The Supreme Court (SC) has ruled that it is the State’s responsibility to ensure that detention facilities are clean, safe, and adequately equipped for individuals in custody.

In a decision penned by Associate Justice Antonio T. Kho, Jr., the SC’s Second Division upheld the Office of the Ombudsman’s dismissal of a complaint filed by the Commission on Human Rights (CHR) against several police officers in Tondo, Manila. The complaint stemmed from the CHR's discovery of an alleged “secret detention cell” at Raxabago Police Station 1.

According to the CHR, a surprise visit uncovered three men and nine women held in a small, unsanitary room concealed behind a wooden shelf. Video evidence was submitted to support claims that this was a secret cell.

The police countered that the facility was overcrowded—holding 96 detainees in a space intended for only 50—and that the room in question served as a temporary holding area while detainees awaited investigation. They maintained that it was not hidden, as it had its own entrances and was visible.

The Ombudsman dismissed the complaint, stating that the video was inconclusive and merely showed a dark room with a urinal. It also acknowledged the issue of overcrowding as a broader systemic problem.

The SC concurred, finding no evidence of a secret cell or a violation of the Anti-Torture Act of 2009 (Republic Act No. 9745), which prohibits the use of hidden or solitary confinement. The Court also found no indication of bad faith on the part of the police, noting the lack of alternative holding spaces at the time.

Nevertheless, the Court emphasized that poor jail conditions must not be overlooked. It recognized the budgetary constraints faced by law enforcement agencies but reiterated that detainees are entitled to humane treatment and decent living conditions.

The SC urged government agencies to take immediate action to improve detention facilities, warning that failure to do so may prompt the Court to intervene when warranted.

“It does not escape the Court that the improvement of penal facilities may be restricted by a budget which only the Congress can provide and which the Court cannot compel to allocate. This budgetary constraint, however, does not mean that the inmates or detainees... are not entitled to their right to live a decent life... The Court can still grant some form of relief... as the ultimate guardian of the Constitution,” the ruling stated.

The Court also reminded police authorities that even temporary detention spaces used during investigations must be clean, sanitary, and properly maintained.

In a dissenting opinion, Senior Associate Justice Marvic M.V.F. Leonen disagreed with the majority, asserting that the CHR’s findings did reveal a secret cell and that the poor conditions could amount to cruel, inhuman, and degrading treatment.