Ex Post Facto

CASE: Santos vs. Secretary of Public Works and Communications G.R. No. L-16949, March 18,
1967

FACTS: Republic Act No. 920 was enacted to impose a new license fee on all jeepney owners
and operators. The new fee was P10 per unit per year. Prior to this, the license fee was only P4
per unit per year. Petitioner Edilberto Santos, a jeepney owner, filed a petition for prohibition
and mandamus with preliminary injunction against the Secretary of Public Works and
Communications and the Director of Public Works, to stop them from enforcing Republic Act
No. 920 on the ground that it is an ex post facto law.

ISSUE: Whether Republic Act No. 920 violates the constitutional prohibition against ex post
facto laws.

RULING: The Supreme Court held that Republic Act No. 920 is not an ex post facto law. The
Court explained that not all laws that have a retrospective effect are ex post facto laws. For a
law to be considered ex post facto, it must either (1) punish an act that was innocent when it
was done, (2) make the punishment for a crime greater than when it was committed, or (3)
deprive a person of a defense. In this case, Republic Act No. 920 did not retroactively change
the legal consequences of the act of operating a jeepney. Instead, it imposed a new obligation
on jeepney owners and operators for future operations.
The Court also noted that the new fee was reasonable and not confiscatory. It was intended to
regulate the use of public highways and to defray the expenses of supervising and regulating the
use of public highways by jeepneys. The Court further stated that the exercise of the police
power of the state to regulate the use of public highways is a valid exercise of the power of the
state.
Therefore, the Court dismissed the petition for lack of merit.

CONCLUSION: Republic Act No. 920, which imposed a new license fee on jeepney owners and
operators, was held to be constitutional and not an ex post facto law. The Court upheld the
State's power to regulate the use of public highways and the reasonableness of the new license
fee.
Habeas Corpus
Case: Ordonez vs. Director of Prisons, G.R. No. 115576. Aug. 4, 1994

Facts:
The petitioner, Reynaldo G. Ordonez, was arrested without a warrant on the evening of March
23, 1994, by the members of the Philippine National Police (PNP) at his residence in Quezon
City. He was charged with illegal possession of firearms and ammunition, a non-bailable offense
under Philippine law. The following day, the petitioner was brought before the Municipal Trial
Court of Quezon City for the issuance of a commitment order. He was then committed to the
Quezon City Jail, where he has been detained since then.
On April 5, 1994, the petitioner filed a petition for habeas corpus before the Regional Trial Court
(RTC) of Quezon City. He argued that his arrest was illegal, and that the evidence against him
was obtained through an illegal search and seizure. He also contended that the Municipal Trial
Court of Quezon City had no jurisdiction to issue a commitment order for a non-bailable
offense, and that he should be released on bail.
The RTC denied the petition for habeas corpus, ruling that the arrest of the petitioner was legal,
and that there was probable cause for his detention. It also held that the Municipal Trial Court
of Quezon City had jurisdiction to issue a commitment order for a non-bailable offense, and that
the petitioner was not entitled to bail.

Issue:
Whether or not the petitioner is entitled to the privilege of the writ of habeas corpus.
Ruling:

The Supreme Court ruled in favor of the petitioner and granted the petition for habeas corpus.
The Court held that the arrest of the petitioner was illegal, as there was no valid warrant of
arrest or any other legal basis for the arrest. The police officers who conducted the arrest did
not have personal knowledge of facts indicating that the petitioner had committed a crime, nor
did they have probable cause to believe that he had committed a crime. The Court also found
that the evidence against the petitioner was obtained through an illegal search and seizure, as
the police officers did not have a search warrant or any other legal basis for the search.
The Court further held that the Municipal Trial Court of Quezon City had no jurisdiction to issue
a commitment order for a non-bailable offense, and that the petitioner was entitled to bail. It
noted that the petitioner was not a flight risk, and that he had strong ties to the community.
In conclusion, the Court ordered the immediate release of the petitioner from detention, and
directed the PNP to return the firearms and ammunition that were seized from him without a
warrant.