HUMAN RIGHTS CASE DIGESTS

Magdalena Estate, Inc. vs. Kapisanan nga mga Manggagawa sa Magdalena Estate, Inc. No. L-18336. May 31, 1963
Facts: The complaint was filed by respondent with the CIR in the name of the Union of which all but one of the 19 dismissed employees
are members. The causes of action arises from petitioner requiring union members to sign application forms which would place
them under temporary basis, and that their refusal to sign said applications caused their dismissal. The respondent prays for their
reinstatement to their former positions with full back wages.
The CIR issued a resolution finding substantial evidence of unfair labor practice justifying the reinstatement of the respondents.
Hence, this petition. Petitioner contends that the dismissal of respondents is due to a retrenchment policy.
Issue: WON the dismissal is valid. NO
Ruling: The dismissal of the 15 laborers cannot be justified by reason of an alleged retrenchment policy, because this policy was
implemented only in the department where a labor union existed, and wherein the dismissed laborers where working.
 (Dismissal of laborers due to their membership in a labor union is illegal as it constitutes unfair labor practice.)
Kaisahan ng mga Manggagawa sa Kahoy sa Pilipinas vs. Gotamco Saw Mill. No. L-1573. March 29, 1948
Facts: The petitioner labor union challenged the CIR’s order finding that they have violated the order of the court (September 23, 1946)
providing, among others, that the laborer’s increase and privilege will take effect upon the return of the workingmen to work
until the final determination of the present controversy.
The petitioner contended that Sec. 19 of CA No. 103, from which the subject order is based, enjoining the workers to return to
work upon order of the court or when the dispute cannot be promptly decided or settled, is unconstitutional for being in violation
of the proscription of involuntary servitude.
Issue: WON Sec. 19 of CA No. 103 is against the proscription of involuntary servitude. NO
Ruling: We agree with the CIR that Sec 19..is constitutional. It does not offend against the constitutional inhibition prescribing
involuntary servitude. An employee entering into a contract of employment after said law went into effect, voluntarily accepts,
among other conditions, those prescribed in said section 19, among which is the implied condition that when any dispute
between the employer or landlord and the employee, tenant or laborer has been submitted to the CIR for settlement or
arbitration, pursuant to the provisions of this Act, and pending award or decision by it, the employee, tenant or laborer shall not
strike or walk out of his employment when so enjoined by the court after hearing and when public interest so requires, and if he
has already done so, that he shall forthwith return to it, upon order of the court, which shall be issued only after hearing when
public interest so requires or when the dispute cannot, in its opinion, be promptly decided or settled.
The voluntariness of the employee’s entering into such a contract of employment – he has a free choice between entering
into it or not – with such an implied condition, negatives the possibility of involuntary servitude ensuing.
People vs. Galit . No L-51770. March 20, 1985
Facts: The accused is sentenced with death imposed by the Circuit Criminal Court of Pasig, Rizal.
The accused assailed the admissibility of the extra-judicial confession extracted from through torture, force and intimidation as
described earlier, and without the benefit of counsel.
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There were no eyewitnesses, no property recovered from the accused, no state witnesses, and not even fingerprints of the
accused at the scene of the crime. The only evidence against him is his alleged confession.
Issue: WON the confession of the accused is admissible evidence against him. NO
Ruling: This Court, in the case of Morales vs. Ponce Enrile, laid down the correct procedure for peace officers to follow when making
an arrest and in conducting a custodial investigation, and which We reiterate:
At the time a person is arrested, it shall be the duty of the arresting officer to inform him of the reason for the arrest
and he must be shown the warrant of arrest, if any. He shall be informed of his constitutional rights to remain silent and
to counsel, and that any statement he might make could be used against him. The person arrested shall have the right to
communicate with his lawyer, a relative, or anyone he chooses by the most expedient means – by telephone if possible –
or by letter or messenger. It shall be the responsibility of the arresting officer to see to it that this accomplished. No
custodial investigation shall be conducted unless it be in the presence of counsel engaged by the person arrested, by any
person on his behalf, or appointed by the court upon petition either of the detainee himself or by anyone on his behalf.
The right to counsel may be waived but the waiver shall not be valid unless made with the assistance of counsel. Any
statement obtained in violation of the procedure herein laid down, whether exculpatory or inculpatory, in whole or in
part, shall be inadmissible in evidence.
xxx Such a long question followed by a monosyllabic answer does not satisfy the requirements of the law that the accused be
informed of his rights under the Constitution and our laws. Instead there should be several short and clear questions and every
right explained in simple words in a dialect or language known to the person under investigation. Accused is from Samar and
there is no showing that he understands Tagalog. Moreover, at the time of his arrest, accused was not permitted to communicate
with his lawyer, a relative, or a friend. xxx His statement does not even contain any waiver of right to counsel and yet during the
investigation he was not assisted by one.
Ramirez vs. Court of Appeals. GR No. 93833. September 28, 1995
Facts: Ramirez filed a civil case for damages against Garcia. She alleged that the latter insulted and humiliated her in a hostile and
furious mood and in a matter offensive to petitioner’s dignity and personality. In support of her claim, Ramirez produced a
verbatim transcript of the event based from a tape recording of the confrontation made by Ramirez.
As a result of Ramirez’s recording of the confrontation, Garcia filed a criminal case before the RTC for violation of RA No. 4200 (An
Act to Prohibit and Penalized Wire Tapping and other Related Violations of Private Communication, and other purposes”.
The trial court granted the motion to quash the information. The CA reversed the trial court.
In her petition, Ramirez argues the applicable provision of RA 4200 does not apply to the taping of a private conversation by one
of the parties to the conversation.
Issue: WON the recording of the confrontation is punishable by RA No. 4200. YES
Ruling: The aforestated provision [Section 1 of RA 4200] clearly and unequivocally makes it illegal for any person, not authorized by all
the parties to any private communication to secretly record such communication by means of a tape recorder. The law makes no
distinction as to whether the party sought to be penalized by the statute ought to be a party other than or different from those
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involved in the private communication. The statute’s intent to penalize all person unauthorized to make such recording is
underscored by the use of the qualifier “any”. Consequently, as respondent CA correctly concluded, “even a (person) privy to ta
communication who records his private conversation with another without the knowledge of the latter (will) qualify as a violator
under this provision of RA 4200.
Guanzon vs. De Villa. GR No. 80508. January 30, 1990
Facts: This is a petition for prohibition with preliminary injunction to prohibit the military and police officers from conducting Area
Target Zonings or Saturation Drives in Metro Manila. 41 petitioners are well-meaning citizens who brought the petition in behalf
of the citizens of Metro Manila who have similar interests in the preservation of the rule o law, protection of human rights and
the reign of peace and order in their communities. They alleged that such saturation drives are in critical areas pinpointed by the
military and police as places where the subversives are hiding. It was alleged that having no specific target house in mind, in the
dead night or early morning hours, police and military units without any search warrant or warrant of arrest cordon an area of
more than one residence and sometimes whole barangay. These raiders allegedly rudely rouse residents from their sleep by
banging on the walls and windows of their homes, shouting, kicking their doors open and then ordering the residents within to
come of their respective residences. Some of the members of the raiding team force their way into each and every house within
the cordoned off area and then proceed to conduct search of the said houses.
Issue: WON the Saturation Drives seeking to cripple subversive movements is subject to limitation of the rights of the people. YES
Ruling: The Constitution grants to the Government the power to seek and cripple subversive movements which would bring down
constituted authority and substitute a regime where individual liberties are suppressed as a matter of policy in the name of
security of the State. However, all police actions are governed by the limitations of the Bill of Rights. The Government cannot
adopt the same reprehensible methods of authoritarian systems both of the right and of the left, the enlargement of whose
spheres of influence it is trying hard to suppress. Our democratic institutions may still be fragile but they are not in the least bit
strengthened through violations of the constitutional protections which are their distinguishing features.
In Roan vs. Gonzales, the Court stated:
“One of the most precious rights of the citizen in a free society is the right to be left alone in the privacy of his own
house…Even then, the lowly subject had his own castle where he was monarch of all he surveyed. This him humble
cottage from which he could bar his sovereign lord and all the forces of the Crown.
That right is guaranteed in the following provisions of Article IV of the 1973 Constitution:
SEC. 3. The right of the people to be secure in their persons, houses, papers and effects against unreasonable
searches and seizures of whatever nature and for any purpose shall not be violated, and no search warrant or
warrant of arrest shall issue except upon probable cause to be determined by the judge, after examination under
oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place
to be searched, and the persons or things to be seized.”
The individual’s right to immunity from such invasion of his body was considered as “far outweighed by the value of its
deterrent effect” on the evil sought to be avoided by the police action.
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Where there is large scale mutiny or actual rebellion, the police or military may go in force to the combat areas, enter affected
residences or buildings, round up suspected rebels and otherwise quell the mutiny or rebellion without having to secure search
warrants and without violating the Bill of Rights…It is clear from the pleadings of both petitioners and respondents, however, that
there was no rebellion or criminal activity similar to that of the attempted coup d’ etats. There appears to have been no
impediment to securing search warrants or warrants of arrest before any houses were searched or individuals roused from sleep
were arrested. There is no strong showing that the objectives sought to be attained by the “areal zoning” could not be achieved
even as the rights of the squatter and low income families are full protected.
Ople vs. Torrest. GR No. 127685. July 23, 1998
Facts: A.O No. 308 (Adoption of a National Computerized Identification Reference System) was issued by President Fidel Ramos. Sec. 4
thereof provides:
The Population Reference Number (RPN) generated by the NSO shall serve as the common reference number to establish
a linkage among concerned agencies. The IACC Secretariat shall coordinate with the different Social Security and Services
Agencies to establish the standards in the use of Biometrics Technology and in computer application designs of their
respective systems.
Petitioner Sen. Ople prays for that the SC invalidate AO No. 308 on two constitutional grounds, viz.: one, it is a usurpation of the
power of Congress to legislate, and two, it is impermissible intrudes on our citizenry’s protected zone of privacy.
Issue: WON there is a constitutionally guaranteed right of privacy, and Corollarily, WON AO No. 308 violates such right. YES
Ruling: Assuming, arguendo, that AO No. 308 need not be the subject of a law, still it cannot pass constitutional muster as an
administrative legislation because facially it violates the right to privacy. The essence of privacy is the right to be let alone. In the
1968 case of Morfe vs. Mutuc, we adopted the Griswold ruling that there is a constitutional right to privacy…we held:
So it is likewise in our jurisdiction. The right to privacy as such is accorded recognition independently of its
identification with liberty; in itself, it is fully deserving of constitutional protection. “The concept of limited government
has always included the idea that governmental powers stop short of certain intrusions into the personal life of the
citizen. This is indeed one of the basic distinctions between absolute and limited government. Ultimate and pervasive
control of the individual, in all aspects of his life, is the hallmark of the absolute state. In contrast, a system of limited
government safeguards a private sector, which belongs to the individual, firmly distinguishing it from the public sector,
which the state can control. Protection of this private sector – protection, in other words, of the dignity and integrity of
the individual – has become increasingly important as modern society has developed. All the forces of a technological age
– industrialization, urbanization, and organization – operate to narrow the area of privacy and facilitate intrusion into it.
Indeed, if we extend our judicial gaze we will find that the right of privacy is recognized and enshrined in several provisions of
our Constitution. It expressly recognized in Section 3(1) of the Bill of Rights:
Other facets of the right to privacy are protected in various provisions of the Bill of Rights, viz.: (Secs. 1, 2, 6, 8, 17)
Zones of privacy are likewise recognized and protected in our laws. The Civil Code provides that (Secs. 35, 32, 723). The
Revised Penal Code makes a crime (Article 229, 290-292, 280). Invasion of privacy is an offense in our special laws like the Anti-
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Wiretapping Law, the Secrecy of Bank of Deposit Act and the Intellectual Property Code. The Rules of Court on privileged
communication likewise recognize the privacy of certain information.
Xxx, we prescind from the premise that the right to privacy is a fundamental right guaranteed by the Constitution, hence, it is
the burden of government to show that AO No. 308 is justified by some compelling state interest and that it is narrowly drawn.
 It is noteworthy that AO No. 308 does not state what specific biological characteristics and what particular biometrics
technology shall be used to identify people who will its coverage.
 AO No. 308 should also raise our antennas for a further look will show that it does not state whether encoding of data is
limited to biological information alone for identification purposes.
 The potential misuse of the data to be gathered xxx cannot be underplayed… Pursuant to said administrative order, an
individual must present his PRN everytime he deals with a government agency to avail of basic services and security. His
transactions … will necessarily be recorded…The data may be gathered for gainful and useful government purposes; but the
existence of this vast reservoir of personal information constitutes a covert invitation to misuse, a temptation that may be too
great for some of our authorities to resist.
 It is plain and we hold that AO No. 308 falls short of assuring that personal information which will be gathered about our
people will only be processed for unequivocally specified purposes.
 We reject the argument of the Solicitor General that an individual has a reasonable expectation of privacy with regard to the
National ID and the use of biometrics technology…
 The reasonableness of a person’s expectation of privacy depends on the two-part test: (1) whether by his conduct, the
individual has exhibited an expectation of privacy; and (2) whether his expectation is one that society recognizes as
reasonable.
 The factual circumstances of the case determines the reasonableness of expectation. However, other factor, such as customs,
physical surroundings and practices of a particular activity, may serve to create or diminish this expectation. The use of
biometrics and computer technology in AO No. 308 does not assure the individual of a reasonable expectation of privacy. As
technology advances, the level of reasonably expected privacy decreases.
Association of Small Landowners in the Philippines, Inc. vs. Secretary Agrarian Reform. GR No. 78742. July 14, 1989
Facts: The petitioners challenges the constitutionality of the several measures involving land reform: RA No. 3844, PD No. 27 and RA No.
6657, etc. They claimed violations of due process and equal protection of laws.
Issue: WON the subject measures are unconstitutional for being violative of due process and equal protection clause. NO
Ruling: (Equal protection of Laws)
Classification has been defined as the grouping of persons or things similar to each other in certain particulars and different
from each other in these same particulars. To be valid, it must conform to the following requirements: (1) it must be based on
substantial distinctions; (2) it must be germane to the purposes of the law; (3) it must not be limited to existing conditions only;
and (4) it must apply equally to all the members of the class.
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Equal protection simply means that all persons or things similarly situated must be treated alike both as to the rights
conferred and the liabilities imposed. The petitioners (small landowners) have not shown that they belong to a different class and
entitled to a different treatment. The argument that not only landowners but also owners of other properties must be made to
share the burden of implementing land reform must be rejected. There is a substantial distinction between these two classes of
owners that is clearly visible except to those who will not see.
(Due process)
It is worth remarking at this juncture that a statute may sustained under the police power only if there is a concurrence of the
lawful subject and the lawful method…One of the basic principles of the democratic system is that where the rights of the
individual are concerned, the end does not justify means. It is enough that there be a valid objective; it is also necessary that the
means employed to pursue it be in keeping with the Constitution. Mere expediency will not excuse constitutional shortcuts.
There is no question that not even the strongest moral conviction or the most urgent public need, subject only to a few notable
exceptions, will excuse the bypassing of an individual’s rights. It is no exaggeration to say that a, person invoking a right
guaranteed under Article III of the Constitution is a majority of one even as against the rest of the nation who would deny him
that right.
Inchong vs. Hernandez. GR No. L-7995. May 31, 1957
Facts: Republic Act No. 1180 is entitled "An Act to Regulate the Retail Business." In effect it nationalizes the retail trade business. The
main provisions of the Act are: (1) a prohibition against persons, not citizens of the Philippines, and against associations,
partnerships, or corporations the capital of which are not wholly owned by citizens of the Philippines, from engaging directly or
indirectly in the retail trade. Petitioner prays for a judicial declaration that said Act is unconstitutional, and to enjoin the Secretary
of Finance and all other persons acting under him, particularly city and municipal treasurers, from enforcing its provisions.
Petitioner contends that it denies to alien residents the equal protection of the laws and deprives of their liberty and property
without due process of law
Issue: WON RA No. 1180 is violative of the due process and the equal protection clause. NO
Ruling: a. The police power. —
There is no question that the Act was approved in the exercise of the police power…It has been said the police power is so far -
reaching in scope, that it has become almost impossible to limit its sweep. As it derives its existence from the very existence of
the State itself, it does not need to be expressed or defined in its scope; it is said to be co-extensive with self-protection and
survival, and as such it is the most positive and active of all governmental processes, the most essential, insistent and illimitable.
Especially is it so under a modern democratic framework where the demands of society and of nations have multiplied to almost
unimaginable proportions; the field and scope of police power has become almost boundless, just as the fields of public interest
and public welfare have become almost all-embracing and have transcended human foresight. Otherwise stated, as we cannot
foresee the needs and demands of public interest and welfare in this constantly changing and progressive world, so we cannot
delimit beforehand the extent or scope of police power by which and through which the State seeks to attain or achieve interest
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or welfare. So it is that Constitutions do not define the scope or extent of the police power of the State; what they do is to set
forth the limitations thereof. The most important of these are the due process clause and the equal protection clause.
b. Limitations on police power. —
The basic limitations of due process and equal protection are found in the following provisions of our Constitution:
SECTION 1.(1) No person shall be deprived of life, liberty or property without due process of law, nor any person be
denied the equal protection of the laws. (Article III, Phil. Constitution)
These constitutional guarantees which embody the essence of individual liberty and freedom in democracies, are not limited to
citizens alone but are admittedly universal in their application, without regard to any differences of race, of color, or of
nationality.
c. The, equal protection clause. —
The equal protection of the law clause is against undue favor and individual or class privilege, as well as hostile discrimination or
the oppression of inequality. It is not intended to prohibit legislation, which is limited either in the object to which it is directed or
by territory within which is to operate. It does not demand absolute equality among residents; it merely requires that all persons
shall be treated alike, under like circumstances and conditions both as to privileges conferred and liabilities enforced. The equal
protection clause is not infringed by legislation which applies only to those persons falling within a specified class, if it applies alike
to all persons within such class, and reasonable grounds exists for making a distinction between those who fall within such class
and those who do not.
d. The due process clause. —
The due process clause has to do with the reasonableness of legislation enacted in pursuance of the police power. Is there public
interest, a public purpose; is public welfare involved? Is the Act reasonably necessary for the accomplishment of the legislature's
purpose; is it not unreasonable, arbitrary or oppressive? Is there sufficient foundation or reason in connection with the matter
involved; or has there not been a capricious use of the legislative power? Can the aims conceived be achieved by the means used,
or is it not merely an unjustified interference with private interest? These are the questions that we ask when the due process
test is applied.
The conflict, therefore, between police power and the guarantees of due process and equal protection of the laws is more
apparent than real. Properly related, the power and the guarantees are supposed to coexist. The balancing is the essence or, shall
it be said, the indispensable means for the attainment of legitimate aspirations of any democratic society. There can be no
absolute power, whoever exercise it, for that would be tyranny. Yet there can neither be absolute liberty, for that would mean
license and anarchy. So the State can deprive persons of life, liberty and property, provided there is due process of law; and persons
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may be classified into classes and groups, provided everyone is given the equal protection of the law. The test or standard, as
always, is reason. The police power legislation must be firmly grounded on public interest and welfare, and a reasonable relation
must exist between purposes and means. And if distinction and classification has been made, there must be a reasonable basis
for said distinction.
We are fully satisfied upon a consideration of all the facts and circumstances that the disputed law is not the product of racial
hostility, prejudice or discrimination, but the expression of the legitimate desire and determination of the people, thru their
authorized representatives, to free the nation from the economic situation that has unfortunately been saddled upon it rightly or
wrongly, to its disadvantage. The law is clearly in the interest of the public, nay of the national security itself, and indisputably falls
within the scope of police power, thru which and by which the State insures its existence and security and the supreme welfare of
its citizens.
The above objectionable characteristics of the exercise of the retail trade by the aliens, which are actual and real, furnish
sufficient grounds for legislative classification of retail traders into nationals and aliens. Some may disagree with the wisdom of
the legislature's classification. To this we answer, that this is the prerogative of the law-making power. Since the Court finds that
the classification is actual, real and reasonable, and all persons of one class are treated alike, and as it cannot be said that the
classification is patently unreasonable and unfounded, it is in duty bound to declare that the legislature acted within its legitimate
prerogative and it can not declare that the act transcends the limit of equal protection established by the Constitution.
Broadly speaking, the power of the legislature to make distinctions and classifications among persons is not curtailed or denied by
the equal protection of the laws clause. The legislative power admits of a wide scope of discretion, and a law can be violative of
the constitutional limitation only when the classification is without reasonable basis.
The law in question is deemed absolutely necessary to bring about the desired legislative objective, i.e., to free national economy
from alien control and dominance. It is not necessarily unreasonable because it affects private rights and privileges (11 Am. Jur.
pp. 1080-1081.) The test of reasonableness of a law is the appropriateness or adequacy under all circumstances of the means
adopted to carry out its purpose into effect (Id.) Judged by this test, disputed legislation, which is not merely reasonable but
actually necessary, must be considered not to have infringed the constitutional limitation of reasonableness.