The case stemmed from a complaint filed by a petitioner who was facing two counts of violation of the Batas Pambansa Blg. 22 before a trial court while the estafa complaint against her was dismissed. As it lifted the Precautionary Hold Departure Order (PHDO) issued against an individual, the Supreme Court (SC) stressed that PHDOs may only be issued for crimes with a minimum penalty of at least six years and one day of imprisonment, or when the respondent is a foreigner, regardless of the penalty. 22 before a trial court while the estafa complaint against her was dismissed. The regional trial court granted the issuance of a PHDO against her and later denied her motion for reconsideration.