GR No.

80508 January 30, 1990

Eddie Guazon, et.al., petitioners
Vs.
Maj. Gen. Renato De Villa, etl.al., respondents

Gutierrez, J.:
Facts: There are numerous “areal target zonings” or “saturation drives” established
around Metro Manila, pinpointed by the military and police as places where the
subversives are hiding. This is intended to flush out subversives and criminal elements
particularly because of the blatant assassinations of public officers and police officials.
They arrest and apprehend numerous of people during the said drives without any
search warrant or warrant of arrest and the petitioners contends that their process in
arresting and apprehending people is a violation of human rights.

Issue: Whether or not these drives are valid.

Ruling: Yes. The conduct of areal target zoning or saturation drive is a valid exercise of
the military powers of the President. There is nothing in the Constitution which denies
the authority of the Chief Executive, to order police actions to stop unabated criminality,
rising lawlessness, and alarming communist activities.
Moreover, not one of person treated in the illegal and inhuman manner described
by the petitioners appears as a petitioner or has come before a trial court to present the
kind of evidence admissible in courts of justice. Hence, there must have been tens of
thousands of nearby residents who were inconvenienced in addition to the several
thousand allegedly arrested. None of those arrested has apparently been charged and
none of those affected has apparently complained.

Critique: Supreme Court must order the investigation what the petitioners contending.
Violation of human rights is serious even it is just a contention or allegation.