Bullying in a Philippine school does not carry one automatic penalty such as a fixed number of suspension days, a standard fine, or immediate imprisonment. The consequences depend on what happened, how serious or repeated it was, the age of the person responsible, the school’s disciplinary rules, and whether the conduct also amounts to a crime or causes compensable damage. A single incident can qualify as bullying when it is severe enough; the victim does not always have to wait for the behavior to happen repeatedly. (Supreme Court E-Library)
In practice, one incident may produce several parallel consequences:
- School discipline and intervention;
- Criminal proceedings for physical injuries, threats, defamation, child abuse, or another offense;
- Civil liability for medical expenses, psychological harm, damaged property, and other losses;
- Administrative liability for teachers, school personnel, or administrators who participate in, conceal, or mishandle the incident; and
- Regulatory sanctions against a school that fails to comply with anti-bullying requirements.
What Law Covers Bullying in Philippine Schools?
The principal law is Republic Act No. 10627, the Anti-Bullying Act of 2013. It requires elementary and secondary schools to adopt policies preventing and addressing bullying.
DepEd issued a substantially revised set of implementing rules in 2025. The Revised Implementing Rules and Regulations of RA 10627, signed on August 1, 2025, repealed DepEd Order No. 55, series of 2013. The revised rules apply to public and private basic education schools, Community Learning Centers, Philippine Schools Overseas, and international schools that are authorized or supervised by DepEd.
Other laws may apply alongside RA 10627, including:
- The Revised Penal Code;
- RA 9344, the Juvenile Justice and Welfare Act, as amended by RA 10630;
- RA 7610, the Special Protection of Children Against Abuse, Exploitation and Discrimination Act;
- RA 10175, the Cybercrime Prevention Act of 2012;
- RA 11313, the Safe Spaces Act;
- The Civil Code and Family Code; and
- DepEd’s Child Protection Policy and the school’s student handbook.
What Counts as Bullying?
Bullying is any severe or repeated written, verbal, electronic, physical, psychological, social, or gender-based conduct by one or more learners against another learner that:
- Causes or reasonably threatens physical or emotional harm;
- Damages or threatens the victim’s property;
- Creates a hostile school environment;
- Infringes the victim’s rights at school; or
- Materially disrupts the educational process or the orderly operation of the school.
The wording “severe or repeated” is important. A single brutal assault, serious threat, humiliating video, or severe sexual or discriminatory act may already qualify. Repetition is not required when the act itself is sufficiently serious. (Supreme Court E-Library)
Common forms of school bullying
The revised rules recognize forms such as:
- Physical bullying: Punching, kicking, pushing, tripping, pinching, slapping, choking, fighting, using objects as weapons, or harmful “pranks.”
- Psychological or emotional bullying: Conduct that harms the learner’s emotional or psychological well-being.
- Verbal bullying: Threats, profanity, name-calling, tormenting, taunting, offensive jokes, or degrading comments about a person’s appearance or body.
- Cyberbullying: Harassment through text messages, email, messaging apps, social media, online games, spam, trolling, hurtful comments, or inappropriate photos and videos.
- Social bullying: Deliberate exclusion, rumor-spreading, reputational attacks, or group conduct meant to isolate a learner.
- Gender-based bullying: Humiliation or exclusion based on sex, gender identity, gender expression, or perceived identity, including sexist, homophobic, misogynistic, or transphobic remarks.
Bullying outside the campus can still be a school matter
Under the revised rules, prohibited bullying may occur:
- On school grounds;
- On property immediately adjacent to the school, within a two-kilometer radius;
- At school-sponsored activities, whether on or off campus;
- At school bus stops;
- In school buses or vehicles used by the school;
- Through school-owned or school-used technology; or
- Elsewhere, including online, when the conduct creates a hostile environment at school, infringes the victim’s school rights, or substantially disrupts education or school operations.
This means a humiliating TikTok video posted from home, a group-chat harassment campaign during the weekend, or an assault near the school may still fall under the school’s anti-bullying jurisdiction if its effects reach the school environment.
What School Penalties Can Be Imposed on a Student Who Bullies?
RA 10627 does not prescribe a nationwide rule saying, for example, that a first offense always means three days’ suspension or that a second offense automatically means expulsion. Each school must maintain a disciplinary range in its anti-bullying policy and handbook, considering the nature, frequency, and gravity of the conduct.
Possible consequences may include:
- A documented teacher intervention;
- Parent conferences;
- Behavioral agreements or corrective activities;
- Restitution for damaged property;
- Counseling or psychosocial intervention;
- Increased supervision or safety restrictions;
- Removal from certain activities or privileges;
- Suspension or another sanction authorized by the school handbook;
- Referral to the principal or school disciplinary body;
- Referral to law enforcement, social welfare authorities, or other agencies; and
- More serious disciplinary action permitted by applicable DepEd rules and due process.
The revised rules emphasize formative, corrective, child-protective, and nonviolent discipline. Counseling, however, does not replace disciplinary action when discipline is warranted.
The three levels of school discipline
The 2025 Revised IRR organizes incidents into three practical levels.
| Level | Type of incident | Usual school response |
|---|---|---|
| First level | Precursors or minor bullying that does not create immediate serious physical, psychological, or emotional harm | Immediate teacher assessment, intervention, documentation, and reporting |
| Second level | Serious or repeated behavior that may create immediate harm | Formal proceedings involving the Learner Formation Officer or designated school personnel |
| Third level | Severe, complex, or unresolved incidents affecting safety and well-being | Principal-led investigation, parent notification, safety planning, and coordination with law enforcement or other external agencies when necessary |
Minor behavior that continues despite teacher intervention should be escalated. A school should not repeatedly label serious conduct as a “minor misunderstanding” merely because the learners are young.
Due Process Before the School Imposes a Penalty
A school cannot lawfully impose a serious disciplinary sanction based only on accusation, rumor, or pressure from other parents. At minimum:
- The alleged bully and the parent or parent-substitute must receive written notice of the complaint.
- The learner must have an opportunity to answer in writing with parental assistance.
- The school head’s decision must be written and must state the facts and reasons.
- The affected party must be informed of the right to appeal.
An anonymous report may trigger protection, fact-finding, monitoring, or an investigation, but the revised rules state that no disciplinary or administrative action may be imposed solely on the basis of an anonymous report. The school must obtain supporting evidence.
School investigation and appeal timelines
The revised rules provide the following key periods:
- The school disciplinary body should investigate and resolve the complaint within 30 days from filing.
- An adversely affected party generally has 10 days from receipt of the decision to appeal.
- The appeal ordinarily proceeds from the school to the Schools Division Office, then to the Regional Office, and finally to the DepEd Undersecretary for Legal and Legislative Affairs or the Secretary.
- No motion for reconsideration is entertained during the appeal process under the revised rules.
- Failure to appeal within the ten-day period makes the decision final and executory.
These periods make written proof of receipt important. Parents should retain the email, receiving copy, courier record, or other evidence showing when a complaint or decision was delivered.
Can a Student Be Arrested or Criminally Charged for Bullying?
Bullying is not automatically a separate crime carrying a fixed prison sentence under RA 10627. However, the specific acts used to bully may constitute crimes under the Revised Penal Code or a special law.
A school complaint and a criminal complaint may proceed at the same time. Filing with the school does not remove the right to go to the police, prosecutor, or another proper authority. The revised rules expressly preserve remedies under other laws.
Examples of possible criminal offenses
| Conduct | Possible legal consequence |
|---|---|
| Punching, kicking, choking, or striking | Slight, less serious, or serious physical injuries, depending on the injury and required medical treatment |
| Threatening to kill, injure, or destroy property | Grave threats, light threats, or another threat-related offense |
| Forcing another learner to surrender money, food, gadgets, or belongings | Robbery, theft, coercion, or another property offense, depending on the facts |
| Publicly making malicious accusations or degrading statements | Oral defamation, libel, or another crime against honor |
| Posting defamatory material online | Possible cyberlibel when all legal elements are present |
| Repeated unwanted conduct meant primarily to irritate, torment, or distress | Possible unjust vexation or another applicable offense |
| Sexually humiliating, harassing, or targeting someone because of gender | Possible liability under the Safe Spaces Act, RA 7610, the Revised Penal Code, or school child-protection rules |
| Severe cruelty or degrading abuse of a child | Possible violation of RA 7610 when the statutory elements are established |
| Causing serious injury or death | More serious criminal charges and juvenile justice proceedings, depending on the offender’s age |
Penalty for slight physical injuries
Under Article 266 of the Revised Penal Code, as amended by RA 10951:
- Injuries requiring medical attendance or causing incapacity for one to nine days are punishable by arresto menor, or imprisonment from one to 30 days.
- Injuries that do not prevent habitual work and do not require medical assistance may be punished by arresto menor or a fine of up to ₱40,000, with censure.
- Ill-treatment by deed that causes no injury may be punished by arresto menor in its minimum period or a fine of up to ₱5,000.
Longer incapacity, permanent injury, disability, loss of a body function, or death can result in substantially heavier charges and penalties. ([Lawphil][2])
Penalty for oral defamation
Serious oral defamation under Article 358 may be punished by imprisonment ranging from four months and one day to two years and four months. Less serious oral defamation may be punished by arresto menor or a fine not exceeding ₱20,000.
Not every insult is automatically defamation. Courts examine the exact words, whether they were communicated to another person, the context, the relationship of the parties, and whether the statement maliciously damaged reputation. ([Supreme Court E-Library][3])
Cyberbullying is not automatically cyberlibel
A cruel message, embarrassing meme, or online insult can violate the school’s anti-bullying policy without necessarily satisfying the technical elements of cyberlibel. Cyberlibel usually requires a defamatory imputation, publication, identifiability, and malice, committed through a computer system.
Other online conduct may instead involve threats, identity misuse, privacy violations, sexual harassment, unauthorized sharing of intimate material, or another offense. The actual content, audience, account ownership, timestamps, and manner of distribution matter.
When RA 7610 may apply
Severe acts against a child may be investigated under Section 10(a) of RA 7610, which carries a much heavier penalty than ordinary slight physical injuries. However, RA 7610 is not automatically applicable every time one child hurts or insults another. Prosecutors and courts must determine whether the conduct satisfies the statutory and jurisprudential requirements for child abuse, cruelty, or conditions prejudicial to the child’s development. ([Lawphil][4])
What Happens When the Alleged Bully Is a Minor?
Most school bullying cases involve children, so the Juvenile Justice and Welfare Act is crucial.
| Age when the offense occurred | Criminal consequence |
|---|---|
| 15 years old or younger | Exempt from criminal liability, but subject to an intervention program |
| Above 15 but below 18, without discernment | Exempt from criminal liability and subject to intervention |
| Above 15 but below 18, with discernment | May undergo juvenile justice proceedings, diversion, rehabilitation, and other child-appropriate measures |
| 18 or older | Regular criminal procedure generally applies |
Discernment means the capacity to understand that the act was wrong and to appreciate its consequences. It must be established; it cannot simply be assumed because the act was serious.
Exemption from criminal liability does not erase civil liability. Medical expenses, property damage, and other legally recoverable losses may still be claimed. Even when a child is found guilty, juvenile justice rules favor diversion, rehabilitation, suspended sentence, and reintegration rather than ordinary adult imprisonment. ([Lawphil][5])
Parents are not automatically imprisoned for what their child did. They may, however, face civil liability in appropriate cases, and they can be separately liable if they personally threaten the victim, destroy evidence, harass witnesses, retaliate, or commit another unlawful act.
Can the Victim Claim Damages?
A bullying victim may have a civil claim even when the alleged bully is too young to be criminally liable.
Possible claims may include:
- Hospital, medication, therapy, and psychological treatment expenses;
- Repair or replacement of damaged property;
- Lost income or other documented financial losses;
- Moral damages for serious anxiety, humiliation, emotional suffering, or mental anguish;
- Exemplary damages in cases involving gross, reckless, or oppressive conduct; and
- Attorney’s fees when legally justified.
Potential legal bases include Articles 19, 20, 21, 2176, and 2180 of the Civil Code, as well as Articles 218, 219, and 221 of the Family Code.
Under Articles 218 and 219 of the Family Code, schools, administrators, and teachers exercise special parental authority over minor learners while the children are under their supervision, instruction, or custody, including during authorized off-campus activities. The persons exercising that authority may be principally and solidarily liable for damages caused by the acts or omissions of an unemancipated minor unless they prove the diligence required by the circumstances. ([Lawphil][6])
A school may also be directly liable for breaching its obligation to maintain a reasonably safe learning environment. In Mother Goose Special School System, Inc. v. Spouses Palaganas, the Supreme Court upheld the school’s liability arising from its own handling of a punching incident, explaining that a school’s obligation to its students includes providing and maintaining a safe learning environment. ([Supreme Court E-Library][7])
School liability is not automatic in every incident. Courts examine prior warnings, supervision, school policies, the foreseeability of harm, the response after reports, and whether reasonable protective measures were taken.
What Penalties Can a School or School Employee Face?
Public school personnel
Public school personnel who fail to comply with RA 10627 or the revised rules may face administrative proceedings under Civil Service rules and DepEd issuances. The school administrator is specifically made accountable for noncompliance with the school’s anti-bullying policy.
A suspiciously perfect “zero bullying” report is not automatically treated as proof that a school is performing well. DepEd’s revised rules recognize that non-reporting may instead indicate failures in detection, recording, or compliance.
Private school personnel and private schools
Private school employees may be subjected to disciplinary sanctions under school rules, employment policies, and applicable labor standards.
A private school that fails to comply may face DepEd administrative proceedings. The Secretary of Education, acting through the Regional Director, may suspend or revoke the school’s permit or recognition when appropriate.
Breach of confidentiality
Schools must protect the identities and personal circumstances of the victim, alleged bully, witnesses, bystanders, and other involved children.
School personnel who improperly reveal confidential information may face:
- School or DepEd administrative proceedings;
- Civil liability;
- Criminal liability where applicable; and
- Possible consequences under RA 10173, the Data Privacy Act of 2012.
Parents should also avoid publicly posting children’s names, faces, school records, medical information, or unredacted screenshots. Providing evidence privately to the school, police, prosecutor, social worker, or court is different from publishing it to shame a child online.
What if the Bully Is a Teacher or School Employee?
RA 10627 primarily defines bullying in terms of conduct by one learner against another learner. When a teacher, coach, administrator, security guard, driver, canteen worker, or other adult mistreats a child, the case should not be reduced to ordinary peer bullying.
Depending on the conduct, the adult may face:
- A complaint under DepEd’s Child Protection Policy;
- An administrative case before DepEd or the appropriate school authority;
- Employment sanctions in a private school, subject to labor due process;
- Criminal liability under the Revised Penal Code;
- Liability under RA 7610 or the Safe Spaces Act; and
- A civil claim for damages.
The incident should be reported to the school head or Child Protection Committee. When the school head is implicated, the complaint should be elevated to the Schools Division Office or the appropriate higher DepEd authority.
How to Report Bullying and Protect the Child
1. Address immediate safety first
For an ongoing assault, credible threat, weapon, serious injury, sexual misconduct, or risk of self-harm:
- Separate the child from the source of danger;
- Seek medical or emergency assistance;
- Inform the school head immediately;
- Contact the PNP, preferably the Women and Children Protection Desk, when criminal conduct may have occurred; and
- Request assistance from the local social welfare and development office when necessary.
Do not delay urgent medical treatment while waiting for a school conference.
2. Preserve evidence
Keep copies of:
- Screenshots showing the full account name, date, time, and conversation;
- Original messages, voice recordings, images, videos, and URLs;
- Damaged clothing or property;
- Medical certificates, prescriptions, receipts, and photographs of injuries;
- Psychological or counseling records;
- Names of witnesses;
- Prior reports to teachers or administrators; and
- Attendance records or evidence of missed classes.
Export or back up digital conversations before blocking an account. Avoid editing, cropping, adding captions, or forwarding the material unnecessarily because this can create authenticity and privacy disputes.
3. File a clear written school complaint
Address the complaint to the Learner Formation Officer, school head, principal, or other disciplining authority identified in the school policy.
The complaint should state:
- The names and grade levels of the learners, if known;
- The date, time, and location of each incident;
- Exactly what happened;
- The resulting injury, fear, disruption, or emotional harm;
- Previous reports and the school’s response;
- The names of witnesses;
- The evidence attached; and
- The immediate protective measures requested.
Ask for a dated receiving copy or email acknowledgment. The Revised IRR does not state that an ordinary school complaint must be notarized, although a school may request a particular form or sworn statement during its investigation.
4. Request interim safety measures
Do not wait 30 days for the final decision before requesting protection. Depending on the facts, reasonable measures may include:
- Separate seating or class schedules;
- Increased supervision;
- Safe arrival and dismissal arrangements;
- A no-contact directive;
- Monitoring of school transport or common areas;
- Preservation of CCTV footage;
- Temporary limits on online school platforms; or
- Counseling and psychological support.
Interim measures should protect the victim without unfairly treating the victim as the problem. Forcing the victim to transfer classes or leave the school should not be the school’s only proposed solution.
5. Monitor the 30-day resolution period
Follow up in writing if there is no meaningful investigation. Ask for:
- The name of the assigned investigator or Learner Formation Officer;
- Confirmation that the evidence was received;
- The safety measures implemented;
- The expected decision date; and
- A written copy of the result.
The identities of minors may remain confidential, but confidentiality does not justify refusing to tell a parent whether the complaint was investigated or whether protective action was taken.
6. Appeal promptly
An appeal generally must be filed within ten days from receipt of the decision. Attach:
- The complaint;
- The school’s written decision;
- Evidence of the date it was received;
- The evidence previously submitted;
- A concise explanation of the factual or procedural errors; and
- The specific relief requested.
Appeals from school decisions proceed through the appropriate DepEd Division, Regional, and Central Office channels under the revised rules.
7. Use external remedies when appropriate
A serious incident may also be reported to:
- The PNP Women and Children Protection Desk;
- The city or provincial prosecutor;
- The Local Council for the Protection of Children;
- The city or municipal social welfare and development office;
- The National Bureau of Investigation for appropriate cybercrime matters; or
- Another agency with jurisdiction over the specific offense.
Not every criminal complaint must begin at the barangay. Barangay conciliation rules depend on the offense, possible penalty, residences of the parties, and statutory exceptions. Emergencies, serious violence, child abuse, and incidents requiring immediate protection should be brought directly to the proper police, medical, social welfare, or prosecutorial authority.
Useful Documents to Prepare
| Document | Why it matters |
|---|---|
| Written chronology | Helps investigators understand the sequence and pattern |
| School complaint and receiving copy | Proves when the 30-day period began |
| Screenshots and exported chats | Supports cyberbullying allegations |
| Medical or medico-legal certificate | Establishes the nature and duration of injuries |
| Psychological evaluation or counseling notes | Documents emotional and psychological effects |
| Receipts | Supports claims for actual damages |
| Witness statements | Corroborates events not captured electronically |
| School handbook and anti-bullying policy | Identifies prohibited acts, procedures, and possible sanctions |
| Birth certificate or other proof of age | Important when juvenile justice rules may apply |
| Police blotter or incident report | Records a report made to law enforcement |
| Authorization or SPA | May be required when a parent abroad appoints someone to act formally on the child’s behalf |
A foreign parent or foreign student receives the same protection under the school rules and Philippine law. For a parent living abroad, schools commonly accept initial reports by email, but a signed authorization may be requested before a local representative obtains confidential records or participates in formal proceedings. When a special power of attorney executed abroad will be used in a Philippine government or court proceeding, the receiving office may require proper notarization and apostille or consular formalities.
Common Mistakes That Weaken Bullying Complaints
Waiting for the conduct to happen again
A single severe incident may qualify. Do not delay reporting a serious assault, threat, or humiliating online publication merely because it was the “first time.”
Reporting only verbally
A hallway conversation with a teacher is difficult to prove later. Follow up with a dated email or letter summarizing what was reported and what action was promised.
Deleting messages after taking one screenshot
One screenshot may omit context, account details, or timestamps. Preserve the original conversation and backup files.
Posting the accusation publicly
Publicly naming minors can harm the victim, prejudice the investigation, expose private data, and create separate defamation or privacy disputes.
Assuming counseling is the only permissible response
Counseling and rehabilitation are important, particularly for children, but the revised rules make clear that supportive intervention does not replace appropriate discipline.
Allowing an unsafe confrontation
Parents may request separate interviews when a face-to-face meeting would frighten, pressure, or retraumatize the child. A victim should not be forced to apologize simply to create the appearance that the dispute has been “settled.”
Missing the ten-day appeal period
Do not wait for an informal promise that the school will reconsider. Protect the deadline by filing the proper appeal within ten days from receipt of the written decision.
Frequently Asked Questions
Can a student be expelled for bullying in the Philippines?
Expulsion is not an automatic penalty under RA 10627. The available sanction depends on the school handbook, the seriousness and frequency of the conduct, applicable DepEd rules, and compliance with due process. Severe violence, repeated serious bullying, or conduct endangering other learners may justify a much stronger response than a minor first-level incident.
Can a first-time bullying incident be punished?
Yes. A single incident may qualify when it is severe. Repetition is only one possible basis for classifying conduct as bullying.
Can parents file a criminal case against a student bully?
A complaint may be filed when the conduct constitutes a crime. The child’s age and discernment determine whether criminal liability can attach under RA 9344. School discipline and civil liability may still apply even when the child is exempt from criminal liability.
Can the parents of the bully be sued?
Potentially. Parents may have civil liability under the Family Code and other laws, depending on who had supervision or custody and whether the required diligence was exercised. Parents are not automatically criminally liable for their child’s act.
Does cyberbullying have to happen during school hours?
No. Off-campus or after-hours online conduct may fall under the school’s policy when it creates a hostile environment at school, infringes the victim’s school rights, or materially disrupts education.
Can a student make an anonymous bullying report?
Yes. Schools must provide mechanisms for anonymous reporting. However, no disciplinary sanction should be based solely on an anonymous accusation without supporting evidence.
What can parents do if the school ignores the complaint?
Request a written response, preserve proof of filing, and elevate the matter to the Schools Division Office. Serious criminal, medical, or child-protection concerns may also be reported directly to the police, prosecutor, social welfare office, or another proper agency.
Does the Anti-Bullying Act apply to private and international schools?
Yes. The revised rules cover public and private basic education schools and DepEd-authorized or supervised international schools. Philippine Schools Overseas and Community Learning Centers are also included within the revised coverage.
What if a teacher is the person bullying or humiliating the child?
Teacher-to-student misconduct is ordinarily handled under child-protection, administrative, employment, civil, and criminal laws rather than solely as learner-to-learner bullying. Report it to the school head or Child Protection Committee, or directly to the Schools Division Office if the school head is involved.
Can the victim transfer schools while the case is pending?
A transfer may be possible, but it should not be treated as a substitute for investigation or accountability. Keep copies of the complaint, evidence, school decision, medical records, and transfer documents. The original school remains responsible for handling and reporting incidents within its jurisdiction.
Key Takeaways
- RA 10627 does not impose one fixed penalty for every bullying incident.
- School consequences depend on the school policy, severity, repetition, evidence, intervention needs, and due process.
- A single severe act can qualify as bullying.
- The school should generally resolve a formal complaint within 30 days, and an appeal ordinarily must be filed within ten days from receipt of the decision.
- Criminal charges may arise when the conduct constitutes physical injuries, threats, defamation, child abuse, cybercrime, sexual harassment, or another offense.
- Children aged 15 or younger are exempt from criminal liability but may undergo intervention, and civil liability may remain.
- Schools, administrators, teachers, parents, and other persons may face civil liability depending on custody, supervision, negligence, and the circumstances.
- Public school personnel may face administrative proceedings, while noncompliant private schools may face sanctions extending to suspension or revocation of their permit or recognition.
- Preserve evidence, file in writing, request immediate safety measures, and avoid publicly identifying the children involved.
[2]: https://lawphil.net/judjuris/juri2019/mar2019/pdf/gr_222974_2019.pdf?utm_source=chatgpt.com "[PDF] ~upreme <!Court data-preserve-html-node="true" MAR 2 O 2019 - Lawphil" [3]: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/65901?utm_source=chatgpt.com "G.R. No. 240012 - MERIAM M. URMAZA, PETITIONER, VS. ..." [4]: https://lawphil.net/statutes/repacts/ra1992/ra_7610_1992.html?utm_source=chatgpt.com "R.A. 7610 - Lawphil" [5]: https://lawphil.net/statutes/repacts/ra2006/ra_9344_2006.html "R.A. 9344" [6]: https://lawphil.net/executive/execord/eo1987/eo_209_1987.html "Executive Order No. 209" [7]: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/69819 "G.R. No. 267331 - MOTHER GOOSE SPECIAL SCHOOL SYSTEM, INC., PETITIONER, VS. SPOUSES SAMUEL PALAGANAS AND VILLA PALAGANAS, RESPONDENTS.D E C I S I O N - Supreme Court E-Library"