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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July 14, 2026
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Pedrito Garma y Miguel v. People, G.R. No. 248317 (March 16, 2022)
Supreme Court decision
Santiago Paera v. People, G.R. No. 181626 (May 30, 2011)
Supreme Court decision
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
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.