manager's checks in the total amount of P15,000.00.[45] On May 19, 2016, pursuant to our Resolution dated April 20, 2016, the checks were turned over to the Cashier, Fiscal Management and Budget Office for safekeeping.[46]


In Ulep v. Legal Clinic, Inc. ,[47] we defined what the phrase "practice of law" means:
Practice of law means any activity, in or out of court, which requires the application of law, legal procedures, knowledge, training and experience. To engage in the practice of law is to perform those acts which are characteristic of the profession. Generally, to practice law is to give advice or render any kind of service that involves legal knowledge or skill.


When a person participates in a trial and advertises himself as a lawyer, he is in the practice of law. One who confers with clients, advises them as to their legal rights and then takes the business to an attorney and asks the latter to look after the case in court, is also practicing law. Giving advice for compensation regarding the legal status and rights of another and the conduct with respect thereto constitutes a practice of law. One who renders an opinion as to the proper interpretation of a statute, and receives pay for it, is, to that extent, practicing law.[48] (Citations omitted.)
Further, practice is more than an isolated appearance, for it consists in frequent or customary actions, a succession of acts of the same kind. In other words, it is frequent habitual exercise.[49]

Meanwhile, under Section 3(e), Rule 71 of the Rules of Court, the acts of "[a]ssuming to be an attorney xxx, and acting as such without authority" constitute indirect contempt.

Here, Kara-an was practicing law when he appeared before various courts in Metro Manila, prepared, signed and filed pleadings before them. As he is not a member of the Philippine Bar, Kara-an had no authority to perform those acts. The fact that Kara-an did not indicate in his pleadings that he is a member of the Bar (i.e., by giving a PTR, Attorney Roll, or MCLE compliance numbers) is of no moment. The justification for excluding from the practice of law those not admitted to the Bar is found not in the protection of the Bar from competition, but in the protection of the public from being advised and represented in legal matters by incompetent and unreliable persons over whom the judicial department can exercise little control.[50]

Thus, following Section 3(e), Rule 71 of the Rules of Court, we find Kara-an guilty of indirect contempt.

Kara-an's claims of lack of intent to engage in unauthorized practice of law and that he was merely exercising his right to self-representation have no merit.

Section 34, Rule 138 of the Rules of Court recognizes the right of an individual to manage, prosecute and defend their own actions.[51] He is allowed to represent himself in any case to which he is a party, as an individual litigant may personally do everything in the course of the proceedings from commencement to the termination of the litigation. In this instance, he would be acting not as a counsel or a lawyer, but as a party exercising his right to represent himself.[52]

The reports submitted by the judges of the first and second level courts of Metro Manila indicate that Kara-an entered his appearance in different cases in the following manner: (1) for and in his own behalf or as a party to the case;[53] (2) as counsel;[54] and (3) as attorney-in-fact, administrator, representative and agent of a party.[55] In cases under 2 and 3, the parties executed special powers of attorney designating Kara-an as their authorized representative and allowing the latter to act as co-litigant or representative of the parties.

We have held, however, that an attorney-in-fact or representative is not a real party in interest. A representative does not stand to be benefited or injured by any judgment in the case; he is merely appointed by the parties for the limited purpose of performing acts on their behalf. The appointment does not mean that the representative is subrogated into the rights of the principal and should be considered a real party in interest.[56]

Thus, Kara-an cannot claim for himself the right of the real parties in interest to represent themselves in the cases where he entered his appearance under Section 34, Rule 138 of the Rules of Court. This right is reserved for, and may be exercised only by, the real parties in interest, in these cases, Kara-an's principals.

Indeed, in Ciocon-Reer vLubao,[57]we already described and rejected the manner by which Kara-an illegally practiced law:
Here, the OCA was able to establish the pattern in Karaan's unauthorized practice of law. He would require the parties to execute a special power of attorney in his favor to allow him to join them as one of the plaintiffs as their attorney-in-fact. Then, he would file the necessary complaint and other pleadings "acting for and in his own behalf and as attorney-in-fact, agent or representative" of the parties. The fact that Karaan did not indicate in the pleadings that he was a member of the Bar, or any PTR, Attorney's Roll, or MCLE Compliance Number does not detract from the fact that, by his actions, he was actually engaged in the practice of law.[58]
Unfortunately, despite our earlier pronouncements against this practice, Kara-an continued to employ the same scheme to illegally practice law.

Clearly, the number and frequency of cases where Kara-an appeared, the manner by which he entered his appearance, and the fact that this is not his first offense, belie his claims that he had no intent to illegally practice law and that he was merely exercising his right to represent himself in litigation pursuant to Section 34, Rule 138 of the Rules of Court. Certainly, Kara-an should not be allowed to circumvent the prohibition against unauthorized practice of law by allowing him to continue his deliberate and wanton scheme.

We likewise reject Kara-an's claim of violation of his due process rights.

Under Sections 3 and 4, Rule 71 of the Rules of Court, a charge for indirect contempt may be initiated through a verified petition or motu proprio by the court against which the contempt was committed. In both cases, the respondent must be given an opportunity to comment on the charge. This rule, however, admits of exception. In University of the Immaculate Conception v. Office of the Secretary of Labor and Employment,[59] we explained:
One exception to the above rule is that the Supreme Court may, incidental to its power to suspend its own rules whenever the interest of justice requires, resolve an issue involving indirect contempt when there is (a) no factual controversy to be resolved or the case falls under the res ipsa loquitur rule and (b) only after granting the respondent the opportunity to comment.[60] (Citations omitted.)
Considering that there is no more question on whether Kara-an is illegally practicing law and Kara-an, as early as November 9, 2015,[61] has been given the opportunity to comment which he has in fact availed no less than nine times, we apply the exception.

Our earlier finding of indirect contempt against Kara-an does not serve as a bar for once again holding him liable for indirect contempt. In Ciocon-Reer, Kara-an was held liable for his appearance in Civil Case No. 7819, entitled "Juvy P. Ciocon-Reer, et al. vGaspar Mayo, et al before the RTC of General Santos City, Branch 22. Here, we hold Kara-an liable for his appearances in various first and second level courts in Metro Manila.

We also hold that forum shopping is not availing in this case. There is forum shopping when a party repetitively avails of several judicial remedies in different courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in or already resolved adversely by some other court.[62] The only similarity in Ciocon-Reer and this case is that Kara-an is the person found to be illegally practicing law; no other similarity as to parties, courts and cases appear. Thus, and contrary to Kara-an's claim, there is no forum shopping in this case.


We now determine the proper penalty to be imposed on Kara-an. Section 7, Rule 71 of the Rules of Court provides:
Sec. 7. Punishment for indirect contempt. - If the respondent is adjudged guilty of indirect contempt committed against a Regional Trial Court or a court of equivalent or higher rank, he may be punished by a fine not exceeding thirty thousand pesos or imprisonment not exceeding six (6) months, or both. If he is adjudged guilty of contempt committed against a lower court, h emay be punished by a fine not exceeding five thousand pesos or imprisonment not exceeding one (1) month, or both, xxx (Emphasis supplied.)
We agree with the OCA that incarceration is no longer an option considering Kara-an's advanced age and health. Due however, to his temerity and unabashed disobedience of our earlier ruling against his scheme and our warning that more serious sanctions will be imposed in case of defiance, we adopt the OCA's recommendation of imposing a penalty of P25,000.00 for each count of Kara-an'sappearance in the RTC and P4,000.00 for each count of appearance in the MeTC.[63]

We disagree with the OCA's determination of the number of cases where Kara-an illegally practiced law. According to the OCA, Kara-an should be liable for 11 counts of indirect contempt. A reading of the OCA Memorandum dated January 14, 2014 however shows that Kara-an appeared in four RTC and nine MeTC civil cases. In two RTC cases and two MeTC cases, Kara-an is the only plaintiff and does not appear to be acting on anyone's behalf.[64] Thus, for Kara-an's blatant, willful, shameless and repeated acts of unauthorized practice of law, we impose on Kara-an a fine of P50,000.00 for the two counts committed in the RTC and a fine of P28,000.00 for seven counts committed in the MeTC, or a total fine of P78,000.00.

WHEREFORE, we find REMBERTO C. KARA-AN, SR. GUILTY of Indirect Contempt under Section 3(e), Rule 71 of the Rules of Court and impose upon him a FINE in the total amount of P78,000.00.

Remberto C. Kara-an, Sr. is DIRECTED to PAY THE FINE before the Cash Division, Financial Management Office, Office of the Court Administrator, within 30 days from receipt of this Resolution.

In the event Remberto C. Kara-an, Sr. fails to pay the fine within the 30-day period, the Docket and Clearance Division, Office of the Court Administrator, is DIRECTED to report said non-payment to the Court.

Remberto C. Kara-an, Sr. is ENJOINED to refrain from further appearing before the courts and practicing law.

Finally, let a copy of this Resolution be furnished all courts of the land for their guidance and information. (Velasco, Jr., J., no part, due to his prior action as Court Administrator; Carpio, J., designated as additional member per Raffle dated August 5, 2013.)


[1]Rollo, pp. 1-12.

[2] Also referred to as "Karaan" in some parts of the records.

[3] Rollo, pp. 524-539.

[4] Id. at 539.

[5] id.

[6]Rollo, pp. 606-620.

[7] Id. at 619-620.

[8] Id. at 634.

[9] Id. at 726.

[10]Id. at 928.

[11] Id. at 929-933.

[12]Id at 930-931.

[13]Id at 763.

[14]Id. at 891.

[15]Id. at 769-770.

[16]Id. at 897.

[17]Id. at 722.

[18]Id. at 915.

[19]Id. at 905-907.

[20] Id. at 908.

[21]Id. at 909.

[22] Id. at 633.

[23] Id. at 925.

[24] A.M. OCA I.P.I. No. 09-3210-RTJ, June 20, 2012, 674 SCRA 13.

[25] Rollo, p. 931.

[26] Id. at 932-933.

[27] Id. at 935-936.

[28] Id. at 937-940.

[29] Kara-an filed the following: (1) Supplemental Comment and Motion for Extension of Time to Plead dated January 10, 2016 [Id. at 954-973]; (2) 2nd Supplemental Comment and Motion for Extension of Time to Plead dated January 21, 2016 [Id. at 976-985]; (3) 3rd Supplemental Comment and Motion for Extension of Time to Plead dated January 31, 2016 [Id. at 1012-1022]; (4) 4th Supplemental Comment and Motion for Extension of Time to Plead dated February 10, 2016 [Id. at 1024-1034]; (5) 5th Supplemental Comment and Motion for Extension of Time to Plead dated February 20, 2016 [Id. at 1141-1158]; (6) 6th Supplemental Comment and Motion for Extension of Time to Plead dated March 3, 2016 [Id. at 1039-1049]; (7) 7th Supplemental Comment and Motion for Extension of Time to Plead dated March 14, 2016 [Id. at 1108-1121]; (8) 8th Supplemental Comment and Motion for Extension of Time to Plead dated March 25, 2016 [Id. at 1168-1190]; and (9) 9th Supplemental Comment and Motion for Extension of Time to Plead dated April 7, 2016 [Id. at 1267-1275].

[30] Id. at 955.

[31] Rule 138, Sec. 34 provides:

Sec. 34. By whom litigation conducted. — In the court of a justice of the peace a party may conduct his litigation in person, with the aid of an agent or friend appointed by him for that purpose, or with the aid of an attorney. In any other court, a party may conduct his litigation personally or by aid of an attorney, and his appearance must be either personal or by a duly authorized member of the bar.

[32] Rollo, pp. 955-956.

[33]Id. at 958.

[34]Id. at 957.

[35]Id. at 961.

[36]Id. at 962.

[37]Id. at 1015.

[38] Id at 1043-1045.

[39]Id. at 1143-1144, 1152-1153.

[40]Id. at 979-980.

[41]Supra note 24.

[42] Rollo, p. 931.

[43]Ciocon-Reer v. Lubao, A.M. OCA, I.P.I. No. 09-3210-RTJ, February 3, 2016, 783 SCRA 15.

[44] Id. at 19-20.

[45] Rollo,p. 1061.

[46] Id. at 1261-1262, 1283-1284.

[47] B.M. No. 553, June 17, 1993, 223 SCRA 378.

[48] Id at 396-397.

[49] People vVillanueva, G.R. No. L-l9450, May 27, 1965, 14 SCRA 109, 112.

[50] Ulep v. Legal Clinic, Inc., supra note 47 at 403.

[51] Maderada v. Mediodea, A.M. No. MTJ-02-1459, October 14, 2003, 413 SCRA 313, 324.

[52] Cruz v. Mijares, G.R. No. 154464, September 11, 2008, 564 SCRA 501, 508-509.

[53] See footnotes 13 & 21.

[54] See footnotes 14, 16 & 17.

[55] See footnotes 15, 18, 19, 20, 22 & 23.

[56] See Ang v. Ang, G.R. No. 186993, August 22, 2012, 678 SCRA 699, 708.

[57] Supra note 24.

[58] Id. at 21.

[59] G.R. Nos. 178085-178086, September 14, 2015, 770 SCRA 430.

[60] Id. at 464.

[61] Rollo, pp. 935-936.

[62] Heirs ofMarcelo Solto v. Palicte, G.R. No. 159691, February 17, 2014, 716 SCRA 175, 178.

[63] Rollo, p. 932.

[64] See footnotes 13 & 21.

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