People v. Bagasala (GR No. L-26182, 31 May 1971)

Facts: At 2 in the morning, five men including Juanito and Tomas Bagasala entered the house of Macario Ongkit and his wife Juliana where Juliana died. The incident was reported by their son. In this case, Juanito Bagasala extrajudicially confessed underoath which in any case, led to their conviction.

Issue: W/N the inadmissibility of Bagasala’s extrajudicial confession may acquit him.

Ruling: NO. Bagasala’s conviction was arrived at not solely because of his admission. His being beaten up while in question, although inadmissible for being contrary to the true meaning of self-incrimination, still lead to a conviction since conviction did not totally rely on the confession.

People v. Ramos (GR No. L-59318, 16 May 1983)

Facts: Malcon Olevere was caught carrying dried marijuana leaves. When he was arrested, he stated that he bought the same from Rogelio Ramos who was also arrested. The constitutional rights of Ramos was read before him however, he only finished Grade VI who may have inadequately understood the same. He was convicted in view of his verbal admissions.

Issue:

W/N the confession of Ramos to the police officers of the commission of the offense charged is admissible as evidence against him.

Ruling:

No. When Ramos’ constitutional rights were read before him, it was not explained to him by the arresting officer despite the fact that he only finished Grade VI. Ramos’ admission was given without understanding the consequences of his acts for being one with insufficient comprehension and given without the attending counsel of the same. Thus, the Supreme Court made Ramos’ admission inadmissible.

People v. Galit (GR No. L-51770, 20 March 1985)

Facts: Francisco Galit was taken by Montalban police who was later on transferred to the hands of National Bureau of Investigation for the killing of Natividad Francisco. During the interrogation with the NBI, Galit was tortured, intimidated and forced to execute extrajudicial confession that he was involved in the said crime.

Issue: W/N the extrajudicial confession of Galit is inadmissible.

Ruling: Yes. The only evidence against the accused is his alleged confession. The alleged confession and the pictures of the supposed re-enactment are inadmissible as evidence because they were obtained in a manner contrary to law.

Association of Small Landowners v. Secretary of Agrarian Reform (GR Nos. 78742, 79310, 79744, and 79777, 14 July 1989)

Facts: The Association of Small Landowners in the Philippines, together with other petitioners assailed the validity of PD 27, EO 228 and 229, and PP 131 for being violative of their constitutional right to equal protection of law. They contend that they have right of retention of rice and corn lands not exceeding 7 hectares.

Issue: W/N the assailed statutes violate the equal protection clause.

Ruling: NO. Petitioners have not shown that they belong to a different class and entitled to a different treatment. The argument that not only landowners but also owners of other properties must be made to share the burden of implementing land reform must be rejected. There is a substantial distinction between these two classes of owners that is clearly visible except to those who will not see.

Ichong vs. Hernandez (101 phil 1155)

Facts: Lao Ichong is a chinese business man in Pasay. In 1954, a law was passed entitling Filipinos the right to engage in the said business. Ichong therefore questions the constitutionality of the said law under the conviction that such violates equal protection clause.

ISSUE: Whether or not a law may invalidate or supersede treaties or generally accepted principles.

HELD: Yes, a law may supersede a treaty or a generally accepted principle. In this case, there is no conflict at all between the raised generally accepted principle and with RA 1180. The equal protection of the law clause “does not demand absolute equality amongst residents; it merely requires that all persons shall be treated alike, under like circumstances and conditions both as to privileges conferred and liabilities enforced”; and, that the equal protection clause “is not infringed by legislation which applies only to those persons falling within a specified class, if it applies alike to all persons within such class, and reasonable grounds exist for making a distinction between those who fall within such class and those who do not.”

People vs cayat

Gr no. L-45987, May 5, 1939

Facts/Issue: Cayat, a native of Baguio, Benguet, Mountain Province, and a member of the non-Christian tribes, was found guilty of violating sections 2 and 3 of Act No. 1639 for having acquired and possessed one bottle of A-1-1 gin, an intoxicating liquor, which is not a native wine. The law made it unlawful for any native of the Philippines who is a member of a non-Christian tribe within the meaning of Act 1397 to buy, receive, have in his possession, or drink any ardent spirits, ale, beer, wine or intoxicating liquors of any kind, other than the so-called native wines and liquors which the members of such tribes have been accustomed to prior to the passage of the law. Cayat challenges the constitutionality of Act 1639 on the grounds that it is discriminatory and denies the equal protection of the laws, violates due process clause, and is an improper exercise of police power.

Issue: W/N Act 1639 is discriminatory and denies the equal protection of the laws.

Held: It is an established principle of constitutional law that the guaranty of the equal protection of the laws is not violated by a legislation based on reasonable classification. (1) must rest on substantial distinctions; (2) must be germane to the purposes of the law; (3) must not be limited to existing conditions only; and (4) must apply equally to all members of the same class. The prohibition enshrined in Act 1397 is designed to insure peace and order in and among non-Christian tribes. It applies equally to all members of the class evident from perusal thereof. That it may be unfair in its operation against a certain number of non-Christians by reason of their degree of culture, is not an argument against the equality of its application.

People v. Austria (GR No. L-55109, 8 April 1991)

Facts: When Tomas Azuela was robbed and stabbed to death, Pablo, Eduardo, Pablo’s son, Jaime de la Torre and Leopoldo Abanilla were accused of robbery with homicide. . On cross-examination, the interrogating officer admitted that he did not apprise both of their rights to remain silent and to counsel as he was merely conducting an informal interview. The trial court convicted Jaime, Pablo, and Eduardo. During the pendency of the appeal, Pablo died of undetermined cause while Jaime died of hypertension in the New Bilibid Prisons Hospital.

Issue: W/N Eduardo’s guilt had been established beyond reasonable doubt.

Ruling: NO. Conviction should be made on the basis of a strong, clear, and compelling evidence. Eduardo’s conviction on an inference based on another inference cannot be maintained. To overcome the presumption of innocence, proof beyond reasonable doubt is needed.

People v. Dramayo (GR No. L-21325, 29 October 1971)

Facts: Pableo Dramayo and Paterno Ecubin were two of the seven suspects in the death of Estelito Nogaliza. The court ruled on their conviction while acquitting the five other suspects on the account of insufficiency of evidence. Dramayo and Ecubin appeal on the ground that since conspiracy was alleged between the seven of them, the two cannot be found guilty while the rest are acquitted.

Issue: W/N Dramayo and Ecubin should be acquitted.

Ruling: NO. It cannot be denied that the credible and competent evidence of record resulted in moral certainty being entertained not only by the trial judge but also by the Supreme Court as to the culpability of the two appellants, Dramayo and Ecubin. The force of the controlling doctrines on presumption of innocence, on the other hand, required that the other three accused be acquitted precisely because, unlike the appellants, the requisite quantum of proof to show guilt beyond reasonable doubt was not present. There is no question as to the other two who testified for the state being likewise no longer subject to any criminal liability.

Guanzon v. De Villa (GR No. 80508, 30 January 1990)

Facts: 41 residents and taxpayers from Metro Manila filed a petition for prohibition with preliminary injunction, maintaining that they have a common or general interest in the preservation of the rule of law, protection of their human rights, and the reign of peace and order in their communities under “Areal Target Zonings” or “Saturation Drives” conducted by the military and police in Metro Manila. According to them, the said saturation drives were conducted in critical areas pinpointed by the military and police as places where the subversives are hiding. The petitioners believe that such are manifestations of human rights abuses

Issue: W/N the saturation drives conducted by the authorities should be enjoined by the courts.

Ruling: NO. The court recognize the fact that violations were actually committed. However, the remedy is not to stop all police actions, including the essential and legitimate ones. Police cannot respond to riots or violent demonstrations if they do not move in sufficient numbers. A show of force is sometimes necessary as long as the rights of people are protected and not violated. A blanket prohibition such as that sought by the petitioners would limit all police actions to one on one confrontations where search warrants and warrants of arrests against specific individuals are easily procured. Limiting the actions of the police will pave way to the rising of anarchy which will be a greater problem.

Villavicencio v. Lukban (GR No. L-14639, 25 March 1919)

Facts: Mayor Justo Lukban of Manila deported 170 prostitutes to Davao after days of confinement in the district by the police. The deportation took place even without the consent of the prostitutes. The governor of Davao had no idea however that the 170women were prostitutes. A petition for habeas corpus was presented to a member of the Supreme Court for all the deported women.

Issue: W/N the women had been restrained of their liberty.

Ruling: YES. The forcible taking of the women from Manila by officials of that city, who handed them over to other parties, who deposited them in a distant region, deprived these women of freedom of locomotion just as effectively as if they had been imprisoned. Placed in Davao without either money or personal belongings, they were prevented from exercising the liberty of going when and where they pleased. The restraint of liberty which began in Manila continued until the aggrieved parties were returned to Manila and released or until they freely and truly waived her right.

Ebralinag v. Division Superintendent of Schools of Cebu (GR No. 95770, 1 March 1993)

Facts: 68 high school and grade school students in Cebu were expelled for not saluting the flag, singing the national anthem, and reciting the patriotic pledge as required by Republic Act No. 1265 and by Department Order No. 8 of the Department of Education, Culture and Sports making the flag ceremony compulsory in all educational institutions because of their personal belief that such is an act of worship to idol which is against their belief.

Issue: W/N school children may be expelled for maintaining a belief contrary to RA 1265 and order of DEP-ED

Ruling: NO. Forcing a small religious group, through the iron hand of the law, to participate in a ceremony that violates their religious beliefs, will hardly be conducive to love of country or respect for duly constituted authorities. Thus, an exemption may be accorded to the Jehovah’s Witnesses with regard to the observance of the flag ceremony out of respect for their religious beliefs. Nevertheless, their right not to participate in the flag ceremony does not give them a right to disrupt such patriotic exercises.

Alejandro Estrada vs. Soledad EscritorA.M. No. P-02-1651June 22, 2006

FACTS:

Soledad Escritor, a member of Jehovah’s witnesses and working as a court interpreter, was the subject of the administrative complaint filed by Estrada on the ground of the commission of immoral act that tarnishes the imae of the court. . Insofar as the congregation is concerned, there is nothing immoral about the conjugal arrangement and they remain members in good standing in the congregation. Escritor appears to be sincere in her religious belief and practice and is not merely using the “Declaration of Pledging Faithfulness” to avoid punishment for immorality

ISSUE: Whether or not Escritor’s religious belief and practice should warrant her claim of religious freedom under Article III, Section 5 of the Constitution.

HELD:

The administrative complaint was dismissed. The OSG categorically concedes that the sincerity and centrality of Escritor’s claimed religious belief and practice are beyond serious doubt. Her request to be exempt from attending the flag ceremony on the ground of the Jehovah’s Witnesses contrary belief and practice was duly noted. The OSG failed to demonstrate “the gravest abuses, endangering paramount interests” which could limit or override Escritor’s fundamental right to religious freedom.

Southern Hemisphere Engagement Network, Inc. v. Anti-Terrorism Council [copied from the internet as the case is tooooooooooooooooooo long. )

632 SCRA 146 October 5, 2010

FACTS:

Petitioners question the constitutionality of RA 9372, “An Act to Secure the State and Protect our People from Terrorism,” aka Human Security Act of 2007. on the basis of being suspected “communist fronts” by the government, whereas individual petitioners invoke the “transcendental importance” doctrine and their status as citizens and taxpayers. Petitioners claim that RA 9372 is vague and broad, in that terms like “widespread and extraordinary fear and panic among the populace” and “coerce the government to give in to an unlawful demand” are nebulous, leaving law enforcement agencies with no standard to measure the prohibited acts.

ISSUES:

1. WON petitioners can invoke the “transcendental importance” doctrine.

2. WON petitioners can be conferred locus standi as they are taxpayers and citizens.

3. WON RA 9372 is vague and broad in defining the crime of terrorism NO.

HELD AND RATIO:

1. No. In Kilosbayan v. Guingona, to invoke the transcendental doctrine, the following are the determinants:

a. The character of the funds or other assets involved in the case

b. The presence of a clear case of disregard of a constitutional or statutory prohibition by the public respondent agency or instrumentality of the government;

c. The lack of any other party with a more direct and specific interest in the questions being raised

In the case at bar, there are other parties not before the Court with direct and specific interests in the questions being raised.

2. No. Petitioners cannot be conferred upon them as taxpayers and citizens.

A taxpayer suit is proper only when there is an exercise of the spending or taxing power of Congress, whereas citizen standing must rest on direct and personal interest in the proceeding. RA 9372 is a penal statute and does not even provide for any appropriation from Congress for its implementation, while none of the individual petitioner-citizens has alleged any direct and personal interest in the implementation of the law. Generalized interest, albeit accompanied by the assertion of a public right, do not establish locus standi. Evidence of a direct and personal interest is key.

3. The doctrines of void-for-vagueness and overbreadth find no application in the present case since these doctrines apply only to free speech cases and that RA 9372 regulates conduct, not speech.

Allegations that a penal statute is vague and overbroad do not justify a facial review of its validity. A facial challenge is allowed to be made to a vague statute and to one, which is overbroad because of possible chilling effect upon protected speech. This does not apply to penal statutes they have general in terrorem effect. If facial challenge is allowed, the State may well be prevented from enacting laws against socially harmful conduct. Overbreadth and vagueness doctrines then have special application only to free speech cases. They are inapt for testing the validity of penal statutes.

Isagani Cruz v. Dept. of Energy and Natural Resources, G.R. No. 135385, December 6, 2000

FACTS: Cruz assailed the validity of the RA 8371 or the Indigenous People’s Rights Act on the ground that the law amount to an unlawful deprivation of the State’s ownership over lands of the public domain as well as minerals and other natural resources therein, in violation of the regalian doctrine embodied in Section 2, Article XII of the Constitution.

ISSUE: Whether or not the IPRA law is unconstitutional.

HELD: When the SC deliberated upon the matter, the votation resulted to a tie thereby concluding the idea that there is no majority. Due to this, Cruz’s petition was dismissed.

G.R. NO. 159618: Feruary 1, 2011

BAYAN MUNA, Represented by Rep. SATUR OCAMPO, Rep. CRISPIN BELTRAN, Rep. LIZA L. MAZA, Petitioner v. ALBERTO ROMULO, in his capacity as Executive Secretary , and BLAS F. OPLE, in his capacity as Secretary of Foreign Affairs, Respondents.

FACTS:

In 2000, the RP, through Charge d’Affaires Enrique A. Manalo, signed the Rome Statute which, by its terms, is “subject to ratification, acceptance or approval” by the signatory states. In 2003, via Exchange of Notes with the US government, the RP, represented by then DFA Secretary Ople, finalized a non-surrender agreement which aimed to protect certain persons of the RP and US from frivolous and harassment suits that might be brought against them in international tribunals. Petitioner imputes grave abuse of discretion to respondents in concluding and ratifying the Agreement and prays that it be struck down as unconstitutional, or at least declared as without force and effect.

ISSUE:

Whether the Respondents abused their discretion amounting to lack or excess of jurisdiction for concluding the RP-US Non Surrender Agreement in contravention of the Rome Statute.

HELD:

The petition is bereft of merit. The Agreement does not contravene nor undermine, nor does it differ from the Rome Statute. Far from going against each other, one complements the other. As a matter of fact, the principle of complementarity underpins the creation of the ICC. According to Art. 1 of the Statute, the jurisdiction of the ICC is to “be complementary to national criminal jurisdictions of the signatory states.” the Rome Statute expressly recognizes the primary jurisdiction of states, like the RP, over serious crimes committed within their respective borders, the complementary jurisdiction of the ICC coming into play only when the signatory states are unwilling or unable to prosecute.