A direct attack on a judgment or decree is an attempt, for sufficient cause, to have it annulled, reversed, vacated, corrected, declared void, or enjoined, in a proceeding instituted for that specific purpose, such as an appeal, writ of error, bill of review, or injunction to restrain its execution; distinguished from a collateral attack,which is an attempt to impeach the validity or binding force of the judgment or decree as a side issue or in a proceeding instituted for some other purpose.
Source: https://thelawdictionary.org/direct-attack/
A collateral attack is an attack, made as an incident in another action, whose purpose is to obtain a different relief.
Source: Go vs. Echavez, G.R. No. 174542, August 03, 2015
http://www.chanrobles.com/cralaw/2015augustdecisions.php?id=626
An action is an attack on a title when the object of the action is to nullify the title, and thus challenge the judgment or proceeding pursuant to which the title was decreed. The attack is direct when the object of an action is to annul or set aside such judgment, or enjoin its enforcement. On the other hand, the attack is indirect or collateral when, in an action to obtain a different relief, an attack on the judgment or proceeding is nevertheless made as an incident thereof.
Source: Heirs of Cayetano Cascayan Vs. Spouses Oliver and Evelyn Gumallaoi, G.R. No. 211947, July 3, 2017
https://www.lawphil.net/judjuris/juri2017/jul2017/gr_211947_2017.html
Friday, November 29, 2019
Articles 381 to 383 of the Civil Code
THE CIVIL CODE
RA. No. 386
TITLE XIV
TITLE XIV
Absence
CHAPTER 1
CHAPTER 1
Provisional Measures in Case of Absence
ART 381. When a person disappears from his domicile, his whereabouts being unknown, and without leaving an agent to administer his property, the judge, at the instance of an interested party, a relative, or a friend, may appoint a person to represent him in all that may be necessary.
This same rule shall be observed when under similar circumstances the power conferred by the absentee has expired. (181a)
ART 382. The appointment referred to in the preceding Art having been made, the judge shall take the necessary measures to safeguard the rights and interests of the absentee and shall specify the powers, obligations and remuneration of his representative, regulating them, according to the circumstances, by the rules concerning guardians. (182)
ART 383. In the appointment of a
representative, the spouse present shall be preferred when there is no legal
separation.
If the absentee left no spouse, or if the spouse
present is a minor, any competent person may be appointed by the court. (183a)
These articles provide provisional measures in case of absence. Article 381 provides the requisites for the declaration of the absence of a person. These are: When a person
- disappears from domicile;
- his/her whereabouts being unknown; and
- he or she has no appointed administrator of his/her properties.
Apparently, when a person has no property to administer, judicial declaration of absence is not necessary.
Article 381 provides “Who may petition for representation of a person who disappears” These are:
1. an interested party
2. a relative
3. a friend
To protect the rights of parties such as creditors and heirs, one may seek judicial declaration of the absence of a person in behalf whom a representative may be appointed by the court.
Article 381 also provides that “The same rule shall be observed when under similar circumstances the power conferred by the absentee has expired.”
This provision applies when the absentee has appointed a representative but the conferment is already beyond its period or time of effectivity has lapsed.
Article 382 provides the reason why judicial declaration of the absence of a person is necessary – that is to protect the rights of the absentee and it is the duty of the court do so. Specifically, Article 382 directs the judge to take the necessary measures to
1. safeguard the rights and interests of the absentee
2. specify the powers, obligations & remuneration of his representative
Under Article 383, any person “In the appointment of a representative, the spousepresent shall be preferred when there is no legal separation.” This means that, as long as there is no judicial dissolution of marriage or when the spouses are not legally separated, the present spouse should be appointed as the representative of the absent spouse. However, if the absentee left no spouse, or if the spouse present is a minor, any competent person may be appointed by the court.
Note that the Family Code renders the phrase “if the spouse present is a minor” ineffective since the minimum age required to capacitate a person to marry is 18 years.
Case Digest
Reyes vs.
Alejandro
G.R. No. L-32026,
January 16, 1986
Facts:
Erlinda Reynoso Reyes were married
to Roberto Reyes on March 20, 1960. On October 25, 1969 Erlinda filed a
petition for the declaration of the absence of Roberto. She alleged in her
petition that Roberto had been absent from their conjugal dwelling since April
1962 and since then, his whereabouts were unknown. Also stated in the same
petition is the fact that Roberto left no will nor any property in his name nor
any debts.
Issue:
Whether or not Erlinda’s petition
should be dismissed.
Ruling:
Yes. Erlinda’s petition should be
dismissed.
The Supreme Court upheld the ruling of the
Court of First Instance of Cavite dismissing Erlinda’s petition. Applying Articles
381 to 384 of the New Civil Code, the Court held that “the need to have a
person judicially declared an absentee is when he has properties which have to
be taken cared of or administered by a representative appointed by the Court; the
spouse of the absentee is asking for separation of property or his wife is
asking the Court that the administration of a classes of property in the
marriage be transferred to her.” Since Roberto left no properties to
administer, there was no valid and urgent reason to grant her petition.
The
Court further explained that “the petition to declare the husband an absentee
and the petition to place the management of the conjugal properties in the
hands of the wife may be combined and adjudicated in the same proceedings.”
Reference:
Albano, Ed Vincent (2017). Persons and Family Relations. Central
Book Supply Inc.: Manila
-------------------------
by Permanent
Class Number 4 in Persons and Family Relations, LSPU, First Semester,
SY2019-2020
Date Last Updated: 30Nov2019
Article 194 of the Family Code
The Family Code of the Philippines
Executive Order No. 209
July 6, 1987
Art. 194. Support comprises everything indispensable for
sustenance, dwelling, clothing, medical attendance, education and
transportation, in keeping with the financial capacity of the family.
The education of the person entitled to be supported
referred to in the preceding paragraph shall include his schooling or training
for some profession, trade or vocation, even beyond the age of majority.
Transportation shall include expenses in going to and from school, or to and
from place of work.
Article
194 defines the nature of support that one may demand from his/her spouse,
ascendants, descendants, brothers and sisters. Included in this legally
demandable support are those that are necessary for family’s
1) sustenance
2) dwelling
3) clothing
4) medical attendance
5) education
6)
transportation
Found in the same article is the proviso
regarding the extent or the amount that maybe demanded: “in keeping with the
financial capacity of the family.” This means that demand for support must be
within the financial capacity to whom the same is demanded. The same article
defines what constitute education and transportation:
Education
- schooling or training for some
profession, trade or vocation, even beyond the age of majority
Transportation
- expenses in going to and from
school, or to and from place of work
Illegitimate children are also
entitled to support as provided for by Article 195. The cases of Agustin vs CA
(G.R. No. 162571, June 15, 2005) and Dolina vs Vallecera (G.R. No. 182367,
December 15, 2010) illustrate the remedy for a woman in case the father of her
illegitimate child denies family support. That is to “file an action for
support, where the issue of compulsory recognition may be integrated and
resolved.” The woman must first prove filiation and then ask for support. If
the father still refuses, the she can file an action based on the provisions of
RA 9262 (VAWC) to compel the alleged father for support.
To prove filiation, the woman may
compel the alleged father for DNA paternity test. She must however bear in mind
that the action for compulsory recognition prescribes when such alleged father
dies. In other words, she cannot sit on her rights and later on, lay claims on
the estate of the alleged father if the latter dies without a final judgement
on compulsory recognition.
Case Digest
Dolina vs
Vallecera
G.R. No. 182367, December 15, 2010
Facts:
Seeking protection under RA 9262 (VAWC),
Dolina filed a petition with prayer for the issuance of a temporary protection
order against Vallecera in February 2008. Dolina alleged that Vallecera
fathered her child as evidenced by latter’s Certificate of Live Birth which
listed Vallecera as the child’s father.
Vallecera opposed the petition. He denied
fathering the child and that his signature in the birth certificate was forged.
He denied living with Dolina and her child. According to him, Dolina was
harassing and forcing him to acknowledge her child and provide financial
support.
The Regional Trial Court denied Dolina’s
petition and admonished her for not filing first a petition for the compulsory
recognition of her child.
Issue:
Whether or not the RTC correctly
dismissed Dolina’s action for temporary protection and denied her application
for temporary support for her child.
Ruling:
Yes. The RTC correctly dismissed
Dolina’s action for temporary protection and denied her application for
temporary support for her child.
According to the Supreme Court, only
those who are entitled may seek protection afforded by RA 9262. To be entitled,
Dolina must have an existing intimate relationship with Vallecera or she was domiciled
in the same place as Vallecera. Her only recourse, to be entitled of protection
afforded by RA 9262 was to first prove Vallecera’s filiation with her child and
then demand support. Alternatively, she may directly file an action for
support, where the issue of compulsory recognition may be integrated and
resolved.
Thus, the Supreme Court upheld the
decision of the RTC in dimissing Dolina’s petition.
-------------------------
by Permanent Class Number 4 in Persons and
Family Relations, LSPU, First Semester, SY2019-2020
Date
Last Updated: 29Nov2019
Articles 159 to 162 of the Family Code
The Family Code of the
Philippines
Executive Order No. 209 July 6, 1987
Executive Order No. 209 July 6, 1987
Art. 159. The
family home shall continue despite the death of one or both spouses or of the
unmarried head of the family for a period of ten years or for as long as there
is a minor beneficiary, and the heirs cannot partition the same unless the
court finds compelling reasons therefor. This rule shall apply regardless of
whoever owns the property or constituted the family home. (238a)
Art. 160. When a
creditor whose claims is not among those mentioned in Article 155 obtains a
judgment in his favor, and he has reasonable grounds to believe that the family
home is actually worth more than the maximum amount fixed in Article 157, he
may apply to the court which rendered the judgment for an order directing the
sale of the property under execution. The court shall so order if it finds that
the actual value of the family home exceeds the maximum amount allowed by law
as of the time of its constitution. If the increased actual value exceeds the
maximum allowed in Article 157 and results from subsequent voluntary
improvements introduced by the person or persons constituting the family home,
by the owner or owners of the property, or by any of the beneficiaries, the
same rule and procedure shall apply.
At the execution
sale, no bid below the value allowed for a family home shall be considered. The
proceeds shall be applied first to the amount mentioned in Article 157, and
then to the liabilities under the judgment and the costs. The excess, if any,
shall be delivered to the judgment debtor. (247a, 248a)
Art. 161. For
purposes of availing of the benefits of a family home as provided for in this
Chapter, a person may constitute, or be the beneficiary of, only one family
home. (n)
Art. 162. The
provisions in this Chapter shall also govern existing family residences insofar
as said provisions are applicable. (n)
Article 159 provides the continued protection
of the family home for a period of 10 years after the death of a spouse or the
head of the family who constituted the same. The heirs are also prohibited from
immediately partitioning the family home. The prohibition may last for more
than ten years for as long as there is a minor living in the family home. The only
exception to this prohibition is that if the court finds a compelling reason to
partition the family home. The reasons for this prohibitions are:
1)
To
preserve the family home as the physical symbol of family love, security and
unity. (Albano)
2)
No
greater calamity, not tainted with crime, can befall a family than to be
expelled from the roof under which it has been gathered and sheltered. (Eulogio
vs Bell, G.R. No. 186322, July 8, 2015)
Article 160 provides relief to creditors
who are not covered by the exceptions under Article 155. Such creditors can go
to court and prove that
1)
the
family home is actually worth more than the maximum amount fixed in Article 157;
or
2)
the
increased in actual value of the family home exceeds the maximum allowed in
Article 157
Under the second option, creditors may successfully
lay claim on the family home, if they have alleged and proved that
1)
there
was an increase in its actual value;
2)
the
increase resulted from voluntary improvements on the property introduced by the
persons constituting the family home, its owners or any of its beneficiaries;
and
3)
the
increased actual value exceeded the maximum allowed under Article 157.
For example, the actual value of the
family home upon its constitution or its value has increased to more than what
is allowed under Article 157, then such creditor can ask the court to auction
the family home. The proceeds should be applied first for the constitution of a
new family home and the expenses of the litigation and other mandatory levies
such as the taxes on the property and then whatever remains shall go to such
creditor. See an illustrative example below.
Article 162 enunciates the
prospective application of the provisions of the Family Code insofar as
gratuitous and inalienable rights to the family home are concerned.
Case Digest
Arriola v. Arriola
G.R. No. 177703, January 28, 2008
Facts:
Fidel Arriola had a son named John Nabor with
his deceased wife. He also had a son, Anthony, with his second wife, Vilma.
Fidel died in March 10, 2003 and left a house and lot in Las Piñas City. The
RTC granted John Nabor’s petition for the partition of the lot. Each heir was
to received 1/3 of the subject lot. However, the heirs failed to agree on how
to partition among themselves the subject land so the RTC ordered a public
auction of the subject land.
Anthony and Vilma refused to include
in the auction the house built on the subject land since it was their family
residence for more than 20 years. Hence, John filed an Urgent Manifestation and
Motion for Contempt of Court. The RTC denied the motion since it recognized the
fact that the house was not included in the petition for partition.
John elevated the issue to the Court
of Appeals, which ruled in his favor. Citing the principle of accession, the CA
ruled that an improvement automatically formed part of the principal. Hence,
when the subject land, the principal, was ordered to be partitioned, the house,
an improvement thereon was also deemed subject to partition.
Issue:
Whether or not, the house that stood on
the parcel of land subject for partition, should also be part of the partition
via public auction.
Ruling:
No. The house that stood on the
parcel of land subject for partition, should not be part of the partition via
public auction.
The Supreme Court agreed with the
CA’s application of the principle of accession on this particular case. However,
the Supreme Court said that both the RTC and CA should have dismissed the
motion filed by John because it was procedurally flawed. This would then effectively
reinstate the ruling of the RTC but for the wrong reason. Thus, instead of
simply remanding the case to the RTC, which could result to prolonged legal
battle between the opposing parties, the Supreme Court resolved the issue on
substantive grounds.
The SC pointed to the pertinence of Article
159 of the Family Code that specifically proscribed the partition of the family
home, unless for a compelling reason, for at least 10 years following the death
of one or both spouses or after the death of the unmarried head of the family
who constituted the family home. The Supreme Court did not see any compelling
reason for the immediate partition of the family home.
Fidel died on March 10, 2003 so the
partition could only be effected on March 10, 2013. During this period, the
Supreme Court allowed the auction of the subject land but not the house and the
portion of the land on which it stood.
Reference:
Albano, Ed Vincent (2017). Persons and Family Relations. Central Book Supply Inc.: Manila
-------------------------
by Permanent Class Number 4 in Persons and Family Relations, LSPU, First Semester, SY2019-2020
Date Last Updated: 30Nov2019
Articles 111 to 115 of the Family Code
The Family Code of the Philippines
Executive Order No.
209 July 6, 1987
Art. 111. A spouse
of age may mortgage, encumber, alienate or otherwise dispose of his or her
exclusive property, without the consent of the other spouse, and appear alone
in court to litigate with regard to the same. (n)
Art. 112. The
alienation of any exclusive property of a spouse administered by the other
automatically terminates the administration over such property and the proceeds
of the alienation shall be turned over to the owner-spouse. (n)
Art. 113. Property
donated or left by will to the spouses, jointly and with designation of
determinate shares, shall pertain to the donee-spouses as his or her own
exclusive property, and in the absence of designation, share and share alike,
without prejudice to the right of accretion when proper. (150a)
Art. 114. If the
donations are onerous, the amount of the charges shall be borne by the
exclusive property of the donee spouse, whenever they have been advanced by the
conjugal partnership of gains. (151a)
Art. 115.
Retirement benefits, pensions, annuities, gratuities, usufructs and similar
benefits shall be governed by the rules on gratuitous or onerous acquisitions
as may be proper in each case. (n)
In conjugal partnership of gains, the spouses retain the
ownership of their exclusive properties. With respect to these properties,
either spouse can perform acts of ownership without the consent of the other
spouse. Article 111 specifically enumerates these acts of ownership:
1)
mortgage
2)
encumber
3)
alienate
or dispose
4)
litigate
Article 112 provides for the effect of the
alienation of the exclusive property by the owner-spouse or by
administrator-spouse or by either with the consent of the other or by both
spouses. These are:
(1)
the
termination of the administration of the designated administrator-spouse
(2)
the
turnover of proceeds, if any, to the owner-spouse.
According to Article 113, when spouses are
named jointly in a donation or to a testate inheritance, the same forms part of
the exclusive properties of the spouses. The shares of each spouse depends on
the designation in the donation or will. If there is no specified share, then
the spouses would equally share and the right of accretion applies.
According to Albano (2017), “accretion is a right
by virtue of which, when two or more persons are called to the same
inheritance, devise or legacy, the part assigned to the one who renounces or
cannot receive his share, or who died before the testator, is added or
incorporated to that of his co-heirs, co-devisees or co-legatees (Art. 1015,
Civil Code).”
For an onerous donation received by a
spouse, the exclusive property of such spouse is liable for such donation
whenever the conjugal partnership advances for any charges that accompany such
donation (Article 114). A donation is said to be onerous when the burdens and
charges or future services equal in value if not greater than that of the thing
donated.
Under Article 115, benefits such as those
from retirements, pensions, annuities, gratuities and usufructs may be conjugal
or not. If the source of the accrual of such benefits come from conjugal funds,
then such benefits are conjugal.
In Republic vs. Yahon
(G.R. No. 201043, June 16, 2014), the Supreme Court held that salaries and
employee benefits such as those held by the GSIS and Armed Forces of the
Philippines Finance Center can be subject to garnishment and writ of execution to
enforce the claims of a spouse who is granted protection under RA 9262
(Anti-violence against Women and Their Children) commonly referred to as the
VAWC. The Supreme Court also reiterates that RA 9262 is constitutional and is
claims of “economically abused wife” can be enforced against the state. This
law is deemed as a limited waiver of sovereign immunity from suits. In short, the
conjugality of gratuities, retirement, pension and other similar benefits is
immaterial if a wife can successfully prove in court that she has been subjected
to “economic abuse” by his husband. She can ask the court to order a government
or a non-government entity to withhold the funds payable to his husband and be disbursed
to her directly.
Case Digest
SOCIAL SECURITY
COMMISSION v. EDNA A. AZOTE
G.R. No. 209741,
April 15, 2015
Facts:
Edna
Azote got married to Edgardo Azate in June 19, 1992. After two years of
marriage, Edgar submitted Form E-4 to the SSS wherein he designated Edna and
their three children as beneficiaries. Seven years later, he resubmitted the
same form to include their three younger children.
Edgardo
passed away in January 13, 2005. Thereafter, Edna filed a petition with the
Social Security Commission to claim death benefits. However, SSC found out that
Edgardo had already filed in November 5, 1982 a form designating Rosemarie
Azote and Elmer Azote as beneficiaries.
Further
investigation by the SSC revealed that prior to the marriage of Edgardo to
Edna, he was validly married to Rosemarie as evidenced by the marriage
certificate from NSO. There was no evidence that Edgar and Rosemarie’s marriage
was declared null and void before Edgar contracted a subsequent marriage with
Edna. Thus, the SSC declared Edna’s marriage with Edgar as null and void and
denied Edna’s petition to claim benefits.
The
Court of Appeals reversed the decision of the SSC. According to the CA, Edna
had substantial evidence to prove her marriage with Edgar when she presented
her marriage certificates and the baptismal certificates of her children.
Edgar’s submission of form E-4, designating her as beneficiary should be
considered as a voluntary act of Edgar changing his designated beneficiary.
The
SSC elevated the case to the Supreme Court.
Issue:
Whether or not Edna was entitled to become a beneficiary
of Edgar.
Ruling:
No. Edna was not
entitled to become a beneficiary of Edgar.
Under Section 8 of Republic Act (R.A.) No. 8282, known as
the SSS Law, the word “legal spouse” was clearly and categorically indicated as
the one who has the right to be a dependent of an SSS member. Edna was not
legally married to Edgar. Edgar’s first marriage was never declared null and
void; hence, he cannot validly contract another marriage.
The SSS law allows the members to designate their
beneficiaries. However, Edgardo’s subsequent submission of Form E-4 naming
another sets of beneficiary could not be construed as revocation of his
original declaration. He should have followed procedures laid down by the SSS
Law to validly change his intended beneficiaries.
The Supreme Court did not give weight on the fact that no
one opposed Edna’s SSS claims. Rosemarie’s death prior to Edgar’s death did not
cure or legitimize Edna’s status.
Dissenting
Opinion of Justice Leonen
The Social Security System has no jurisdiction to declare
any marriage null and void. It’s action on Edna’s case was null and void many
times over.
There was no opposition on Edna’s claims. Contesting her
marriage for purposes of SSS claims amounts to disturbing domestic peace and
disrespecting autonomy of intimate relationship. There was no actual
controversy regarding Edna’s marriage with Edgar so the Court must not
adjudicate on the same.
Important point from Justice Leonen:
"Edna’s case and a lot more show that without divorce, our laws remain insensitive to a multitude of intimate relations. As people with autonomous and private choices that do no harm to society, they are wholly and immoderately disregarded. This case, like many others, should be basis for Congress to seriously consider the respect due to voluntary adult. choices of our people. A divorce law is no longer a luxury; it has become a just and inevitable necessity."
Reference:
Albano, Ed Vincent (2017). Persons and Family Relations. Central Book Supply Inc.: Manila
-------------------------
by Permanent Class Number 4 in Persons and
Family Relations, LSPU, First Semester, SY2019-2020
Date
Last Updated: 29Nov2019
Article 30 Civil Code of the Philippines
THE CIVIL CODE
RA. No. 386
Preliminary Title
Chapter 1
Effect and Application of Laws
Article
30. When a separate civil action is brought to demand civil liability arising
from a criminal offense, and no criminal proceedings are instituted during the pendency
of the civil case, a preponderance of evidence shall likewise be sufficient to
prove the act complained of.
An offended party can
initiate a court action to enforce the civil liability arising from the crime
of an offender. This action is deemed civil in nature. Thus, the offended party
or the plaintiff is required to prove his case by mere preponderance of
evidence as opposed to proof beyond reasonable doubt required in criminal
cases. However, if the plaintiff initiates a criminal action, the civil action
is deemed suspended until the criminal action is adjudicated with finality. The
pending civil action may also be consolidated with the criminal action upon
proper application with the court. If the application is granted, the evidence
produced in the civil action is deemed reproduced in the criminal action
without prejudice to rights of the opposing parties to present more evidence in
their favor. Consolidated civil and criminal actions are tried and decided
jointly. (Rule 111, Section 2(a) of the Revised Rules of Court.)
In the case law, FEBTC vs. Chante (G.R.
No. 170598 October 9, 2013), a succinct definition of preponderant evidence is
provided. Following the words of Section 1, Rule 133 of the Rules of Court, the
Supreme Court states that “preponderant evidence refers to evidence that is of
greater weight, or more convincing, than the evidence offered in opposition to
it. It is proof that leads the trier of facts to find that the existence of the
contested fact is more probable than its nonexistence.”
According to the Supreme Court, “in
the hierarchy of evidentiary values…, proof beyond reasonable doubt [is] at the
highest level, followed by clear and convincing evidence, preponderance of
evidence, and substantial evidence, in that order.” (Spouses Vicente And Gloria
Manalo vs Roldan-Confesor et al, G.R. No. 102358 November 19, 1992)
Case
Digest
Torrijos
vs. CA
G.R.
No. L-40336. October 24, 1975
Facts:
Wakat
Diamnuan and his wife sold their 1/4 share of a parcel of land in favor of
Torrijos. Five years later, the entire property, including the share of Wakat
and his wife, were sold to Victor de Guia. Hence, Torrijos filed a case of
estafa against Wakat who was subsequently convicted by the trial court. While
the conviction was on appeal, Wakat died.
Issue:
Should the appeal regarding the civil liability of Wakat
be allowed to proceed?
Held:
Yes. The Supreme Court held that the appeal should be
allowed to proceed with respect to the civil liability of Wakat. Death
extinguishes both criminal and civil liability only when the civil liability could
only arise from a criminal conviction. Civil liability survives the death of an
accused when it can be predicated on other sources of obligations other than
acts or omissions punished by law. In this particular case, there was a
predicate source of obligation, the contract of purchase and sale between Wakat
and Torrijos. Thus, it was held that Torrijos could still enforce Wakat’s civil
liability against Wakat’s heirs. Seeking the enforcement of this civil
liability independent of criminal prosecution is what Article 30 of the Civil
Code provides.
It should be noted, however, that in
the case of Torrijos, the Supreme
Court did not cite Article 30. Article 30 was mentioned in People vs Bayotas
(G.R. No. 102007 September 2, 1994) vis a
vis the case of Torrijos and Sendaydiego to drive this point: “What
Article 30 recognizes is an alternative and separate civil action which may be
brought to demand civil liability arising from a criminal offense independently
of any criminal action. In the event that no criminal proceedings are
instituted during the pendency of said civil case, the quantum of evidence
needed to prove the criminal act will have to be that which is compatible with
civil liability and that is, preponderance of evidence and not proof of guilt
beyond reasonable doubt.”Reference:
Albano, Ed Vincent (2017). Persons and Family Relations. Central Book Supply Inc.: Manila
-------------------------
by Permanent Class Number 4 in Persons and Family Relations, LSPU, First Semester, SY2019-2020
Date Last Updated: 29Nov2019
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