Ramirez vs.

Garcia
G.R. No. 93833 September 28, 1995

Facts:

Socorro D. Ramirez, petitioner, filed a civil case damages in Regional Trial Court of Quezon
City against Ester S Garcia, alleging that the latter insulted and humiliated her and in a manner
offensive to petitioner’s dignity and personality, contrary to morals, good customs and public
policy. The petitioner produced a verbatim transcript of the event taken from a tape recording of
the confrontation made by her. Thus, the private respondent filed a criminal case against the
petitioner before the RTC of Pasay City for violation of Republic Act 4200, entitled "An Act to
prohibit and penalize wiretapping and other related violations of private communication, and
other purposes."

Issue/s:

Whether or not recording of private conversation without the consent of both parties is a
violation of R.A. 4200.

Ruling:

Yes. R.A. 4200 is clear and unambiguous and leaves us with no discretion. Any person recording
a private communication without the consent of both parties are illegal. Legislative intent is
determined principally from the language of a statute. Where the language of a statute is clear
and unambiguous, the law is applied according to its express terms, and interpretation would be
resorted to only where a literal interpretation would be either impossible or absurd or would lead
to an injustice.