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CECILIA ZULUETA, petitioner,

vs.
COURT OF APPEALS and ALFREDO MARTIN, respondents.

Case Facts: The case involves a petition filed by Cecilia Zulueta against the Court of Appeals and
Alfredo Martin. Cecilia Zulueta is the wife of Alfredo Martin, a doctor. She forcibly entered her
husband's clinic and took 157 documents without his consent, including private correspondence
between Dr. Martin and his alleged paramours, diaries, and photographs. Cecilia Zulueta then filed
the papers for the evidence of her case of legal separation and disqualification from the practice of
medicine against her husband.

Dr. Martin sued to recover the documents and for damages since they were taken by his wife without
his knowledge and consent. The Regional Trial Court ruled in Dr. Martin's favor, ordering Zulueta to
return the documents and pay damages. On appeal, the Court of Appeals affirmed the decision of the
RTC, leading to this appeal to the Supreme Court.

Statement of the Problem: The main issue of the case is whether the evidence obtained by Petitioner
Cecilia is admissible, considering its violation of Dr. Martin's right to privacy of communication and
correspondence.

Court Decision: The Supreme Court ruled that the evidence obtained by Zulueta was inadmissible
due to its violation of Dr. Martin's right to privacy of communication and correspondence.

Applicable Law: Article III, Section 3 of the Philippine Constitution provides that the privacy of
communication and correspondence shall be inviolable except upon lawful court order or when public
safety or order requires otherwise. Evidence obtained in violation of this provision is deemed
inadmissible in any proceeding.

Explanation: The case underscores the inviolability of privacy between spouses and the
inadmissibility of evidence obtained through unauthorized means. Zulueta's actions in taking
documents from her husband's clinic without his consent violated his privacy rights. The Court
emphasized that marriage does not diminish an individual's right to privacy, and constitutional
protections apply equally within marital relationships. The intimacies between husband and wife do
not justify any one of them in breaking the drawers and cabinets of the other and in ransacking them
for any telltale evidence of marital infidelity. Therefore, the documents taken unlawfully by Zulueta
could not be used as evidence in legal proceedings against Dr. Martin

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