Professional Documents
Culture Documents
Over and above all these, the newspaper must be available to the public in
general, and not just to a select few chosen by the publisher. 2 Further, the newspaper
need not have the largest circulation, so long as it is of general circulation.3
In the case of Metropolitan Bank and Trust Company, Inc. v. Peafiel, 4 the
Supreme Court has succinctly characterized what it takes to be a newspaper of general
circulation, to wit:
The Office of the Court Administrator (OCA), or any governmental office for that
matter, does not have an official list of newspapers of general circulation wherein legal
or judicial notices may be published. It is the Executive Judge of a Regional Trial Court
(RTC) who has the power to accredit newspapers or periodicals that may publish such
legal or judicial notices.
1 Alvarez v. People of the Philippines, G.R. No. 192591, June 29, 2011; Perez v. Perez,
G.R. No. 143768, March 28, 2005.
2 Id.
3 Banta v. Pacheco, G.R. No. L-48133, December 31, 1942
4 G.R. No. 173976, February 27, 2009
5 Section 1, A.M. No. 01-1-07-SC, Guidelines in the Accreditation of Newspapers and
Periodicals and in the Distribution of Legal Notices and Advertisements for Publication,
16 October 2001.
circulation in a particular province or city.6 According to the OCA, the RTCs in each
locality have a record of these accredited newspapers and periodicals.