LAW AND ORDER
SC lists significant decisions in upholding the rule of law in 2024
1/28/25, 9:06 AM
The Supreme Court under the leadership of Chief Justice Alexander G. Gesmundo disposed of 4,294 cases in 2024, registering a clearance rate of 87% and a disposition rate of 22%.
Among the significant rulings the court issued have enriched Philippine jurisprudence with just, impartial and correct interpretation of laws and their application.
Here are some of the important decisions released this year:
On Right to life, liberty, and security
In Deduro v. Vinoya, the SC declared that red-tagging, vilification, labelling, and guilt by association threaten a person’s right to life, liberty, or security, which entitles one to protection under the writ of amparo.
The writ of amparo has also protected abducted environmental advocates, as in the case of Castro v. Dela Cruz, where the SC found elements of enforced disappearance.
However, in Roque v. House of Representatives Quad-Committee, the SC denied Atty. Herminio Harry L. Roque, Jr.’s prayer for the writ of amparo, holding that it is not the proper remedy against Congressional contempt and detention orders. The SC clarified that the scope of amparo is limited to extralegal killings and enforced disappearances or such threats, which were not present in this case.
In Besmonte v. NAPOLCOM-NCR, the SC found a police officer guilty of simple misconduct for using unnecessary force and violence during a buy-bust operation. The SC issued a reminder that it does not condone the indiscriminate use of force by police officers against persons under arrest.
In Ridon v. People, the SC emphasized that simply violating ordinances and regulations is not enough to justify a valid warrantless search and seizure, especially when the penalty does not involve imprisonment.
In People v. Agustin and Antonio, the SC ruled that imprisonment beyond the maximum penalty is not only cruel and inhumane but also undermines the dignity of detainees. The SC stressed that the power of the courts to commit prisoners carries with it the duty to immediately release them in case of detention for a period equivalent to or longer than the maximum imposable penalty.
[1] As of September 30, 2024
[2] The clearance rate shows how many cases are resolved compared to the number of new cases filed. The disposition rate shows the percentage of cases that have been resolved by the SC out of all existing cases.
On Due process
To ensure fair prosecution, the SC has ensured strict observation of due process. In People v. Valencia, the SC determined that even minor changes in the receipts documenting the transfer of seized drugs can undermine the integrity of the chain of custody in drug cases.
In Guinto v. DOJ, the SC found that the Department of Justice (DOJ), in enacting its 2019 Implementing Rules and Regulations, exceeded its power of subordinate legislation when it excluded persons convicted of heinous crimes, repeat offenders, habitual delinquents, and escapees from the benefits of Republic Act No. (RA) 10592, or the New Good Conduct Time Allowance law.
Pursuant to its constitutional power to order a change of venue to avoid a miscarriage of justice, the SC, in Re: Transfer of Venue, granted the request of DOJ Secretary Jesus Crispin C. Remulla to move the venue of two criminal cases against Apollo C. Quiboloy from the Regional Trial Court (RTC) of Davao City to the RTC of Quezon City.
In Togado v. People, the SC established guidelines on when a confiscated firearm must be presented in court, stressing that in cases involving violations of RA 10591 or the Comprehensive Firearms and Ammunition Regulation Act, the absence of the actual confiscated firearm cannot be overlooked. It further emphasized that a mere certificate stating that the accused lacks a license to own or possess the firearm is not enough to secure a conviction.
In Navales v. People and Guillen v. People, the SC ruled that a violation of procurement laws by public officers will not automatically result in a conviction under RA 3019, or the Anti-Graft and Corrupt Practices Act. All elements of graft must be proven beyond a reasonable doubt, not just the deficiencies in the procurement process.
On free speech
In ABS-CBN Corporation v. Ampatuan, Jr., the SC established the limits of free speech for participants in legal proceedings and clarified the guidelines for imposing the subsequent punishment of indirect contempt. The SC cautioned that while courts’ contempt powers can limit the speech of the media and the public, they should not be broadly used to prevent the press from reporting on important public matters. The SC also recognized social media speech as a fourth type of regulated speech, acknowledging the influence of fake news online on public trust in the judiciary and its application of justice.
The SC emphasized the importance of balancing free speech with the protection of judicial independence in Re: Statements made by Lorraine Marie T. Badoy. It found that certain social media posts attacking a judge were contemptuous. While the SC ruled that expressing criticism of a court’s decision in a pending case, when done in good faith, may be permitted, it made clear that accusing a judge of improper motives and trying to rally public support to pressure that judge is not acceptable.
In Labargan v. People, the SC ruled that statements against public officers do not amount to oral defamation or slander when these concern their discharge of official duties, unless they are made maliciously. The SC recognizes that the right to free speech empowers citizens to hold public officers accountable, as public office is considered a public trust.
On right to privacy
In IBP v. Purisima and Jacinto-Henares, the SC upheld the right to privacy of professionals and their clients, invalidating a regulation from the Bureau of Internal Revenue that required self-employed professionals to submit their rates and register appointment books to monitor their tax compliance.
In People v. Rodriguez, the SC reiterated that using online chat logs and videos as evidence does not violate the right to privacy when they are used to assess if a crime has been committed. RA No. 10173, or the Data Privacy Act of 2012, permits the processing of sensitive personal information to determine a person’s criminal liability and to protect the rights and interests of individuals in court proceedings.
In Tria v. People, the SC upheld the conviction of an accused for robbery for demanding money from his ex-girlfriend in exchange for deleting her nude photos posted on Facebook.
On right to suffrage
In National Press Club v. COMELEC, the SC ruled that the Commission on Elections (COMELEC) may be compelled, via a writ of mandamus, to allow the witnessing of the printing of ballots and disclose the complete transmission diagram and data/communications network architecture of vote counting machines (VCMs). Mandamus is an extraordinary writ that compels a person, tribunal, corporation, board, or officer to perform a legally required action if they have failed or refused to do so. This action must be ministerial, meaning it requires no exercise of discretion or judgment in performance.
The SC, however, clarified in Rio v. COMELEC that the election body cannot be forced to either grant or deny requests for a ballot recount as this requires the exercise of COMELEC’s discretion or judgment. It is not a ministerial duty that can be the subject of a writ of mandamus.
In Smartmatic v. COMELEC, the SC reversed the COMELEC resolutions disqualifying Smartmatic TIM Corporation and Smartmatic Philippines, Inc. from participating in any public bidding for elections. However, the SC recognized that requiring the COMELEC to conduct another round of public bidding would seriously disrupt its preparations for the 2025 elections. Thus, the SC held that its ruling would apply prospectively, or to future events or cases.
In Macalino v. COA, the SC ruled that the Constitutional prohibition on appointing individuals to government positions within one year after an election applies to all losing candidates. This applies regardless of the position they seek or the place or jurisdiction of the office to which they are appointed.
In Sinsuat v. Ebrahim, the SC emphasized that the creation of new municipalities must be approved or ratified in a plebiscite by a majority vote of qualified voters from both the newly created municipalities and the original parent municipalities. Limiting the plebiscite to only those residing in the newly formed municipalities denies the voting rights of individuals from the original parent municipalities.
In Duterte Youth v. COMELEC, the SC held that the deadlines for substituting party-list candidates remain in effect even after the elections. The SC emphasized the importance of the timing for nominee substitutions, as it directly affects voters’ right to know the identities of the nominees from party lists. This knowledge allows voters to make informed and intelligent choices on election day.
In Rosal v. COMELEC, the SC affirmed the COMELEC’s disqualification of Noel E. Rosal as Governor of Albay, Carmen Geraldine Rosal as Mayor of Legazpi City, and Jose Alfonso V. Barizo as Councilor of Legazpi City, during the 2022 National and Local Elections. They were disqualified for violating the Omnibus Election Code by disbursing and releasing government funds during the prohibited period before a regular election.
On right to autonomy and self-determination
In Province of Sulu v. Executive Secretary, the SC upheld the validity of RA11054 or the Organic Law for the BARMM, but declared the Province of Sulu not part of the BARMM after the province rejected the law’s ratification.
On access to justice
In De Guzman-Lara v. COMELEC and Mamba, the SC pointed out that since technological advances now permit electronic filing, filings by email may be made even beyond office hours, as long as they are completed within the same day.
On inclusivity
The SC also reminded a judge and a prosecutor in Yokogawa-Tan v. Tan to use gender-fair language in the courtroom, consistent with promoting gender equality in the Judiciary.
In People v. ZZZ (G.R. No. 266706), the SC ruled that in instances of rape committed through force, threat, or intimidation, there is no requirement to prove that the victim resisted. The SC clarified that previous decisions stating that a woman cannot claim to be a rape victim unless she fought back are inconsistent with the current legal framework. These earlier pronouncements often reinforce misguided stereotypes that contribute to gender bias and insensitivity. It is essential to recognize and respect women’s rights to autonomy and bodily integrity.
In People v. Bragais and Tacuyo, the SC highlighted that a person’s ability to testify as a witness depends on their capacity to relay their knowledge, regardless of any intellectual disability they may have. If their testimony is clear and understandable, it can be accepted. The SC acknowledged the need to improve how people with disabilities are described, promoting the use of people-first language that highlights the individual before their disability.
On separation of powers
In Biong v. COA, the SC ruled that the Commission on Audit (COA) cannot expand its audit powers to include imposing administrative penalties. As the COA’s authority is limited to initiating the proper administrative, civil, and/or criminal action upon discovering a violation during an audit, the imposition of administrative penalties is outside the scope of its audit powers.
In An Waray v. COMELEC, the SC upheld the COMELEC resolutions cancelling An Waray’s registration as a party-list organization. The SC held that under both the Constitution and the Party-List System Act, it is the COMELEC that has exclusive jurisdiction to rule on the cancellation of party-list registrations.
In MAGSASAKA Party-List v. COMELEC and Villamin, the SC ruled that party-list organizations must be allowed to interpret their own internal rules on how to remove their officials, declaring that Soliman Villamin, Jr. was validly removed from his position as National Chairperson of Magkakasama sa Sakahan, Kaunlaran.
The SC also affirmed in FEJODAP v. Manila City the exclusive power of the Manila Metropolitan Development Authority to enforce traffic laws, rules and regulations over local governments in Metro Manila.
In MWSS v. Bulacan, the SC affirmed its decision that the Metropolitan Waterworks and Sewerage System is not required to share its proceeds from using Angat Dam with the Bulacan government.
On social welfare
In Spouses Gabun v. Stolk, Sr. the SC ruled that when parental authority is granted solely to the mother, as in the case of illegitimate children, substitute parental authority shall be exercised by the grandparents or other persons specified in the Family Code.
In Dela Cruz v. Lanuza, Jr. the SC ruled that decades-long unjustified absence from the marital home may be evidence of a spouse’s psychological incapacity to comply with marital obligations. Under Article 68 of the Family Code, spouses must live together, observe mutual love, respect, and fidelity, and render mutual help and support.
In Republic v. Ng, the SC ruled that foreign divorce decrees do not require judicial proceedings abroad to be recognized in the Philippines. It held that Philippine courts can recognize divorces obtained abroad, whether through legal or administrative processes or by mutual agreement of the spouses.
In XXX v. People (G.R. No. 252739), the SC ruled that in determining whether marital infidelity caused psychological violence under RA 9262 or the Anti-Violence Against Women and Their Children Act, criminal intent is presumed in acts of marital infidelity.
Protecting children’s welfare, the SC in CICL XXX v. People set guidelines to streamline the process for determining discernment in crimes involving children in conflict with the law, recognizing there is a different standard in determining a minor’s culpability for crimes.
In People v. Adrales, the SC held that under the sexual abuse shield rule, evidence showing a victim’s sexual predisposition or past sexual behavior is not admissible in any criminal proceeding involving child sexual abuse.
In People v. XXX258054, the SC reiterated that under the unavailable child doctrine, child abuse cases can still be tried even when child victims are unable to testify in court. The SC recognized that vulnerable children may be pressured to avoid attending hearings to prevent them from testifying or may be too traumatized to give their testimony.
In Dolera v. SSS, the SC voided the provision in the Social Security Act that disqualifies as primary beneficiaries those who become the pensioner’s legitimate spouse only after the pensioner suffers permanent total disability.
In Guiao v. PAGCOR, the SC ordered the Philippine Amusement and Gaming Corporation (PAGCOR) and Philippine Charity Sweepstakes Office (PCSO) to remit a portion of their income for the funding of the Philippine Sports Commission (PSC). As to PAGCOR, the SC held that the remittance required under RA 6847, or the PSC Act, is not subject to any deductions. As to the PCSO, the SC ruled that funding for the PSC shall also be sourced from sweepstakes or lottery draws.
On economy
In IDEALS, Inc. v. Senate, the SC upheld the validity of the Japan-Philippines Economic Partnership Agreement, ruling that it does not facilitate the indiscriminate importation of hazardous and toxic wastes in the Philippines.
In Executive Secretary Mendoza v. Pilipinas Shell, the SC upheld Section 14(e) of RA 8479 or the Downstream Oil Industry Deregulation Act, giving the Department of Energy, on behalf of the President, the power to take over oil firms in case of national emergency.
Supporting micro, small, and medium enterprises or MSMEs, the SC, in Icebergs Food Concepts, Inc. v. FILSCAP, recommended that Congress consider exemptions for small businesses in addition to the existing limitations in copyright infringement cases under the Intellectual Property Code of the Philippines.
In ILECO v. Executive Secretary, the SC ruled that electric cooperatives do not have a constitutional right to an exclusive franchise within their coverage areas.
In BCDA v. CJH Development Corporation, the SC reaffirmed the State’s policy favoring arbitration. Courts can only intervene in arbitration cases under specific, limited exceptions outlined in arbitration laws. As a result, the SC upheld the arbitral ruling requiring CJH Development Corporation to vacate a portion of the John Hay Special Economic Zone it had leased from the Bases Conversion Development Authority.
On labor
In line with state policy aimed at providing full protection to labor, the SC in Bison Management Corporation v. AAA ruled that it is illegal to dismiss an employee solely for testing positive for HIV, declaring such termination discriminatory.
In Bohol Wisdom School et al v. Mabao, the SC ruled that it was illegal for a school to suspend its unmarried teacher for being pregnant. It held that sexual relations between two unmarried, consenting adults are not immoral. No law prohibits this, nor does it go against any fundamental state policy found in the Constitution, making it an invalid reason valid ground for suspension.
In SCIPSI v. Montefalco, Jr., the SC held that the employer’s withholding of union fees pursuant to a check-off provision in the collective bargaining agreement constitutes unfair labor practice.
The SC also invalidated a series of quitclaims after finding that the employer tricked its employees into signing them in the case Naldo, Jr. v. CORPS. Additionally, in Abad v. San Roque Metals, the SC emphasized that compromise agreements and settlements between employers and employees that provide excessively low amounts to employees are invalid.
In Bartolome v. Toyota, the SC ruled that demotion, verbal abuse, and indifferent behavior by an employer that forces an employee to resign constitute constructive illegal dismissal. It held that the standard for constructive dismissal is whether a reasonable person in the employee’s position would have felt forced to give up their employment under the circumstances.
Habitual negligence, however, is a ground for dismissal as held by the SC in Lingganay v. DLTBCo. The SC emphasized that under Article 297(b) of the Labor Code, employers may terminate employees for gross and habitual neglect of duties, including carelessness and inefficiency in their tasks.
In C.P. Reyes Hospital v. Barbosa, the SC clarified that illegally dismissed probationary employees, like regular employees, are entitled to backwages up to their actual reinstatement rather than only until the end of their probationary period.
On consumer protection
In Department of Trade and Industry v. Toyota, the SC ruled that consumers with brand-new motor vehicle issues may avail of the remedies under the Philippine Lemon Law, the Consumer Act, or any other applicable law. The Lemon Law is an alternative remedy granted to the consumer, and the consumer is free to choose to enforce their rights under the Consumer Act or any other law.
On cleansing the bench and the Bar
Reminding all court personnel to always act above board and beyond suspicion to earn and keep the public’s respect for the Judiciary, the SC dismissed three Court of Appeals employees in A.M. No. CA-23-001-P for testing positive for shabu for the second time.
In A.M. No. RTJ-20-2579, the SC dismissed a judge for gross misconduct after finding messages on his laptop asking for bribes from lawyers and litigants in exchange for favorable rulings in cases before him.
The SC also enlisted the help of the National Bureau of Investigation, in A.M. No. 24-05-21-SC, upon an anonymous tip that a court employee and judge were engaging in bribery. Following an entrapment operation, the SC ordered the preventive suspension of a Pasay City judge and an acting branch clerk of court to ensure a thorough and uninterrupted formal investigation.
In A.M. No. MTJ-23-014, another judge was dismissed by the SC for falsification of official documents and serious dishonesty for making false certifications and misappropriating her staff’s salaries.
In A.M No. MTJ-23-017, the SC dismissed a judge for manipulating the procurement of medical supplies for the City of Manila, emphasizing that judges must follow the highest standards of conduct and avoid any behavior that could seem improper.
In A.M. No. 23-05-05-SC, the SC imposed a fine on Atty. Persida V. Rueda-Acosta, Chief of the Public Attorney’s Office (PAO), for her conduct that was deemed grossly undignified and harmful to the justice system. Her actions were related to her opposition to a new conflict of interest rule for the PAO, which is now Section 22, Canon III of the Code of Professional Responsibility and Accountability.
In A.C. No. 13496, the SC disbarred a lawyer for grossly immoral conduct for engaging in extramarital affairs with at least three women during his marriage, entering into a bigamous marriage, and sexually harassing his staff.
In A.C. No. 13842, the SC found previously disbarred Lorenzo G. Gadon guilty of gross misconduct for committing perjury and making accusations based on hearsay.
In A.M. No. 23-04-05-SC, the SC found Atty. Nilo T. Divina guilty of simple misconduct under the CPRA for committing impropriety when he sponsored the trips of Integrated Bar of the Philippines-Central Luzon officers.