Case Notes pertain to a documentation of the entire counseling service availed by the learner. It includes an accurate account of what went on in a session (also known as a progress note), and it aims to make a record of the counseling or clinical management of the entire case (ACA, 2018). By creating an accurate and complete documentation of counseling service, the Guidance Counselor ensures that counseling sessions are beneficial to the counselees (learners), conforms to their ethical obligation to provide the needed service, and ensures a legally defensible record of counseling practice.