Challenging SEC Decisions: “No One is Above the Law in Regulatory Actions”

No one is above the law, and this principle applies equally to individuals, corporations, and government agencies alike. Even quasi-judicial agencies like the Securities and Exchange Commission (SEC) can be subject to scrutiny and challenge when their decisions appear to be based on incomplete or unverified information. In the case of New Seataoo Corporation, the SEC issued a Revocation Order based on allegations from anonymous sources without first conducting thorough investigations or obtaining firsthand evidence. This decision, made without hearing the side of the company or legitimate sellers, raises concerns about the fairness and due process in regulatory actions.

The principle of fairness demands that all parties involved in a dispute have the opportunity to present their case before a decision is made. In this instance, New Seataoo Corporation was not given the chance to defend itself against the accusations that led to the SEC’s Revocation Order. The absence of a comprehensive investigation, coupled with the reliance on unverified reports, suggests that the SEC may have acted prematurely or without sufficient basis. This highlights the importance of due diligence and the need for regulatory bodies to ensure that their actions are supported by concrete evidence and fair procedures.

Decisions made by government agencies, including the SEC, are not infallible and can be reversed or set aside if found to be flawed. The case of New Seataoo Corporation serves as a reminder that even the highest authorities are accountable for their actions and must adhere to the principles of justice and fairness. When a decision is based on incomplete information or procedural missteps, it is not only subject to challenge but also reversible upon review by the appropriate judicial or appellate bodies. This underscores the essential role of the legal system in safeguarding the rights of individuals and corporations against potential overreach by regulatory agencies.

Nakatanggap ng Report or Letter ang SEC from Anti-Scam Advocate

Noong 2023 ay nakatanggang ng letter ang Securities and Exchange Commission ng sulat na hindi naman ipinakita at sinabi na ang sulat ay notaryado, an ordinary letter coming from the Anti-Scam Advocate.

Ang sulat ay mula sa grupo ni Ciemny Aniol na ang layunin ay ipaalam sa Securities and Exchange Commission ang mga activities na ginagawa ng Seataoo Information Technology OPC na kung ating iintindihin ay inirereport ng kanyang grupo na ang SEATAOO do OFFER, SELL, SOLICIT Securities in the From of Investment contracts as provided for the Securities Regulation Code.

MY OPINION

Base sa sagot ng Director na si Atty. Oliver O. Leonardo, ang mga sinubmit na mga patunay o proof ng grupo ng Anti-Scam Advocate ay mga SCREEN GRAB o kinuhang mga screenshot sa iba’t ibang mga Social Media Platform.

Legal naman ang mga SCREENSHOTS at maaaring gamiting ebidensya, subalit ang mga katulad na ebidensya ay may mga guidelines na dapat sundin.

Bagamat mandated ang SEC to Investigate and File Cases  against erring entities including its people for  for violation of the Securities Regulation Code, Revised Regulation Code, and Violation of the SEC Rules and Regulation…..

LAGING nakalagay sa kanilang mga sulat or response…. WE ENCOURAGE YOU TO FILE A COMPLAINT-AFFIDAVIT against Seataoo Technology OPC containing a complete narration of the of the incidents surrounding your investment and attaching thereto the affidavits of your witnesses.

  1. Valid and Verified ba ang mga Screenshots or Screengrabs?
  2. Ang grupo ba ng Anti-Scam Advocate ay may FORMAL AFFIDAVIT-COMPLAINT?
  3. May sapat bang mga ebidensya ang Anti-Scam Advocate?
  4. My mga witnesses ba ang Anti-Scam Advocates?

Those are are the questions na kailangang sagutin at ipaliwanag ng Securities and Exchange Commission particular na ng EIPD. Sapagkat lagi nilang sinasabi na para mag-umpisang gumalaw ang kanilang mandato, kinakailangang mayroong formal complaint. BUT hindi malinaw sa kanilang sagot at hindi binanggit ng SEC kung formal ba ang reports na kanilang natanggap mula sa Anti-Scam Advocate.

Bilang Seller, noong mga nakaraang buwan o linggo ay nagpapadala ako ng email, ng sulat na hindi naman formal kaya hindi ako nakakakuha sa kanila ng mga sagot sa aking katanungan. Ibig sabihin, para mapanigan at masagot ang aking mga katanungan, dapat ay mag-file muna ako ng FORMAL COMPLAINT.

Noong nag-file ako ng FORMAL COMPLAINT, ay hindi na ako nakatanggap ng kasagutan mula sa ahensya. Ano kaya ang itinatago ahensya?

Utilizing Digital Evidence in Legal Complaints in the Philippines

Query: Can I attach screenshots of a group chat where I was bullied as part of a complaint letter?

In the context of the Philippines, the admissibility of digital evidence, including screenshots, is governed under the Rules on Electronic Evidence (A.M. No. 01-7-01-SC). According to these rules, electronic documents such as screenshots are considered as admissible evidence provided they meet certain criteria of authenticity, reliability, and relevance.

Guidelines for Using Screenshots as Evidence:

  1. Authenticity: To be admissible, it must be demonstrable that the electronic document is what it claims to be. This involves confirming that the screenshots have not been altered and originate from the sources they claim to represent.
  2. Reliability: The method of capturing the screenshot must safeguard against alterations or tampering. This includes using software or methods that can provide a timestamp or some form of verification to prove the integrity of the screenshot at the time it was captured.
  3. Relevance: The screenshots must be directly relevant to the case at hand. They should contribute substantively to a fact in issue or dispute within the legal proceedings.
  4. Presentation: Screenshots should be presented in a manner that retains their legibility and clarity when printed or viewed in digital format. This may involve providing supporting documentation that explains the context of the screenshots and their significance to the complaint.

Procedure for Attaching Screenshots to a Complaint Letter:

  • When preparing to file a formal complaint where electronic evidence is involved, including a declaration or an affidavit that describes how the screenshots were obtained and ensuring that all electronic evidence is attached as annexes to the complaint.
  • If you are unsure of the process or the acceptability of your screenshots as evidence, it might be beneficial to consult with a legal professional who can provide guidance on proper procedure and help ensure that your evidence is compiled in a way that will be recognized by the courts.

Considerations for Privacy and Legality:

  • It is crucial to ensure that no privacy laws are violated in the process of obtaining screenshots. Unauthorized access to someone else’s electronic communications without their consent can be illegal under certain circumstances.

Conclusion: Attaching screenshots to a complaint letter can be a powerful tool in proving claims of bullying or other forms of electronic harassment. However, it is essential to ensure that these electronic documents meet the criteria set out by Philippine law to be considered valid evidence in any legal proceedings. Proper handling and presentation of this evidence are crucial to support the integrity and credibility of your case.

Maaari bang mabago or ma-reverse ang Decision ng SEC?

Sa Ramona Favis-Velasco and Eliva L. Yulo vs. Jay Marjorie Roxas Gonzales. SEC En-Banc Case Number 08-19-460 ay na reversed at na set-aside ang naging decision ng SEC.

Onus Probandi

The principle that the burden of proof lies with the accuser, also known as “onus probandi,” is a fundamental concept in legal systems worldwide. This principle ensures fairness in legal proceedings by requiring that the party making an allegation or accusation must prove their claim.

1. Presumption of Innocence

  • Criminal Law: In criminal cases, the accused is presumed innocent until proven guilty. This presumption is a cornerstone of justice systems, particularly in common law countries. It places the burden of proof on the prosecution to establish the defendant’s guilt beyond a reasonable doubt.
  • Civil Law: In civil cases, the burden of proof usually lies with the plaintiff, who must prove their case by a preponderance of the evidence or, in some cases, by clear and convincing evidence.

2. Standard of Proof

  • Criminal Cases: The burden of proof in criminal cases is higher because the consequences of a guilty verdict are severe, including the possibility of imprisonment. The prosecution must prove the defendant’s guilt beyond a reasonable doubt, meaning there is no other reasonable explanation derived from the evidence presented at trial.
  • Civil Cases: In civil matters, the burden of proof is lower. The accuser (plaintiff) must prove their case by a preponderance of the evidence, meaning it is more likely than not that the claim is true. In some situations, a higher standard, such as clear and convincing evidence, may be required.

3. Shifting the Burden of Proof

  • Prima Facie Case: The burden of proof may initially lie with the accuser to present a prima facie case—a case that is sufficiently established by evidence to justify a verdict in their favor if not rebutted by the opposing party. If the accuser meets this burden, the burden may shift to the defendant to provide a defense or refutation.
  • Affirmative Defenses: In some cases, a defendant may raise an affirmative defense, such as self-defense or insanity. When such defenses are invoked, the burden may shift to the defendant to prove the defense by the relevant standard of proof.

4. Legal Provisions and Case Law

  • International Human Rights: The presumption of innocence and the burden of proof on the accuser are recognized under international human rights law, including Article 11 of the Universal Declaration of Human Rights and Article 6 of the European Convention on Human Rights.
  • Case Law: Numerous court rulings have reinforced the principle that the burden of proof lies with the accuser, emphasizing the importance of this principle in ensuring a fair trial.

5. Rationale

  • Fairness: Requiring the accuser to bear the burden of proof prevents individuals from being unjustly accused and punished without sufficient evidence.
  • Prevention of Abuse: This principle protects against the misuse of legal processes by ensuring that the accuser cannot simply make an allegation without having to substantiate it with credible evidence.

Conclusion

The burden of proof lying with the accuser is a fundamental principle designed to protect individuals’ rights and ensure fairness in legal proceedings. It reflects the notion that it is better for the guilty to go free than for the innocent to be wrongly convicted.

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