LEGAL CITATION

Legal Research
Atty. Patricia Gail Cayco-Magbanua
Arellano University School of Law
• Citation is particularly essential in the legal profession because legal
analyses depend on the examination of binding rules and norms.
• It is imperative to determine with precision what rules and norms are.
• Citation facilitates this determination.
• A citation refers to the sentence or clause
immediately preceding it.
• Citation serves at least three purposes.
• First, it provides support or contrast
to assertions.
• Second, it allows proper attribution
of non-original input.
• Third, it helps readers identify
sources of further study or research.
PRIMARY SOURCES
 JURISPRUDENCE
Decisions of the Supreme Court may be cited by indicating the following:
• G.R. Number – This refers to the number issued to identify the case;
• Title – This refers to the parties involved in the controversy;
• Date of Promulgation – This refers to the official date the decision is given
out;
• Publication – This refers to the name of the publication that reports out the
decision. This could be SCRA, the Official Gazette, or the Philippine Reports.
 Case Name

General Rule – Cite cases by giving the surname of the parties, the volume,
title, and page of reports, and the year of promulgation in parenthesis.
Abbreviate versus as v. When used in the text, italicize the title of the case, and
place the source or citation in the footnote.
Ariaga v. Javellana, 92 Phil. 330 (1952)
 Exceptions

• Cite Islamic and Chinese names in full. As to those with Christian first
names, follow the general rule
• Lim Sian Tek v. Ladislas (not Lim v. Ladislao)
• Wong v. Dizon (not Joseph Wong vs. Dizon)
• Una Kibad vs. Commission on Elections (not Kibad vs. Commission on Elections)
• Cite compound names in full
• People v. De la Pena (not People vs. Pena de la)
• Abad Santos vs. Commissioner of Internal Revenue (not Santos vs. Commissioner of
Internal Revenue)
• Galeos-Valdehuesa vs. Republic (not Valdehuesa v. Republic)
• Always cite names of corporations, associations, business firms and
partnerships in full. Words forming part of such names may be abbreviated,
except the first word.
• Mata vs. Rita Legarda, Inc.
• Allie Workers Ass’n of the Phil. Vs. Republic Trading Corp.
• Cite cases involving the Government of the Philippines and criminal cases as
follows:
• Republic v. Lim
• People v. Santos
Cite cases involving public officers as follows:
• Where the person is named in his official capacity, give the name of the person only
• City of Manila v. Estrada (not City of Manila v. Estrada, in his capacity as Civil Service
Commissioner)
• When the office is named, give the complete name of the office.
• Commissioner of Internal Revenue v. Sabungan Bagong Silangan
Always cite Municipality of ____, City of ______, or Province of _____ as they
appear in the decisions.
• City of Taguig v. Ledesma
• Municipality of Pateros v. Cayetano
• Province of Rizal v. De Leon
Cite case names beginning with procedural terms like Ex parte (“from/out of
the party of”; “on behalf of”), Ex rel (“upon being related” or “upon
information”), and in re as they appear in the decisions. Use In re (“in the legal
case of”; “with regard to”) instead of In the matter of.
• In Re Ricardo Dalisay, Ex Rel. Cebu City Chapter of the Integrated Bar of the
Philippines.
• An ex parte decision is one decided by a judge without requiring all of the
parties to the dispute to be present
Case Reports
 SUPREME COURT DECISIONS

Philippine Reports
• Cite as: volume Phil. Page (year)
• Diaz v. Estera 78 Phil. 637 (1947
• Official Gazette
Cite G.R. docket no. and date of promulgation before the O.G. citation
Cite as G.R. No. _____, date promulgated, volume, O.G. page (month and year of
issue)
• Espiritu v. Rivera, G.R. No. 17092, September 30, 1963, 62 O.G. 7226 (Oct. 1966)
• General Register (G.R.)
• Cite as G.R. No. _____, date of promulgation
• G.R. No. 145612,Sept. 11, 1989
• Supreme Court Reports Annotated (SCRA)
• Cite as Case Name, volume SCRA page
• People v. Go, 123 SCRA 456
• Other acceptable means
• Case name, G.R. No.
• Case name, [date promulgated]
• Case name, G.R. No. SCRA citation [year]
 Court of Appeals

Cite as C.A.-G.R. No. ______-R or SP, date of promulgation

• Caliboso v. Bueno, C.A. G.R. No. 20401-SP, April 8, 1960
 Other Courts

• There is no printed compilation for Sandiganbayan, Court of Tax Appeals

and lower court decisions. The full text of important decisions can be found
in the internet
Sandiganbayan Decisions
• Cite as: Case name, Sandiganbayan Crim. Case No. _______, date of promulgation
• People vs. Estrada, Sandiganbayan Crim. Case No. 001, March 16, 2001
Court of Tax Appeals Decisions
• Cite as: Case name, CTA Case No. ______, date of promulgation
• Abad v. Commissioner of Internal Revenue, CTA Case No. 12345, April 1, 2020
Regional Trial Court Decisions
• Cite as RTC (Place & Branch no.) Crim. Case No., Civil Case No. or SP No. R-________, date
of promulgation
• People vs. Dalisay, RTC (Taguig City, Br. 123), Crim. Case No. 56799, May 15, 2020
Metropolitan Trial Court Decisions
• Cite as MeTC (Place & Branch no.) Crim. Case No. or Civil Case No. ________, date of
promulgation
• Pilipinas Shell Inc. v. Barrameda, MeTc (Manila Br. 10), Civil Case No. 12345, July 15, 1993
Municipal and Municipal Circuit Trial Courts Decisions
• Cite as MCTC or MTC (Place & Branch no.) Crim. Case No. or Civil Case No. ________, date
of promulgation
• People v. Go, MCTC (San Juan City, Branch 15), Crim. Case No. 56743, March 15,2017
Shari’ah District and Circuit Courts
• Cite as: Shari’a Dist./Circ. Ct. (place), Case No., date of promulgation
• Al-awadhi v. Alawi, Shari’ah Dist. Ct. (Marawi City), Sp. Proc. No. 011-97, September 15,
2008
 Administrative Decisions

• Cite by the name of the agency (when there is an abbreviated form, use
abbreviation or acronym), case number, and date of promulgation
 STATUTORY MATERIALS
• Laws may be cited in a number of ways. By number, by its official title, by its short
title, or by its popular title.
• Number – This refers to the number given to the statute when it was signed into
law. Examples are Republic Act No. 9165; R.A. No. 9262; B.P. Blg. 22.
• Official Title – The official nomenclature of the law is what is indicated in its Title.
Examples are: “The Comprehensive Dangerous Drugs Act of 2002”, “The Anti-
Money Laundering Act of 2001”, and many more.
• Short Title – This is usually given under the very first section of the law itself. One
has to understand that the official name of the law is rather lengthy and the law
itself provides for it short title for ease of reference.
• Popular Title – There are times when a law is remembered by its author rather
than by its official name or number. Examples are Recto Law and Maceda Law.
 Constitution

• The Constitution is cited by reference to the article, section, and paragraph.

When the constitution is no longer in force, put the year in parenthesis.
Const., Art. VII
• Const. (1935), Art. III, Sec. 1, Par. (3)
 Republic Acts

• Cite as Rep. Act No. _______ (year of effectivity)

• Full Title, [Short title], statute no., (year of effectivity)
• Short Title, pinpoint citation
• An Act Defining Gender-Based Sexual Harassment in Streets, Public Spaces,
Online, Workplaces, and Educational or Training Institutions, Providing Protective
Measures and Prescribing Penalties Therefor [Safe Spaces Act], Republic Act. No.
11313 (2019)
• Safe Spaces Act, Sec. 1
 Codes
As a general rule, cite the name of the particular code, article number or
section number without any indication of date. But when the code is no longer
in force or has been subsequently revised, put the year of effectivity in the
parenthesis.
• Revised Corporation Code, Sec. 26
• The Family Code of the Philippines [FAMILY CODE], Executive Order No. 209, art. 68
(1987)
 Congress Bills, Resolutions, and Committee
Reports

Cite bills, resolutions, or committee reports in the following manner: House

where it originated, serial report number, the Congress, session, and year in
parenthesis. For committee reports, give the name of the committee.
• H. Res. 1, 16th Cong., 1st Sess. (2015)
• Comm. On Education, H. Rept. 15, 15th Cong., 1st Sess. (2014)
 Treaties and International Agreements

• Cite the name of the agreement and the exact date of signature by the
Philippines. The effectivity date or date of entry into force may be given
parenthetically at the end of the citation. Shorten the title of the cited
agreement by substituting “with” for “Between the Republic of the
Philippines and”. Give the source of the text of the treaty.
• Philippines Extradition Treaty with the United States, signed November 13,
1994. 8 PTS 978.
 Presidential Acts

• Executive Order – Exec. Order No. _____ (year)

• Proclamations – Proc. No. ______ (year)
• Administrative Orders – Adm. Order No. ____ (year)
 Administrative Rules and Regulations

They are cited by the abbreviation of the name of each agency, followed by
the name of the specific rule or regulation. It is important to indicate the year
in parenthesis for each year, the number of the rules and regulations start with
the first number (No.1).
• Administrative Order No. 1 promulgated by the Department of Energy on January 5,
2006
• Cited as: DOE Adm. Order No. 1 (2006 )
 Ordinances

Cite provincial and city ordinances in the following manner: Name of the
municipal or provincial unit, serial number, and date of adoption.
• Manila Ordinance 6120, January 15 ,2021
 Court Rules

Rules of Court is cited as a code.

• Rules of Court, Rule 1, Sec.2
• Rules on Evidence, Rule 128, Sec. 1
SECNDARY SOURCES
Books
Generally cited as author (initial of first name and surname), title of book, page, section or
paragraph, edition and date in parenthesis.
E. Rabuya, The Law on Persons and Family Relations (2nd ed., 2012)
Collection of Essays or Articles
If all are by the same author, his name and the title of the book are printed in
large and small capitals and the title in italics. If essays are by various authors, their
names are printed in regular roman.
Periodical Articles and Journal Articles
Materials published in periodical which are paged consecutively throughout a
volume are cited by the initial of first name followed by the surname of the author in
regular roman, title of the article in italics, volume, name of periodical in large and
small capitals, page and year in parenthesis.
O.C. Cajucom, Plagiarism with the Legal Profession and the Academe, 55 Ateneo L.J. 787 (2010)
Letters, Speeches, and Interviews
Indicate the name of the letter written and his correspondent and the date the letter
was written.
For interview, cite the person interviews, his designation, place of interview, and date.
For speeches with no title, cite the speaker, occasion, place, and date. For speeches with
title, follow the rule on periodical articles. If found in printed work, include the citation to it.

Letter of Apolinario Mabini to Emilio Jacinto, December 17, 1898 in LETTERS OF

APOLINARIO MABINI 81 (1955)
Interview with Manuel Roura, Chief of the Polygraph Division, National Bureau of
Investigation, Manila, February 20, 2021
J.N. Bellosillo, Challenges for the Judiciary in the 21st Century (8th National Convention –
Seminar of the Philippine Women Judges Association, Manila Hotel, March 12, 1999) 4 C.T.
Systems J. (June 1999)
Newspapers
• Title of newspapers are printed in regular roman and are cited with the date of issue,
page, and column. A signed article but not a news report is cited by author and title.

Philippine Daily Inquirer, May 21, 2021, p.5, col. 1

A. Cabrera, As Easy as ABC, Business World, April 15, 2015, p. 10, col. 2
 Internet Sources

• This should only be resorted to if no other rule is applicable to the source intended
to be cited. This is typically used to cite sources in PDF and sources that were
generated by owners or managers of web pages or domains.
Cited as Author or Organization, Title (description of material, if needed), pinpoint citation if
possible, available at internet address (last accessed date) [permanent link if possible]
Jose Ramon T. Villarin, S.J. et. al., In the Eye of the Perfect Storm: What the Philippines Should Do About Climate
Change (S.C. Johnson Professional Lecture Working Paper, July 8, 2008) at 70-73, available at
http://citeseerx.ist.psu.edu/viewdoc/download?doi-10.1.1.504.2436&rep=rep1&type=pdf (last accessed May 22,
20200 [http://perma.cc/BZ8D-PP47]
 Magazines and News Articles Online

• Cite articles only from the official domain name of their respective
magazine and news publications.
• Cite as Author, Title, Abbreviated Name of Magazine or News Agency, date of
publication or report, available at internet address (last accessed date) [permanent link
if possible]
Chiara Zambrano, Chinese Vessel Blocks Pinoy Fishermen in Scarborough Shoal, ABS-
CBN News, July 14, 2016, available at http://news-abs-
cbn.com/news/07/14/16/chinese-vessel-blocks-pinoy-fishermen-in-scarborough-s
hoal (last accessed Nov. 5, 2019)[http://perma.cc/R44M-3RP8]
 Social Media

• This applies to every internet medium which allows end-users, not the owners or
managers of web pages, to generate, participate, or share content on the internet
(such as social networking and video-sharing sites), and even comments on a
general internet source or magazine or news article online.
• Cite as Author or Content Creator, username, kind or description of content, title of
cited content, platform or website, date of posting: time of posting, available at
internet address (last accessed date) [permanent link if available]
• Barack H. Obama, @POTUS44, Tweet, Twitter, Aug. 20, 2016: 9:28 A.M., available
at http://twitter.com/POTUS44/status/770297035274584068 (last accessed Sept,
26, 2019) [http://perma.cc/Y4FP-GYML]
• Ateneo Law Journal, Status Update, Facebook, April 22, 2016: 2:23 p.m., available
at http://www.facebook.com/ateneolawjournal/posts/816777568478093 (last
accessed June 22, 2019) [http://perma.cc/4TF5-6B6T]
• Arete Ateneo, Video, Magisterial Lectures: Roberto Conrado Guevara, Ph.D, - On
Journeys & Crossroads: Reflections on Exodus, Youtube, Aug. 11, 2020, available at
http://www.youtube.com/watch?v=grVahohecPQ (last accessed Aug. 27, 2020)
 E-mails, Letters, and Other Correspondences

• Type of correspondence From Author, title or institutional affiliation if

needed, to addressee, title or institutional affiliation if needed (date) (on file
with physical repository)
E-mail from Domingo Navarro, Dean, Arellano University School of Law, to all Students of
Arellano University School of Law (May 15, 2021) (on file with author)
Repeating Citations
• Supra (above)
Use the word “supra” to identify a case or publication previously cited on the same or
preceding page. It is not used if more than one page intervenes between the citations. It
can be used where a reference to a complete footnote is made. It is used when referring
to the same source in a footnote that is not immediately above. In such case, Id. must
instead be used.
• People v. Dela Cruz, supra at 27
• See note 15, supra
Ibid.
• Where the reference to a citation is immediately repeated with the same volume and
page number, the successive designation should read only: Ibid. It is always italicized
 Id. (Idem, “the same”)
• It is used when citing exactly all the authorities in the immediately preceding
authority within the same footnote or in the immediately preceding footnote. It is used in
citation sentences and clauses for any kind of authority.
 Sources

• Legal Research by Atty. David Robert Aquino

• Philippine Manual of Legal Citations by Myrna Feliciano
• Philippine Legal Research by Milagros Santos-Ong
• Ateneo Law Journal Legal Citation Guide