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20/05/2026

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10/05/2026

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GREGORY ISRAEL vs. PEOPLE OF THE PHILIPPINES
G.R. No. 265736, November 19, 2025

FACTS:

Gregory Israel, a Belgian national, was contracted by fellow Belgians Christine Navez and Olivier Denonville for a building project in Bohol. Disputes over construction defects led the complainants to file a civil case for damages against Israel. In early 2017, Navez alleged that Israel made threatening gestures toward her on two occasions, specifically mimicking holding a gun and pulling a trigger, and making a decapitation motion across his neck. One incident occurred when Israel was traveling to the RTC to receive a summons and nearly figured in a vehicular collision with Navez. The prosecution charged Israel with Grave Threats under Article 282 of the Revised Penal Code (RPC). The MCTC convicted Israel, a ruling later affirmed with modification by the RTC and subsequently affirmed by the Court of Appeals (CA). Israel argued that his gestures were non-verbal and made in the heat of anger during a traffic altercation, thus lacking criminal intent. He filed a Petition for Review on Certiorari before the Supreme Court challenging the conviction. The petitioner maintained that the lower courts failed to appreciate the context of the incident which negated the 'persistence' required for the crime. The State argued that the gestures were clear and unequivocal threats to the victim's life.

ISSUE:

Whether or not the non-verbal gestures performed by Israel constitute the crime of Grave Threats under Article 282 of the Revised Penal Code.

RULING:

The Supreme Court GRANTED the petition and ACQUITTED Gregory Israel. The Court ruled that the prosecution failed to prove the mens rea or criminal intent for Grave Threats beyond reasonable doubt. While the Court acknowledged that non-verbal gestures can indeed constitute Grave Threats under Article 282 of the RPC, it emphasized that context is critical in such assessments. The Court found that the lower courts failed to fully appreciate the circumstances of the encounter, particularly that the gestures were performed spontaneously in the heat of anger following a near-vehicular collision. Jurisprudence requires that for a threat to be actionable under Article 282, there must be 'persistence' in the idea involved in the threat. Gestures made as a result of a momentary outburst or a sudden traffic altercation lack this required persistence and deliberate intent. Since Israel was merely reacting to the near-collision while en route to a court appearance, the Court held that the prosecution did not satisfy the high burden of proof required to establish a criminal mind. Consequently, the CA's decision was reversed and set aside.

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Case Link:https://sc.judiciary.gov.ph/wp-content/uploads/2026/05/265736.pdf

05/05/2026

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People of the Philippines vs. Francisca P. Calabio and Rosalie S. Alviar, G.R. No. 253996, December 03, 2025 (Date uploaded on SC website: 04/24/2026)

FACTS:

On June 23, 2017, law enforcement officers conducted a buy-bust operation against Francisca P. Calabio and Rosalie S. Alviar in San Pablo City, Laguna. A poseur-buyer allegedly purchased one heat-sealed sachet of shabu from the accused, and a subsequent search of Calabio yielded two more sachets. While the marking of the seized items was done at the place of arrest, the physical inventory and photography were conducted at the police station. The prosecution admitted that the required witnesses—an elected public official and a representative from the media—were not present at the time and place of the actual seizure. Instead, these witnesses were only called to the police station after the suspects and the drugs had already arrived. The accused argued that the failure to have the witnesses present during the seizure and at the place of arrest constituted a fatal break in the chain of custody. The Regional Trial Court (RTC) convicted both accused, ruling that the prosecution sufficiently established the elements of the crime. The Court of Appeals (CA) affirmed the conviction, holding that the integrity of the evidence was preserved despite the procedural deviations. The accused then appealed to the Supreme Court, maintaining that the non-compliance with Section 21 of R.A. No. 9165 warranted their acquittal. The Supreme Court reviewed the case to determine if the 'immediate' requirement of the chain of custody was met.

ISSUE(S):

1. 1. Whether or not the prosecution established the integrity and evidentiary value of the seized items despite the failure to conduct the inventory and photography in the presence of the required witnesses at the place of arrest.

RULING:

The Supreme Court ruled to ACQUIT the accused and REVERSED the CA decision. The Court held that strict compliance with the chain of custody rule under Section 21 of R.A. No. 9165, as amended by R.A. No. 10640, is mandatory for a valid conviction. The law requires that the inventory and photography be conducted in the presence of the accused, an elected public official, and a representative of the National Prosecution Service or the media. The Court emphasized that these witnesses must be present at or near the scene of the arrest to witness the 'immediate' seizure of the drugs. Calling witnesses to the police station after the items have already been confiscated and transported is a clear violation of the law. The Court explained that the presence of witnesses at the initial point of seizure is intended to insulate the process against the planting of evidence and to ensure the identity of the corpus delicti. Since the prosecution failed to provide a justifiable ground for the witnesses' absence at the scene of the arrest, the chain of custody was broken. This failure created reasonable doubt as to the source and integrity of the drugs, leading to the acquittal of the accused.

KEY DOCTRINE:

The mandatory witnesses required under Section 21 of R.A. No. 9165 must be present at or near the scene of the arrest to witness the actual seizure and marking of the evidence. Summoning the witnesses only at the police station after the items have been confiscated constitutes a fatal flaw in the chain of custody that compromises the integrity of the corpus delicti.

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04/05/2026

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30/04/2026

29/04/2026

https://www.facebook.com/share/p/18U2MqJj2K/?mibextid=wwXIfr

The (SC) 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session today, April 29, 2026, dismissed the petition for mandamus filed by Catalino Aldea Generillo, Jr., which sought to compel the Senate to immediately convene as an impeachment court to try the charges against Vice President Sara Duterte.

In a 14-0-1 Decision written by Associate Justice Rodil V. Zalameda, the SC held that mandamus, which is meant to enforce a clear legal duty, was not the proper remedy. It ruled that the Senate’s actions within its sphere cannot be revised or controlled by the judicial department through mandamus. As a co-equal constitutional body, the Senate’s exercise of its duties is beyond the SC’s power of review, except in cases of grave abuse of discretion.

However, specifically for this case and in the interest of equity, the SC treated the petition as one for certiorari and proceeded to determine whether the Senate acted unlawfully or abused its discretion when it did not convene immediately as an impeachment court during its session break.

Contrary to the petitioner’s claim, the SC found that the Senate acted on the impeachment complaint in a timely manner.

While the Constitution requires the House of Representatives to act within a certain number of session days on an impeachment complaint, it does not specify a fixed timeframe for the Senate to start an impeachment trial. It simply provides that the trial “shall forthwith proceed,” leaving the timing to the Senate’s discretion.

The SC clarified that the term “forthwith” in Article XI, Section 3(4) of the Constitution means within a reasonable time, which may be longer or shorter, depending on the circumstances of each case. This allows the Senate to make the necessary preparations to convene as an impeachment court.

While the Constitution does not set an exact date for the trial, the Senate must avoid undue delay to uphold the principle that public officers must at all times be accountable to the people.

The SC considered the petition moot because the Senate had begun impeachment preparations, and the Articles of Impeachment against Vice President Duterte were nullified by the SC’s July 25, 2025 Decision and January 28, 2026 Resolution in Duterte v. House of Representatives. A case is moot when subsequent events remove any issues, making court rulings unnecessary. Since no Articles of Impeachment remained, the SC had no reason to order the Senate to convene as an impeachment court.

Senior Associate Justice Marvic M.V.F. Leonen concurred only in the result, that the petition was moot. However he was of the position that the impeachment court should have been convened immediately and that the impeachment court—not merely the Senate President—should have taken charge of organizing that court. (Updated as of April 29, 2026, 5:30 p.m.)

Associate Justice Alfredo Benjamin S. Caguioa took no part.

Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=164510

The full text of the Decision will be uploaded to the SC website once available.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy.