ibp vs zamora.doc

8/14/2019 IBP VS ZAMORA.doc

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EN BANC

[G.R. No. 141284. August 15, 2000]

INTEGRATED BAR OF THE PHILIPPINES, petitioner, vs. HON. RONALDO B. A!ORA, GEN. PANFILO !.LA"SON, GEN. EDGAR B. AGLIPA#, $%& GEN. ANGELO RE#ES, respondents.

D E " I S I O N

'AP(NAN, J .)

At bar is a special civil action for certiorari and prohibition with prayer for issuance of a temporary restrainingorder seeking to nullify on constitutional grounds the order of President Joseph Ejercito Estrada commanding thedeployment of the Philippine arines !the " arines#$ to join the Philippine National Police !the "PNP#$ in visibilitypatrols around the metropolis%

&n view of the alarming increase in violent crimes in etro anila' like robberies' kidnappings and carnappings'the President' in a verbal directive' ordered the PNP and the arines to conduct joint visibility patrols for the purposeof crime prevention and suppression% (he )ecretary of National *efense' the Chief of )taff of the Armed +orces ofthe Philippines !the "A+P#$' the Chief of the PNP and the )ecretary of the &nterior and ,ocal -overnment were taskedto e.ecute and implement the said order% &n compliance with the presidential mandate' the PNP Chief' through PoliceChief )uperintendent Edgar B% Aglipay' formulated ,etter of &nstruction /010/// 234 !the ",5$ which detailed themanner by which the joint visibility patrols' called (ask +orce Tulungan ' would be conducted% 204 (ask+orce Tulungan was placed under the leadership of the Police Chief of etro anila%

)ubse6uently' the President confirmed his previous directive on the deployment of the arines in aemorandum' dated 07 January 0///' addressed to the Chief of )taff of the A+P and the PNP Chief% 284 &n theemorandum' the President e.pressed his desire to improve the peace and order situation in etro anila through a

more effective crime prevention program including increased police patrols% 274 (he President further stated that toheighten police visibility in the metropolis' augmentation from the A+P is necessary% 294 &nvoking his powers asCommander:in:Chief under )ection 3;' Article


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b. The principle o% integration o% e%%orts shall be applie# to era#icate all %orms o% high-pro%ile crimes perpetrate# byorgani)e# crime syn#icates operating in $etro $anila. This concept re7uires the military an# police to or,cohesi&ely an# uni%y e%%orts to ensure a %ocuse#+ e%%ecti&e an# holistic approach in a##ressing crime pre&ention.

(long this line+ the role o% the military an# police asi#e %rom neutrali)ing crime syn#icates is to bring a holesomeatmosphere herein #eli&ery o% basic ser&ices to the people an# #e&elopment is achie&e#. 8an#-in-han# ith this

oint !"RPO-Philippine $arines &isibility patrols+ local Police Units are responsible %or the maintenance o% peace an#or#er in their locality.

c. To ensure the e%%ecti&e implementation o% this pro ect+ a pro&isional Tas, 0orce 9TU3U! (!; shall be organi)e#to pro&i#e the mechanism+ structure+ an# proce#ures %or the integrate# planning+ coor#inating+ monitoring an#assessing the security situation.

...% 2;4

(he selected areas of deployment under the ,5& are@ onumento Circle' North Edsa !) City$' Araneta)hopping Center' -reenhills' ) egamall' akati Commercial Center' , (1 ( )tations and the NA&A and*omestic Airport%2 4

5n 3? January 0///' the &ntegrated Bar of the Philippines !the "&BP#$ filed the instant petition to annul ,5&/010/// and to declare the deployment of the Philippine arines' null and void and unconstitutional' arguing that@

I

( E *EP,5D EN( 5+ ( E P &,&PP&NE A &NE) &N E( 5 AN&,A &)


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Fhen 6uestions of constitutional significance are raised' the Court can e.ercise its power of judicial review onlyif the following re6uisites are complied with' namely@ !3$ the e.istence of an actual and appropriate caseH !0$ apersonal and substantial interest of the party raising the constitutional 6uestionH !8$ the e.ercise of judicial review ispleaded at the earliest opportunityH and !7$ the constitutional 6uestion is the lis mota of the case%2304

The IBP has not sufficiently complied with the requisites of standing in this case.

",egal standing# or locus stan#i has been defined as a personal and substantial interest in the case such thatthe party has sustained or will sustain direct injury as a result of the governmental act that is being challenged% 2384 (heterm "interest# means a material interest' an interest in issue affected by the decree' as distinguished from mereinterest in the 6uestion involved' or a mere incidental interest% 2374 (he gist of the 6uestion of standing is whether aparty alleges "such personal stake in the outcome of the controversy as to assure that concrete adverseness whichsharpens the presentation of issues upon which the court depends for illumination of difficult constitutional6uestions%#2394

&n the case at bar' the &BP primarily anchors its standing on its alleged responsibility to uphold the rule of lawand the Constitution% Apart from this declaration' however' the &BP asserts no other basis in support of its locusstan#i % (he mere invocation by the &BP of its duty to preserve the rule of law and nothing more' while undoubtedlytrue' is not sufficient to clothe it with standing in this case% (his is too general an interest which is shared by othergroups and the whole citi=enry% Based on the standards above:stated' the &BP has failed to present a specific andsubstantial interest in the resolution of the case% &ts fundamental purpose which' under )ection 0' ule 38 :A of the

ules of Court' is to elevate the standards of the law profession and to improve the administration of justice is aliento' and cannot be affected by the deployment of the arines% &t should also be noted that the interest of the NationalPresident of the &BP who signed the petition' is his alone' absent a formal board resolution authori=ing him to file thepresent action% (o be sure' members of the BA ' those in the judiciary included' have varying opinions on the issue%

oreover' the &BP' assuming that it has duly authori=ed the National President to file the petition' has not shown anyspecific injury which it has suffered or may suffer by virtue of the 6uestioned governmental act% &ndeed' none of itsmembers' whom the &BP purportedly represents' has sustained any form of injury as a result of the operation of the

joint visibility patrols% Neither is it alleged that any of its members has been arrested or that their civil liberties havebeen violated by the deployment of the arines% Fhat the &BP projects as injurious is the supposed "militari=ation# oflaw enforcement which might threaten Philippine democratic institutions and may cause more harm than good in thelong run% Not only is the presumed "injury# not personal in character' it is likewise too vague' highly speculative anduncertain to satisfy the re6uirement of standing% )ince petitioner has not successfully established a direct andpersonal injury as a conse6uence of the 6uestioned act' it does not possess the personality to assail the validity of

the deployment of the arines% (his Court' however' does not categorically rule that the &BP has absolutely nostanding to raise constitutional issues now or in the future% (he &BP must' by way of allegations and proof' satisfy thisCourt that it has sufficient stake to obtain judicial resolution of the controversy%

aving stated the foregoing' it must be emphasi=ed that this Court has the discretion to take cogni=ance of asuit which does not satisfy the re6uirement of legal standing when paramount interest is involved% 23>4 &n not a fewcases' the Court has adopted a liberal attitude on the locus stan#i of a petitioner where the petitioner is able to craftan issue of transcendental significance to the people% 23?4 (hus' when the issues raised are of paramount importance tothe public' the Court may brush aside technicalities of procedure% 23;4 &n this case' a reading of the petition shows thatthe &BP has advanced constitutional issues which deserve the attention of this Court in view of their seriousness'novelty and weight as precedents% oreover' because peace and order are under constant threat and lawlessviolence occurs in increasing tempo' undoubtedly aggravated by the indanao insurgency problem' the legalcontroversy raised in the petition almost certainly will not go away% &t will stare us in the face again% &t' therefore'behooves the Court to rela. the rules on standing and to resolve the issue now' rather than later%

The President did not commit grave abuse of discretion in calling out the Marines.

&n the case at bar' the bone of contention concerns the factual determination of the President of the necessity ofcalling the armed forces' particularly the arines' to aid the PNP in visibility patrols% &n this regard' the &BP admitsthat the deployment of the military personnel falls under the Commander:in:Chief powers of the President as stated in)ection 3;' Article


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citi=enry' a point discussed in the latter part of this decision% &n the words of the late Justice &rene Cortes in $arcos &.$anglapus @

ore particularly' this case calls for the e.ercise of the PresidentKs powers as protector of the peace% 2 ossiter' The (merican Presi#ency 4% (he power of the President to keep the peace is not limited merely to e.ercising thecommander:in:chief powers in times of emergency or to leading the )tate against e.ternal and internal threats to itse.istence% (he President is not only clothed with e.traordinary powers in times of emergency' but is also tasked withattending to the day:to:day problems of maintaining peace and order and ensuring domestic tran6uility in times whenno foreign foe appears on the hori=on% Fide discretion' within the bounds of law' in fulfilling presidential duties intimes of peace is not in any way diminished by the relative want of an emergency specified in the commander:in:chiefprovision% +or in making the President commander:in:chief the enumeration of powers that follow cannot be said toe.clude the PresidentKs e.ercising as Commander:in:Chief powers short of the calling of the armed forces' orsuspending the privilege of the writ of habeas corpus or declaring martial law' in order to keep the peace' andmaintain public order and security%

... 2034

Nonetheless' even if it is conceded that the power involved is the PresidentKs power to call out the armed forcesto prevent or suppress lawless violence' invasion or rebellion' the resolution of the controversy will reach a similarresult%

Fe now address the )olicitor -eneralKs argument that the issue involved is not susceptible to review by the judiciary because it involves a political 6uestion' and thus' not justiciable%

As a general proposition' a controversy is justiciable if it refers to a matter which is appropriate for court review%2004 &t pertains to issues which are inherently susceptible of being decided on grounds recogni=ed by law%Nevertheless' the Court does not automatically assume jurisdiction over actual constitutional cases brought before iteven in instances that are ripe for resolution% 5ne class of cases wherein the Court hesitates to rule on are "political6uestions%# (he reason is that political 6uestions are concerned with issues dependent upon the wisdom' not thelegality' of a particular act or measure being assailed% oreover' the political 6uestion being a function of theseparation of powers' the courts will not normally interfere with the workings of another co:e6ual branch unless thecase shows a clear need for the courts to step in to uphold the law and the Constitution%

As Ta


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that grave abuse was committed because the power to call was e.ercised in such a manner as to violate theconstitutional provision on civilian supremacy over the military% &n the performance of this CourtKs duty of "purposefulhesitation #2804 before declaring an act of another branch as unconstitutional' only where such grave abuse of discretionis clearly shown shall the Court interfere with the PresidentKs judgment% (o doubt is to sustain%

(here is a clear te.tual commitment under the Constitution to bestow on the President full discretionary powerto call out the armed forces and to determine the necessity for the e.ercise of such power% )ection 3;' Article


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% *E ,5) EDE)% )o actually' if a President feels that there is imminent danger' the matter can be handled bythe +irst )entence@ "(he President%%%%may call out such Armed +orces to prevent or suppress lawless violence'invasion or rebellion%# )o we feel that that is sufficient for handling imminent danger' of invasion or rebellion' insteadof imposing martial law or suspending the writ of habeas corpus ' he must necessarily have to call the Armed +orcesof the Philippines as their Commander:in:Chief% &s that the ideaL

% E-A,A*5% (hat does not re6uire any concurrence by the legislature nor is it subject to judicial review %2874

(he reason for the difference in the treatment of the aforementioned powers highlights the intent to grant thePresident the widest leeway and broadest discretion in using the power to call out because it is considered as thelesser and more benign power compared to the power to suspend the privilege of the writ of habeas corpus and thepower to impose martial law' both of which involve the curtailment and suppression of certain basic civil rights andindividual freedoms' and thus necessitating safeguards by Congress and review by this Court%

oreover' under )ection 3;' Article


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&n this regard' it is not correct to say that -eneral Angelo eyes' Chief of )taff of the A+P' by his allegedinvolvement in civilian law enforcement' has been virtually appointed to a civilian post in derogation of the aforecitedprovision% (he real authority in these operations' as stated in the ,5&' is lodged with the head of a civilian institution'the PNP' and not with the military% )uch being the case' it does not matter whether the A+P Chief actuallyparticipates in the (ask +orce Tulungan since he does not e.ercise any authority or control over the same% )incenone of the arines was incorporated or enlisted as members of the PNP' there can be no appointment to civilianposition to speak of% ence' the deployment of the arines in the joint visibility patrols does not destroy the civilian

character of the PNP%Considering the above circumstances' the arines render nothing more than assistance re6uired in conducting

the patrols% As such' there can be no "insidious incursion# of the military in civilian affairs nor can there be a violationof the civilian supremacy clause in the Constitution%

&t is worth mentioning that military assistance to civilian authorities in various forms persists in Philippine jurisdiction% (he Philippine e.perience reveals that it is not averse to re6uesting the assistance of the military in theimplementation and e.ecution of certain traditionally "civil# functions% As correctly pointed out by the )olicitor-eneral' some of the multifarious activities wherein military aid has been rendered' e.emplifying the activities thatbring both the civilian and the military together in a relationship of cooperation' are@

3% ElectionsH2704

0% Administration of the Philippine National ed Cross H2784

8% elief and rescue operations during calamities and disastersH 2774

7% Amateur sports promotion and development H2794

9% *evelopment of the culture and the artsH 27>4

>% Conservation of natural resources H27?4

?% &mplementation of the agrarian reform programH 27;4

;% Enforcement of customs lawsH 27 4

% Composite civilian:military law enforcement activitiesH 29/4

3/% Conduct of licensure e.aminationsH 2934

33% Conduct of nationwide tests for elementary and high school studentsH 2904

30% Anti:drug enforcement activities H2984

38% )anitary inspectionsH 2974

37% Conduct of census work H2994

39% Administration of the Civil Aeronautics Board H29>4

3>% Assistance in installation of weather forecasting devices H29?4

3?% Peace and order policy formulation in local government units %29;4

(his un6uestionably constitutes a gloss on e.ecutive power resulting from a systematic' unbroken' e.ecutivepractice' long pursued to the knowledge of Congress and' yet' never before 6uestioned% 29 4 Fhat we have here ismutual support and cooperation between the military and civilian authorities' not derogation of civilian supremacy%

&n the nited )tates' where a long tradition of suspicion and hostility towards the use of military force fordomestic purposes has persisted' 2>/4 and whose Constitution' unlike ours' does not e.pressly provide for the power tocall' the use of military personnel by civilian law enforcement officers is allowed under circumstances similar to thosesurrounding the present deployment of the Philippine arines% nder the Posse "omitatus Act 2>34 of the )' the useof the military in civilian law enforcement is generally prohibited' e.cept in certain allowable circumstances% Aprovision of the Act states@

38;9% se of Army and Air +orce as posse comitatus

Fhoever' e.cept in cases and under circumstances e.pressly authori=ed by the Constitution or Act of Congress'willfully uses any part of the Army or the Air +orce as posse comitatus or otherwise to e.ecute the laws shall be finednot more than O3/'/// or imprisoned not more than two years' or both %2>04

(o determine whether there is a violation of the Posse "omitatus Act in the use of military personnel' the )courts 2>84 apply the following standards' to wit@

Fere Army or Air +orce personnel used by the civilian law enforcement officers at Founded Gnee in such a mannerthat the military personnel subjected the citi=ens to the e.ercise of military power which was regulatory' proscriptive'or compulsory 2>74 -eorge Fashington ,aw eview' pp% 7/7:788 !3 ;>$' which discusses the four divergent standardsfor assessing acceptable involvement of military personnel in civil law enforcement% See likewise 5N5 E* &N( E B EEC @ P E)&*EN(&A, A ( 5 &(D (5 EIEC (E ( E ,AF) F&( &,&(A D +5 CE' ;8 Dale ,awJournal' pp% 38/:390' 3 ?8% >7 in nature' either presently or prospectivelyL

. . .

7 IBC vs. Zamora (political law1)
http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn42http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn43http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn43http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn44http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn45http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn45http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn46http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn47http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn47http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn48http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn49http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn50http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn51http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn52http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn53http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn53http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn54http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn55http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn55http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn56http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn56http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn57http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn57http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn58http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn58http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn59http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn60http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn60http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn61http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn61http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn62http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn62http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn63http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn64http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn64http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn64http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn42http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn43http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn44http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn45http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn46http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn47http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn48http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn49http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn50http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn51http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn52http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn53http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn54http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn55http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn56http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn57http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn58http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn59http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn60http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn61http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn62http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn63http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn64


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Fhen this concept is transplanted into the present legal conte.t' we take it to mean that military involvement' evenwhen not e.pressly authori=ed by the Constitution or a statute' does not violate the Posse Comitatus Act unless itactually regulates' forbids or compels some conduct on the part of those claiming relief% A mere threat of some futureinjury would be insufficient% !emphasis supplied$

Even if the Court were to apply the above rigid standards to the present case to determine whether there ispermissible use of the military in civilian law enforcement' the conclusion is inevitable that no violation of the civiliansupremacy clause in the Constitution is committed% 5n this point' the Court agrees with the observation of the)olicitor -eneral@

8% (he designation of tasks in Anne. A 2>94 does not constitute the e.ercise of regulatory' proscriptive' orcompulsory military power% +irst' the soldiers do not control or direct the operation% (his is evident from Nos% >'2>>4 ;!k$ 2>?4 and !a$ 2>;4 of Anne. A% (hese soldiers' second' also have no power to prohibit or condemn% &n No%

!d$2> 4 of Anne. A' all arrested persons are brought to the nearest police stations for proper disposition% Andlast' these soldiers apply no coercive force% (he materials or e6uipment issued to them' as shown in No% ;!c$2?/4 of Anne. A' are all low impact and defensive in character% (he conclusion is that there being no e.ercise ofregulatory' proscriptive or compulsory military power' the deployment of a handful of Philippine arinesconstitutes no impermissible use of military power for civilian law enforcement% 2?34

&t appears that the present petition is anchored on fear that once the armed forces are deployed' the military willgain ascendancy' and thus place in peril our cherished liberties% )uch apprehensions' however' are unfounded% (hepower to call the armed forces is just that : calling out the armed forces% nless' petitioner &BP can show' which ithas not' that in the deployment of the arines' the President has violated the fundamental law' e.ceeded hisauthority or jeopardi=ed the civil liberties of the people' this Court is not inclined to overrule the PresidentKsdetermination of the factual basis for the calling of the arines to prevent or suppress lawless violence%

5ne last point% )ince the institution of the joint visibility patrol in January' 0///' not a single citi=en hascomplained that his political or civil rights have been violated as a result of the deployment of the arines% &t wasprecisely to safeguard peace' tran6uility and the civil liberties of the people that the joint visibility patrol wasconceived% +reedom and democracy will be in full bloom only when people feel secure in their homes and in thestreets' not when the shadows of violence and anarchy constantly lurk in their midst%

*HEREFORE ' premises considered' the petition is hereby *&) &))E*%

SO ORDERED.

>a&i#e+ Jr.+ ".J.+ $elo+ Purisima+ Par#o+ uena+ on)aga-Reyes+ 4nares-Santiago+ and >e 3eon+ Jr.+JJ.+ concur%

ellosillo+ J.+ on official leave%Puno+ J.+ see separate opinion%Vitug+ J.+ see separate opinion%$en#o)a+ J.+ see concurring and dissenting opinion%Panganiban+ J.+ in the result%?uisumbing+ J.+ joins the opinion of J % endo=a%

8 IBC vs. Zamora (political law1)
http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn65http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn66http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn67http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn68http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn68http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn69http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn69http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn70http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn71http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn65http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn66http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn67http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn68http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn69http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn70http://sc.judiciary.gov.ph/jurisprudence/2000/aug2000/141284.htm#_edn71

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