REPEATING CITATIONS AND SIGNALS TO SUPPORT STATEMENTS MADE IN TEXT

A. “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 should not be used to refer to cases, statutes or
constitutions except in extraordinary circumstances, such as when the name of the authority is extremely long. It
is always italicized. (Underline, in case of typewritten work.)

1. If the case or other publication has been previously cited on the same footnote, a dictum or another
reference may be indicated.

Example:
Lao Ichong, v. Hernandez, supra at 27
N. Gonzales, supra at 188

2. Use “supra” where reference to a complete footnote is made. However, it should not be used when the
full citation is too far removed form the shortened citation. In which case, the full citation should be
repeated.

Example:
See note 15, supra

B. “infra” (below)
Seldom used for citation cross-reference because it is considered best to put the full citation first. However, when
it is used for this purpose, the rules are the same as those indicated for “supra” cross-reference.

C. “Ibid” (the same reference)

Where a reference to a citation is immediately repeated with the same volume and page number, the successive
designation should read only: Ibid. It always italicized and not to be used to cite primary sources.

Example:
(Ibid., pp. 24-25)

D. “Id”
It is used in citation sentences and clauses for any kind of authority. In briefs, legal memoranda and similar
materials, use “id.” when citing to the immediately preceding authority. In periodical article footnotes, use “id.”
when citing to the immediately preceding authority within the same footnote when the preceding footnote contains
only one authority. If the first citation is to only part of an authority, do not use ‘Id.’ for a subsequent citation to the
entire authority. If the successive citation is to different page of the same case or publication, use Id. And indicate
page. It is also italicized and not to be used to cite primary sources.

Examples:
V. SINCO, PHILIPPINE POLITICAL LAW, 551 (11TH ED., 1962) Id., at 555.

E. “Op. cit.” (work cited) and “Op. cit. supra”

To avoid repeating titles of books and periodicals articles, use op. cit. supra, preceded by the author’s name and
followed by the earlier footnote reference and page number. For treatise or scholarly writings, the word supra is
generally omitted.

Examples:
F. CAPISTRANO, op. cit. supra note 15 at 198
V. SINCO, op. cit.., note 5 at 133

F.
If a source is cited several times, use the complete citation of the source once and thereafter, abbreviate the
citation either to the first words of the title of the publication or to the commonly used designation. Such abbreviation
must be enclosed in brackets in the first citation and must be used consistently thereafter.

Example:
INTERNATIONAL LABOUR OFFICE, SHARING IN DEVELOPMENT ; A PROGRAMME OF EMPLOYMENT,
EQUITY AND GROWTH FOR THE PHILIPPINES 304 [1974] [hereinafter referred to as the RANIS REPORT].

G.
Signals are used to indicate supporting, contrary and other positions relating to the propositions of law or fact. It
indicates the distinctions and gradations of authorities and arguments.

Kinds of Signals:
1. Signals that Indicate Support (positive signals)

1.1 E.g., - The cited authority is one of several examples that could be given in support of the proposition
Example:
E.g., Harvey v. Defensor Santiago, 162 SCRA 840
 1.2 Accord – Accord is used to introduce a second authority or line of authorities after one authority has been
cited in direct support of the statement made.
Example:
Election is expression of choice by voters of body politic. (Javellana v. The Executive Secretary, 50 SCRA
30. Accord. Ginsburg v. Giles, 72 S.W. 2d 438)

1.3 See – The cited authority supports the proposition for which it is cited. However, the statement is not made
directly in the cited authority but logically follows from it.
Example:
The disciplinary authority… See e.g., Zaldivar v. Gonzales, 166 SCRA 316

1.4 See also – The cited authority constitutes additional material in support of the cited proposition, which cannot
be included with a preceding group of authorities because of some variation fro the original proposition.
Example:
…(People v. Bacani, 181 SCRA 393. See also People v. Ayo, 305 SCRA 543)

1.5 Cf. – It is derived from the latin conferre, to compare. It is used whenever the cited authority supports a
different proposition from the one made in text, but the different proposition is sufficiently analogous to lend
support to the statement made in text.
Example:
…(Javellana v. Executive Secretary, 50 SCRA 30, Cf. Rothfels v. Southworth, 356 P. 2d 612)

2. Signals that indicate contradiction ( negative signal)

2.1 Contra – This is used when the cited authority directly contradicts a statement made in the text. No comma is
used after this signal.

2.2 But see – This is used when the cited authority directly contradicts a stated proposition.

2.3 But cf. – The cited authority supports a proposition analogous to the opposite of the position stated in the
text. Use of an explanatory parenthetical is strongly recommended.