NBI Regional Director Atty. Jeremy C. Lotoc cited Garma while explaining the investigation's view of the intent element of grave threats; Atty. Mark C. Vinluan then asked about the citation in Lotoc's affidavit of investigation.
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Research record
July 14, 2026
Formal sources named during the July 14 sitting, linked where a primary official copy was located.
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Pedrito Garma y Miguel v. People, G.R. No. 248317 (March 16, 2022)
Supreme Court decision
Open source ↗Santiago Paera v. People, G.R. No. 181626 (May 30, 2011)
Supreme Court decision
Open source ↗Atty. Amando Virgil D. Ligutan referred to Paera while responding to Senator-Judge Pia Cayetano's question about whether a private complainant must execute an affidavit in a grave-threats case.
Revised Rules on Evidence (Rules 128–134), Rule 130, Section 53
Rule of court
Open source ↗Atty. Amando Virgil D. Ligutan invoked Rule 130, Section 53 in seeking NBI Regional Director Atty. Jeremy C. Lotoc's impressions of the Vice President's emotional state; Atty. Mark C. Vinluan objected and the presiding officer overruled the objection.