Section 14:

No person shall be held to answer for a criminal offense without due process of law.
In all criminal prosecutions, the accused shall be presumed innocent until the contrary is
proved, and shall enjoy the right to be heard by himself and counsel, to be informed of the
2
nature and cause of the accusation against him, to have a speedy, impartial, and public trial, to
meet the witnesses face to face, and to have compulsory process to secure the attendance of
witnesses and the production of evidence in his behalf. However, after arraignment, trial may
proceed notwithstanding the absence of the accused: Provided, that he has been duly notified
and his failure to appear is unjustifiable.

. Mejia vs Pamaran, GR No. L-56741-42

Facts:
In this case, petitioner Aurora Mejia was charged and convicted by the Sandiganbayan for violation
of the Anti-Graft and Corrupt Practices Act. She was accused of soliciting and receiving money
from complainants in exchange for favorable resolutions in court cases where she served as branch
clerk of court.

Petitioner raised the issue that the Sandiganbayan acted without jurisdiction and violated her right
to due process under Article 3, Section 14 of the 1987 Constitution, which guarantees the rights of
the accused to a fair trial. She argued that the procedures under the Sandiganbayan were ex post
facto laws and denied her equal protection by limiting her appeal rights.

The Court, however, found that due process was observed: petitioner was informed of the charges,
had the opportunity to be heard and to cross-examine witnesses, and the conviction was based on
credible evidence. The Court emphasized that due process requires a fair and impartial trial with
reasonable opportunity to prepare a defense, which was met in this case. The recall of petitioner for
further cross-examination was within the court’s discretion and relevant to the case.

Issue:
Did the Sandiganbayan act without jurisdiction and violate due process as it was not created in
accordance with constitutional mandates?

Ruling:
No, the Sandiganbayan did not act without jurisdiction nor violate due process despite questions on
its creation.

Article 3, Section 14 of the 1987 Constitution guarantees the right of the accused to due process.
The Supreme Court in Nunez v. Sandiganbayan held that the President had authority under the 1976
Amendments to the 1973 Constitution to create the Sandiganbayan, and the court exercising
jurisdiction under a valid law satisfies due process requirements.

Although petitioner argued the Sandiganbayan was not constitutionally created, the Court affirmed
its valid creation under the President’s legislative powers during martial law. The Sandiganbayan is a
1
court of competent jurisdiction, and petitioner was afforded notice, opportunity to be heard, and
trial according to law, satisfying due process under Article 3, Section 14.

Thus, the Sandiganbayan acted within its jurisdiction and did not violate petitioner’s constitutional
right to due process.

. People vs Ablaneda, GR No. 128075

Facts:
In the case of People v. Alfredo Ablaneda y Peconia, the accused-appellant was charged with rape.
The facts reveal that the accused was arrested on May 28, 1994, several months after the alleged
incident on May 21, 1993. The accused contended that he was ordered by armed men, suspected to
be NPA members, to bring the complainant to a location for questioning, and denied committing
rape. The complainant delayed reporting the incident for three months, initially giving a sworn
statement that no rape was consummated. The accused raised the issue of his constitutional right
against unreasonable searches and seizures and the right to due process under Article III, Section
14 of the 1987 Constitution, which protects against unlawful arrests and detentions. The Court
reviewed whether the accused's arrest and detention complied with constitutional safeguards,
including the requirement of a valid warrant and proper procedure. Ultimately, the Court acquitted
the accused, emphasizing the presumption of innocence and the failure of the prosecution to prove
guilt beyond reasonable doubt. The case underscores the importance of upholding the accused's
constitutional rights during investigation and trial.

Issue:
Did the trial court err in giving weight to the testimony of the complainant, which the accused
claims is full of improbabilities and inconsistencies?

Ruling:
Yes, the trial court erred in giving weight to the complainant's testimony despite the improbabilities
and inconsistencies.

Article III, Section 14 of the 1987 Philippine Constitution guarantees the right of the accused to be
presumed innocent until proven guilty beyond reasonable doubt.

The complainant's sworn statement before the barangay captain contradicted her court testimony,
stating that the accused did not consummate the alleged rape. Additionally, her calm demeanor
after the incident and the three-month delay in reporting raise serious doubts about her credibility.
The prosecution failed to present physical evidence such as torn clothing, and the medical
examination did not conclusively establish rape. These inconsistencies and lack of corroborative
evidence undermine the presumption of guilt and support the presumption of innocence.

Given the contradictions and insufficient evidence, the trial court should not have given full
credence to the complainant's testimony. Upholding the constitutional presumption of innocence,
the accused's guilt was not proven beyond reasonable doubt.

. People vs So, GR No. 133861

Facts:
In the case of People v. Robert So y Chua, the accused-appellant was apprehended in a buy-bust
operation for illegal sale of methamphetamine hydrochloride. After his arrest, he alleged violations
of his rights under Article III, Section 14 of the 1987 Constitution, which protects against involuntary
confessions and guarantees the right to counsel.

Specifically, Robert So claimed that he was subjected to physical torture, including being tied,
blindfolded, electrocuted, and mauled by police officers who also threatened to kill him if he did not
disclose information. He further alleged that he was extorted for money during his detention, with
police officers demanding large sums in exchange for his release and non-filing of charges.

Despite these claims, the trial court found no medical evidence supporting physical torture, as the
Medical Examination Report showed normal vital signs and no indications of torture. The court also
noted that the alleged extortion occurred after the commission of the crime and did not affect the
credibility of the prosecution witnesses or negate the guilt of the accused.

Thus, while the accused raised issues related to his constitutional rights against involuntary
confession and illegal detention, the court ruled that these rights were not violated in a manner that
would invalidate the evidence or the conviction.

Issue:
Did the trial court err in convicting Robert So y Chua despite the prosecution's failure to establish
his guilt beyond a reasonable doubt?

Ruling:
The trial court did not err in convicting Robert So y Chua despite the prosecution's failure to
establish his guilt beyond a reasonable doubt.

Article III, Section 14 of the 1987 Constitution of the Philippines guarantees the right of an accused
to be presumed innocent until proven guilty and protects against involuntary confessions.

In the case of Robert So, the trial court found sufficient evidence from the testimonies of police
officers involved in the buy-bust operation, which included the actual delivery of illegal drugs.
Although So claimed he was subjected to torture and extortion by the police, the court determined
that the evidence presented by the prosecution was credible and established the commission of the
crime beyond a reasonable doubt. The court also noted that the alleged police misconduct occurred
after the crime was committed and did not negate the fact that So engaged in drug trafficking.

Therefore, the trial court's conviction of Robert So y Chua was upheld as the evidence sufficiently
demonstrated his guilt, and the protections under Article III, Section 14 were not violated in this
context.

. People vs Reyes, 60 SCRA 126

Facts:
The case involves Angel Reyes y Alcantara, who was convicted of murder qualified by treachery.
The incident occurred on October 1, 1970, when Reyes, a policeman in civilian clothes, shot
Norberto Flores in a police precinct after a confrontation. The shooting followed Reyes threatening
Flores, indicating an intention to kill. The trial court found no merit in Reyes' claims of accidental
shooting, noting that his actions were intentional and premeditated.

The court also addressed the credibility of witnesses, ruling that inconsistencies in their testimonies
were minor and did not undermine their reliability. The accused's position as a policeman was
considered an aggravating circumstance, as he misused his authority and service firearm. The trial
court imposed the death penalty and ordered indemnities to the heirs of the deceased.

Issue:
Did the trial court err by finding the testimonies of the prosecution witnesses credible despite their
relationship with the victim?

Ruling:
No, the trial court did not err in finding the testimonies of the prosecution witnesses credible
despite their relationship with the victim.
Article 3, Section 14 of the 1987 Philippine Constitution provides that "no person shall be deprived
of the right to be heard by himself and counsel." This includes the right to present evidence and the
credibility of witnesses.

In the case of Angel Reyes y Alcantara, the trial court evaluated the testimonies of prosecution
witnesses Jose Garcia and Conchita Flores, who were related to the victim. The court found that
their testimonies, despite minor inconsistencies, were credible and consistent in the essential
details of the incident. The relationship of the witnesses to the victim did not automatically bias
their testimonies, as the court noted that their accounts were not rehearsed and reflected good
faith.

Therefore, the trial court's determination of credibility was supported by the evidence presented
and aligned with constitutional provisions, affirming that the relationship of the witnesses to the
victim did not impair their testimonies.

Section 15: The privilege of the writ of habeas corpus shall not be suspended except in cases of
invasion or rebellion, when the public safety requires it.

. Caballes vs CA, 452 SCRA 312

Facts:
In the case of Glenn Caballes, he was charged with the rape of a minor and detained as it was a
non-bailable offense. After several delays in the trial, attributed to both the prosecution and the
defense, Caballes filed a petition for habeas corpus, claiming he was deprived of his right to a
speedy trial. The Court of Appeals dismissed his petition, stating that habeas corpus was not the
proper remedy for reviewing trial court proceedings.

The Supreme Court upheld this dismissal, clarifying that a writ of habeas corpus is intended to
enforce civil rights and is not a means to review errors of trial court procedures. The Court
emphasized that Caballes failed to demonstrate that his right to a speedy trial was violated, as the
delays were not solely attributable to the prosecution. Ultimately, the Supreme Court denied the
petition for lack of merit, affirming that the appropriate remedy for his claims should have been
through a petition for certiorari rather than habeas corpus.

Issue:
Is the proper remedy for the appellate court's denial of a petition for a writ of habeas corpus a
petition for certiorari under Rule 65 of the Rules of Court? If so, is Caballes entitled to the issuance
of the writ?

Ruling:
No, the proper remedy for the appellate court's denial of a petition for a writ of habeas corpus is not
a petition for certiorari under Rule 65 of the Rules of Court.

Article III, Section 15 of the 1987 Constitution provides that "the right to a speedy disposition of
cases shall be guaranteed." However, the remedy for a denial of a writ of habeas corpus is
specifically governed by the rules pertaining to habeas corpus cases, which require an appeal to be
filed within 48 hours from notice of the judgment.

In the case of Glenn Caballes, the Court of Appeals dismissed his petition for habeas corpus,
stating it was not the proper remedy to review trial court proceedings. The Supreme Court upheld
this dismissal, clarifying that certiorari cannot coexist with an appeal, and that the petitioner failed
to establish his right to the writ.

Therefore, Caballes is not entitled to the issuance of the writ of habeas corpus as he did not follow
the proper procedural remedy, and the Supreme Court found no merit in his claims regarding the
denial of his right to a speedy trial.

. Alejano vs Cabuay, 468 SCRA 188

Facts:

The case involves a petition for habeas corpus filed by several detained military officers, including
Capt. Gary Alejano and Lt. SG Antonio Trillanes IV, following their involvement in the Oakwood
incident on July 27, 2003, where they led an armed takeover of the Oakwood Premier Luxury
Apartments. The petitioners challenged the legality of their detention by the Intelligence Service of
the Armed Forces of the Philippines (ISAFP) after being charged with coup d'état.

The Court of Appeals dismissed the habeas corpus petition, asserting that the detainees were
lawfully charged and that their confinement was valid. The Supreme Court clarified that the purpose
of habeas corpus is to inquire into the legality of detention, not to address conditions of
confinement. The Court emphasized that allegations of constitutional rights violations must meet a
high threshold to warrant the issuance of the writ, and found that the conditions imposed by ISAFP
were reasonable for security purposes.

Ultimately, the Supreme Court affirmed the Court of Appeals' decision, dismissing the habeas
corpus petition and underscoring the limited scope of the writ in addressing issues related to
detention conditions.

Issue:
Whether the Court of Appeals erred in reviewing and reversing an earlier decision of the Supreme
Court regarding the habeas corpus petition.

Ruling:
Yes, the Court of Appeals erred in reviewing and reversing the Supreme Court's earlier decision
regarding the habeas corpus petition.

Article III, Section 15 of the 1987 Constitution provides that the privilege of the writ of habeas
corpus shall not be suspended except in cases of invasion or rebellion when the public safety
requires it. This section emphasizes the finality of the Supreme Court's decisions in matters of
habeas corpus.

In the case, the Supreme Court had previously issued a resolution directing the Court of Appeals to
conduct a factual hearing on the habeas corpus petition. However, the Court of Appeals dismissed
the petition, effectively reversing the Supreme Court's directive without proper authority. The
petitioners did not question the legality of their detention but instead challenged the conditions
surrounding it, which the Court of Appeals incorrectly addressed as a matter of legality.

The Court of Appeals acted beyond its jurisdiction by reviewing and reversing the Supreme Court's
decision, which undermines the finality of the Supreme Court's rulings as mandated by Article III,
Section 15. Therefore, its dismissal of the habeas corpus petition was erroneous.
Section 16. All persons shall have the right to a speedy disposition of their cases before all
judicial, quasi-judicial, or administrative bodies.

. Bermisa vs. Court of Appeals, G.R. No. L-32506

Facts:
In the case of Dominador Bermisa, he was initially charged with Frustrated Murder on May 8, 1963.
After a lengthy process, the case was provisionally dismissed on June 2, 1965, due to the absence
of witnesses, with Bermisa consenting to this dismissal. The case was refiled on September 10,
1969, after a delay of over four years.

Bermisa filed a Motion to Quash before entering a plea to the second Information, claiming a
violation of his constitutional right to a speedy trial as guaranteed by Article 3, Section 16 of the
1987 Constitution. The Court denied his Motion to Quash, stating that the delay did not constitute a
violation of his right to a speedy trial, as there was no trial in the legal sense due to the provisional
dismissal.

The Court emphasized that Bermisa's consent to the provisional dismissal constituted a waiver of
his right to contest the delay. Ultimately, the Court concluded that his claims regarding the denial of
his right to a speedy trial lacked legal merit, and the case was allowed to proceed.

Issue:
Whether or not the petitioner’s constitutional right to a speedy trial was violated by the delay
between the provisional dismissal and the refiling of the criminal case.

Ruling:
The petitioner's constitutional right to a speedy trial was not violated by the delay between the
provisional dismissal and the refiling of the criminal case.

Article 3, Section 16 of the 1987 Constitution guarantees the right of the accused to a speedy,
impartial, and public trial. This right is intended to prevent undue delays that could prejudice the
accused.

In the case of Dominador Bermisa, the initial charge of Frustrated Murder was provisionally
dismissed on June 2, 1965, with his consent due to the absence of witnesses. The case was refiled
on September 10, 1969, after a delay of over four years. The Court found that this delay did not
constitute a violation of the right to a speedy trial because the provisional dismissal was agreed
upon by Bermisa, and there was no trial pending during the interim period.

Therefore, since Bermisa consented to the provisional dismissal and the refiled case was within the
prescriptive period, his constitutional right to a speedy trial was not violated.

. Kalaw vs Apostol, 64 PHIL 852

Facts:
In the case of Gregorio K. Kalaw vs. Segundo Apostol, the petitioner sought the dismissal of criminal
case No. 10656, which arose from a previous case of frustrated murder that had been dismissed
before he could plead. The petitioner experienced significant delays, with over one and a half years
passing before a partial trial occurred. The court found that these delays were unjustified, primarily
due to the convenience of the private prosecutor and the fiscal, violating the petitioner's right to a
speedy trial as guaranteed by Article III, Section 16 of the 1987 Constitution. The court emphasized
that the right to a speedy trial is fundamental and must be protected from vexatious and oppressive
delays. Ultimately, the court granted the petitioner's request, dismissing the case and ordering that
he not be prosecuted again for the same facts and crime.

Issue:
Was the petitioner denied his right to a speedy trial, and does this violation warrant the dismissal of
the second information?

Ruling:
Yes, the petitioner was denied his right to a speedy trial, and this violation warrants the dismissal of
the second information.

Article 3, Section 16 of the 1987 Constitution of the Philippines guarantees the right of the accused
to a speedy and public trial.

In the case of Gregorio K. Kalaw vs. Segundo Apostol, the petitioner experienced over one and a
half years of unjustified delays before a partial trial occurred. The court found that these delays
were primarily due to the convenience of the private prosecutor and the fiscal, which constituted a
violation of the petitioner's right to a speedy trial.

Given the significant delays and the court's finding of unjustified postponements, the violation of
the petitioner's right to a speedy trial warranted the dismissal of the second information against
him.

. Lumanlaw vs Judge Peralta, GR No. 164953

Facts:

In the case of John Joseph Lumanlaw y Bulinao, the petitioner was charged with illegal possession
of a dangerous drug and was detained since December 2002. His arraignment was initially set for
January 8, 2003, but was postponed multiple times due to various reasons, including the absence
of his counsel and the failure of jail wardens to bring him to court. Over a span of almost two years,
there were fourteen postponements, resulting in the petitioner remaining uninformed of the charges
against him while in detention.

The repeated delays in conducting the arraignment constituted a violation of his constitutional right
to a speedy trial as guaranteed under Article 3, Section 16 of the 1987 Constitution. The court
emphasized that such vexatious and oppressive delays not only infringed upon the right to a speedy
trial but also undermined public confidence in the judiciary. Ultimately, the court granted the
petition for mandamus, dismissing the case against the petitioner due to the violation of his right to
a speedy trial and ordering his release from detention.

Issue:
Did the failure of the respondent to conduct the arraignment of the petitioner, resulting in a delay of
one year, nine months, and four days, constitute an undue and unjustifiable delay that violated his
constitutional right to a speedy trial?

Ruling:
Yes, the failure to conduct the arraignment within a reasonable time constituted an undue and
unjustifiable delay that violated the petitioner's constitutional right to a speedy trial.
Article 3, Section 16 of the 1987 Constitution of the Philippines guarantees the right of the accused
to a speedy, impartial, and public trial. This right is further supported by Rule 116 of the Revised
Rules on Criminal Procedure, which mandates that arraignment should occur within thirty days from
the court's acquisition of jurisdiction over the accused.

In the case of John Joseph Lumanlaw y Bulinao, the petitioner experienced a delay of one year, nine
months, and four days before his arraignment. This delay was characterized by fourteen
postponements, many of which were due to the failure of jail wardens to bring him to court and the
absence of his counsel. The repeated delays were not justified and resulted in the petitioner
remaining uninformed of the charges against him while in detention.

Given the excessive length of the delay and the lack of reasonable justification for the
postponements, the court found that the petitioner's right to a speedy trial was violated, warranting
the dismissal of the information against him.

Section 17. No person shall be compelled to be a witness against himself.

. People vs Ayson, GR No. 85215

Facts:
In the case of Felipe Ramos, the controversy arose from the interpretation of the right against self-
incrimination under Section 20, Article IV of the 1973 Constitution, which is now reflected in Article
III, Section 17 of the 1987 Constitution. Ramos, a ticket freight clerk at Philippine Airlines, was
subjected to an administrative investigation regarding alleged irregularities in ticket sales.

Prior to the investigation, he submitted a handwritten note expressing his willingness to settle the
alleged irregularities. During the investigation, he provided answers to questions posed by the
Branch Manager without the presence of legal counsel. Subsequently, he was charged with estafa
based on these statements.

The respondent judge ruled that Ramos's statements were inadmissible as evidence due to the
absence of legal counsel during questioning, invoking the self-incrimination clause. The prosecution
contested this ruling, arguing that the statements should be admissible. The court ultimately
clarified that the right against self-incrimination must be actively asserted and is not self-executing,
leading to the annulment of the judge's orders and the admission of Ramos's statements as
evidence.

Issue:
Was Ramos subjected to custodial interrogation when he made the statements, thereby invoking the
constitutional protections against self-incrimination and the right to counsel?

Ruling:
No, Ramos was not subjected to custodial interrogation when he made his statements, and
therefore the constitutional protections against self-incrimination and the right to counsel were not
invoked.

Article III, Section 17 of the 1987 Constitution states that no person shall be compelled to be a
witness against himself and that any person under investigation for the commission of an offense
shall have the right to remain silent and to counsel.

In the case of Felipe Ramos, the investigation conducted by Philippine Airlines was administrative in
nature and not a custodial interrogation as defined by law. Ramos voluntarily provided statements
during the investigation without being deprived of his freedom or subjected to coercive questioning
by law enforcement. The investigation did not meet the criteria for custodial interrogation, which
requires that a person be in custody or deprived of their liberty in a significant way.

Since Ramos was not under custodial interrogation, the protections afforded by Article III, Section
17 of the 1987 Constitution did not apply, and his statements made during the administrative inquiry
were admissible.

This case highlights the distinction between the right against self-incrimination and the rights of
individuals during custodial interrogation, emphasizing that the latter rights apply specifically to
individuals under investigation by law enforcement.

. Chavez vs CA, 24 SCRA 663

Facts:
In the case of Roger Chavez, the issue of self-incrimination arose when Chavez, an accused in a
criminal case for qualified theft, was compelled to testify as a witness for the prosecution. During
the trial, Chavez's counsel objected to this move, asserting that it violated his constitutional right
against self-incrimination as enshrined in Article III, Section 17 of the 1987 Constitution, which
states that no person shall be compelled to be a witness against themselves.

Despite the objection, the trial court insisted on calling Chavez to the witness stand, asserting that
it was within the prosecution's rights to do so. Chavez was ultimately forced to testify, which led to
the prosecution using his statements as key evidence against him, branding him as the "star
witness." The trial court's reliance on Chavez's compelled testimony to establish his guilt
constituted a clear violation of his constitutional rights, as he was not given the option to refuse to
testify.

The Supreme Court ultimately ruled that Chavez was indeed compelled to testify against himself,
which breached his constitutional right to remain silent. This ruling emphasized the mandatory
nature of the privilege against self-incrimination and underscored the importance of protecting
individuals from being forced to provide evidence that could lead to their own conviction.

Issue:
Was Roger Chavez denied his constitutional right not to be compelled to testify against himself?

Ruling:
Yes, Roger Chavez was denied his constitutional right not to be compelled to testify against himself.

Article III, Section 17 of the 1987 Constitution states that no person shall be compelled to be a
witness against himself.

In this case, Chavez objected to being compelled to testify, asserting his right against self-
incrimination. Despite this, the court forced him to take the stand and answer questions that led to
his self-incrimination, violating his constitutional right.

Thus, Chavez's forced testimony without his voluntary waiver constitutes a violation of his
constitutional right under Article III, Section 17.

Section 18. No person shall be detained solely by reason of his political beliefs and aspirations.
No involuntary servitude in any form shall exist except as a punishment for a crime whereof the
party shall have been duly convicted.

. People vs Pimentel, GR No. 100210

Facts:
The case involves Antonio A. Tujan, who was initially charged with subversion under Republic Act
No. 1700 in 1983. After being arrested in 1990, an unlicensed firearm and ammunition were found in
his possession, leading to a new charge of illegal possession of firearms in furtherance of
subversion under Presidential Decree No. 1866. Tujan filed a motion to quash the new charge,
arguing that it constituted double jeopardy since he was already facing a subversion charge. The
trial court granted his motion, but the Court of Appeals upheld this decision. However, the Supreme
Court later disagreed, stating that the two charges were distinct offenses that could coexist. The
Supreme Court ultimately dismissed the subversion charge due to its repeal by Republic Act No.
7636 and amended the illegal possession charge to simple illegal possession of firearms, ordering
Tujan's release from detention.

Issue:
How legislative changes—specifically the repeal of R.A. No. 1700 by R.A. No. 7636 and the
subsequent amendment under R.A. No. 8294—affect the prosecution and punishment of the
accused in relation to double jeopardy and the nature of the offense charged.

Ruling:
The repeal of R.A. No. 1700 by R.A. No. 7636 and the amendment under R.A. No. 8294 significantly
affect the prosecution and punishment of Antonio A. Tujan, eliminating the basis for his subversion
charge and altering the nature of the illegal possession charge.

Article III, Section 18 of the Philippine Constitution states that no person shall be detained solely by
reason of his political beliefs and aspirations, and it also embodies the principle of double jeopardy,
which protects individuals from being prosecuted for the same offense after a conviction or
acquittal.

Here, the repeal of R.A. No. 1700 rendered the subversion charge against Tujan legally baseless, as
there was no longer a law under which he could be prosecuted for subversion. Furthermore, the
amendment under R.A. No. 8294 changed the nature of the illegal possession charge from one that
could lead to severe penalties to a lesser charge of simple illegal possession of firearms, which is
now bailable. This alteration means that Tujan cannot be tried for the same offense of subversion
again, as it no longer exists, thus reinforcing his protection against double jeopardy.

Thus, the legislative changes effectively protect Tujan from further prosecution for subversion and
reduce the severity of the illegal possession charge, aligning with the constitutional guarantee
against double jeopardy and ensuring that he is not punished for an offense that has been repealed.

. Rubi vs The Provincial Board of Mindoro, GR No. L-14078

Facts:
The case of Rubi et al. (Manguianes) vs. The Provincial Board of Mindoro revolves around an
application for habeas corpus filed by Rubi and other Manguianes from the Province of Mindoro.
The petitioners claimed they were being unlawfully detained by provincial officials. The events
leading to the case began on February 1, 1917, when the Provincial Board of Mindoro adopted
Resolution No. 25, which mandated that the Manguianes be settled in a designated area at Tigbao,
Mindoro. This resolution was based on the belief that previous attempts to advance the Manguianes
had failed and that a permanent settlement was necessary for their education and protection. The
resolution was approved by the Secretary of the Interior on February 21, 1917. Subsequently, on
December 4, 1917, the provincial governor issued Executive Order No. 2, directing all Manguianes
in the vicinity to relocate to the Tigbao site by December 31, 1917, under the threat of
imprisonment for non-compliance. The petitioners argued that this directive was unconstitutional
and challenged the validity of the relevant sections of the Administrative Code, particularly Section
2145, which allowed the provincial governor to direct non-Christians to settle in designated areas.

Issue:
Did the actions of the provincial officials constitute an unlawful deprivation of the plaintiffs' liberty
without due process of law?

Ruling:
No, the actions did not constitute an unlawful deprivation of liberty without due process of law.

Article 3, Section 18 of the 1987 Constitution guarantees the right to due process of law before
deprivation of liberty.

The court found that the confinement of the Manguianes was carried out under lawful authority—
Section 2145 of the Administrative Code, with proper approval, aimed at their welfare and civilizing
efforts. The law provided for a uniform process, and the confinement was not arbitrary or without
legal basis.

Therefore, the detention was within the bounds of due process, and the actions of the provincial
officials did not violate Article 3, Section 18.

Section 19. Excessive fines shall not be imposed, nor cruel, degrading or inhuman punishment
inflicted.
Neither shall death penalty be imposed, unless, for compelling reasons involving heinous
crimes, the Congress hereafter provides for it. Any death penalty already imposed shall be
reduced to reclusion perpetua. The employment of physical, psychological, or degrading
punishment against any prisoner or detainee or the use of substandard or inadequate penal
facilities under subhuman conditions shall be dealt with by law.

. Echegaray vs Executive Secretary, GR No. 132601

Facts:
Leo Echegaray was convicted of raping the 10-year-old daughter of his common-law spouse, and
the Supreme Court affirmed his conviction and imposed the death penalty on June 25, 1996.
Echegaray filed motions for reconsideration, raising factual issues and the constitutionality of the
death penalty law, which were denied. Subsequently, Congress enacted Republic Act No. 8177,
changing the method of execution from electrocution to lethal injection. Echegaray then filed a
petition challenging the constitutionality of lethal injection and the implementing rules, alleging it
was cruel, degrading, and inhuman, and raising issues of unlawful delegation of legislative power
and discrimination. The Court examined these issues, ultimately upholding the constitutionality of
the death penalty and the method of lethal injection, while invalidating certain provisions of the
implementing rules.

Issue:
Is the imposition of the death penalty through lethal injection unconstitutional as it constitutes
cruel, degrading, or inhuman punishment under the 1987 Constitution?
Ruling:
No, the imposition of the death penalty through lethal injection is not unconstitutional as cruel,
degrading, or inhuman punishment under the 1987 Constitution.

Article III, Section 19 of the 1987 Constitution prohibits cruel, degrading, or inhuman punishment.
Jurisprudence, including the case of Harden v. Director of Prisons, affirms that the death penalty
per se is not cruel or inhuman.

The Court found that lethal injection, as a modern and humane method of execution, does not
constitute cruel or inhuman punishment. The law provides sufficient guidelines, and the process
involves drugs that induce sleep and stop the heart, which the Court considers not barbarous.

Therefore, lethal injection as a method of executing the death penalty does not violate Article III,
Section 19 of the Constitution.

. People v. Echegaray, G.R. 117472, Feb. 7, 1997

Facts:
The case involves Leo Echegaray, who was accused of raping his ten-year-old daughter in April
1994, during the period when Republic Act No. 7659 (the Death Penalty Law) was in effect. The
Supreme Court affirmed his conviction and sentenced him to death on June 25, 1996. Echegaray
filed a Motion for Reconsideration, which was denied, and later retained new counsel who filed a
supplemental motion raising issues such as alleged incompetence of previous counsel, the
constitutionality of R.A. No. 7659, and other procedural and substantive defenses. The court
ultimately upheld the conviction and the death sentence, emphasizing the sufficiency of evidence
and the law's constitutionality.

Issue:
Did the court erroneously affirm the conviction and the imposed death penalty based on a failure to
establish Echegaray's identity as the father of the complainant?

Ruling:
No, the court did not erroneously affirm the conviction and death penalty based on Echegaray's
relationship to the complainant.

Article III, Section 19 of the 1987 Constitution prohibits cruel, degrading, or inhuman punishment.

The Supreme Court found that the positive identification and testimonies of the prosecution
sufficiently established Echegaray's guilt, regardless of the dispute over whether he was the father
or stepfather. The issue of relationship was a factual matter that did not affect the legality of the
conviction or the constitutionality of the death penalty.

The affirmation of the conviction and death penalty was proper, as the evidence overwhelmingly
proved guilt and the law does not consider the relationship issue as a basis for invalidating the
sentence under the constitutional prohibition against inhuman punishment.

Section 20. No person shall be imprisoned for debt or

non-payment of a poll tax.
 . Lozano vs Martinez, 230 Phil 406
Facts:
The case involves petitions challenging the constitutionality of Batas Pambansa Bilang 22 (BP 22),
known as the Bouncing Check Law, enacted in 1979. The law criminalizes the act of issuing a check
knowing insufficient funds are available, with penalties including imprisonment and fines. The
petitioners argue that BP 22 conflicts with the constitutional prohibition against imprisonment for
debt, claiming it effectively penalizes non-payment of debts rather than the act of issuing worthless
checks. The Court examined whether BP 22's focus on punishing the act of issuing a worthless
check, rather than the non-payment of a debt, aligns with constitutional protections. The Court
ultimately upheld BP 22 as a valid exercise of police power, emphasizing that it penalizes the act of
issuing worthless checks as a public nuisance, not the mere non-payment of debts.

Issue:
Is the Bouncing Check Law (BP 22) unconstitutional for violating the prohibition against
imprisonment for debt?

Ruling:
No, BP 22 is not unconstitutional for violating the prohibition against imprisonment for debt.

Article III, Section 20 of the 1987 Constitution prohibits imprisonment for non-payment of a debt,
but BP 22 penalizes the act of issuing a worthless check, not the non-payment of a debt itself.

The Court clarified that BP 22’s gravamen is the act of making and issuing a check known to be
insufficient in funds, which is a public nuisance and an offense against public order, not a mere debt
non-payment. The law aims to protect the integrity of the banking system and public welfare, not to
imprison debtors for their inability to pay.

Therefore, BP 22 does not violate the constitutional prohibition against imprisonment for debt, as it
criminalizes a specific act (issuance of worthless checks) rather than the non-payment of a debt.

Section 21. No person shall be twice put in jeopardy of punishment for the same offense. If an
act is punished by a law and an ordinance, conviction or acquittal under either shall constitute a
bar to another prosecution for the same act.

. Almario v. CA, GR No. 127772

Facts:
The case involves criminal charges against Roberto P. Almario for estafa through falsification of a
public document and estafa, with RCBC as the offended party. The cases were filed in 1992, and
after pre-trial, they faced multiple postponements due to court transitions and procedural issues.
On September 8, 1995, Almario's counsel moved to dismiss the cases, citing violation of his right to
a speedy trial, which the court initially granted. However, the court later reconsidered and
reinstated the cases, ruling that delays were justified and did not violate the right to a speedy trial.
Almario filed a petition with the Court of Appeals, claiming this reinstatement violated his
constitutional right against double jeopardy. The appellate court upheld the trial court's decision,
and the Supreme Court affirmed that the dismissal was made with Almario's consent and that no
unreasonable delay or violation of his speedy trial right occurred, thus double jeopardy did not
attach.

Issue:
Did double jeopardy attach in Almario's case, thereby violating his constitutional right against being
tried for the same offense twice?

Ruling:
No, double jeopardy did not attach in Almario's case, so his constitutional right was not violated.

Article III, Section 21 of the 1987 Constitution prohibits double jeopardy, which attaches only when
there is a valid indictment, a competent court, and a case that is finally terminated without the
accused’s consent.

The cases against Almario were dismissed upon his motion due to alleged violations of his right to a
speedy trial. This dismissal was made with his consent and was later reconsidered and reinstated by
the court. Since the initial dismissal was not a final judgment of acquittal or conviction, and Almario
consented to it, double jeopardy did not set in.

Therefore, Almario’s right against double jeopardy was not violated, as the case was not finally
terminated without his consent, and the reinstatement was lawful.

. Tangan vs People, GR No. 73963

Facts:
Eladio C. Tangan was initially charged with murder for the death of Generoso Miranda III, with an
information filed on July 1, 1985. Before arraignment, the case was amended to charge homicide,
and an additional information was filed for illegal possession of firearms and ammunition used in the
commission of the homicide. The second information was filed on October 30, 1985, based on the
same incident. Petitioner filed a motion to quash, claiming that the second charge violated the rule
against double jeopardy. The lower court denied the motion, ruling that the offenses charged were
different and that jeopardy had not yet attached. The Supreme Court ultimately upheld this ruling,
stating that the filing of the second information did not constitute double jeopardy because the first
jeopardy had not yet attached

Issue:
Was the petitioner subjected to double jeopardy when the second information was filed, given that
the two cases arose from the same incident?

Ruling:
No, the petitioner was not subjected to double jeopardy when the second information was filed.

Article 3, Section 21 of the 1987 Constitution states that no person shall be twice put in jeopardy of
punishment for the same offense.

The Court clarified that double jeopardy attaches only after a valid indictment, arraignment, and
plea, and only if the subsequent prosecution is for the same offense. In this case, the first case
involved murder/homicide, while the second involved illegal possession of firearms and ammunition
—distinct offenses under different laws. The Court found that jeopardy had not yet attached
because the second case was based on a different offense, despite arising from the same incident.

Therefore, the filing of the second information did not violate the constitutional protection against
double jeopardy, as the cases involved different offenses and jeopardy had not yet attached.

. People vs Serrano, GR No. 135451

Facts:
The case involves Judge Pepe P. Domael of the Regional Trial Court in Naval, Biliran, who allowed an
appeal filed by the prosecution from a decision of acquittal in a criminal case against Danilo F.
Serrano, Sr. The prosecution initially filed a complaint for rape, which resulted in Serrano's acquittal
by the trial court. Despite the finality of this acquittal, Judge Domael granted the prosecution's
appeal, citing Memorandum Circular No. 3 of the Department of Justice. This act was found to be a
violation of the constitutional guarantee against double jeopardy, as an appeal from an acquittal on
the merits is prohibited by law. The Supreme Court subsequently disciplined Judge Domael for this
error, emphasizing the importance of judges' knowledge of fundamental legal principles.

Issue:
Did Judge Pepe P. Domael commit gross ignorance of the law by allowing the prosecution's appeal
from a judgment of acquittal?

Ruling:
Yes, Judge Pepe P. Domael committed gross ignorance of the law by allowing the prosecution's
appeal from a judgment of acquittal.

Article 3, Section 21 of the 1987 Constitution prohibits double jeopardy, which includes the finality
of an acquittal and prohibits appeals that would re-examine the merits of such verdict.

Judge Domael granted the prosecution's appeal despite the final and unappealable nature of the
judgment of acquittal, demonstrating a lack of awareness of the constitutional protection against
double jeopardy and elementary legal principles.

Therefore, his act of allowing the appeal from an acquittal constitutes gross ignorance of the law,
warranting disciplinary action.

Section 22. No ex post facto law or bill of attainder shall be enacted.

. Chavez vs Romulo, GR No. 157036

Facts:
The case involves the issuance of guidelines by the PNP Chief in response to President Arroyo's
directive to implement a nationwide gun ban. Petitioner Francisco I. Chavez, a licensed firearm
holder with a valid Permit to Carry Firearms Outside of Residence (PTCFOR), challenged these
guidelines, arguing they revoked his permit without due process and violated his property rights.
The petitioner contended that the guidelines effectively imposed a new restriction retroactively,
thus constituting an ex post facto law, which is prohibited under the 1987 Philippine Constitution.
The Court examined whether the revocation of existing permits under the guidelines was lawful,
considering the authority of the PNP Chief, the nature of the right to bear arms, and the
constitutional prohibition against ex post facto laws.

Issue:
Whether the Guidelines, by affecting permits issued prior to their publication, amount to an ex post
facto law penalizing acts that were lawful at the time they were committed.

Ruling:
The Guidelines do not constitute an ex post facto law because they are prospective in application
and do not penalize acts that were lawful at the time they were committed.

Article 3, Section 22 of the 1987 Philippine Constitution states that "No law shall be passed...
impairing the obligation of contracts or any rights acquired in accordance with law before the law's
effectivity."

The revocation of permits issued prior to the Guidelines' issuance affects existing rights, but the
permits are considered privileges, not vested property rights. The Guidelines are regulatory
measures aimed at public safety and are applied prospectively, not retroactively penalizing lawful
acts.

Therefore, the Guidelines do not violate Article 3, Section 22, as they do not impose penalties for
acts committed before their promulgation, and are valid exercises of police power.

. Benedicto vs CA, GR No. 125359

Facts:
The case involves criminal charges against Roberto S. Benedicto, Hector T. Rivera, and Mrs. Imelda
Marcos for violations of Central Bank Circular No. 960 related to failure to report foreign exchange
earnings and maintain foreign accounts without authorization. The charges stem from their alleged
failure to submit reports of foreign exchange earnings from abroad and to register foreign accounts,
in violation of the Circular and the Central Bank Act. Multiple informations were filed from 1991 to
1992, accusing them of conspiring and committing acts of foreign exchange violations, including
receiving interest earnings from foreign accounts in Swiss banks. The cases were consolidated
before the Regional Trial Court of Manila. The charges were based on violations punishable by
imprisonment of up to five years, under the law then in force. The petitioners moved to quash the
informations, claiming lack of jurisdiction, repeal of laws, prescription, exemption from reporting,
and immunity under a compromise agreement. The court denied the motions, and the case
proceeded, with the Supreme Court eventually dismissing the petition, noting that the death of
Roberto S. Benedicto extinguished his liability.

Issue:
Whether the increase in penalties under Section 36 of Republic Act No. 7653, which was enacted
after the commission of the acts, violates constitutional protections.

Ruling:
No, the increase in penalties under Section 36 of Republic Act No. 7653 does not violate the
constitutional protections against ex post facto laws.

Article 3, Section 22 of the 1987 Philippine Constitution prohibits ex post facto laws, which make an
act criminal after it was committed or increase penalties retroactively. However, penal laws generally
operate prospectively unless expressly made retroactive or favorable to the accused.

The law in question, Section 36 of Republic Act No. 7653, was enacted after the acts were
committed. The Court found that the law did not explicitly state retroactive application and that
increased penalties are generally prospective in nature. Since the law was not intended to apply
retroactively and did not impose harsher penalties for acts already committed, it does not violate
constitutional protections.

Therefore, the law's increased penalties are not ex post facto and do not contravene Article 3,
Section 22 of the Constitution.

. Wright v. CA, GR No. 113213

Facts:
The case involves the extradition of Paul Joseph Wright, an Australian citizen, sought by Australian
authorities for multiple indictable crimes committed prior to the effectivity of the Philippines-
Australia Extradition Treaty ratified in 1990. Wright was arrested in the Philippines based on a
diplomatic note from Australia, which included warrants and charges for offenses such as obtaining
property by deception, false testimony, and perjury under Victorian law. The Philippine trial court
ordered his extradition, a decision upheld by the Court of Appeals, and affirmed by the Supreme
Court. Wright challenged the extradition order, arguing that the treaty's retroactive application
violated the constitutional prohibition against ex post facto laws, since the offenses occurred before
the treaty's ratification. The Court, however, ruled that the treaty's provisions do not constitute
criminal legislation and do not violate the constitutional prohibition, as they merely facilitate the
extradition of persons wanted for offenses committed prior to the treaty's effectivity, provided the
acts were crimes under the law at the time they were committed.

Issue:
Does the application of the extradition treaty retroactively violate the constitutional prohibition
against ex post facto laws as per Section 21, Article VI of the 1987 Constitution?

Ruling:
No, the application of the extradition treaty does not violate the constitutional prohibition against ex
post facto laws.

Article 3, Section 22 of the 1987 Constitution prohibits ex post facto laws, which criminalize acts
committed before the law's effectivity. However, treaties are not criminal legislation; they are
agreements that facilitate international cooperation, including extradition, and are not inherently
penal laws.

The Supreme Court clarified that the treaty's provisions do not constitute criminal legislation and do
not create new offenses or increase penalties for past acts. The treaty merely provides for the
extradition of persons wanted for offenses already committed and punishable under the laws of
both countries at the time of the acts.

Therefore, the treaty's retroactive application does not violate the constitutional prohibition against
ex post facto laws, as it is an international agreement, not criminal legislation, and does not impose
criminal penalties for acts committed prior to its effectivity.