FUNDAMENTAL CONCEPTS AND RULES INTERPRETING THE

CONSTITUTION

Title: OCAMPO v. ENRIQUEZ

Citation: G.R. No. 225973, 8 November 2016

Facts:
President Rodrigo Duterte allowed the burial of the late dictator Marcos in the
Libingan ng mga Bayani. Petitioners filed a case stating that the burial was contrary to the
provisions of the Constitution specifically, Sections 2, 11, 13, 23, 26, 27 and 28 of Article II
and Sec. 1 of Art. XI.

Issue/s:
Whether the provisions are a source of enforceable right to prohibit the burial if
Marcos in the Libingan ng mga Bayani

Decision of the Court:

No, the Supreme Court ruled in Tañada v. Angara that Article 2 is a non-self-
executing provision. In the same vein, Sec. 1 of Art. XI of the Constitution is not a self-
executing provision considering that a law should be passed by the Congress to clearly define
and effectuate the principle embodied therein which was through the Ombudsman Act, Anti
Red Tape Act and the Code of Conduct and Ethical Standards for Public Officials and
Employees, which are all irrelevant to the case.

Title: COUNCIL OF TEACHERS AND STAFF OF COLLEGES AND UNIVERSITIES

OF THE PHILIPPINES v. SECRETARY OF EDUCATION
Citation: G.R. No. 216930, 9 October 2018

Facts:

Issue/s:

Decision of the Court: