Midterm Coverage Consti II

CONSTITUTIONAL LAW II
MIDTERM COVERAGE
Basic Principles of the Constitution

Doctrine of Constitutional Supremacy
I. POLICE POWER
• Concept and Basic Principles

• Sources of the Power
• Test of Valid Exercise
Ø Lawful Subject
Ø Lawful Means
• Police Power using Power of Taxation as an Implement
• Police Power exercised as a Complement of Eminent Domain
• Regulation vs. Taking
• Limitations of Exercise of Police Power by Local Government Units
II. EMINENT DOMAIN
• Concept and Basic Principles

• Basis of the Inherent Exercise
• What may be expropriated
• Requisites for a Valid Exercise
Ø Necessity of Expropriation
Ø Taking in Eminent Domain
Ø Public Use
Ø Just Compensation
• Eminent Domain and State Immunity
• Requisites for the Exercise by Local Government Units
III. POWER OF TAXATION
• Concept/Basic Principles
• Uniformity or Equality in Taxation
• Equitable Taxation
• Progressive vs Regressive
• Public Purpose in Taxation
• Double Taxation
• Tax Exemption
Ø Voting Requirement
Ø Real Property Tax
Ø Non-Stock Non-Profit Educational Institution
IV. DUE PROCESS
• Concept
• Origin
• Essence of Due Process
• Two Aspects of Due Process
Ø Substantive
Ø Procedural
• Minimum Requirements
Ø Prior Notice
Ø Hearing
• Judicial Due Process
• Administrative Due Process
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• Due Process in School Disciplinary Proceedings
• Void for Vagueness Doctrine
• Overbreadth Doctrine
V. EQUAL PROTECTION
• Concept
• Classification
• Requisites of a Valid Classification
Ø Substantial Distinction
Ø Classification must be Germane to the Purpose of the Law
Ø The reasonableness of the classification must not be limited to existing conditions only
Ø The law must apply to all of the same class
• Analytical Tool in Determining Reasonableness of Classification
Ø Strict Scrutiny Test
Ø Intermediate Test
Ø Rational Relationship Test
VI. RIGHT AGAINST UNREASONABLE SEARCHES AND SEIZURES
• Meaning/Extent
• Private Intrusion
• Search Warrant
• Warrant of Arrest
• Administrative Warrant
• Requisites of a Valid Warrant
Ø Probable Cause
Ø Personally Determined by a Judge
Ø Under oath or affirmation of the Complainant
Ø Particularity in the Description
• Warrantless Arrest
Ø In Flagrante Delicto
Ø Hot Pursuit
Ø Arrest of Prisoner or Detainee
Ø Arrest after escape or rescue
Ø Arrest of Accused on Bail
• Warrantless Search
Ø Search incidental to a lawful arrest
Ø Stop and Frisk
Ø Seizure of evidence in plain view
Ø Consented Search
Ø Customs Search
Ø Airport Search
Ø Checkpoint Search
Ø Exclusionary Principle
Ø Fruit of the Poisonous Tree Doctrine
VII. RIGHT TO PRIVACY
• Concept
• Two Categories of Privacy
• Zones of Privacy
• Test of Reasonable Expectation of Privacy
Ø Objective
Ø Subjective
• Requirements in order that personal information may be compelled to be disclosed
• Privacy of Communications
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• Statutes Creating Zones of Privacy
VIII. FREE SPEECH, EXPRESSION, PRESS, ASSEMBLY AND PETITION
• Extent of Protection
• Theory of Deliberative Democracy
• Concept of Market Place of Ideas
• Safety Valve Theory
• Concept of Privilege Speech
Ø Absolute
Ø Qualified
• Kinds of Speeches
Ø Political
Ø Commercial
• Types of Regulations
Ø Content Based
Ø Content Neutral
• Tests to Determine the Validity of Governmental regulation
Ø Clear and Present Danger
Ø O’Brien Test
• Assembly vs. Strike
• Free Speech in Campus
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CASE DIGESTS
Table of Contents
A. INTRODUCTION 6
MANILA PRINCE HOTEL V. GSIS 6
B. POLICE POWER 8
PHILIPPINE ASSOCIATION OF SERVICE EXPORTERS VS. DRILON [G.R. NO. L-81958, JUNE 30,
1988] 8
YNOT VS. INTERMEDIATE APPELLATE COURT [G.R. NO. 74457, MARCH 20, 1987] 9
LUTZ VS. ARANETA [G.R. NO. L-7859, DECEMBER 22, 1955] 10
ASSOCIATION OF SMALL LANDOWNERS VS. SECRETARY OF AGRARIAN REFORM [G.R. NO.
78742, JULY 14, 1989] 11
MOSQUEDA VS. PILIPINO BANANA GROWERS & EXPORTERS ASSOCIATION [G.R. NOS. 189185 &
189305, AUGUST 16, 2016] 12
C. EMINENT DOMAIN 14
CITY OF MANILA VS. CHINESE COMMUNITY OF MANILA [G.R. NO. 14355, OCTOBER 31, 1919] 14
REPUBLIC VS. PHILIPPINE LONG DISTANCE TELEPHONE CO. [G.R. NO. L-18841, JANUARY 27,
1969] 16
REPUBLIC VS. VDA. DE CASTELLVI [G.R. NO. L-20620, AUGUST 15, 1974] 17
REPUBLIC VS. LIM [G.R. NO. 161656, JUNE 29, 2005] 19
D. POWER OF TAXATION 20
SISON VS. ANCHETA, [G.R. NO. L-59431, JULY 25, 1984] 20

PASCUAL VS. SECRETARY OF PUBLIC WORKS [G.R. NO. L-10405, DECEMBER 29, 1960] 21
LLADOC VS. COMMISSIONER OF INTERNAL REVENUE [G.R. NO. L-19201, JUNE 16, 1965] 22
ABRA VALLEY COLLEGE VS. AQUINO [G.R. NO. L-39086, JUNE 15, 1988] 23
E. DUE PROCESS 24
ATTY. HOWARD M. CALLEJA, ET AL. VS. EXECUTIVE SECRETARY, ET AL. [G.R. NO. 252578, ET
AL., DECEMBER 7, 2021] 24
YNOT VS. INTERMEDIATE APPELLATE COURT [G.R. NO. 74457, MARCH 20, 1987] 25
ALONTE VS. SAVELLANO [G.R. NO. 131652, MARCH 9, 1998] 27
PHILIPPINE COMMUNICATIONS SATELLITE CORP. VS. ALCUAZ [G.R. NO. 84818, DECEMBER 18,
1989] 29
ANG TIBAY VS. COURT OF INDUSTRIAL RELATIONS [G.R. NO. 46496, FEBRUARY 27, 1940] 31
ATENEO DE MANILA VS. CAPULONG [G.R. NO. 99327, MAY 27, 1993] 32
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F. EQUAL PROTECTION 34
PEOPLE VS. VERA [G.R. NO. 45685, NOVEMBER 16, 1937] 34

BIRAOGO VS. THE PHILIPPINE TRUTH COMMISSION [G.R. NO. 192935, DECEMBER 7, 2010] 35
ORMOC SUGAR CO., INC. VS. TREASURER OF ORMOC CITY [G.R. NO. L-23794, FEBRUARY 17,
1968] 36
G. RIGHT AGAINST UNREASONABLE SEARCHES AND SEIZURES 37
PEOPLE VS. MARTI [G.R. NO. 81561, JANUARY 18, 1991] 37

STONEHILL VS. DIOKNO [G.R. NO. L-19550, JUNE 19, 1967] 38
SOLIVEN VS. MAKASIAR [G.R. NO. 82585, NOVEMBER 14, 1988] 39
HARVEY VS. SANTIAGO [G.R. NO. 82544, JUNE 28, 1988] 41
PEOPLE VS. SUCRO [G.R. NO. 93239, MARCH 18, 1991] 42
LUZ VS. PEOPLE [G.R. NO. 197788, FEBRUARY 29, 2012] 43
UNITED LABORATORIES VS. ISIP, [G.R. NO. 163858, JUNE 28, 2005] 44
PEOPLE VS. O’COCHLAIN [G.R. NO. 229071, DECEMBER 10, 2018] 45
H. RIGHT TO PRIVACY 46
OPLE VS. TORRES [G.R. NO. 127685, JULY 23, 1998] 46

DISINI VS. SECRETARY OF JUSTICE [G.R. NO. 203335, FEBRUARY 11, 2014] 47
ZULUETA VS. COURT OF APPEALS [G.R. NO. 107383, FEBRUARY 20, 1996] 49
CHRISTIAN CADAJAS Y CABIAS VS. PEOPLE OF THE PHILIPPINES [G.R. NO. 247348, NOVEMBER
16, 2021] 50
I. FREE SPEECH, EXPRESSION, PRESS, ASSEMBLY AND PETITION 51
DIOCESE OF BACOLOD VS. COMELEC, G.R. NO. 205728, JANUARY 21, 2015 51
UNITED STATES VS. BUSTOS [G.R. NO. L-12592, MARCH 8, 1918] 52
REYES VS. BAGATSING [G.R. NO. L-65366, NOVEMBER 9, 1983] 53
SOCIAL WEATHER STATIONS, INC. VS. COMELEC [G.R. NO. 147571, MAY 5, 2001] 54
BAYAN VS. ERMITA [G.R. NO. 169838, APRIL 25, 2006] 55
J. RELIGIOUS FREEDOM AND NON-ESTABLISHMENT OF RELIGION 56
AGLIPAY VS. RUIZ [G.R. NO. 45459, MARCH 13, 1937] 56

TARUC VS. DE LA CRUZ [G.R. NO. 144801, MARCH 10, 2005] 57
IGLESIA NI CRISTO VS. COURT OF APPEALS [G.R. NO. 119673, JULY 26, 1996] 59
ESTRADA VS. ESCRITOR [A.M. NO. P-02-1651, JUNE 22, 2006] 61
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A. INTRODUCTION
Manila Prince Hotel v. GSIS
Facts:
The case Manila Prince Hotel v. Government Service Insurance System involves a bidding process for
the privatization of the Manila Hotel in the Philippines. The petitioner, Manila Prince Hotel, and the
respondent, Renong Berhad, both pre-qualified for the bidding process. The bidding rules and
procedures stated that the winning bidder must pass the pre-qualification process, submit the highest
bid on a price per share basis, and negotiate and execute necessary contracts with the Government
Service Insurance System (GSIS) and Manila Hotel Corporation (MHC) by a certain date.
During the second public bidding, Renong Berhad submitted the highest bid of P44.00 per share for
15,300,000 shares. Manila Prince Hotel submitted a bid of P41.00 per share for the same number of
shares. Renong Berhad was declared the highest bidder and Manila Prince Hotel's bid security was
returned.
Ten days after the bidding, Manila Prince Hotel wrote to GSIS offering to match Renong Berhad's bid
and requested that the award be given to them based on the second paragraph of Section 10, Article
XII of the Constitution, which gives preference to qualified Filipinos in the grant of rights, privileges,
and concessions covering the national economy and patrimony. GSIS refused to entertain Manila
Prince Hotel's request as they were already in the process of negotiating with Renong Berhad.
Manila Prince Hotel filed a petition arguing that they should be given the opportunity to match Renong
Berhad's bid based on their status as a qualified Filipino bidder.
Issue:
The main issues raised in the case were:
1. whether Section 10, paragraph 2 of Article XII of the Constitution is self-executing and does
not need implementing legislation,
2. whether the Manila Hotel is part of the national patrimony,
3. whether GSIS is included in the term "State" and mandated to implement the preference for
qualified Filipinos,
4. whether GSIS failed to give preference to Manila Prince Hotel over Renong Berhad, and
5. whether Manila Prince Hotel is estopped from questioning the sale to Renong Berhad.
Ruling:
The Supreme Court held that:
1. Section 10, paragraph 2 of Article XII of the Constitution is self-executing and does not need
implementing legislation.
2. The Manila Hotel is part of the national patrimony.
3. GSIS, as a government-owned and controlled corporation, is included in the term "State" and
is mandated to implement the preference for qualified Filipinos.
4. Manila Prince Hotel is not entitled to match Renong Berhad's bid as the bidding rules and
regulations did not provide for such a right.
5. Manila Prince Hotel is estopped from questioning the sale to Renong Berhad as they were
aware of the rules and regulations and participated in the bidding process.
Ratio:
The Supreme Court ruled that Section 10, paragraph 2 of Article XII of the Constitution is self-executing
and does not require implementing legislation. The Court emphasized that the Constitution is the
supreme law of the land and all other laws and contracts must conform to it. Therefore, the preference
for qualified Filipinos in the grant of rights, privileges, and concessions covering the national economy
and patrimony should be upheld.
The Court also held that the Manila Hotel is part of the national patrimony, as it has historical and
cultural significance. The Court recognized the Manila Hotel as a landmark and a living testimonial of
Philippine heritage.
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Furthermore, the Court clarified that the term "State" in the Constitution refers not only to the
government but also to its instrumentalities, such as the GSIS. Therefore, GSIS, as a government-
owned and controlled corporation, is included in the term "State" and is mandated to implement the
preference for qualified Filipinos.
However, the Court found that Manila Prince Hotel is not entitled to match Renong Berhad's bid
because the bidding rules and regulations did not provide for such a right. The Court emphasized that
the bidding rules and procedures must be followed and respected.
Lastly, the Court held that Manila Prince Hotel is estopped from questioning the sale to Renong Berhad
because they were aware of the rules and regulations and participated in the bidding process. The
Court emphasized the importance of upholding the integrity of the bidding process and respecting the
rights of other bidders.
In conclusion, the Supreme Court ruled that the Filipino First Policy provision is self-executing and
applies to the sale of the controlling shares of the Manila Hotel Corporation. The Court ordered GSIS
to cease the sale to the foreign corporation and to accept the matching bid of the petitioner. The Court
also directed GSIS to execute the necessary agreements and documents to effect the sale to the
petitioner.
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B. POLICE POWER
Philippine Association of Service Exporters vs. Drilon [G.R. No. L-81958, June 30, 1988]
Facts:
The case of Philippine Association of Service Exporters, Inc. v. Drilon involves the challenge to the
Constitutional validity of Department Order No. 1, Series of 1988. This order temporarily suspended
the deployment of Filipino domestic and household workers. The petitioner, Philippine Association of
Service Exporters, Inc. (PASEI), argues that the measure discriminates against males or females, does
not apply to all Filipino workers, and violates the right to travel. PASEI also claims that the order was
passed without prior consultations and violates the non-impairment clause of the Constitution.
Issue:
The main issues raised in the case are as follows:
• Whether Department Order No. 1, Series of 1988 is constitutional.

• Whether the order discriminates against males or females.
• Whether the order applies to all Filipino workers.
• Whether the order violates the right to travel.
• Whether the order was passed without prior consultations.
• Whether the order violates the non-impairment clause of the Constitution.
Ruling:
The Supreme Court upholds the Constitutional validity of Department Order No. 1 and dismisses the
petition.
Ratio:
The Court finds that Department Order No. 1 is a valid exercise of police power and does not violate
the right to travel. The order was implemented to protect the welfare of Filipino workers abroad, which
falls within the scope of police power. The Court recognizes that the government has the authority to
regulate the deployment of workers to ensure their safety and well-being.
Regarding the claim of discrimination, the Court finds that the classification made in the order, favoring
female workers, is justified. There is evidence of the mistreatment suffered by female domestic workers
abroad, which justifies the preferential treatment. The order applies to all female domestic overseas
workers and does not prescribe a total ban on overseas deployment.
The Court also rejects the argument that the order does not apply to all Filipino workers. The order
specifically targets domestic and household workers, which is a distinct category of workers. It does
not exclude other Filipino workers from overseas deployment.
In terms of prior consultations, the Court finds that the order was a valid exercise of executive power
and did not require prior consultations. The government has the authority to issue orders and
regulations to protect the welfare of its citizens.
Lastly, the Court rules that the order does not violate the non-impairment clause of the Constitution.
The order is a valid implementation of the Labor Code and does not constitute an invalid exercise of
legislative power.
In conclusion, the Supreme Court upholds the Constitutional validity of Department Order No. 1,
stating that it is a valid exercise of police power and does not violate the right to travel. The order's
classification and application are justified, and it does not violate the non-impairment clause.
Therefore, the petition is dismissed.
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Ynot vs. Intermediate Appellate Court [G.R. No. 74457, March 20, 1987]
Facts:
In the case of Ynot v. Intermediate Appellate Court, the petitioner, Restituto Ynot, transported six
carabaos from Masbate to Iloilo. However, the police confiscated the carabaos for violating Executive
Order No. 626-A, which prohibited the interprovincial movement of carabaos and the slaughtering of
carabaos not complying with certain requirements. Ynot filed a complaint for recovery, but the trial
court upheld the confiscation and ordered the confiscation of Ynot's bond. The Intermediate Appellate
Court affirmed the trial court's decision, prompting Ynot to file a petition for review on certiorari before
the Supreme Court.
Issue:
The main issue raised in the case was the constitutionality of Executive Order No. 626-A, specifically
the provision authorizing the confiscation of carabaos or carabeef being transported across provincial
boundaries. Ynot argued that the penalty was imposed without giving the owner a right to be heard
before a competent and impartial court, thereby violating due process. He also challenged the exercise
of legislative power by the former President under Amendment No. 6 of the 1973 Constitution.
Ruling:
The Supreme Court ruled in favor of Ynot, declaring Executive Order No. 626-A unconstitutional. The
Court held that the method employed in the executive order, which imposed an absolute ban on the
interprovincial transport of carabaos, was not reasonably necessary to achieve the purpose of the law
and was unduly oppressive. The Court also found that due process was violated because the owner
of the confiscated property was denied the right to be heard in his defense and was immediately
condemned and punished. Additionally, the Court found that there was an encroachment on judicial
functions and an invalid delegation of legislative powers in the executive order.
Ratio:
The Court reasoned that the absolute ban on the interprovincial transport of carabaos was not
reasonably necessary to achieve the purpose of the law, which was to prevent the spread of diseases
among carabaos. The Court emphasized that there were less restrictive means available to achieve
the same objective, such as requiring the certification of veterinarians or the imposition of stricter
sanitary measures. The Court found that the method employed in the executive order was unduly
oppressive as it deprived the owners of their property without due process.
Furthermore, the Court held that due process was violated because the owner of the confiscated
property was not given the opportunity to be heard in his defense before a competent and impartial
court. The Court emphasized that the right to be heard is a fundamental aspect of due process and
should not be disregarded. The immediate condemnation and punishment of the owner without a fair
hearing was deemed unconstitutional.
The Court also found that there was an encroachment on judicial functions and an invalid delegation
of legislative powers in the executive order. The Court emphasized that the power to determine the
guilt or innocence of an accused and to impose penalties for violations of the law belongs to the
judiciary and cannot be delegated to the executive branch. The executive order, in authorizing the
confiscation of property without judicial intervention, encroached upon the functions of the judiciary
and violated the principle of separation of powers.
In conclusion, the Supreme Court ruled that Executive Order No. 626-A was unconstitutional due to
its unreasonable and oppressive method, violation of due process, encroachment on judicial functions,
and invalid delegation of legislative powers. The Court reversed the decision of the Intermediate
Appellate Court, cancelled the supersedeas bond, and ordered the restoration of the bond amount to
Ynot. The Court commended Ynot for asserting and protecting his rights, highlighting the importance
of the people's courage to invoke their rights whenever they are ignored or violated.
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Lutz vs. Araneta [G.R. No. L-7859, December 22, 1955]
The Supreme Court affirms the constitutionality of taxes imposed by the Sugar Adjustment Act,
stating that the protection and promotion of the sugar industry is a valid exercise of the state's
police power.
Facts:
The case of Lutz v. Araneta involves the constitutionality of taxes imposed by the Sugar Adjustment
Act, specifically Commonwealth Act No. 567. The plaintiff, Walter Lutz, as the Judicial Administrator
of the Intestate Estate of Antonio Jayme Ledesma, filed a case in the Court of First Instance of Negros
Occidental to challenge the legality of the taxes imposed by the said act. The law was enacted in 1940
due to the threat to the sugar industry posed by the imminent imposition of export taxes on sugar. The
law aimed to stabilize the sugar industry and readjust the benefits derived from it. It provided for an
increase in the tax on the manufacture of sugar and levied a tax on owners or persons in control of
lands devoted to sugar cane cultivation. The taxes collected were to be placed in a special fund known
as the Sugar Adjustment and Stabilization Fund, which would be used for various purposes related to
the sugar industry.
Issue:
The main issue raised in the case was whether the taxes imposed by the Sugar Adjustment Act were
constitutional. The plaintiff argued that the tax was not for a public purpose and therefore violated the
constitutional limitations on taxation.
Ruling:
The Supreme Court, in its ruling, affirmed the constitutionality of the taxes imposed by the Sugar
Adjustment Act.
Ratio:
The Court held that the protection and promotion of the sugar industry is a matter of public concern,
and therefore, the legislature has the power to determine what is necessary for its protection and
expedient for its promotion. The Court emphasized that the Act was primarily an exercise of the state's
police power rather than a pure exercise of the taxing power. It stated that if the objective and methods
of the law are constitutionally valid, there is no reason why the state cannot levy taxes to raise funds
for their prosecution and attainment.
The Court also noted that it is inherent in the power to tax that a state be free to select the subjects of
taxation, and inequalities resulting from singling out a particular class for taxation do not infringe any
constitutional limitation. The Court further explained that even if the Act were considered a pure tax
measure, the expenditure of tax money for experimental stations and the improvement of living and
working conditions in the sugar industry does not constitute expenditure for private purposes.
In summary, the Supreme Court affirmed the constitutionality of the taxes imposed by the Sugar
Adjustment Act, stating that the protection and promotion of the sugar industry is a valid exercise of
the state's police power. The Court held that the legislature has the power to determine what is
necessary for the industry's protection and expedient for its promotion. The Court also emphasized
that it is within the state's power to select the subjects of taxation and that inequalities resulting from
singling out a particular class for taxation do not violate constitutional limitations.
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Association of Small Landowners vs. Secretary of Agrarian Reform [G.R. No. 78742, July 14,
1989]
The Supreme Court upholds the constitutionality of agrarian reform measures in the Philippines,
affirming the government's power of eminent domain and the provisions on just compensation,
in order to address the imbalance in land distribution and benefit the entire Filipino nation.
Facts:
The case of Association of Small Landowners in the Philippines, Inc. v. Secretary of Agrarian Reform
involves the constitutionality of agrarian reform measures in the Philippines. The petitioners in this case
include small landowners and sugar planters who are challenging the constitutionality of various
agrarian reform measures, including Presidential Decree (P.D.) No. 27, Executive Order (E.O.) Nos. 228
and 229, and Republic Act (R.A.) No. 6657. These measures were enacted to address the imbalance
in land distribution in the country and provide just compensation to landowners.
Issue:
The main issue raised in this case is the constitutionality of the agrarian reform measures, particularly
whether they violate the separation of powers, due process, equal protection, and the constitutional
requirement of just compensation.
Ruling:
The Supreme Court ruled that the agrarian reform measures are constitutional. The Court held that the
President had the authority to promulgate these measures under the Transitory Provisions of the 1987
Constitution. The Court also found that the measures did not violate the constitutional requirements
of due process, equal protection, and just compensation.
Ratio:
The Court explained that the judiciary has the power to annul acts of the legislative or executive
branches that are not conformable to the Constitution. However, this power is not lightly assumed and
must be exercised with restraint. The Court will only intervene if there is an actual case or controversy,
the constitutional question has been raised by the proper party, and the resolution of the question is
necessary to decide the case.
The Court also emphasized that the agrarian reform measures were enacted to address the social
justice goals of the Constitution. The measures aim to distribute agricultural lands to landless farmers
and provide just compensation to landowners. The Court found that the measures were enacted in
accordance with the Constitution and were supported by the legislative branch.
Furthermore, the Court rejected the argument that the measures violated the constitutional
requirement of just compensation. The Court held that the determination of just compensation is a
function of the courts and may be reviewed if necessary. The Court also noted that the measures
provided for retention limits for landowners and allowed for the payment of compensation in various
forms, not just in money.
Overall, the Court upheld the constitutionality of the agrarian reform measures, affirming the
government's power of eminent domain and the provisions on just compensation. The Court
recognized the importance of addressing the imbalance in land distribution and promoting social
justice in the country.
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Mosqueda vs. Pilipino Banana Growers & Exporters Association [G.R. Nos. 189185 & 189305,
August 16, 2016]
The Supreme Court declares Davao City Ordi ce No. 0309-07 banning aerial spraying in
agriculture unconstitutional due to its unreasonable transition period, violation of the Equal
Protection Clause, violation of due process, and disregard for the jurisdiction of the Fertilizer
and Pesticide Authority.
Facts:
The case involves the constitutionality of Davao City Ordinance No. 0309-07, which bans aerial
spraying in agriculture. The petitioners, residents of Davao City, argue that the ordinance is valid and
constitutional, while the respondents, including the Pilipino Banana Growers & Exporters Association
(PBGEA), argue that the ordinance is unreasonable and oppressive.
The Sangguniang Panlungsod of Davao City enacted Ordinance No. 0309-07, which bans aerial
spraying as an agricultural practice in all agricultural activities within the city. The ordinance defines
aerial spraying as the application of substances through the use of aircraft that dispenses the
substances in the air. It also requires agricultural entities to provide a 30-meter buffer zone within their
agricultural farms/plantations. Violation of the ordinance is punishable by fines, imprisonment, and
suspension or cancellation of permits and licenses.
The PBGEA and its members, Davao Fruits Corporation and Lapanday Agricultural and Development
Corporation, filed a petition in the Regional Trial Court (RTC) challenging the constitutionality of the
ordinance. They argued that the ordinance exemplified the unreasonable exercise of police power,
violated the equal protection clause, amounted to the confiscation of property without due process of
law, and lacked proper publication. The residents living near the banana plantations, led by Wilfredo
Mosqueda, also filed a motion to intervene and opposed the issuance of a preliminary injunction.
The RTC upheld the validity and constitutionality of the ordinance, ruling that the City of Davao had
validly exercised police power and that the ordinance was based on a valid classification. However,
the RTC recognized the impracticability of the 3-month transition period under the ordinance and
recommended an extended transition period.
The PBGEA appealed the decision to the Court of Appeals (CA), which reversed the RTC's ruling. The
CA declared Section 5 of the ordinance as void and unconstitutional for being unreasonable and
oppressive. It found the three-month transition period impractical and oppressive, and ruled that the
ban violated the equal protection clause. The CA also held that the maintenance of the 30-meter buffer
zone constituted taking of property without due process.
The City of Davao and the intervenors filed separate motions for reconsideration, but the CA denied
the motions. The separate appeals were then consolidated and brought to the Supreme Court.
Issue:
The main issue in the case is whether or not Ordinance No. 0309-07 is unconstitutional on due process
and equal protection grounds.
Ruling:
The Supreme Court ruled that the ordinance violates the due process clause because the three-month
transition period is unreasonable and oppressive. The Court found that it would be physically
impossible for the agricultural entities to shift to other modes of pesticide application within the given
timeframe. The Court also ruled that the imposition of the 30-meter buffer zone does not constitute a
taking of property without just compensation.
The Court did not rule on the equal protection issue, as it found that the rational basis test was the
appropriate standard to apply. The Court held that the legislative classification under the ordinance,
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which applies to all agricultural entities within Davao City, is reasonable and based on substantial
distinctions. The Court did not find any violation of the equal protection clause.
Ratio:
The Supreme Court declared Ordinance No. 0309-07 unconstitutional due to its unreasonable
transition period, but did not find any violation of the equal protection clause. The Court reasoned that
the three-month transition period imposed by the ordinance is unreasonable and oppressive because
it would be physically impossible for the agricultural entities to comply within that timeframe. The Court
emphasized that the petitioners would need more time to acquire the necessary equipment, train
workers, and review safety procedures for alternative spraying methods.
Regarding the equal protection issue, the Court applied the rational basis test and found that the
legislative classification under the ordinance is reasonable and based on substantial distinctions. The
Court held that the ordinance applies to all agricultural entities within Davao City, which justifies the
classification. The Court did not find any violation of the equal protection clause.
In conclusion, the Supreme Court declared Ordinance No. 0309-07 unconstitutional due to its
unreasonable transition period, but did not find any violation of the equal protection clause. The Court
permanently enjoined the City of Davao from enforcing and implementing the ordinance and ordered
the petitioners to pay the costs of the suit.
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C. EMINENT DOMAIN
City of Manila vs. Chinese Community of Manila [G.R. No. 14355, October 31, 1919]
Facts:
The case of City of Manila v. Chinese Community of Manila involves the city of Manila seeking to
expropriate a Chinese cemetery for the extension of a public road. The defendants, the Chinese
Community of Manila and others, oppose the expropriation, arguing that the cemetery is already
dedicated to a public use and cannot be taken without specific legislative authority. The case involves
the expropriation of land for the extension of Rizal Avenue in Manila. The city of Manila filed a petition
for condemnation against the "Comunidad de Chinos de Manila" and Ildefonso Tambunting, who
opposed the expropriation. The Court of First Instance of Manila dismissed the petition, stating that
there was no need for the proposed street and that the land chosen for the extension was not the best
or least expensive option. The court also considered the fact that the proposed street would require
the removal of approximately 400 graves and monuments in the Chinese Cemetery. The city of Manila
appealed the decision, arguing that the court erred in deciding the necessity and convenience of the
expropriation and in declaring that the city had no right to expropriate the land.
Issue:
The main issue raised in the case is whether the courts have the authority to inquire into and hear proof
upon the necessity of the expropriation.
Ruling:
The court ruled in favor of the defendants, stating that the courts have the authority to make inquiry
and hear proof upon the necessity of the expropriation. The court emphasized that the right of
expropriation is not inherent in a municipal corporation and must be conferred upon it by law. The
court also noted that the necessity and expediency of exercising the right of eminent domain are
questions that can be decided by the courts, especially when the property being taken is not private
or the purpose of the expropriation is not public. The court further explained that while the legislature
may directly determine the necessity for expropriating private property for a particular improvement,
when the law does not designate the property to be taken or how much may be taken, the necessity
of taking private property becomes a question for the courts. The court also emphasized that the
necessity and expediency of exercising the right of eminent domain are questions that should be
strictly construed and that the authority must be strictly followed.
Ratio:
The court based its ruling on the principle that the power of eminent domain is inherent in all
sovereignties and can only be denied or restricted by fundamental law. The court cited various
authorities stating that the question of necessity is a political question and belongs to the legislature,
unless the constitution or statute requires judicial determination. The court also considered the fact
that the land in question was already dedicated to a public use as a cemetery and that taking it for
another public use would require special authority from the legislature. The court referred to similar
cases in the United States where it was held that land already devoted to a public use cannot be taken
for another use without special authority.
In a dissenting opinion, one justice argued that the court should not interfere with the determination of
the necessity of the expropriation, as it is the prerogative of the city of Manila. Another justice dissented
from the majority opinion, stating that the city of Manila has the right to expropriate the land for public
use and that the Chinese Cemetery, even if considered a public cemetery, can still be taken for public
use.
In conclusion, the court affirmed the decision of the lower court, ruling that the city of Manila does not
have the right to expropriate the land in question for the extension of Rizal Avenue. The court held that
the determination of the necessity and convenience of the expropriation lies with the court and not
Page 14 of 62 | 1M 2023-2024
with the Municipal Board of the city of Manila. The court also found that the proposed street was not
the best or least expensive option and that an alternative route suggested by one of the defendants
would be more cost-effective and avoid the destruction of graves and monuments in the Chinese
Cemetery. The court based its ruling on the principle that land already devoted to a public use cannot
be taken for another use without special authority from the legislature.
Page 15 of 62 | 1M 2023-2024
Republic vs. Philippine Long Distance Telephone Co. [G.R. No. L-18841, January 27, 1969]
The Republic of the Philippines successfully compelled the Philippine Long Distance Telephone
Company (PLDT) to allow interconnection with the government telephone system, based on the
exercise of eminent domain and the payment of just compensation, rejecting PLDT's claims of
unfair competition and misuse of facilities.
Facts:
The case of Republic v. Philippine Long Distance Telephone Co. involves the Republic of the
Philippines compelling the Philippine Long Distance Telephone Company (PLDT) to allow
interconnection with the government telephone system. The Republic exercised eminent domain and
argued that just compensation should be paid to PLDT. PLDT claimed unfair competition and misuse
of facilities. The case was decided by the Supreme Court of the Philippines on January 27, 1969.
The Republic of the Philippines, through its Bureau of Telecommunications, sought to compel PLDT
to enter into a contract for the use of its telephone facilities throughout the country. PLDT had
disconnected the trunk lines it had previously leased to the Bureau, which resulted in the isolation of
the Philippines from other countries. The Republic argued that the disconnection of the trunk lines
would prevent the Bureau from properly discharging its functions, to the prejudice of the general
public. The Republic filed a complaint in the Court of First Instance of Manila, seeking to compel PLDT
to execute a contract and requesting a preliminary injunction to restore the severed connections.
Issue:
The main issue raised in the case is whether the Republic has the power to compel PLDT to enter into
an interconnecting contract and whether just compensation should be paid to PLDT.
Ruling:
The ruling of the Supreme Court is as follows: The court held that while the Republic cannot force
PLDT to enter into a contract, it can exercise the power of eminent domain to require PLDT to permit
interconnection of the government telephone system and that of PLDT. The court stated that the use
of PLDT's lines and services for interconnection is similar to subjecting private property to an easement
of right of way. The court also noted that if the State can transfer utilities to public ownership upon
payment of just compensation, there is no reason why the State cannot require a public utility to render
services in the general interest, provided just compensation is paid. The court further held that the
lower court should have treated the case as one of condemnation and proceeded to determine just
and reasonable compensation for the interconnecting services.
Ratio:
The ratio of the case is that the Republic has the power to compel PLDT to allow interconnection with
the government telephone system based on the exercise of eminent domain and the payment of just
compensation. The court emphasized that the needs of the general public should not be subordinated
to the profit interests of PLDT. The court also clarified that the Public Service Commission does not
have jurisdiction over actions for the taking of private property under eminent domain and that the
Bureau of Telecommunications, as a public service owned by the Republic, is exempt from the
jurisdiction, supervision, and control of the Public Service Commission. The court also rejected PLDT's
claims of unfair competition and misuse of facilities, stating that the competition was hypothetical and
that PLDT's franchise is non-exclusive. The court recognized PLDT's right to just compensation for
the services rendered to the government telephone system and its users.
Page 16 of 62 | 1M 2023-2024
Republic vs. Vda. De Castellvi [G.R. No. L-20620, August 15, 1974]
The court sets the fair market value of expropriated lands at P5.00 per square meter, rules that
interest is only payable from the date of possession, and denies a motion for a new trial based
on newly discovered evidence in the case of Republic v. Vda. de Castellvi.
Facts:
The case of Republic v. Vda. de Castellvi involves an expropriation proceeding filed by the Republic
of the Philippines against Carmen M. Vda. de Castellvi and Maria Nieves Toledo Gozun. The Republic
sought to acquire parcels of land owned by the defendants for public use. The lower court fixed the
provisional value of the lands at P259,669.10 and appointed three commissioners to determine the
just compensation for the properties. The commissioners recommended a price of P10.00 per square
meter for the lands, but the defendants argued that the fair market value was P15.00 per square meter.
The lower court ultimately ruled that P10.00 per square meter was a fair and just compensation for the
lands.
Issue:
The main issue raised in the case is whether the fair market value of the lands should be fixed at P10.00
per square meter, as determined by the lower court, or at a different amount.
Ruling:
The Supreme Court upheld the lower court's ruling, stating that the lands were residential and suitable
for subdivision development. The court considered the commissioners' recommendation, the
documentary evidence, and the location and potential uses of the lands in determining the fair market
value. The court concluded that P5.00 per square meter would be a fair valuation and just
compensation for the lands. The court also held that the Republic was not liable to pay interest on the
value of the lands from the date of illegal possession, as the possession was a result of the
expropriation proceedings.
Ratio:
The court considered various factors in determining the fair market value of the lands. It took into
account the commissioners' recommendation, which was based on their observations and the
testimonies of the owners and other witnesses. The court also considered the documentary evidence
and the location and potential uses of the lands. The court noted that the lands were residential and
suitable for subdivision development, which increased their value.
In fixing the fair market value at P5.00 per square meter, the court also took into consideration the
rising trend of land values and the lowered purchasing power of the Philippine peso. The court found
that P10.00 per square meter, as determined by the lower court, was exorbitant and unconscionable.
Therefore, the court decided to lower the fair market value to P5.00 per square meter.
Regarding the issue of interest, the court held that the Republic was not liable to pay interest on the
value of the lands from the date of illegal possession. The court reasoned that the possession was a
result of the expropriation proceedings and that Castellvi had agreed to receive rentals from the
Republic for the period in question. Therefore, Castellvi cannot be entitled to interest during the same
period.
The court also addressed the Republic's argument for a new trial based on newly discovered evidence.
The court found that the alleged newly discovered evidence, which included deeds of sale showing
the sale price of other lands in the area, was immaterial and irrelevant. The court noted that the lands
in question were residential lands, while the sales mentioned in the deeds were for sugar lands.
Additionally, the court found that the Republic did not exercise reasonable diligence in discovering
and producing the evidence during the trial. Therefore, the court denied the motion for a new trial.
Page 17 of 62 | 1M 2023-2024
In conclusion, the court modified the decision appealed from by fixing the fair market value of the lands
at P5.00 per square meter and ordering the Republic to pay just compensation to Castellvi and Toledo-
Gozun. The court also enforced the attorney's lien of Atty. Alberto Cacnio and ordered the Republic
to pay the costs of the case.
Page 18 of 62 | 1M 2023-2024
Republic vs. Lim [G.R. No. 161656, June 29, 2005]
The Supreme Court of the Philippines grants the Denzons the right to recover possession of
expropriated property after the Republic fails to compensate them for over 50 years,
emphasizing the importance of prompt payment of just compensation in expropriation cases.
Facts:
The case of Republic v. Lim involves the Republic of the Philippines' failure to compensate the owners
of Lots 932 and 939 for over 50 years after expropriating the properties for the purpose of establishing
a military reservation. The Republic took possession of the lots in 1938 and a court decision in 1940
ordered the Republic to pay just compensation to the owners, but it failed to do so. The owners filed
an action for recovery of possession in 1961, and in 1962, the court ruled in their favor, declaring them
as the owners of the lots and ordering them to execute a deed of sale in favor of the Republic. However,
the court also acknowledged that the Republic had not paid just compensation and allowed the owners
to demand the fair market value of the lots.
Issue:
The main issue raised in the case is whether the Republic's failure to pay just compensation for over
50 years constitutes a deliberate refusal and entitles the owners to recover possession of the lots.
Ruling:
The Supreme Court ruled in favor of the owners and allowed them to recover possession of the lots.
The court affirmed the lower court's decision but emphasized the importance of prompt payment of
just compensation in expropriation cases. The court stated that the non-payment of just compensation
within five years from the finality of the judgment in the expropriation proceedings would entitle the
owners to recover possession of their property.
Ratio:
The court based its decision on the principle that the government cannot keep the property and
dishonor the judgment. It emphasized that it is the government's duty to facilitate the payment of just
compensation and that the non-payment of just compensation within a reasonable time renders the
expropriation process incomplete. The court noted that the Republic's failure to pay just compensation
for over 50 years constituted a deliberate refusal and was contrary to the rules of fair play. The court
also highlighted that just compensation includes not only the correct determination of the amount to
be paid but also the payment within a reasonable time. Therefore, the court concluded that the owners
were entitled to recover possession of the lots due to the Republic's failure to pay just compensation.
Page 19 of 62 | 1M 2023-2024
D. POWER OF TAXATION
Sison vs. Ancheta, [G.R. No. L-59431, July 25, 1984]
A petitioner challenges the constitutionality of a provision in the National Internal Revenue Code,
arguing that it violates equal protection and uniformity in taxation, but the court dismisses the
petition, stating that there is no factual foundation to prove arbitrariness and that the distinction
between compensation and taxable net income is reasonable.
Facts:
The case of Sison, Jr. v. Ancheta involves a challenge to the constitutionality of a provision in the
National Internal Revenue Code. The petitioner, Sison, Jr., questioned the constitutionality of Section
21 of the Code, which imposed a higher tax rate on compensation income compared to taxable net
income. Sison, Jr. argued that this distinction violated the equal protection clause and the principle of
uniformity in taxation. The case was decided on July 25, 1984, by the Supreme Court of the Philippines,
with Chief Justice Fernando as the ponente.
Issue:
The main issue raised in the case was whether the provision in the National Internal Revenue Code,
which imposed a higher tax rate on compensation income compared to taxable net income, violated
the equal protection and uniformity in taxation clauses of the Constitution.
Ruling:
The Supreme Court, in its ruling, dismissed the petition and upheld the constitutionality of the provision
in question. The Court held that there was no factual foundation to prove arbitrariness in the distinction
between compensation and taxable net income. The Court also found that the distinction was
reasonable and based on valid considerations, such as the need to provide relief to low-income
individuals and to ensure the progressivity of the tax system.
Ratio:
In its ratio decidendi, the Court explained that the equal protection clause does not require absolute
equality in taxation. It only requires that the classification made by the law must be reasonable and
based on valid distinctions. The Court found that the distinction between compensation and taxable
net income was reasonable, as it was based on the different nature and sources of these types of
income. The Court also emphasized that the legislature has the power to classify subjects of taxation
and to prescribe different tax rates for different classes of income.
Furthermore, the Court held that the principle of uniformity in taxation does not mean that all taxpayers
should be treated identically. It only requires that all persons belonging to the same class be taxed
alike. In this case, the Court found that the distinction between compensation and taxable net income
created a valid classification, as it treated individuals with different types of income differently.
Conclusion
In conclusion, the Supreme Court dismissed the petition challenging the constitutionality of the
provision in the National Internal Revenue Code. The Court held that there was no factual foundation
to prove arbitrariness in the distinction between compensation and taxable net income. The Court also
found that the distinction was reasonable and based on valid considerations, such as the need to
provide relief to low-income individuals and to ensure the progressivity of the tax system.
Page 20 of 62 | 1M 2023-2024
Pascual vs. Secretary of Public Works [G.R. No. L-10405, December 29, 1960]
The Supreme Court rules in favor of Pascual, declaring the appropriation and subsequent
donation of private feeder roads to the government as unconstitutional, establishing principles
on the use of public funds and the right of taxpayers to challenge legislation involving public
expenditure.
Facts:
The case of Pascual v. Secretary of Public Works and Communications involves a dispute over the
appropriation and subsequent donation of private feeder roads to the government. The petitioner,
Wenceslao Pascual, in his capacity as Provincial Governor of Rizal, filed a petition for declaratory relief
and injunction, arguing that the appropriation of funds for the construction of the feeder roads was
unconstitutional. The respondent, Secretary of Public Works and Communications, argued that the
petitioner did not have the legal capacity to sue and that the appropriation was valid.
Issue:
The main issue in the case is whether the appropriation of public funds for the construction of private
feeder roads is constitutional.
Ruling:
The Supreme Court ruled in favor of the petitioner, declaring the appropriation and subsequent
donation of the private feeder roads to the government as unconstitutional.
Ratio:
The Court held that the legislature is without power to appropriate public revenues for anything but a
public purpose. The essential character of the direct object of the expenditure must determine its
validity as justifying a tax, and not the magnitude of the interests to be affected or the degree to which
the general advantage of the community may be benefited. The Court emphasized that public funds
may only be used for a public purpose, and the right of the legislature to appropriate public funds is
correlative with its right to tax. The Court further stated that the test of the constitutionality of a statute
requiring the use of public funds is whether the statute is designed to promote the public interests, as
opposed to the furtherance of the advantage of individuals.
The Court also held that the subsequent donation of the private feeder roads to the government did
not cure the basic defect of the appropriation. The donation was made over five months after the
approval and effectivity of the Act, and it was done to give a "semblance of legality" to the
appropriation. The Court ruled that the appropriation was null and void because the land on which the
feeder roads were to be constructed belonged to a private person at the time of the appropriation. The
Court further emphasized that a judicial nullification of the donation was not necessary before declaring
the appropriation unconstitutional.
Additionally, the Court recognized the right of taxpayers to contest the constitutionality of legislation
appropriating public funds. The Court stated that the relationship between the people of the Philippines
and its taxpayers, and the Republic of the Philippines, is closer to that existing between the people
and taxpayers of each state and the government thereof. Therefore, the rule recognizing the right of
taxpayers to challenge the constitutionality of legislation appropriating local or state public funds,
which has been upheld by the Federal Supreme Court, has greater application in the Philippines.
In conclusion, the Supreme Court ruled in favor of the petitioner, declaring the appropriation and
subsequent donation of private feeder roads to the government as unconstitutional. The Court
established principles on the use of public funds and the right of taxpayers to challenge legislation
involving public expenditure.
Page 21 of 62 | 1M 2023-2024
Lladoc vs. Commissioner of Internal Revenue [G.R. No. L-19201, June 16, 1965]
A Catholic priest appeals a gift tax assessment on a donation made to the church, arguing that
he should not be held liable as he was not the parish priest at the time, leading to the Supreme
Court affirming the tax liability but holding the Head of the Diocese responsible for payment.
Facts:
In the case of Lladoc v. Commissioner of Internal Revenue, Rev. Fr. Casimiro Lladoc appealed a gift
tax assessment on a donation made to the church. The donation was made by M.B. Estate, Inc. in
1957 for the construction of a new Catholic Church in Victorias, Negros Occidental. The total amount
of P10,000.00 was spent for the intended purpose. The donor filed the gift tax return in 1958, and in
1960, the Commissioner of Internal Revenue issued an assessment for the donee's gift tax against the
Catholic Parish of Victorias, of which Fr. Lladoc was the priest. Fr. Lladoc protested the assessment,
claiming that he should not be liable for the tax as he was not the parish priest at the time of the
donation. He also argued that the assessment would be a violation of the Constitution.
Issue:
The main issues raised in the case are:
Whether or not Fr. Lladoc should be held liable for the gift tax assessment on the donation made to
the church.
Whether or not the assessment of gift tax on the donation would be a violation of the Constitution.
Ruling:
The Court of Tax Appeals affirmed the assessment, stating that the gift tax is not a property tax but an
excise tax imposed on the transfer of property by way of gift inter vivos. The court held that the
exemption from taxation for religious purposes in the Constitution only applies to property taxes, not
excise taxes. The court also noted that the head of the diocese, not the parish priest, is the real party
in interest in the imposition of the gift tax on property donated to the church. Therefore, the court
ordered the Head of the Diocese to pay the gift tax. The decision of the Court of Tax Appeals was
affirmed by the Supreme Court, with the modification that Fr. Lladoc is not personally liable for the gift
tax and the Head of the Diocese should pay the tax.
Ratio:
The court ruled that Fr. Lladoc should not be held personally liable for the gift tax assessment on the
donation made to the church. The court explained that the gift tax is an excise tax imposed on the
transfer of property by way of gift inter vivos, and it is not considered a property tax. Therefore, Fr.
Lladoc, as the parish priest at the time of the assessment, should not be held personally liable for the
tax.
The court also clarified that the exemption from taxation for religious purposes in the Constitution only
applies to property taxes, not excise taxes. This means that while religious institutions may be exempt
from property taxes, they are still subject to other types of taxes, such as gift taxes.
Furthermore, the court emphasized that the head of the diocese, not the parish priest, is the real party
in interest in the imposition of the gift tax on property donated to the church. Therefore, the court
ordered the Head of the Diocese to pay the gift tax assessment.
In summary, the court held that Fr. Lladoc is not personally liable for the gift tax assessment, and the
Head of the Diocese should pay the tax. The court's decision was based on the distinction between
property taxes and excise taxes, as well as the interpretation of the exemption for religious purposes
in the Constitution.
Page 22 of 62 | 1M 2023-2024
Abra Valley College vs. Aquino [G.R. No. L-39086, June 15, 1988]
Abra Valley College, Inc. files a complaint to annul the seizure and sale of its property for non-
payment of real estate taxes, but the Supreme Court rules that the property is not exempt from
taxes due to its incidental use for residential and commercial purposes.
Facts:
The case of Abra Valley College, Inc. v. Aquino involves a complaint filed by Abra Valley College, Inc.
to annul the seizure and sale of its property for non-payment of real estate taxes. The complaint was
filed on July 10, 1972, by Abra Valley College, Inc., represented by Pedro V. Borgonia. The property in
question is a lot and building located in Bangued, Abra. The seizure and sale of the property were
carried out by the Municipal Treasurer of Bangued and the Provincial Treasurer of Abra. The highest
bid of P6,000.00 was made by Dr. Paterno Millare, the then Municipal Mayor of Bangued, and the
certificate of sale was issued to him. The trial court declared the seizure and sale valid and ordered
the college to pay the back taxes. The court also confiscated the deposit made by the college and
ordered the dismissal of the case.
Issue:
The main issue in the case is whether the lot and building of Abra Valley College, Inc. are used
exclusively for educational purposes.
Ruling:
The Supreme Court ruled in favor of the respondents and affirmed the decision of the trial court with
a modification.
Ratio:
The Court held that the phrase "used exclusively for educational purposes" includes incidental use
and facilities that are reasonably necessary for the accomplishment of educational purposes. However,
the Court noted that the lease of the ground floor of the college building to a commercial establishment
was not raised in the trial court and cannot be considered for the first time on appeal. The Court
affirmed the validity of the seizure and sale of the property and ordered the college to pay half of the
assessed tax.
Page 23 of 62 | 1M 2023-2024
E. DUE PROCESS
Atty. Howard M. Calleja, et al. Vs. Executive Secretary, et al. [G.R. No. 252578, et al., December
7, 2021]
The Supreme Court affirms the constitutionality of the Anti-Terrorism Act of 2020, balancing
national security concerns with civil liberties and human rights protection.
Facts:
The case titled "Calleja v. Executive Secretary" was decided by the Supreme Court on December 7,
2021. The case involves multiple petitioners who challenged the constitutionality of the Anti-Terrorism
Act of 2020. The petitioners include lawyers, religious groups, labor unions, party-list representatives,
trade unions, human rights advocates, journalists, and various individuals. They argued that the Anti-
Terrorism Act of 2020 violates several provisions of the Constitution, particularly those protecting civil
liberties and human rights. They raised concerns about the broad and vague definition of terrorism,
the powers granted to the Anti-Terrorism Council (ATC), the potential for abuse and violation of due
process rights, and the chilling effect on freedom of expression and assembly.
Issue:
The main issue raised in the case is whether or not the Anti-Terrorism Act of 2020 is constitutional.
The petitioners argued that the law is unconstitutional due to its potential to infringe on civil liberties
and human rights.
Ruling:
The Supreme Court, in a majority decision, upheld the constitutionality of the Anti-Terrorism Act of
2020. The Court ruled that the law is a valid exercise of the state's police power to protect national
security and public safety. The Court emphasized the importance of balancing national security
concerns with the protection of civil liberties and human rights.
Ratio:
The Court's ruling was based on several key arguments. Firstly, the Court held that the definition of
terrorism under the law is not overly broad or vague, as it includes specific elements and requirements.
The Court also emphasized that the law contains sufficient safeguards and procedural safeguards to
prevent abuse and protect the rights of individuals.
Furthermore, the Court ruled that the powers granted to the ATC are necessary and proportionate to
address the threat of terrorism. The Court noted that the ATC is subject to checks and balances,
including judicial review, and that its actions are subject to scrutiny and accountability.
The Court also addressed concerns about the potential chilling effect on freedom of expression and
assembly. The Court held that the law does not unduly restrict these rights and that legitimate forms
of dissent and protest are protected. The Court emphasized that the law targets only acts of terrorism
and not legitimate forms of expression or advocacy.
In conclusion, the Supreme Court affirmed the constitutionality of the Anti-Terrorism Act of 2020. The
Court balanced national security concerns with the protection of civil liberties and human rights, ruling
that the law is a valid exercise of the state's police power. The Court emphasized that the law contains
sufficient safeguards and procedural safeguards to prevent abuse and protect individual rights.
Page 24 of 62 | 1M 2023-2024
Ynot vs. Intermediate Appellate Court [G.R. No. 74457, March 20, 1987]
A man fights against the unconstitutional confiscation of his carabaos by challenging an

executive order that prohibits their interprovincial movement, leading to a landmark Supreme
Court ruling on due process and separation of powers.
Facts:
In the case of Ynot v. Intermediate Appellate Court, the petitioner, Restituto Ynot, transported six
carabaos from Masbate to Iloilo. However, the police confiscated the carabaos for violating Executive
Order No. 626-A, which prohibited the interprovincial movement of carabaos and the slaughtering of
carabaos not complying with certain requirements. Ynot filed a complaint for recovery, but the trial
court upheld the confiscation and ordered the confiscation of Ynot's bond. The Intermediate Appellate
Court affirmed the trial court's decision, prompting Ynot to file a petition for review on certiorari before
the Supreme Court.
Issue:
The main issue raised in the case was the constitutionality of Executive Order No. 626-A, specifically
the provision authorizing the confiscation of carabaos or carabeef being transported across provincial
boundaries. Ynot argued that the penalty was imposed without giving the owner a right to be heard
before a competent and impartial court, thereby violating due process. He also challenged the exercise
of legislative power by the former President under Amendment No. 6 of the 1973 Constitution.
Ruling:
The Supreme Court ruled in favor of Ynot, declaring Executive Order No. 626-A unconstitutional. The
Court held that the method employed in the executive order, which imposed an absolute ban on the
interprovincial transport of carabaos, was not reasonably necessary to achieve the purpose of the law
and was unduly oppressive. The Court also found that due process was violated because the owner
of the confiscated property was denied the right to be heard in his defense and was immediately
condemned and punished. Additionally, the Court found that there was an encroachment on judicial
functions and an invalid delegation of legislative powers in the executive order.
Ratio:
The Court reasoned that the absolute ban on the interprovincial transport of carabaos was not
reasonably necessary to achieve the purpose of the law, which was to prevent the spread of diseases
among carabaos. The Court emphasized that there were less restrictive means available to achieve
the same objective, such as requiring the certification of veterinarians or the imposition of stricter
sanitary measures. The Court found that the method employed in the executive order was unduly
oppressive as it deprived the owners of their property without due process.
Furthermore, the Court held that due process was violated because the owner of the confiscated
property was not given the opportunity to be heard in his defense before a competent and impartial
court. The Court emphasized that the right to be heard is a fundamental aspect of due process and
should not be disregarded. The immediate condemnation and punishment of the owner without a fair
hearing was deemed unconstitutional.
The Court also found that there was an encroachment on judicial functions and an invalid delegation
of legislative powers in the executive order. The Court emphasized that the power to determine the
guilt or innocence of an accused and to impose penalties for violations of the law belongs to the
judiciary and cannot be delegated to the executive branch. The executive order, in authorizing the
confiscation of property without judicial intervention, encroached upon the functions of the judiciary
and violated the principle of separation of powers.
In conclusion, the Supreme Court ruled that Executive Order No. 626-A was unconstitutional due to
its unreasonable and oppressive method, violation of due process, encroachment on judicial functions,
Page 25 of 62 | 1M 2023-2024
and invalid delegation of legislative powers. The Court reversed the decision of the Intermediate
Appellate Court, cancelled the supersedeas bond, and ordered the restoration of the bond amount to
Ynot. The Court commended Ynot for asserting and protecting his rights, highlighting the importance
of the people's courage to invoke their rights whenever they are ignored or violated.
Page 26 of 62 | 1M 2023-2024
Alonte vs. Savellano [G.R. No. 131652, March 9, 1998]
The conviction of two individuals for rape is upheld despite the complai t's affidavit of
desistance, as the court emphasizes the importance of due process and the unreliability of such
affidavits.
Facts:
This case involves two separate petitions filed by Bayani M. Alonte and Buenaventura Concepcion,
who were both found guilty of rape by the Regional Trial Court (RTC) of Manila. The charges were
based on a complaint filed by Juvie-lyn Punongbayan. The case was initially assigned to Branch 25 of
the RTC of Biñan, Laguna, but was later transferred to Branch 53 of the RTC of Manila.
During the proceedings, Punongbayan executed an affidavit of desistance, expressing her desire to
withdraw her complaint. However, the court found that the affidavit of desistance did not warrant the
dismissal of the case, as it was filed after the institution of the criminal case. The court also noted that
the affidavit did not disavow the veracity of Punongbayan's original complaint.
The court further found that there were procedural irregularities in the trial. The order of trial was not
followed, as the prosecution presented evidence on the voluntariness and validity of the affidavit of
desistance before the accused had the opportunity to present their defense. The court emphasized
the importance of due process and the need for a fair trial.
The court also discussed the legal implications of an affidavit of desistance in cases of private crimes,
such as rape. It clarified that an affidavit of desistance, by itself, is not a ground for the dismissal of a
criminal case once it has been instituted. The court stated that the affidavit may constitute evidence,
but its weight and probative value would be subject to the court's evaluation.
Based on these findings, the court declared the judgment of the RTC null and void and remanded the
case for further proceedings. The court also enjoined Judge Maximo A. Savellano, Jr. from further
hearing the case and ordered that it be raffled among the other branches of the RTC of Manila for
proper disposition.
In a separate concurring and dissenting opinion, Justice Puno agreed with the majority's decision to
remand the case for further proceedings but disagreed with the disqualification of Judge Savellano.
Justice Puno emphasized the need for an impartial and neutral judge and the importance of civility
among members of the legal profession.
Issue:
The main issue in the case is whether the affidavit of desistance filed by the private complainant is a
valid ground for the dismissal of the rape charge against the petitioners.
Ruling:
The ruling of the court is that the affidavit of desistance cannot be considered as a valid ground for the
dismissal of the rape charge. The court emphasized that the affidavit did not state that the private
complainant was not raped by the petitioners. Furthermore, the court found that the affidavit was likely
influenced by threats and bribes made to the complainant and her family.
Ratio:
The court highlighted the importance of scrutinizing affidavits of desistance and retractions, as they
can easily be obtained through intimidation or monetary considerations. The court stated that the
previous testimony or statement of the complainant should be carefully compared with the affidavit of
desistance, and the circumstances and motives behind the change should be scrutinized.
Page 27 of 62 | 1M 2023-2024
In this case, the court found that the affidavit of desistance was not credible and did not negate the
previous testimony of the complainant. The court also noted that the filing of a complaint in private
crimes is a condition precedent to the exercise of prosecutorial power, and once the complaint is filed,
the action proceeds as in any other crime.
The court ultimately convicted the petitioners and sentenced them to reclusion perpetua. The court
found that the evidence presented by the prosecution, including the previous testimony of the
complainant, was sufficient to establish the guilt of the petitioners beyond reasonable doubt. The court
also found that the petitioners were denied due process of law, as they were not given the opportunity
to cross-examine the complainant and present their own evidence.
Overall, the court emphasized the importance of carefully considering affidavits of desistance and
retractions, and the need to ensure that the rights of the accused are protected throughout the trial
process.
Page 28 of 62 | 1M 2023-2024
Philippine Communications Satellite Corp. vs. Alcuaz [G.R. No. 84818, December 18, 1989]
The Philippine Supreme Court rules in favor of Philippine Communications Satellite Corporation
(PHILCOMSAT) in their challenge against the National Telecommunications Commission's order
to reduce rates, citing violations of procedural and substantive due process.
Facts:
The case involves the Philippine Communications Satellite Corporation (PHILCOMSAT), the sole
provider of public utility services in the Philippines. PHILCOMSAT filed a petition to annul an order
issued by the National Telecommunications Commission (NTC) that directed a reduction of rates for
certain services provided by PHILCOMSAT. PHILCOMSAT argued that the order violated the
constitutional prohibition against undue delegation of legislative power and denied procedural and
substantive due process.
PHILCOMSAT was granted a franchise to establish and operate satellite communication facilities in
the Philippines. It established various earth stations and provided satellite services to international
carriers. In 1987, PHILCOMSAT was placed under the jurisdiction of the NTC, which required it to
apply for a certificate of public convenience and necessity and seek approval for its rates.
PHILCOMSAT filed an application to continue its operations and charge the current rates. It was
granted a provisional authority, which was extended multiple times. However, the NTC issued an order
directing a reduction of rates by 15% based on an initial evaluation of PHILCOMSAT's financial
statements.
Issue:
The main issue raised in the case is whether the NTC's order to reduce rates is a violation of the
constitutional prohibition against undue delegation of legislative power and a denial of procedural and
substantive due process.
Ruling:
The Supreme Court ruled in favor of PHILCOMSAT. The Court held that the NTC's rate-fixing power
is a valid delegation of legislative power because it is guided by the requirements of public safety,
public interest, reasonable feasibility, and reasonable rates. The Court also held that the NTC's order
violated procedural due process because it was issued without prior notice and hearing. The Court
emphasized that even temporary rate-fixing orders should be subject to the statutory procedural
requirements of notice and hearing. The Court further ruled that the rate reduction imposed by the
NTC was confiscatory and violated substantive due process because it would adversely affect
PHILCOMSAT's operations and the quality of its service. The Court nullified the NTC's order and
directed the NTC to proceed with the hearing and determination of PHILCOMSAT's application for a
certificate of public convenience and necessity.
Ratio:
The Supreme Court's decision was based on several grounds. Firstly, the Court held that the NTC's
rate-fixing power is a valid delegation of legislative power. The Court reasoned that the NTC's power
is guided by the requirements of public safety, public interest, reasonable feasibility, and reasonable
rates, which are sufficient standards to prevent the abuse of discretion. Therefore, the delegation of
legislative power to the NTC is constitutional.
Secondly, the Court found that the NTC's order violated procedural due process. The Court
emphasized the importance of notice and hearing in rate-fixing proceedings, even for temporary rate
reductions. The NTC's failure to provide PHILCOMSAT with prior notice and an opportunity to be heard
before issuing the rate reduction order was a violation of procedural due process.
Lastly, the Court ruled that the rate reduction imposed by the NTC was confiscatory and violated
substantive due process. The Court considered the adverse impact of the rate reduction on
Page 29 of 62 | 1M 2023-2024
PHILCOMSAT's operations and the quality of its service. The Court concluded that the rate reduction
was unreasonable and would unduly burden PHILCOMSAT, thus violating substantive due process.
In conclusion, the Supreme Court ruled in favor of PHILCOMSAT, declaring that the NTC's order to
reduce rates violated the constitutional prohibition against undue delegation of legislative power and
denied procedural and substantive due process. The Court emphasized the importance of notice and
hearing in rate-fixing proceedings and nullified the NTC's order. The Court directed the NTC to proceed
with the hearing and determination of PHILCOMSAT's application for a certificate of public
convenience and necessity.
Page 30 of 62 | 1M 2023-2024
Ang Tibay vs. Court of Industrial Relations [G.R. No. 46496, February 27, 1940]
In the Philippine Jurisprudence case of Ang Tibay v. Court of Industrial Relations, the Court
grants a new trial to allow the presentation of additional evidence, emphasizing the importance
of due process and the right to a fair hearing in administrative proceedings.
Facts:
The case of Ang Tibay v. Court of Industrial Relations involves a dispute between Ang Tibay,
represented by Toribio Teodoro, and the National Workers' Brotherhood, against the Court of Industrial
Relations and the National Labor Union, Inc. The case was decided on February 27, 1940, by the En
Banc of the Supreme Court of the Philippines, with Justice Laurel as the ponente.
Issue:
The main issue raised in the case is whether the Court of Industrial Relations violated the fundamental
requirements of due process in trials and investigations of an administrative character.
Ruling:
The Court ruled in favor of the respondent and granted a new trial. The case was remanded to the
Court of Industrial Relations with instructions to reopen the case, receive all relevant evidence, and
proceed in accordance with the requirements of due process.
Ratio:
The Court emphasized that the Court of Industrial Relations, although a special court with broad
powers, is not exempt from the fundamental requirements of due process. The Court must respect
cardinal primary rights, including the right to a hearing and the right to present evidence. The tribunal
must consider the evidence presented and render a decision based on the evidence presented at the
hearing or contained in the record. The decision must be supported by substantial evidence.
In this case, the Court found that the record was barren and did not provide a factual basis for a
rational conclusion of law, except for the alleged agreement between Ang Tibay and the National
Workers' Brotherhood. However, the respondent requested the opportunity to present evidence to
prove their allegations, including records from the Bureau of Customs and the Books of Accounts of
native dealers in leather.
The Court concluded that the interest of justice would be better served by granting a new trial and
allowing the respondent to present the relevant evidence. The legislation that created the Court of
Industrial Relations is new, and the parties may not have fully understood the fundamental issue
involved. Therefore, the case was remanded to the Court of Industrial Relations with instructions to
reopen the case, receive all relevant evidence, and proceed in accordance with the requirements of
due process.
The decision was concurred by Chief Justice Avancea and Justices Villa-Real, Imperial, Diaz,
Concepcion, and Moran.
Page 31 of 62 | 1M 2023-2024
Ateneo de Manila vs. Capulong [G.R. No. 99327, May 27, 1993]
The Ateneo De Manila University expelled students accused of participating in hazing activities,
leading to a legal battle over whether the students were afforded procedural due process, with
the court ultimately ruling in favor of the university.
Facts:
The case of Ateneo De Manila University v. Capulong involves the expulsion of students accused of
participating in hazing activities. In February 1991, the Aquila Legis fraternity held initiation rites, during
which a student named Leonardo Villa died from serious physical injuries and another student named
Bienvenido Marquez was hospitalized. The university formed a Joint Administration-Faculty-Student
Investigating Committee to look into the incident. The committee found a prima facie case against the
accused students and required them to submit written statements in response to the charges. Some
students complied, while others requested copies of the charges. The committee then held hearings
and considered the evidence before finding the students guilty of violating the university's disciplinary
rules on hazing.
Issue:
The main issue raised in the case is whether the students were denied procedural due process in the
disciplinary proceedings.
Ruling:
The court ruled in favor of the university, finding that the students were afforded procedural due
process.
Ratio:
The court cited previous cases that established the minimum standards to be satisfied in disciplinary
proceedings in academic institutions. These standards include informing the students in writing of the
nature and cause of the accusations against them, giving them the right to answer the charges with
the assistance of counsel, informing them of the evidence against them, allowing them to adduce
evidence in their own behalf, and ensuring that the evidence is duly considered by the investigating
committee or official designated by the school authorities.
The court found that the university met these requirements by providing the students with written
notices and opportunities to submit written statements and present evidence in their defense. The
court also rejected the argument that the students were entitled to cross-examine the affiants-
neophytes, as disciplinary proceedings involving students do not necessarily include the right to cross-
examination.
The court also addressed the argument that the university failed to define the term "hazing" and did
not provide proof that the students were furnished copies of the rules prohibiting hazing. The court
held that the disciplinary proceedings were administrative in nature and did not require the same level
of specificity as criminal proceedings. The court found that the university had given prior notice to the
students that hazing would be defined in accordance with a proposed bill on the subject, and that this
was sufficient for the purposes of the investigation.
The court also considered the issue of academic freedom and the right of the university to establish
its own disciplinary rules and standards. The court recognized that universities have the right to
establish reasonable rules and regulations for the admission, discipline, and promotion of students.
The court emphasized that the university's decision to expel the students was congruent with the
gravity of their misdeeds and necessary to maintain a morally conducive and orderly educational
environment.
Page 32 of 62 | 1M 2023-2024
In conclusion, the court ruled in favor of the university, finding that the students were afforded
procedural due process in the disciplinary proceedings and that the penalty of dismissal imposed by
the university was proper under the circumstances. The court reversed the order of the trial court
reinstating the students and affirmed the university's decision to expel them.
Page 33 of 62 | 1M 2023-2024
F. EQUAL PROTECTION
People vs. Vera [G.R. No. 45685, November 16, 1937]
The Supreme Court denies the petition for a supersedeas bond, ruling that it is not applicable
to the judgment declaring the Probation Act unconstitutional and void, but rather to the final
judgment in the criminal case against Mariano Cu Unjieng.
Facts:
The case of People v. Vera involves a petition filed by the People of the Philippines and the Hongkong
& Shanghai Banking Corporation against Jose O. Vera, the Judge ad interim of the First Instance of
Manila, and Mariano Cu Unjieng. The case was decided on December 22, 1937, by the First Division
of the Supreme Court, with Justice Laurel as the ponente.
Issue:
The main issue in the case is whether a supersedeas bond should be granted to stay the execution of
the judgment declaring the Probation Act unconstitutional and void.
Ruling:
The Supreme Court ruled that the supersedeas bond is not applicable to the judgment declaring the
Probation Act unconstitutional and void.
Ratio:
The court explains that the judgment does not command or permit any act to be done, and therefore,
there is nothing to be actively enforced by execution or otherwise. The supersedeas bond is intended
to operate on the decision and judgment in the criminal case against Mariano Cu Unjieng. The court
emphasizes that the public interest and the speedy administration of justice demand the prompt
execution of the final sentence of conviction against the petitioner. Mariano Cu Unjieng has already
had ample time and opportunity to defend himself, and he must abide by the judgment and serve his
term. The court also notes that the petition for probation has already been denied by the trial court.
The court further explains that as a rule of federal practice in the United States, the execution and
enforcement of a final judgment or decree subject to review by the Supreme Court of the United States
on writ of certiorari is discretionary with a judge of the court rendering the judgment or decree or a
Justice of the Supreme Court. The court cites a case from the Supreme Court of the United States,
which states that the circuit court of appeals, with its complete knowledge of the case, is in a position
to judge whether the case is likely to be taken up by the Supreme Court on certiorari and whether the
balance of convenience requires a suspension of its decree. The Supreme Court requires an
extraordinary showing before granting a stay of the decree below pending the application for a
certiorari.
Based on these arguments and legal principles, the Supreme Court denies the petition for a
supersedeas bond, stating that it is not applicable to the judgment declaring the Probation Act
unconstitutional and void, but rather to the final judgment in the criminal case against Mariano Cu
Unjieng. The court emphasizes the importance of prompt execution of the final sentence of conviction
and the need for Mariano Cu Unjieng to serve his term.
Page 34 of 62 | 1M 2023-2024
Biraogo vs. The Philippine Truth Commission [G.R. No. 192935, December 7, 2010]
The Supreme Court declares Executive Order No. 1 unconstitutional for encroaching on the
powers of Congress, violating the equal protection clause, and supplanting the powers of the
Office of the Ombudsman and the Department of Justice.
Facts:
On July 30, 2010, President Benigno Aquino III signed Executive Order No. 1, creating the Philippine
Truth Commission of 2010. The purpose of the commission was to investigate reports of graft and
corruption allegedly committed during the previous administration. The commission was composed
of a Chairman and four members, and it had the power to subpoena witnesses and collect documents.
Issue:
The main issue raised in the case is whether or not Executive Order No. 1 is constitutional. The
petitioners argue that the creation of the commission violates the separation of powers, as it
encroaches on the powers of Congress to create a public office and appropriate funds. They also
argue that the commission supplants the powers of the Office of the Ombudsman and the Department
of Justice, and that it violates the equal protection clause by selectively targeting officials of the
previous administration.
Ruling:
The Supreme Court ruled that Executive Order No. 1 is unconstitutional. The Court held that the power
to create a public office is not within the President's authority to reorganize the Office of the President
under Section 31 of the Revised Administrative Code. The Court also found that the commission's
power to investigate does not violate the powers of the Ombudsman and the Department of Justice,
as it is limited to fact-finding and does not have quasi-judicial powers. However, the Court found that
the commission's selective targeting of officials of the previous administration violates the equal
protection clause, as it does not apply equally to all members of the same class. The Court emphasized
that the commission's findings are only recommendatory and do not have the power to adjudicate
rights or impose penalties.
Ratio:
The Court reasoned that the power to create a public office is a legislative power that belongs to
Congress, and the President does not have the authority to create a new office without a law
authorizing it. The Court found that Executive Order No. 1 goes beyond the President's authority to
reorganize the Office of the President and creates an entirely new office, which is a legislative function.
The Court also explained that the commission's power to investigate does not violate the powers of
the Ombudsman and the Department of Justice, as it is limited to fact-finding and does not have quasi-
judicial powers. The commission's role is to gather evidence and make recommendations, but it does
not have the power to adjudicate rights or impose penalties.
Furthermore, the Court found that the commission's selective targeting of officials of the previous
administration violates the equal protection clause. The commission's focus on the previous
administration and its exclusion of other administrations and officials creates a classification that is
not based on substantial distinctions. This differential treatment is not justified by a compelling state
interest.
In conclusion, the Supreme Court declared Executive Order No. 1 unconstitutional for encroaching on
the powers of Congress, violating the equal protection clause, and supplanting the powers of the
Office of the Ombudsman and the Department of Justice. The Court emphasized the importance of
upholding the separation of powers and the equal protection of the laws.
Page 35 of 62 | 1M 2023-2024
Ormoc Sugar Co., Inc. vs. Treasurer of Ormoc City [G.R. No. L-23794, February 17, 1968]
The Supreme Court declares a municipal tax on the export sale of sugar unconstitutional, ruling
that the tax ordi ce violated the equal protection clause and the rule of uniformity of taxation.
Facts:
The case of Ormoc Sugar Co. Inc. v. Treasurer of Ormoc City involves the constitutionality of a
municipal tax imposed on the export sale of sugar. On January 29, 1964, the Municipal Board of Ormoc
City passed Ordinance No. 4, Series of 1964, which imposed a municipal tax of one percent on the
export sale of centrifugal sugar produced by Ormoc Sugar Company, Inc. The company paid the tax
under protest, amounting to a total of P12,087.50. Ormoc Sugar Company, Inc. then filed a complaint
before the Court of First Instance of Leyte, alleging that the ordinance was unconstitutional for violating
the equal protection clause and the rule of uniformity of taxation, as well as being an export tax
prohibited under the Revised Administrative Code.
Issue:
The main issue raised in the case is whether the tax ordinance is constitutional.
Ruling:
The Court ruled that the tax ordinance violated the equal protection clause and the rule of uniformity
of taxation.
Ratio:
The equal protection clause applies only to persons or things identically situated and does not bar a
reasonable classification of the subject of legislation. A classification is reasonable if it is based on
substantial distinctions that make real differences, is germane to the purpose of the law, applies to
present and future conditions, and applies only to those who belong to the same class. In this case,
the tax ordinance only applied to centrifugal sugar produced and exported by Ormoc Sugar Company,
Inc., excluding any subsequently established sugar central of the same class. Therefore, the
classification was not reasonable.
The Court also held that the tax ordinance violated the rule of uniformity of taxation. The ordinance
should not be singular and exclusive as to exclude any subsequently established sugar central from
the coverage of the tax. As it stood, even if another sugar central of the same class as the plaintiff was
established, it would not be subject to the tax because the ordinance specifically targeted Ormoc
Sugar Company, Inc.
Regarding the refund of the taxes paid under protest, the Court ruled that the appellant was not entitled
to interest on the refund because the taxes were not arbitrarily collected. At the time of collection, the
ordinance provided a sufficient basis to preclude arbitrariness, and the constitutionality of the statute
is presumed until declared otherwise.
In conclusion, the Supreme Court declared the tax ordinance unconstitutional and ordered the
defendants to refund the amount paid by the plaintiff under protest.
Page 36 of 62 | 1M 2023-2024
G. RIGHT AGAINST UNREASONABLE SEARCHES AND SEIZURES
People vs. Marti [G.R. No. 81561, January 18, 1991]
Defendant Andre Marti is convicted of violating the Dangerous Drugs Act after packages he
attempted to ship containing marijuana are found and seized by a private individual, leading
to a Supreme Court ruling that the evidence is admissible in court despite the defendant's
claim of violation of his constitutional rights.
Facts:
On August 14, 1987, Andre Marti and his common-law wife went to the booth of "Manila Packing
and Export Forwarders" to ship four gift-wrapped packages to a friend in Zurich, Switzerland. The
proprietor of the booth, Anita Reyes, asked to inspect the packages but Marti refused and assured
her that they only contained books, cigars, and gloves. The packages were placed inside a box and
sealed. Before delivery to the Bureau of Customs and/or Bureau of Posts, the proprietor opened
the boxes for final inspection and discovered a peculiar odor coming from one of the packages.
Upon further inspection, dried marijuana leaves were found inside the packages. The proprietor
reported the shipment to the NBI and turned over the samples to them. The NBI agents then went
to the proprietor's office and opened the packages in the presence of the proprietor. Dried
marijuana leaves were found inside. The NBI agents took custody of the packages and submitted
them for laboratory examination, which confirmed that they contained marijuana.
Issue:
The main issue raised in the case is whether the evidence obtained through the search and seizure
of the packages is admissible in court despite the defendant's claim of violation of his constitutional
rights against unreasonable search and seizure.
Ruling:
The court ruled that the evidence is admissible. The court held that the constitutional guarantee
against unreasonable search and seizure applies only to acts committed by the government and its
agencies, not private individuals. In this case, the search and seizure were conducted by a private
individual, the proprietor of the forwarding agency, without the intervention of police authorities.
Therefore, the constitutional rights of the defendant were not violated. The court also noted that the
mere presence of the NBI agents during the search did not convert it into a warrantless search and
seizure, as they were only observing and looking at what was in plain sight.
Ratio:
The court explained that the constitutional rights against unreasonable search and seizure cannot
be invoked against acts of private individuals. The protection against unreasonable searches and
seizures is directed only against the government and its agencies tasked with the enforcement of
the law. The court emphasized that the constitution does not govern relationships between
individuals.
Furthermore, the court found the defendant's claim that he was not the owner of the packages to
be incredulous and self-serving. The defendant failed to provide a plausible explanation for why he
would agree to ship packages for a complete stranger without first ascertaining their contents. The
court also noted that the defendant had a previous conviction for possession of hashish in Germany
and that the consignee of the packages was also convicted for drug abuse.
Based on these findings, the court affirmed the judgment of conviction against the defendant.
Page 37 of 62 | 1M 2023-2024
Stonehill vs. Diokno [G.R. No. L-19550, June 19, 1967]
The court declares search warrants null and void, emphasizing the importance of protecting
the right to be secure against unreasonable searches and seizures, and abandoning the
doctrine allowing the use of evidence obtained through illegal searches and seizures.
Facts:
The case of Stonehill v. Diokno involved the declaration of search warrants as null and void by the
Supreme Court of the Philippines. The decision was made on June 19, 1967, with Chief Justice
Concepcion as the ponente. The case originated from the issuance of search warrants against
several corporations and individuals, including petitioner Stonehill, by respondent Judge Diokno.
The search warrants were issued based on an application filed by the NBI (National Bureau of
Investigation), alleging that the petitioners were involved in various offenses, such as violation of
the Central Bank Act, Tariff and Customs Code, and the Internal Revenue Code. The search
warrants authorized the seizure of documents, papers, and personal properties believed to be
connected to the alleged offenses.
Issue:
The main issue raised in the case was the validity of the search warrants. The petitioners argued
that the search warrants were null and void because they were issued in violation of their
constitutional rights, particularly their right to be secure against unreasonable searches and
seizures. They contended that the search warrants were based on general warrants, which did not
sufficiently describe the things to be seized.
Ruling:
The Supreme Court ruled in favor of the petitioners and declared the search warrants null and void.
The Court emphasized the importance of protecting the right to be secure against unreasonable
searches and seizures, as enshrined in the Constitution. It held that the search warrants were indeed
general warrants, as they failed to particularly describe the things to be seized. The Court also
rejected the doctrine allowing the use of evidence obtained through illegal searches and seizures,
stating that such evidence should be excluded as a deterrent to unlawful police conduct.
Ratio:
In its ratio decidendi, the Court emphasized that the constitutional provision protecting against
unreasonable searches and seizures should be given the utmost importance. It stressed that search
warrants must be based on probable cause and must particularly describe the things to be seized.
The Court also emphasized that evidence obtained through illegal searches and seizures should be
excluded to discourage law enforcement agencies from violating the constitutional rights of
individuals. This landmark decision in Stonehill v. Diokno significantly strengthened the protection
of individual rights against unreasonable searches and seizures in the Philippines.
Page 38 of 62 | 1M 2023-2024
Soliven vs. Makasiar [G.R. No. 82585, November 14, 1988]
A group of petitioners, including newspaper publishers and editors, challenge the filing of
libel charges against them by the President of the Philippines, arguing that it violates their
right to due process and freedom of speech, while also raising concerns about the potential
chilling effect on press freedom.
Facts:
The case of Soliven v. Makasiar involves a group of petitioners, including newspaper publishers
and editors, who challenge the filing of libel charges against them by the President of the
Philippines. The case was heard by the Regional Trial Court of Manila, Branch 35, with Judge
Ramon P. Makasiar presiding.
Issue:
The main issues raised in the case are: (1) whether the petitioners were denied due process when
libel charges were filed against them while the existence of a prima facie case was still under review
by the Secretary of Justice and the President, (2) whether the constitutional rights of petitioner
Beltran were violated when the judge issued a warrant for his arrest without personally examining
the complainant and witnesses to determine probable cause, and (3) whether the President of the
Philippines has the authority to initiate criminal proceedings against the petitioners through the filing
of a complaint-affidavit.
Ruling:
The first issue became moot and academic when the Secretary of Justice denied the petitioners'
motion for reconsideration and upheld the finding of a prima facie case against them. The second
issue regarding the issuance of warrants of arrest was clarified by the court, stating that the judge
is not required to personally examine the complainant and witnesses to determine probable cause.
The judge may rely on the report and supporting documents submitted by the fiscal, or require the
submission of supporting affidavits of witnesses. Regarding the third issue, the court ruled that the
privilege of immunity from suit granted to the President does not prevent her from initiating criminal
proceedings against the petitioners. The President has the prerogative to waive the privilege and
submit to the court's jurisdiction if she chooses to do so. The court also stated that the defense of
privileged character of publication should be left to the trial court to appreciate after receiving the
evidence of the parties.
Ratio:
The court's decision was based on the following arguments and legal basis. First, the court found
that the petitioners were not denied due process as the Secretary of Justice had already reviewed
the existence of a prima facie case against them. The court emphasized that the Secretary of
Justice's decision to uphold the finding of a prima facie case was within his authority and did not
violate the petitioners' right to due process. Second, the court clarified that the judge is not required
to personally examine the complainant and witnesses to determine probable cause for the issuance
of warrants of arrest. The judge may rely on the report and supporting documents submitted by the
fiscal, or require the submission of supporting affidavits of witnesses. This procedure allows judges
to focus on hearing and deciding cases rather than being burdened with preliminary examination
and investigation. Third, the court ruled that the privilege of immunity from suit granted to the
President does not prevent her from initiating criminal proceedings against the petitioners. The
President has the prerogative to waive the privilege and submit to the court's jurisdiction if she
chooses to do so. The court also stated that the defense of privileged character of publication
should be left to the trial court to appreciate after receiving the evidence of the parties. The court
did not rule on the potential chilling effect on press freedom, as it found no basis to do so at that
stage of the case.
Page 39 of 62 | 1M 2023-2024
In conclusion, the court dismissed the petitions, finding no grave abuse of discretion on the part of
the public respondents. The court lifted the order to maintain status quo and allowed the libel case
to proceed. The court emphasized the importance of freedom of expression and the need for
safeguards to prevent the invasion of this freedom in the application of criminal libel laws.
Page 40 of 62 | 1M 2023-2024
Harvey vs. Santiago [G.R. No. 82544, June 28, 1988]
American and Dutch nationals residing in the Philippines are detained and face deportation
after being apprehended for suspected involvement in pedophilia, leading to a legal battle
questioning the validity of their arrest and detention.
Facts:
American and Dutch nationals, Andrew Harvey, John Sherman, and Adriaan Van Den Elshout, were
detained by the Commission on Immigration and Deportation (CID) in Pagsanjan, Laguna, on
suspicion of being involved in pedophilia. They were part of twenty-two suspected alien pedophiles
apprehended after close surveillance in the area. The petitioners challenged the legality of their
arrest and detention, claiming a lack of legal basis for their apprehension, violation of their
constitutional rights against unreasonable searches and seizures, and the absence of a specific
Philippine law criminalizing pedophilia.
Issue:
Whether the arrest and detention of the petitioners were valid and in accordance with the law.
Ruling:
The court upheld the actions of the Commissioner of Immigration and Deportation, affirming the
legality of the petitioners' arrest and detention.
Ratio:
The court ruled that the arrest was based on probable cause after surveillance, justifying the seizure
of incriminating evidence without a warrant. It emphasized that deportation charges were in line
with immigration laws, and the denial of bail was within the Commissioner's discretion. Deportation
proceedings were deemed administrative, not criminal, and the right to bail was not guaranteed in
such cases. The court highlighted the state's authority to exclude undesirable aliens for self-
preservation and public interest, especially in cases involving offenses against children. Ultimately,
the petition was dismissed, and the writ of Habeas Corpus was denied, confirming the legality of
the petitioners' detention and deportation proceedings.
Page 41 of 62 | 1M 2023-2024
People vs. Sucro [G.R. No. 93239, March 18, 1991]
Accused-appellant Edison Sucro is convicted of selling prohibited drugs based on a lawful

arrest and credible testimony, as ruled by the Supreme Court of the Philippines.
Facts:
In the case of People v. Sucro, accused-appellant Edison Sucro was convicted of selling prohibited
drugs based on a lawful arrest and credible testimony. On March 21, 1989, Pat. Roy Fulgencio, a
member of the INP, Kalibo, Aklan, was instructed to monitor the activities of Sucro, who was
suspected of selling marijuana. Fulgencio positioned himself under the house of Arlie Regalado,
adjacent to a chapel where Sucro was seen entering and exchanging items with various individuals.
Fulgencio relayed the information to P/Lt. Seraspi, who instructed him to continue monitoring. Later,
Fulgencio reported that a buyer, Ronnie Macabante, was transacting with Sucro. The police team
intercepted Macabante and found him in possession of a tea bag of marijuana, which he admitted
to buying from Sucro. The police then arrested Sucro and recovered 19 sticks and 4 tea bags of
marijuana from the chapel. Sucro was charged with violation of Section 4, Article II of the Dangerous
Drugs Act.
Issue:
The main issue in the case is whether or not the arrest without warrant of the accused is lawful and
consequently, whether or not the evidence resulting from such arrest is admissible.
Ruling:
The court ruled in favor of the prosecution, affirming the conviction of Sucro.
Ratio:
The court held that the arrest without warrant was lawful under Section 5, Rule 113 of the Rules on
Criminal Procedure, which allows for warrantless arrest when the person to be arrested has
committed, is actually committing, or is attempting to commit an offense, or when an offense has
just been committed and the arresting officer has personal knowledge of facts indicating that the
person to be arrested has committed it. In this case, the police officers had personal knowledge of
Sucro's illegal activities through their surveillance and the immediate apprehension of Macabante,
who admitted to buying marijuana from Sucro.
The court also held that the search and seizure of the marijuana was valid as it was incidental to a
lawful arrest. The police officers had the authority to search the immediate vicinity of the arrestee
for weapons or evidence that could be easily destroyed or concealed.
The court further rejected the accused's defense of alibi, stating that it cannot prevail against the
positive identification of the appellant as the seller of the prohibited substances. The court
emphasized that the findings of the trial court, which found the testimony of Macabante to be
credible and corroborated by the police officers, are entitled to great weight and should not be
disturbed on appeal.
In conclusion, the court affirmed the conviction of Sucro for selling prohibited drugs based on a
lawful arrest and credible testimony. The court held that the arrest without warrant and the
subsequent search and seizure were valid, and that the defense of alibi was unavailing against the
positive identification of the appellant.
Page 42 of 62 | 1M 2023-2024
Luz vs. People [G.R. No. 197788, February 29, 2012]
In the case of Luz y Ong v. People, the Supreme Court acquits Rodel Luz y Ong of illegal
possession of dangerous drugs due to an invalid arrest and illegal search and seizure,
highlighting the importance of constitutional rights in criminal proceedings.
Facts:
The case of Luz y Ong v. People involves the acquittal of Rodel Luz y Ong of illegal possession of
dangerous drugs due to an invalid arrest and illegal search and seizure. On March 10, 2003, PO2
Emmanuel L. Alteza, a traffic enforcer, flagged down the accused for not wearing a helmet while
driving a motorcycle. While issuing a citation ticket, PO2 Alteza noticed that the accused was acting
uneasy and kept getting something from his jacket. He asked the accused to empty the contents
of his pocket, which included a metal container containing four plastic sachets of suspected shabu.
The accused was then arrested and charged with illegal possession of dangerous drugs.
Issue:
The main issue raised in the case is whether the arrest and subsequent search and seizure of the
accused were valid.
Ruling:
The court ruled that there was no valid arrest of the accused. The flagging down of the accused for
a traffic violation did not automatically constitute an arrest. The court cited the Land Transportation
and Traffic Code, which states that the general procedure for dealing with a traffic violation is the
confiscation of the driver's license, not the arrest of the offender. The court also noted that under
City Ordinance No. 98-012, the violation of not wearing a helmet while riding a motorcycle is
penalized by a fine only, and a warrantless arrest cannot be made for such an offense. Therefore,
the accused was not lawfully arrested.
Since there was no valid arrest, the subsequent search and seizure of the accused were also illegal.
The court stated that a warrantless search is only allowed in certain instances, such as a search
incidental to a lawful arrest or a search of evidence in plain view. None of these instances applied
to the case. The evidence seized, which included the drugs, was not in plain view and was actually
concealed inside a metal container in the accused's pocket. There was also no consented
warrantless search, as the alleged consent given by the accused was not shown to be voluntary
and unequivocal. Therefore, the search and seizure were deemed illegal.
Ratio:
Based on the illegal arrest and search and seizure, the court held that the evidence seized, including
the drugs, was inadmissible. The drugs were the very corpus delicti of the crime of illegal
possession of dangerous drugs, and their inadmissibility precluded conviction. Therefore, the
accused was acquitted.
In conclusion, the court ruled that the arrest and subsequent search and seizure of the accused
were invalid, leading to his acquittal of the charge of illegal possession of dangerous drugs. The
court emphasized the importance of constitutional rights in criminal proceedings and the need to
exercise the power to search and seize without contravening the constitutional rights of citizens.
Page 43 of 62 | 1M 2023-2024
United Laboratories vs. Isip, [G.R. No. 163858, June 28, 2005]
A petition to contest the validity of a search warrant leads to the Supreme Court ruling that
the seizure of certain products was not justified under the plain view doctrine, resulting in the
quashing of the search warrant and suppression of the seized items as evidence against the
respondents.
Facts:
The case involves a petition filed by United Laboratories, Inc. (UNILAB) to contest the validity of a
search warrant issued by the Regional Trial Court (RTC) of Manila. UNILAB sought to challenge the
seizure of certain products during the execution of the search warrant. The application for the
search warrant alleged that Shalimar Philippines, owned by Ernesto Isip, was involved in the
manufacture and distribution of counterfeit UNILAB products, specifically Revicon multivitamins.
The search warrant authorized the seizure of counterfeit Revicon multivitamins and related
documents. However, during the execution of the search warrant, NBI agents discovered sealed
boxes containing Disudrin and Inoflox products, which were not listed in the search warrant. The
NBI agents seized these products based on the plain view doctrine, claiming that they were
incriminating and immediately apparent.
Issue:
The main issue raised in the case is whether the seizure of the Disudrin and Inoflox products was
justified under the plain view doctrine.
Ruling:
The Supreme Court affirmed the decision of the trial court, ruling that the seizure of the Disudrin
and Inoflox products was not valid.
Ratio:
The Court held that a search warrant must particularly describe the place to be searched and the
things to be seized. The officers executing the warrant are only authorized to seize those things
specifically described in the warrant. The Court emphasized that the plain view doctrine is not an
exception to the warrant, but rather a supplement to the prior justification for the search.
In this case, the Court found that the petitioner and the NBI failed to prove the essential
requirements for the application of the plain view doctrine. They did not provide evidence to show
that the seized items, Disudrin and Inoflox products, were incriminating and immediately apparent.
Therefore, the Court concluded that the seizure of these products was not valid.
The Court's ruling highlights the importance of strict adherence to the requirements of a search
warrant. It emphasizes that the warrant must specifically describe the items to be seized, and the
officers executing the warrant are limited to seizing only those items. The plain view doctrine cannot
be used as a justification for seizing items not listed in the warrant. The Court's decision serves as
a reminder that the rights of individuals must be protected, and any search and seizure must be
conducted within the bounds of the law.
Page 44 of 62 | 1M 2023-2024
People vs. O’Cochlain [G.R. No. 229071, December 10, 2018]
An Irish national married to a Filipina is convicted of illegal possession of marijuana after a

lawful search conducted by airport authorities, with the court ruling that the search was
lawful and there was substantial compliance with the chain of custody rule.
Facts:
This case involves the conviction of Eanna O'Cochlain, an Irish national married to a Filipina, for
illegal possession of marijuana. On July 14, 2013, Eanna was at the Laoag City International Airport
for his flight to Manila. Security Screening Officer Dexter Suguitan (SSO Suguitan) received
information from another officer that the parking area smelled like marijuana and suspected that
Eanna was the one who smoked the illegal drug. SSO Suguitan conducted a pat down search on
Eanna and found two rolled sticks of dried marijuana leaves in his pocket. The confiscated items
were later turned over to the police investigator, PO3 Joel Javier, who marked and submitted them
to the crime laboratory for examination. The forensic chemist confirmed that the seized items tested
positive for marijuana.
Issue:
The main issue raised in the case is whether the search conducted by the airport authorities was
lawful and whether there was substantial compliance with the chain of custody rule.
Ruling:
The court ruled that the search was lawful and there was substantial compliance with the chain of
custody rule.
Ratio:
The court held that airport screening searches are constitutionally reasonable administrative
searches, as they are conducted to ensure public safety and prevent the carrying of weapons or
explosives onto aircraft. The court also found that Eanna voluntarily consented to the search, as he
agreed to the pat down search requested by SSO Suguitan. The court further ruled that there was
substantial compliance with the chain of custody rule, as the prosecution was able to establish a
complete account of the custody of the seized items from the time of seizure to their presentation
in court.
In conclusion, the court affirmed the conviction of Eanna O'Cochlain for illegal possession of
marijuana, ruling that the search was lawful and there was substantial compliance with the chain of
custody rule.
Page 45 of 62 | 1M 2023-2024
H. RIGHT TO PRIVACY
Ople vs. Torres [G.R. No. 127685, July 23, 1998]
The Supreme Court of the Philippines upholds the validity of Administrative Order No. 308,
establishing a National Computerized Identification Reference System to facilitate
government transactions and prevent fraud, ruling that it does not violate privacy rights.
Facts:
The case of Ople v. Torres involves the validity of Administrative Order No. 308, which establishes a
National Computerized Identification Reference System in the Philippines. The order was issued by
President Fidel V. Ramos on December 12, 1996, with the aim of providing Filipino citizens and
foreign residents with a convenient way to transact business with government agencies and reduce
fraudulent transactions. The order establishes a decentralized Identification Reference System and
creates an Inter-Agency Coordinating Committee to oversee its implementation. The National
Computer Center is designated as the secretariat to the committee. The Population Reference
Number (PRN) generated by the National Statistics Office serves as the common reference number
among concerned agencies. The order also mandates the conduct of an information dissemination
campaign and provides for the funding and submission of regular reports.
Issue:
The main issue raised in the case is whether Administrative Order No. 308 is a valid exercise of
executive power or an unconstitutional usurpation of legislative power. The petitioner, Senator Blas
F. Ople, argues that the order should have been enacted as a law by Congress.
Ruling:
The Supreme Court grants the petition and declares Administrative Order No. 308 invalid.
Ratio:
The court explains that legislative power is vested in Congress, while executive power is vested in
the President. Administrative orders are issued by the President to implement laws and should be in
harmony with the law and for the purpose of carrying out legislative policy. In this case,
Administrative Order No. 308 goes beyond the scope of an administrative order as it establishes a
system of identification that affects the life and liberty of every citizen and violates their right to
privacy. The court emphasizes that the right to privacy is a fundamental right recognized and
protected by the Constitution.
The court further states that Administrative Order No. 308 lacks proper safeguards to protect the
privacy and integrity of personal information and gives the government unfettered discretion to
determine the parameters of the ID system. The court concludes that the order is not narrowly drawn
and does not pass constitutional scrutiny. Therefore, it is declared null and void.
In summary, the court rules that Administrative Order No. 308 is an administrative order within the
executive powers of the President. However, it is invalid because it violates the right to privacy. The
court emphasizes the need for proper safeguards and well-defined standards to prevent
unconstitutional invasions of privacy.
Page 46 of 62 | 1M 2023-2024
Disini vs. Secretary of Justice [G.R. No. 203335, February 11, 2014]
The Disini, Jr. v. Secretary of Justice case challenges the constitutionality of provisions in the
Cybercrime Prevention Act of 2012 in the Philippines, resulting in the Supreme Court striking
a balance between freedom of speech and expression and the prevention of harm in
cyberspace by declaring certain provisions unconstitutional while upholding others.
Facts:
The case of Disini, Jr. v. Secretary of Justice involves a challenge to the constitutionality of certain
provisions of the Cybercrime Prevention Act of 2012 in the Philippines. The petitioners, including
Jose Jesus M. Disini, Jr., Rowena S. Disini, Lianne Ivy P. Medina, Janette Toral, and Ernesto Sonido,
Jr., brought the case against the Secretary of Justice, the Secretary of the Department of the Interior
and Local Government, the Executive Director of the Information and Communications Technology
Office, the Chief of the Philippine National Police, and the Director of the National Bureau of
Investigation. The petitioners argue that several provisions of the Cybercrime Prevention Act violate
their constitutional rights, including freedom of speech and expression, right to privacy and
correspondence, and right to due process.
Issue:
The main issue in this case is whether the provisions of the Cybercrime Prevention Act, specifically
those on illegal access, data interference, cyber-squatting, identity theft, cybersex, child
pornography, unsolicited commercial communications, libel, aiding or abetting in the commission of
cybercrimes, attempt in the commission of cybercrimes, and penalties, violate the constitutional
rights of the petitioners.
Ruling:
The Supreme Court ruled that some provisions of the Cybercrime Prevention Act were constitutional,
while others were not. The Court upheld the provisions on illegal access, data interference, cyber-
squatting, cybersex, and child pornography, as they were found to be necessary to prevent harm in
cyberspace. However, the Court declared the provision on unsolicited commercial communications
unconstitutional, as it infringed on the freedom of expression. The Court also declared the provisions
on libel and aiding or abetting in the commission of cybercrimes unconstitutional, as they violated
the freedom of expression. The Court struck a balance between protecting freedom of speech and
expression and preventing harm in cyberspace.
Ratio:
The Court held that the provision on illegal access did not violate the freedom of speech and
expression, as it punished the act of accessing a computer system without right, which is universally
condemned. The provision on data interference was also upheld, as it punished the intentional
alteration, damaging, deletion, or deterioration of computer data without right. The provision on
cyber-squatting was found to be constitutional, as it punished the acquisition of a domain name in
bad faith to profit, mislead, destroy reputation, or deprive others of registering the same.
The Court also upheld the provision on cybersex, which penalized the engagement, maintenance,
control, or operation of any lascivious exhibition of sexual organs or sexual activity with the aid of a
computer system for favor or consideration. The provision on child pornography was also upheld,
as it incorporated the offenses defined and punishable under the Anti-Child Pornography Act of
2009.
However, the Court declared the provision on unsolicited commercial communications, which
prohibited the transmission of commercial electronic communication without prior consent from the
recipient, unconstitutional. The Court found that this provision infringed on the freedom of
expression, as it prohibited legitimate forms of expression such as unsolicited advertisements.
Page 47 of 62 | 1M 2023-2024
The Court also declared the provisions on libel, which incorporated the penal code provisions on
libel, as well as the provision on aiding or abetting in the commission of cybercrimes,
unconstitutional. The Court found that these provisions violated the freedom of expression, as they
imposed criminal liability on individuals who merely reacted to or shared defamatory statements
online.
In conclusion, the Supreme Court struck a balance between protecting the rights to freedom of
speech and expression and preventing harm in cyberspace. It declared certain provisions of the
Cybercrime Prevention Act unconstitutional, while upholding others.
Page 48 of 62 | 1M 2023-2024
Zulueta vs. Court of Appeals [G.R. No. 107383, February 20, 1996]
A wife's unauthorized seizure of her husband's private documents, including correspondence

and personal items, is deemed a violation of his right to privacy, resulting in the court ruling in
favor of the husband and declaring the seized evidence inadmissible.
Facts:
The case of Zulueta v. Court of Appeals involves a dispute between spouses Cecilia Zulueta and
Alfredo Martin. On March 26, 1982, Cecilia entered Alfredo's clinic without his knowledge and
consent and forcibly opened his drawers and cabinet. She took 157 documents, including private
correspondence, greeting cards, diaries, and photographs, which she intended to use as evidence
in a case for legal separation and disqualification from the practice of medicine that she had filed
against her husband. Alfredo filed a case against Cecilia for the recovery of the documents and
papers and for damages. The Regional Trial Court of Manila ruled in favor of Alfredo, declaring him
as the owner of the seized properties and ordering Cecilia to return them and pay damages. The
Court of Appeals affirmed the decision, leading to this petition for review.
Issue:
The main issue in this case is whether the documents and papers seized by Cecilia from Alfredo's
clinic should be returned to him and declared inadmissible as evidence.
Ruling:
The court ruled in favor of Alfredo, stating that the documents and papers belong to him and were
taken without his knowledge and consent. The court emphasized that the right to privacy, including
the privacy of communication and correspondence, is inviolable. The only exception to this
constitutional provision is if there is a lawful court order or when public safety or order requires
otherwise. Any violation of this provision renders the evidence obtained inadmissible for any purpose
in any proceeding. The court emphasized that the intimacies between husband and wife do not justify
one of them in breaking into the other's personal belongings to find evidence of marital infidelity.
Marriage does not strip individuals of their integrity or their right to privacy, and the constitutional
protection is available to both spouses. Therefore, the court ordered Cecilia to return the seized
properties to Alfredo and declared them inadmissible as evidence.
Ratio:
The court's decision was based on the inviolability of the right to privacy, including the privacy of
communication and correspondence. The court emphasized that this right is protected by the
Constitution and can only be violated if there is a lawful court order or when public safety or order
requires otherwise. In this case, Cecilia's actions in forcibly opening Alfredo's drawers and cabinet
and taking his documents and papers without his knowledge and consent clearly violated his right
to privacy. The court further emphasized that the right to privacy is available to both spouses in a
marriage and that marriage does not strip individuals of their integrity or their right to privacy. The
court concluded that the seized properties should be returned to Alfredo and declared inadmissible
as evidence, as their acquisition violated his right to privacy.
Page 49 of 62 | 1M 2023-2024
Christian Cadajas y Cabias vs. People of the Philippines [G.R. No. 247348, November 16, 2021]
In summary, the court rules that the evidence obtained from the petitioner's Facebook
Messenger account is admissible, as it was obtained by a private individual and not by the state.
The court also finds the petitioner guilty of violating the Anti-Child Pornography Act based on
the evidence presented by the prosecution.
Facts:
The case involves Christian Cadajas y Cabias, the petitioner, who was found guilty of violating specific
provisions of Republic Act (R.A.) No. 10175, known as the Cybercrime Prevention Act of 2012, in
connection with R.A. No. 9775 or the Anti-Child Pornography Act of 2009. The case originated when
Cadajas, a 24-year-old male, engaged in an online relationship with a 14-year-old girl identified as
AAA. Their relationship, initiated through Facebook Messenger, evolved to include the exchange of
sexually explicit messages and photographs. The situation came to light when AAA's mother
discovered the nature of these exchanges. She confronted Cadajas and was able to obtain a copy of
their conversation, which contained explicit requests from Cadajas and compliance from AAA.
Following this discovery, Cadajas was charged and found guilty by the Regional Trial Court (RTC) of
Valenzuela City. The Court of Appeals (CA) later affirmed this decision with modifications regarding
the penalty imposed. Cadajas appealed to the Supreme Court, challenging the admissibility of the
evidence obtained from his Facebook Messenger account and alleging a violation of his right to
privacy.
Issue:
The primary issue for determination by the Supreme Court was whether the evidence obtained from
Cadajas's Facebook Messenger account was admissible and whether such evidence violated his right
to privacy. Additionally, the Court examined whether Cadajas's actions constituted child pornography
under the relevant statutes, considering the existence of a purported romantic relationship between
him and AAA.
Ruling:
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals with
modifications to the penalty. The Court ruled that the evidence obtained from Cadajas's Facebook
Messenger account was admissible since it was procured by a private individual, AAA's mother, and
not by the state, thereby not infringing upon Cadajas's right to privacy. Furthermore, the Supreme
Court held that Cadajas's act of inducing AAA to send explicit photographs amounted to child
pornography, as defined under the pertinent laws. The Court underscored that the minor's consent,
given the context of a romantic relationship, was immaterial due to the inherent power imbalance
between an adult and a child. The ruling emphasized the state's duty to protect minors from
exploitation and abuse.
Ratio:
In reaching its decision, the Supreme Court elaborated on several critical points. Firstly, it clarified the
admissibility of evidence obtained from private communications, highlighting that the right to privacy
does not extend to shielding criminal activities, especially when the evidence is procured by non-state
actors. Secondly, the Court delineated the legal framework surrounding child pornography, affirming
that such acts are considered mala in se—wrong in themselves—requiring proof of criminal intent. The
Court pointed out that the existence of a romantic relationship does not exempt an individual from
liability for acts constituting child pornography. Lastly, the Court reaffirmed the legislative intent behind
the stringent penalties for child pornography, emphasizing society's obligation to safeguard minors
from sexual exploitation and abuse in the digital era. The decision reflects a nuanced understanding
of the complexities surrounding privacy rights, the exploitation of minors, and the evolving landscape
of digital communication.
Page 50 of 62 | 1M 2023-2024
I. FREE SPEECH, EXPRESSION, PRESS, ASSEMBLY AND PETITION
Diocese of Bacolod vs. COMELEC, G.R. No. 205728, January 21, 2015
The Supreme Court ruled in favor of the Diocese of Bacolod, stating that the Commission on
Elections does not have the authority to limit expressions made by citizens who are not
candidates during elections, affirming the importance of protecting freedom of speech and
expression.
Facts:
The case of The Diocese of Bacolod v. Commission on Elections involves a dispute over the authority
of the Commission on Elections (COMELEC) to limit expressions made by citizens who are not
candidates during elections. The petitioners, the Diocese of Bacolod represented by Bishop Vicente
M. Navarra, posted two tarpaulins within a private compound housing the San Sebastian Cathedral
of Bacolod. One tarpaulin contained the message "IBASURA RH Law" referring to the Reproductive
Health Law of 2012, while the other tarpaulin listed candidates as either "(Anti-RH) Team Buhay" or
"(Pro-RH) Team Patay" based on their vote on the adoption of the RH Law. The COMELEC issued a
notice and letter ordering the removal of the tarpaulin for being oversized and in violation of COMELEC
Resolution No. 9615. The petitioners filed a special civil action for certiorari and prohibition with the
Supreme Court, arguing that the COMELEC's actions violated their right to freedom of expression
and the principle of separation of church and state.
Issue:
The main issue raised in the case is whether the COMELEC has the authority to limit expressions
made by citizens who are not candidates during elections.
Ruling:
The Supreme Court ruled in favor of the petitioners, stating that the COMELEC does not have the
authority to limit expressions made by citizens who are not candidates during elections.
Ratio:
The Court's ruling is based on the interpretation of relevant constitutional provisions and election
laws. The Court held that the COMELEC's authority to regulate election propaganda is limited to
candidates and political parties, and does not extend to expressions made by citizens who are not
candidates. The Court also emphasized the importance of protecting political speech and the right of
citizens to participate in the political discourse during elections. The Court concluded that the
COMELEC's actions in this case violated the petitioners' right to freedom of expression and the
principle of separation of church and state.
Page 51 of 62 | 1M 2023-2024
United States vs. Bustos [G.R. No. L-12592, March 8, 1918]
A group of citizens accused a justice of the peace of malfeasance in office, leading to a libel
case against them, but they were acquitted as the court recognized their right to criticize
judicial conduct and emphasized the importance of freedom of speech and press.
Facts:
The case of U.S. v. Bustos, also known as People vs. Bustos, involves a group of citizens who
accused a justice of the peace, Roman Punsalan, of malfeasance in office. The citizens prepared and
signed a petition, along with affidavits, charging Punsalan with various acts of misconduct and
submitted it to the Executive Secretary through their lawyers. The petition was then referred to the
judge of first instance for investigation. After conducting an investigation, the judge recommended to
the Governor-General that Punsalan be removed from his position. However, Punsalan filed a motion
for a new trial, and the judge granted it, subsequently suppressing the charges against Punsalan and
acquitting him.
Following this, criminal action was initiated against the citizens who signed the petition, charging them
with libel against Punsalan. The trial court found thirty-two of the defendants guilty and sentenced
them to pay a nominal fine.
Issue:
The main issue in this case is whether the defendants are guilty of libel against Punsalan.
Ruling:
The ruling of the court is that the defendants are not guilty.
Ratio:
The court emphasizes the importance of freedom of speech and press, as well as assembly and
petition, in a democratic society. It states that the interests of society and the maintenance of good
government require a full discussion of public affairs and that complete liberty to comment on the
conduct of public officials is necessary for free speech. The court also recognizes that the right to
criticize judicial conduct is included in the guaranties of free speech and press.
The court further explains that the doctrine of privileged communications, which is based on public
policy, protects communications made in good faith and without malice on matters of public concern.
It states that even if the statements made in the petition were found to be false, as long as there was
probable cause for belief in their truthfulness and the charge was made in good faith, the defendants
are still protected by privilege.
In this case, the court finds that the defendants acted in good faith, their ends and motives were
justifiable, and they did not abuse the privilege. Therefore, they are acquitted and should be
commended for their good citizenship.
Page 52 of 62 | 1M 2023-2024
Reyes vs. Bagatsing [G.R. No. L-65366, November 9, 1983]
The Supreme Court ruled in favor of the petitioner's right to freedom of expression and peaceful
assembly, affirming that the denial of the permit by the Mayor violated these fundamental
rights.
Facts:
The case of Reyes v. Bagatsing involves a petition filed by Jose B.L. Reyes on behalf of the Anti-
Bases Coalition (ABC) against Ramon Bagatsing, the Mayor of the City of Manila. The petitioner
sought a permit to hold a peaceful march and rally from Luneta, a public park, to the gates of the
United States Embassy in Manila. The purpose of the rally was to present a petition to the US
Embassy based on a resolution adopted at an international conference for general disarmament,
world peace, and the removal of all foreign military bases. The petitioner assured that all necessary
steps would be taken to ensure a peaceful march and rally.
The petitioner filed the petition after not receiving any response from the city regarding the permit. It
was later revealed that the permit was denied due to police intelligence reports indicating a potential
danger of subversive elements infiltrating the rally. The respondent Mayor suggested that the rally
could be held at the Rizal Coliseum or any other enclosed area where the safety of the participants
could be ensured.
Issue:
The main issue raised in the case is whether the denial of the permit for the proposed march and rally
violates the petitioner's right to freedom of expression and peaceful assembly.
Ruling:
The Supreme Court ruled in favor of the petitioner's right to freedom of expression and peaceful
assembly.
Ratio:
The Court emphasized that free speech and peaceful assembly are fundamental rights that should be
accorded the utmost deference and respect. The Court stated that these rights should only be limited
if there is a clear and present danger of a substantive evil that the state has a right to prevent. The
burden of proof lies on the licensing authority to show the existence of such a danger.
The Court also emphasized that the choice of the rally's location should not be limited or denied
unless there is a clear and present danger. The Court cited previous cases that recognized the
freedom of access to public places, such as parks and streets, and stated that their use should not
be dependent on the identity of the applicant. The Court also noted that licensing authorities should
not have arbitrary discretion to issue or refuse permits.
In this case, the Court held that there was no valid reason to deny the permit for the proposed march
and rally. It stated that the denial based on police intelligence reports was not sufficient to justify the
limitation of the petitioner's rights. The Court also rejected the argument that the rally violated an
ordinance prohibiting rallies or demonstrations within 500 feet of any foreign mission or chancery. The
Court stated that the applicability of the ordinance was not proven, and even if it applied, it could still
be challenged as an unconstitutional application of the right to peaceable assembly.
In conclusion, the Supreme Court granted the mandatory injunction allowing the proposed march and
rally to proceed. The Court emphasized the importance of protecting the exercise of the rights to free
speech and peaceable assembly and stated that the judiciary has the responsibility to ensure respect
for and deference to these rights.
Page 53 of 62 | 1M 2023-2024
Social Weather Stations, Inc. vs. COMELEC [G.R. No. 147571, May 5, 2001]
The Supreme Court of the Philippines declares Section 5.4 of Republic Act No. 9006
unconstitutional, ruling that the restriction on the publication of election survey results violates
freedom of speech and of the press.
Facts:
The case of Social Weather Stations, Inc. v. Commission on Elections involves the constitutionality of
Section 5.4 of Republic Act No. 9006, also known as the Fair Election Act. This provision prohibits
the publication of election surveys within fifteen days before a national election and seven days before
a local election. The petitioners in this case are Social Weather Stations, Inc. and Kamahalan
Publishing Corporation. They argue that the restriction on the publication of election survey results
violates their freedom of speech and of the press. They claim that there is no clear and present danger
to justify such restraint and that the restriction is not imposed on politicians or media outlets. The
Commission on Elections justifies the restriction as necessary to prevent the manipulation and
corruption of the electoral process.
Issue:
The main issue raised in this case is whether Section 5.4 of Republic Act No. 9006, which prohibits
the publication of election surveys within a certain period before an election, is constitutional and
does not violate the freedom of speech and of the press.
Ruling:
The Supreme Court of the Philippines ruled that Section 5.4 of Republic Act No. 9006 is
unconstitutional. The Court declared that this provision constitutes an unconstitutional abridgment of
freedom of speech, expression, and the press. The Court found that the restriction on the publication
of election survey results constitutes a prior restraint on freedom of speech and that the government
had not shown sufficient justification for such restraint. The Court also found that the restriction was
not narrowly tailored to meet the government's objectives and that there were less restrictive means
available to achieve those objectives. Therefore, the Court concluded that the restriction violated the
constitutional guarantee of freedom of expression and declared Section 5.4 unconstitutional.
Ratio:
The Court recognized the legitimate objectives of Section 5.4, which include preventing the
bandwagon effect, avoiding the manipulation of voters' minds, and preserving the principle of equality
and impartiality in elections. However, the Court found that the restriction on the publication of
election survey results was not justified and was not narrowly tailored to achieve these objectives.
The Court noted that other countries impose similar restrictions on the publication of surveys before
elections, but it emphasized that the Philippine Constitution provides a higher level of protection for
freedom of speech and of the press. The Court rejected the argument that other provisions of the Fair
Election Act, such as Sections 5.2 and 5.3, which prescribe requirements for the publication of
surveys and allow for their inspection, are sufficient to address the concerns raised by Section 5.4.
The Court concluded that the restriction on the publication of election survey results violated the
constitutional guarantee of freedom of expression and declared Section 5.4 unconstitutional.
Page 54 of 62 | 1M 2023-2024
Bayan vs. Ermita [G.R. No. 169838, April 25, 2006]
The Bayan v. Ermita case in the Philippines involves petitions challenging the constitutionality
of a law and policy regulating public assemblies, with the Court ruling that the law and policy
are not vague or overbroad, but orders the designation of freedom parks and the discontinuation
of the Calibrated Preemptive Response policy.
Facts:
The case of Bayan v. Ermita involves petitions challenging the constitutionality of a law and policy
regulating public assemblies in the Philippines. The petitioners argue that their rights to peaceful
assembly and freedom of expression were violated when their rallies were dispersed by the police.
They also argue that the law and policy are vague, overbroad, and an undue delegation of power to
the mayors. The respondents argue that the petitioners have no standing and that the law and policy
are constitutional.
Issue:
The main issue raised in this case is whether the law and policy regulating public assemblies in the
Philippines violate the petitioners' rights to peaceful assembly and freedom of expression.
Ruling:
The Court rules in favor of the petitioners and declares that their rights to peaceful assembly and
freedom of expression are protected by the Constitution. The Court also rules that the law and policy
are not vague or overbroad, but orders the designation of freedom parks and the discontinuation of
the Calibrated Preemptive Response policy.
Ratio:
The Court explains that the right to peaceful assembly and freedom of expression are fundamental
rights that enjoy primacy in the realm of constitutional protection. However, these rights are not
absolute and can be limited if there is a clear and present danger to public order, safety, convenience,
morals, or health.
The Court further clarifies that the Calibrated Preemptive Response policy is not a new rule, but a more
proactive enforcement of existing laws to prevent chaos in the streets. The Court emphasizes that the
policy should only be used in exceptional cases where there is a clear and present danger.
The Court also emphasizes the importance of freedom parks as alternative venues for peaceful
assembly. It orders local governments to establish or designate such parks within 30 days to provide
a space for citizens to exercise their right to peaceful assembly.
Overall, the Court upholds the fundamental rights of the people and emphasizes the need for maximum
tolerance and respect for peaceful assembly and freedom of expression. It recognizes that these rights
are essential for a democratic society and should be protected, while also acknowledging the need for
reasonable limitations to ensure public order and safety.
Page 55 of 62 | 1M 2023-2024
J. RELIGIOUS FREEDOM AND NON-ESTABLISHMENT OF RELIGION
Aglipay vs. Ruiz [G.R. No. 45459, March 13, 1937]
The Supreme Court denies a petition to prevent the issuance and sale of postage stamps
commemorating a religious event, ruling that it does not violate the constitutional principle of
separation of church and state.
Facts:
The case of Aglipay v. Ruiz involves the petitioner, Mons. Gregorio Aglipay, who is the Supreme
Head of the Philippine Independent Church. The petitioner sought the issuance of a writ of prohibition
to prevent the respondent Director of Posts from issuing and selling postage stamps
commemorating the Thirty-third International Eucharistic Congress. The respondent Director of
Posts issued the postage stamps under the provision of Act No. 4052, which appropriated funds for
the cost of plates and printing of postage stamps with new designs. The stamps were designed to
advertise the Philippines and attract more tourists to the country, with the main purpose being the
promotion of the Philippines rather than the promotion of any religious event.
Issue:
The main issue raised in the case is whether the issuance and sale of the postage stamps
commemorating the Thirty-third International Eucharistic Congress violate the constitutional
principle of separation of church and state.
Ruling:
The Supreme Court denied the petition for a writ of prohibition, ruling that the issuance and sale of
the stamps did not violate the constitutional principle of separation of church and state.
Ratio:
The Court held that Act No. 4052, under which the postage stamps were issued, did not contemplate
any religious purpose. The law appropriated funds for the cost of plates and printing of postage
stamps with new designs, with the main purpose being the promotion of the Philippines. The Court
emphasized that the stamps were designed to advertise the country and attract more tourists, and
any resulting propaganda received by the Roman Catholic Church was not the aim and purpose of
the government. The Court further stated that the Director of Posts had discretionary power to
determine when the issuance of special postage stamps would be advantageous to the government.
The Court concluded that the main purpose of promoting the Philippines should not be frustrated by
incidental results of a religious nature, and therefore, there had been no constitutional violation in the
case.
Page 56 of 62 | 1M 2023-2024
Taruc vs. De la Cruz [G.R. No. 144801, March 10, 2005]
A group of lay members of a church in the Philippines filed a complaint for damages after
being expelled for disobedience, but the court ruled that it did not have jurisdiction to hear the
case due to the principle of separation of Church and State.
Facts:
The case of Taruc v. De la Cruz involves a group of lay members of the Philippine Independent
Church (PIC) who filed a complaint for damages after being expelled from the church for
disobedience. The respondents in the case are Bishop Porfirio B. De la Cruz, Rev. Fr. Rustom
Florano, and Delfin Bordas. The events took place in Socorro, Surigao del Norte.
The petitioners, led by Dominador Taruc, requested the transfer of Fr. Florano to another parish, but
Bishop De la Cruz denied their request. The animosity between the two factions arose because Fr.
Florano's wife's family belonged to a political party opposed to petitioner Taruc's. Despite the
Bishop's attempts to dissuade Taruc from organizing an open mass with a questionable priest, Taruc
proceeded with the event.
As a result, Bishop De la Cruz declared the petitioners expelled/excommunicated from the PIC for
disobedience, inciting dissension, and threatening to forcibly occupy the Parish Church. The
petitioners appealed to the Obispo Maximo, who suggested that Fr. Florano voluntarily step down
to prevent further hostility. However, the Obispo Maximo did not intervene in the diocesan decision.
The petitioners then filed a complaint for damages with preliminary injunction against Bishop De la
Cruz, Fr. Florano, and Delfin Bordas. They argued that their expulsion was illegal because it was
done without trial, violating their right to due process. The respondents filed a motion to dismiss the
case for lack of jurisdiction, which was initially denied by the lower court but later granted by the
Court of Appeals.
Issue:
The main issue in this case is whether the courts have jurisdiction to hear a case involving the
expulsion/excommunication of members of a religious institution.
Ruling:
The court ruled that the courts do not have jurisdiction in such cases.
Ratio:
The court cited the principle of separation of Church and State and the constitutional provision on
the free exercise of religion. The court emphasized that the expulsion/excommunication of members
is a matter best left to the discretion of the officials and laws of the religious institution. It is not for
the courts to exercise control over church authorities in their discretionary and official functions.
The court also referred to the doctrine established in the case of Fonacier v. Court of Appeals, which
states that doctrinal and disciplinary differences in disputes involving religious institutions are outside
the province of civil courts. The court concluded that the case did not involve a violation or protection
of civil or property rights, and therefore, the court did not have jurisdiction.
In addition, the court addressed the petitioners' claim that they were not heard before their expulsion.
The court noted that the Bishop had pleaded with the petitioners multiple times to refrain from acts
detrimental to the church and warned them of the consequences. Despite these warnings, the
petitioners proceeded with their plans, causing chaos and disunity. The court held the petitioners
responsible for the consequences of their actions.
Page 57 of 62 | 1M 2023-2024
In conclusion, the court denied the petition for lack of merit and upheld the decision of the Court of
Appeals to dismiss the case for lack of jurisdiction. The court emphasized the separation of Church
and State and the limited role of civil courts in matters involving religious institutions.
Page 58 of 62 | 1M 2023-2024
Iglesia Ni Cristo vs. Court of Appeals [G.R. No. 119673, July 26, 1996]
The Philippine Jurisprudence case of Iglesia ni Cristo v. Court of Appeals involves the Supreme
Court ruling that the Movie and Television Review and Classification Board (MTRCB) cannot
censor a religious TV program, as it falls within the realm of protected religious expression
and does not pose a clear and present danger.
Facts:
The case of Iglesia ni Cristo v. Court of Appeals involves the Supreme Court ruling that the Movie
and Television Review and Classification Board (MTRCB) cannot censor a religious TV program, as
it falls within the realm of protected religious expression and does not pose a clear and present
danger.
The facts of the case are as follows: Iglesia ni Cristo (INC), a religious organization, has a television
program called "Ang Iglesia ni Cristo" that airs on Channel 2 and Channel 13. The program presents
and propagates the religious beliefs, doctrines, and practices of INC.
In September, October, and November 1992, INC submitted VTR tapes of its TV program series to
the respondent Board of Review for Motion Pictures and Television (BRMPT) for review. The BRMPT
classified the series as "X" or not for public viewing, stating that they "offend and constitute an attack
against other religions, which is expressly prohibited by law."
INC appealed the decision of the BRMPT to the Office of the President, which reversed the decision
and allowed the exhibition of one of the series. INC also filed a civil case against the BRMPT, alleging
that the board acted without jurisdiction or with grave abuse of discretion in requiring the submission
of VTR tapes and x-rating them.
The trial court granted a writ of preliminary injunction in favor of INC, but the Court of Appeals
reversed the decision, ruling that the BRMPT has the power to review the TV program and did not
act with grave abuse of discretion in prohibiting its exhibition.
Issue:
The main issue in the case is whether the BRMPT has the power to review and prohibit the exhibition
of INC's TV program.
Ruling:
The Supreme Court held that the BRMPT does have the power to review the program under PD No.
1986, which grants the board the authority to review and examine all motion pictures and television
programs.
The Court also ruled that the BRMPT did not act with grave abuse of discretion in prohibiting the
exhibition of the program, as it falls within the board's power to prohibit materials that are "immoral,
indecent, contrary to law and/or good customs, injurious to the prestige of the Republic of the
Philippines and its people, or with a dangerous tendency to encourage the commission of violence
or of a wrong or crime."
Ratio:
However, the Court also emphasized that the exercise of religious freedom is protected by the
Constitution and cannot be unduly restricted. The Court held that the program of INC is a form of
religious expression and falls within the realm of protected religious freedom. The Court ruled that
the program does not pose a clear and present danger and is not indecent or contrary to law and
good customs. The Court emphasized the importance of freedom of religion and speech and the
need to encourage the marketplace of ideas.
Page 59 of 62 | 1M 2023-2024
In conclusion, the Supreme Court ruled that the BRMPT has the power to review and prohibit the
exhibition of INC's TV program, but it did not act with grave abuse of discretion in this case. The
Court affirmed the decision of the Court of Appeals, upholding the prohibition of the exhibition of the
program.
Page 60 of 62 | 1M 2023-2024
Estrada vs. Escritor [A.M. No. P-02-1651, June 22, 2006]
A court interpreter is charged with "disgraceful and immoral conduct" for cohabiting with a
married man, but argues that her religious beliefs allow for her conjugal arrangement, leading
to a court decision that her conduct does not constitute "disgraceful and immoral conduct"
under the Civil Service Law, while clarifying that its decision does not pass judgment on
religious beliefs or practices.
Facts:
The case of Estrada v. Escritor involves the respondent, Soledad Escritor, a court interpreter, who
was charged with "disgraceful and immoral conduct" for cohabiting with a married man. The
complainant, Alejandro Estrada, filed a letter-complaint against Escritor, alleging that she was living
with a man who was not her husband and that they had a child together. Escritor, in her defense,
claimed that their conjugal arrangement was in conformity with her religious beliefs as a Jehovah's
Witness. She presented a "Declaration of Pledging Faithfulness" that she and her partner had
executed, which stated their commitment to each other in a marital relationship. Escritor argued that
their conjugal arrangement was recognized and approved by their religious congregation.
The case was initially referred to Judge Jose F. Caoibes, Jr., who conducted a preliminary
conference. Escritor moved for the judge's inhibition, as she had previously filed an administrative
complaint against him. The motion was denied, and the preliminary conference proceeded. Estrada
confirmed that he filed the complaint because he believed that Escritor's live-in arrangement was
immoral and tarnished the image of the court. During the investigation, Escritor testified that she had
been living with her partner for twenty years and that their conjugal arrangement was in accordance
with their religious beliefs. She presented witnesses from her congregation to confirm the validity of
their "Declaration of Pledging Faithfulness."
The investigating judge found Escritor's factual allegations credible and recommended the dismissal
of the complaint based on her right to religious freedom. However, the Office of the Court
Administrator disagreed with the investigating judge's recommendation. They argued that Escritor's
relationship with a married man, voluntarily carried on, could still subject her to disciplinary action.
They recommended that Escritor be found guilty of immorality and be penalized with a six-month
suspension without pay.
Issue:
The main issue in the case is whether Escritor's conduct constitutes "disgraceful and immoral
conduct" under the Civil Service Law, and whether her right to religious freedom should carve out
an exception from the prevailing jurisprudence on illicit relations for government employees.
Ruling:
The court ruled in favor of Escritor, stating that her conduct does not constitute "disgraceful and
immoral conduct" under the Civil Service Law. The court emphasized that its decision does not pass
judgment on religious beliefs or practices. It recognized the importance of religious freedom as a
fundamental right and stated that the state's interest must be balanced with an individual's religious
freedom. The court also noted that Escritor's conjugal arrangement was in accordance with the
beliefs and practices of her religious congregation.
Ratio:
The court's decision is based on the principle of religious freedom and the need to balance it with
the state's interest in regulating conduct. The court recognizes that religious freedom is a
fundamental right that should be protected to the greatest extent possible. It emphasizes that the
state's interest in regulating conduct must be compelling and that it must be shown that the conduct
in question poses a substantive evil. In this case, the court finds that the state has not adequately
demonstrated a compelling interest that justifies overriding Escritor's religious belief and practice.
Page 61 of 62 | 1M 2023-2024
The court also clarifies that its decision only applies to the realm of public and secular morality, and
does not pass judgment on religious morality. Overall, the court's ruling upholds Escritor's right to
religious freedom and recognizes that her conduct does not constitute "disgraceful and immoral
conduct" under the Civil Service Law.
Page 62 of 62 | 1M 2023-2024

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CONSTITUTIONAL LAW II

 Basic Principles of the Constitution

• Concept and Basic Principles

II. EMINENT DOMAIN

• Concept and Basic Principles

III. POWER OF TAXATION

IV. DUE PROCESS

VI. RIGHT AGAINST UNREASONABLE SEARCHES AND SEIZURES

VII. RIGHT TO PRIVACY

VIII. FREE SPEECH, EXPRESSION, PRESS, ASSEMBLY AND PETITION

MANILA PRINCE HOTEL V. GSIS 6

SISON VS. ANCHETA, [G.R. NO. L-59431, JULY 25, 1984] 20

PEOPLE VS. VERA [G.R. NO. 45685, NOVEMBER 16, 1937] 34

G. RIGHT AGAINST UNREASONABLE SEARCHES AND SEIZURES 37

PEOPLE VS. MARTI [G.R. NO. 81561, JANUARY 18, 1991] 37

OPLE VS. TORRES [G.R. NO. 127685, JULY 23, 1998] 46

I. FREE SPEECH, EXPRESSION, PRESS, ASSEMBLY AND PETITION 51

J. RELIGIOUS FREEDOM AND NON-ESTABLISHMENT OF RELIGION 56

AGLIPAY VS. RUIZ [G.R. NO. 45459, MARCH 13, 1937] 56

Manila Prince Hotel v. GSIS

The main issues raised in the case are as follows:

• Whether Department Order No. 1, Series of 1988 is constitutional.

Sison vs. Ancheta, [G.R. No. L-59431, July 25, 1984]

The main issues raised in the case are:

A man fights against the unconstitutional confiscation of his carabaos by challenging an

People vs. Vera [G.R. No. 45685, November 16, 1937]

People vs. Marti [G.R. No. 81561, January 18, 1991]

Accused-appellant Edison Sucro is convicted of selling prohibited drugs based on a lawful

An Irish national married to a Filipina is convicted of illegal possession of marijuana after a

Ople vs. Torres [G.R. No. 127685, July 23, 1998]

A wife's unauthorized seizure of her husband's private documents, including correspondence

Aglipay vs. Ruiz [G.R. No. 45459, March 13, 1937]

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Basic Principles of the Constitution