ARTICLE II

DECLARATION OF PRINCIPLES AND STATE POLICIES

STATE POLICIES
Section 16. The State shall protect and advance the right of the people to a
balanced and healthful ecology in accord with the rhythm and harmony of nature.
Resident Marine Mammals vs Reyes, G.R. No. 180771, April 21, 2015
The case of Resident Marine Mammals of the Protected Seascape Tañon Strait v.
Reyes involves the nullification of Service Contract No. 46 for violating the
Constitution, with the Court ruling that the contract should have been signed by the
President herself and that the notification requirement was not complied with.
Facts:
 The case involves the nullification of Service Contract No. 46 for violating the
Constitution.
 Petitioners, represented by Gloria Estenzo Ramos and Rose-Liza Eisma-
Osorio, filed a petition against Secretary Angelo Reyes, Secretary Jose L.
Atienza, Leonardo R. Sibbaluca, Director Malcolm J. Sarmiento Jr., Andres M.
Bojos, Japan Petroleum Exploration Co., Ltd. (JAPEX), and Supply Oilfield
Services, Inc.
 The Central Visayas Fisherfolk Development Center (FIDEC) and other
individuals also filed a similar petition against the same respondents.
Issue:
 Whether Service Contract No. 46 (SC-46) violated the 1987 Constitution,
Republic Act No. 7586, and Presidential Decree No. 1586.
Ruling:
 SC-46 was violative of the Constitution.
 The President herself should have signed the contract, as required by the
1987 Constitution.
 The doctrine of qualified political agency or alter ego doctrine cannot apply in
this case.
 The argument that the word "may" in the Constitution allows the President to
designate a representative to sign the contract was rejected.
 The court emphasized that the term "may" refers to the President's authority
to enter into such agreements, not to how or who can enter into them.
 The notification requirement under the Constitution was not complied with.
 The belated submission of evidence does not reverse the nullity of the
contract.
Ratio:
  The court reiterated that the President herself should have signed the
contract, as required by the 1987 Constitution.
 The doctrine of qualified political agency or alter ego doctrine, which states
that the acts of the heads of executive departments are presumed to be acts
of the President, cannot apply in this case.
 The court rejected the argument that the word "may" in the Constitution allows
the President to designate a representative to sign the contract.
 The court emphasized that the term "may" refers to the President's authority
to enter into such agreements, not to how or who can enter into them.
 The court found that the notification requirement under the Constitution was
not complied with.
 The belated submission of evidence does not reverse the nullity of the
contract.
Conclusion:
 The court denied the motions for reconsideration filed by the respondents.
 The court affirmed its previous decision nullifying Service Contract No. 46 for
violating the Constitution.

Oposa v. Factoran, Jr., G.R. No. 101083, July 30, 1993

A group of minors and environmental organizations file a complaint against the
Secretary of the Department of Environment and Natural Resources, arguing that the
granting of Timber License Agreements violates their right to a balanced and
healthful ecology, leading to a court ruling in favor of the plaintiffs and emphasizing
the importance of protecting the environment for the well-being and survival of the
Filipino people.
Facts:
This case involves a group of minors, represented by their parents, and an
environmental organization, who filed a complaint against the Secretary of the
Department of Environment and Natural Resources (DENR) and the Presiding Judge
of the Regional Trial Court (RTC) in Makati. The complaint alleges that the
defendants violated the minors' right to a balanced and healthful ecology by granting
timber license agreements (TLAs) that allowed the logging of the country's
rainforests. The plaintiffs argue that the continued deforestation will cause
irreparable damage to their generation and future generations.
Issue:
The main issue in this case is whether the plaintiffs have a cause of action to prevent
the misappropriation or impairment of Philippine rainforests and protect the right to a
balanced and healthful ecology.
Ruling:
The Supreme Court ruled in favor of the plaintiffs and set aside the dismissal order of
the trial court. The Court held that the complaint sufficiently alleged a cause of action
based on the right to a balanced and healthful ecology, which is explicitly provided
for in the Constitution. The Court also held that the issue raised in the complaint is
justiciable and not a political question. The Court further ruled that the non-
impairment clause of the Constitution does not apply to the cancellation of timber
license agreements (TLAs) because TLAs are not contracts and can be revoked by
executive action.
Ratio:
The right to a balanced and healthful ecology, as provided for in the Constitution, is a
fundamental legal right that carries with it the correlative duty to refrain from
impairing the environment. The right to a balanced and healthful ecology is not less
important than any of the civil and political rights enumerated in the Constitution. The
right to a balanced and healthful ecology is self-executing and judicially enforceable.
The political question doctrine is no longer an insurmountable obstacle to the
exercise of judicial power. TLAs are not contracts and can be revoked by executive
action. The non-impairment clause does not apply to TLAs.

Section 17. The State shall give priority to education, science and technology, arts,
culture, and sports to foster patriotism and nationalism, accelerate social progress,
and promote total human liberation and development.
Section 18. The State affirms labor as a primary social economic force. It shall
protect the rights of workers and promote their welfare.
Section 19. The State shall develop a self-reliant and independent national economy
effectively controlled by Filipinos.
Section 20. The State recognizes the indispensable role of the private sector,
encourages private enterprise, and provides incentives to needed investments.
Section 21. The State shall promote comprehensive rural development and agrarian
reform.
Section 22. The State recognizes and promotes the rights of indigenous cultural
communities within the framework of national unity and development.
Section 23. The State shall encourage non-governmental, community-based, or
sectoral organizations that promote the welfare of the nation.
Section 24. The State recognizes the vital role of communication and information in
nation-building.
Section 25. The State shall ensure the autonomy of local governments.
Section 26. The State shall guarantee equal access to opportunities for public
service and prohibit political dynasties as may be defined by law.
Section 27. The State shall maintain honesty and integrity in the public service and
take positive and effective measures against graft and corruption.
Section 28. Subject to reasonable conditions prescribed by law, the State adopts
and implements a policy of full public disclosure of all its transactions involving public
interest.

ARTICLE III
BILL OF RIGHTS
Section 1. No person shall be deprived of life, liberty, or property without due
process of law, nor shall any person be denied the equal protection of the laws.
White Light Corp. v. City of Manila, G.R. No. 122846, January 20, 2009
The Supreme Court declares a Manila ordinance prohibiting short-time admission
and wash-up rate schemes in hotels unconstitutional, emphasizing the importance of
protecting individual rights and the need for the government to employ more
judicious means to promote morality.
Facts:
 City Mayor Alfredo S. Lim signed into law Ordinance No. 7774 on December
3, 1992.
 The ordinance prohibits short-time admission and wash-up rate schemes in
hotels, motels, inns, lodging houses, pension houses, and similar
establishments in the City of Manila.
 The Malate Tourist and Development Corporation (MTDC) filed a complaint
for declaratory relief challenging the validity of the ordinance.
 The White Light Corporation (WLC), Titanium Corporation (TC), and Sta.
Mesa Tourist and Development Corporation (STDC) filed a motion to
intervene as the ordinance directly affects their business interests as
operators of drive-in hotels and motels in Manila.
 The Regional Trial Court (RTC) granted the motion to intervene and issued a
temporary restraining order (TRO) against the enforcement of the ordinance.
 The RTC declared the ordinance null and void, stating that it violates the
constitutional rights to liberty and due process.
 The City of Manila filed a petition for review on certiorari with the Supreme
Court, which referred the petition to the Court of Appeals.
 The Court of Appeals reversed the decision of the RTC and affirmed the
constitutionality of the ordinance, stating that it did not violate the right to
privacy or freedom of movement and was a valid exercise of police power.
 The petitioners, WLC, TC, and STDC, filed a petition for review on certiorari
with the Supreme Court.
Issue:
  Whether the ordinance prohibiting short-time admission and wash-up rate
schemes in hotels, motels, and similar establishments in the City of Manila is
constitutional.
Ruling:
 The Supreme Court declared the ordinance unconstitutional and reinstated
the decision of the RTC.
Ratio:
 The court addressed the issue of the petitioners' standing and concluded that
they have standing to assert the constitutional rights of their patrons.
 The court applied the overbreadth doctrine and recognized that the petitioners
have a right to assert the constitutional rights of their clients to patronize their
establishments for a "wash-rate" time frame.
 The court analyzed the ordinance under the substantive due process standard
and held that it was an arbitrary and whimsical intrusion into the rights of the
establishments and their patrons.
 The court emphasized that the ordinance prevented legitimate uses of wash
rates and renting out rooms more than twice a day, and that less intrusive
measures could be employed to achieve the legitimate goals of curbing illicit
activities.
 Based on these findings, the court declared the ordinance unconstitutional
and reinstated the decision of the RTC.
 The court emphasized the importance of protecting individual rights and the
need for the government to employ more judicious means to promote
morality.

Section 2. The right of the people to be secure in their persons, houses, papers, and
effects against unreasonable searches and seizures of whatever nature and for any
purpose shall be inviolable, and no search warrant or warrant of arrest shall issue
except upon probable cause to be determined personally by the judge after
examination under oath or affirmation of the complainant and the witnesses he may
produce, and particularly describing the place to be searched and the persons or
things to be seized.
Section 3. (1) The privacy of communication and correspondence shall be inviolable
except upon lawful order of the court, or when public safety or order requires
otherwise, as prescribed by law.
(2) Any evidence obtained in violation of this or the preceding section shall be
inadmissible for any purpose in any proceeding.
Salcedo-Ortañez vs. Court of Appeals Salcedo, G.R. No. 110662 August 4, 1994
Salcedo-Ortanez v. Court of Appeals is a Philippine jurisprudence case where the
Supreme Court declared cassette tapes obtained through illegal wiretapping as
inadmissible evidence in a case for annulment of marriage, setting aside the decision
of the Court of Appeals.
Facts:
 Complaint for annulment of marriage filed by Rafael S. Ortanez against
Teresita Salcedo-Ortanez.
 Grounds for annulment: lack of marriage license and/or psychological
incapacity of the petitioner.
 Case filed with the Regional Trial Court of Quezon City, raffled to Branch 94,
presided over by Judge Romeo F. Zamora.
 Private respondent Ortanez offered several exhibits, including three cassette
tapes of alleged telephone conversations between petitioner Salcedo-Ortanez
and unidentified persons.
 Trial court admitted all evidence offered by Ortanez, including the cassette
tapes.
 Petitioner Salcedo-Ortanez objected to the admission of the tapes, but her
motion for reconsideration was denied.
 Petitioner filed a petition for certiorari in the Court of Appeals, challenging the
admission of the cassette tapes as evidence.
Issue:
 Whether or not the remedy of certiorari is available to challenge the admission
of the cassette tapes as evidence.
Ruling:
 The remedy of certiorari is available in this case.
 Certiorari may be allowed when the assailed order is patently erroneous and
the remedy of appeal would not afford adequate and expeditious relief.
 The trial court admitted the cassette tapes as evidence, which were obtained
through illegal wiretapping.
 The admission of the tapes violated the law on wiretapping, which prohibits
the recording and interception of private communications without the consent
of all parties involved.
 Section 4 of Republic Act No. 4200 states that any communication obtained in
violation of the law shall not be admissible in any judicial, quasi-judicial,
legislative, or administrative hearing or investigation.
 Therefore, the Court declared the cassette tapes inadmissible as evidence.
Ratio:
 The Court's decision was based on the clear provisions of Republic Act No.
4200, which prohibits the recording and interception of private
communications without the consent of all parties involved.
 The inadmissibility of the cassette tapes is mandatory under the law.
 Violation of the wiretapping law carries a penalty of imprisonment.
  The Court did not address other arguments raised by the parties, as it had
already concluded that the cassette tapes were inadmissible under Philippine
law.
 Therefore, the Court set aside the decision of the Court of Appeals and
declared the cassette tapes inadmissible as evidence.
Section 4. No law shall be passed abridging the freedom of speech, of expression,
or of the press, or the right of the people peaceably to assemble and petition the
government for redress of grievances.
RA 4200, “An Act to Prohibit and Penalize Wire Tapping and other Related
Violations of the Privacy of Communication, and for other Purposes”. Chavez
vs Gonzales, G.R. No. 168338, February 15, 2008
A petition is filed against the Secretary of the Department of Justice and the National
Telecommunications Commission for violating freedom of expression, freedom of the
press, and the right to information by issuing warnings and orders against individuals
and media organizations in possession of an audiotape obtained through
wiretapping. The court rules in favor of the petitioner, emphasizing the importance of
freedom of speech and the press, and striking down any law or regulation that
restricts these freedoms unless it passes the strict scrutiny test and is necessary to
achieve a compelling government interest.
Facts:
 Petition filed against the Secretary of the Department of Justice and the
National Telecommunications Commission (NTC) for violating freedom of
expression, freedom of the press, and the right to information.
 Respondents issued warnings and orders against individuals and media
organizations in possession of an audiotape obtained through wiretapping.
 Petitioner argues that these actions restrict the freedoms of speech and the
press.
 Case involves the issuance of press releases and statements by the NTC and
the Secretary of Justice warning radio and television stations against airing
taped conversations allegedly between the President and a high-ranking
official of the Commission on Elections (COMELEC).
 Petitioner filed a petition to nullify these warnings, claiming that they constitute
unconstitutional prior restraint on freedom of speech.
Issue:
 Whether the warnings issued by the NTC and the Secretary of Justice
constitute prior restraint on freedom of speech.
Ruling:
 The warnings issued by the NTC and the Secretary of Justice do constitute
prior restraint on freedom of speech.
 There can be no content-based prior restraint on protected expression.
  The NTC warning, which threatens suspension or revocation of licenses for
airing the tapes, is a classic form of prior restraint.
 The warnings do not meet the strict scrutiny test, as there is no compelling
state interest justifying the prior restraint.
 The petition is granted, and the writs of certiorari and prohibition are issued to
nullify the official statements made by the respondents.
 The warnings constitute unconstitutional prior restraint on the exercise of
freedom of speech and of the press.
Ratio:
 Any law or regulation that restricts freedom of speech and the press must
pass the strict scrutiny test and be necessary to achieve a compelling
government interest.
 Prior restraint and censorship are not justified in this case.
 Evidence presented by the respondents did not satisfy the clear and present
danger test, which is used to determine if a restriction on speech is justified.
 The court upholds the exercise of freedom of speech and the press.

Section 5. No law shall be made respecting an establishment of religion, or

prohibiting the free exercise thereof. The free exercise and enjoyment of religious
profession and worship, without discrimination or preference, shall forever be
allowed. No religious test shall be required for the exercise of civil or political rights.
Estrada vs. Escritor, 492 SCRA 1, A.M. No. P-02-1651 June 22, 2006
A court interpreter's conjugal arrangement with a married man is challenged on
grounds of immorality, raising questions about religious freedom and the extent of
accommodations under the Philippine Constitution. The court dismisses the
administrative complaint, asserting that the arrangement does not constitute
disgraceful and immoral conduct and upholds the interpreter's right to religious
freedom.
Facts:
 The case involves Soledad Escritor, a court interpreter, who is accused of
living with a man who is not her husband and having a child with him.
 The complainant, Alejandro Estrada, argues that Escritor's actions are
immoral and tarnish the image of the court where she is employed.
 Escritor claims that her conjugal arrangement is in accordance with her
religious beliefs as a member of the Jehovah's Witnesses.
 She argues that their congregation approves of their arrangement and that
they have executed a "Declaration of Pledging Faithfulness" to make their
union moral and binding within the congregation.
Issue:
  Whether Escritor's conjugal arrangement constitutes disgraceful and immoral
conduct that should result in her being held administratively liable.
Ruling:
 The court rules in favor of Escritor, dismissing the administrative complaint
against her.
 The court asserts that her conjugal arrangement does not constitute
disgraceful and immoral conduct and upholds her right to religious freedom.
 The court applies the compelling state interest test to determine if the state
has a more compelling interest to override Escritor's religious belief and
practice.
 The court finds that the evidence presented by the state does not prove a
more compelling interest, and therefore, Escritor's right to religious freedom
prevails.
Ratio:
 The court discusses the history and interpretation of the religion clauses in the
United States and the Philippines.
 The court explains that while the U.S. Court has adopted a strict neutrality or
separation approach, the Philippine Constitution and jurisprudence have
embraced a benevolent neutrality or accommodation approach.
 The court emphasizes that the Philippine Constitution incorporates mandatory
accommodations for religion, as seen in provisions on tax exemption of
church property, salary of religious officers in government institutions, and
optional religious instruction.
 The court rejects the U.S. Court's interpretation of the religion clauses, which
denies accommodations based on the neutrality and general applicability of
laws.
 The court upholds the Philippine approach of mandatory and permissive
accommodations for religion.
 The court applies the compelling state interest test to determine if the state
has a more compelling interest to override Escritor's religious belief and
practice.
 The court finds that the government has failed to demonstrate a compelling
secular objective and the least restrictive means in preventing the exemption.
 The court concludes that Escritor's conjugal arrangement does not constitute
disgraceful and immoral conduct under the Civil Service Law.
 The court dismisses the administrative complaint against Escritor.

Section 6. The liberty of abode and of changing the same within the limits
prescribed by law shall not be impaired except upon lawful order of the court. Neither
shall the right to travel be impaired except in the interest of national security, public
safety, or public health, as may be provided by law.
Manotok vs CA, G.R. No. L-62100, May 30, 1986
The Republic of the Philippines loses its appeal in the expropriation case against
Manotok Estate Corp., with the Supreme Court affirming the determination of just
compensation at Php7,500.00 per square meter and ordering the payment of the
unpaid balance with legal interest.
Facts:
 Expropriation complaint filed by the Republic of the Philippines, represented
by the Toll Regulatory Board (TRB), against Manotok Estate Corporation,
Manotok Realty, Incorporated, Phil-Ville Development and Housing
Corporation, Francisco Guy Co Chia, Jaime C. Castillo, and CLT Realty
Development Corporation.
 Republic sought to expropriate lands for the rehabilitation and expansion of
the North Luzon Expressway (NLEX).
 Registered owners of the properties sought to be expropriated are the
respondents in the case.
 Republic amended its complaint to reflect the zonal value of the subject
properties, which was set at Php900.00 per square meter.
 Regional Trial Court (RTC) issued a writ of possession and appointed three
commissioners to determine just compensation.
 RTC ruled in favor of the respondents, fixing the amount of just compensation
at Php7,500.00 per square meter.
 Republic appealed the case to the Court of Appeals (CA), but the CA affirmed
the RTC's decision.
Issue:
 Credibility of the expert witness, Engr. Victor Salinas, who recommended the
amount of just compensation.
 Amount of just compensation to be awarded to the respondents.
Ruling:
 Supreme Court denied the petition and affirmed the decision of the CA.
 Credibility of a witness, including an expert witness, is a factual issue that is
not reviewable by the Court.
 Trial court has the authority to rule on the credibility of a witness based on its
observation of the witness's comportment and the evidence presented.
 Determination of just compensation is an inherently judicial function, and
issues pertaining to the value of the property expropriated are questions of
fact.
 RTC and CA's findings on the amount of just compensation were supported
by the evidence on record and should not be disturbed.
 Court ordered the payment of the unpaid balance of just compensation with
legal interest at the rate of 12% per annum from the date of the issuance of
the writ of possession until June 30, 2013, and at the rate of 6% per annum
from July 1, 2013, until full payment.
Section 7. The right of the people to information on matters of public concern shall
be recognized. Access to official records, and to documents and papers pertaining to
official acts, transactions, or decisions, as well as to government research data used
as basis for policy development, shall be afforded the citizen, subject to such
limitations as may be provided by law.

Akbayan vs Aquino, G.R. No. 84642, September 13, 1988

The case involves the demand for disclosure of documents related to the Japan-
Philippines Economic Partnership Agreement (JPEPA) negotiations, with the court
ultimately upholding the claim of executive privilege and denying access to the
documents, citing the need for confidentiality in diplomatic negotiations and
protection of national interest.
Facts:
 The case involves the demand for disclosure of documents related to the
Japan-Philippines Economic Partnership Agreement (JPEPA) negotiations.
 The petitioners, including non-government organizations, Congresspersons,
citizens, and taxpayers, seek to obtain the full text of the JPEPA, including the
Philippine and Japanese offers submitted during the negotiation process and
all pertinent attachments and annexes.
 The petitioners argue that the refusal to disclose these documents violates
their right to information on matters of public concern and contravenes
constitutional provisions on transparency.
Issue:
 Whether the documents related to the JPEPA negotiations should be
disclosed to the public.
Ruling:
 The court ruled in favor of the respondents, upholding the claim of executive
privilege and denying access to the documents.
 The court cited the need for confidentiality in diplomatic negotiations and the
protection of national interest as the basis for their decision.
 They recognized that diplomatic negotiations are privileged and that the public
interest in favor of disclosure must be strong enough to overcome this
privilege.
 The court also addressed procedural issues, such as standing and mootness,
finding that the petitioners had standing to sue and that the case was not
entirely moot.
Ratio:
  The court upheld the claim of executive privilege and denied access to the
documents related to the JPEPA negotiations, citing the need for
confidentiality and the protection of national interest.
 They recognized that diplomatic negotiations are privileged and that the public
interest in favor of disclosure must be strong enough to overcome this
privilege.
 The court also addressed procedural issues, such as standing and mootness,
finding that the petitioners had standing to sue and that the case was not
entirely moot.

Section 8. The right of the people, including those employed in the public and
private sectors, to form unions, associations, or societies for purposes not contrary to
law shall not be abridged.
SSS Employees Association vs CA, G.R. No. 85279, July, 28, 1989.
The case of SSS Employees Association v. Soriano determines whether the Social
Security System in the Philippines is a government-owned or controlled corporation
performing proprietary functions and falls under the operation of the Magna Carta of
Labor.
Facts:
 The case involves the Social Security System (SSS) in the Philippines.
 The SSS is determined to be a government-owned or controlled corporation
performing proprietary functions.
 The Acting Secretary of Finance denied the System's request for exemption
from the payment of customs duty and tax on its importation.
 The Acting Secretary of Finance stated that the SSS is not performing a
strictly governmental function and is operated like a business corporation.
 The Government Corporate Counsel opined that the System only exercises
ministrant functions and is not part of the national or other branches of the
government.
 The SSS brochure describes the System as an insurance scheme of general
application.
 Several issues of the Philippine Security Bulletin published by the SSS state
that it is a counterpart of the GSIS for government employees and explain
how its funds have been invested and how its assets and income have
increased.
Issue:
 Whether the SSS is a government-owned or controlled corporation performing
proprietary functions and falls under the operation of the Magna Carta of
Labor.
Ruling:
  The SSS is a government-owned or controlled corporation performing
basically proprietary functions, and as such, it comes under the operation of
the Magna Carta of Labor.
Ratio:
 The evidence presented in the case supports the conclusion that the SSS is
operated like a business corporation and performs proprietary functions.
 The Acting Secretary of Finance denied the System's request for exemption
from customs duty and tax, stating that it is not performing a strictly
governmental function.
 The Government Corporate Counsel opined that the System only exercises
ministrant functions and is not part of the national or other branches of the
government.
 The SSS brochure and the Philippine Security Bulletin published by the SSS
describe the System as an insurance scheme of general application and a
counterpart of the GSIS for government employees.
 The consolidated balance sheets of the SSS show the increase in its assets
and income as a result of its operation.
 Based on these facts, the court concludes that the SSS is a government-
owned or controlled corporation performing proprietary functions and is
subject to the Magna Carta of Labor.
Section 9. Private property shall not be taken for public use without just
compensation.
Mactan Cebu International Airport vs Lozada, G.R. No. 176625, February 25,
2010.
In a case involving the Mactan Cebu International Airport Authority and the heirs of
Gavina Ijordan, the court ruled that the sale of a jointly owned property by one co-
owner without the consent of the others is unenforceable against the latter, affirming
the lower courts' decision and declaring MCIAA as the owner of 1/22 share of the
property.
Facts:
 The Mactan Cebu International Airport Authority (MCIAA) filed a lawsuit
against the heirs of Gavina Ijordan.
 The heirs named in the lawsuit are Julian Cuison, Francisca Cuison,
Damasina Cuison, Pastor Cuison, Angelina Cuison, Mansueto Cuison,
Bonifacia Cuison, Basilio Cuison, Moises Cuison, and Florencio Cuison.
 The lawsuit aimed to cancel their title to a jointly owned property, Lot No.
4539 situated in Ibo, Municipality of Opon (now Lapu-Lapu City).
 MCIAA claimed that the property had been sold to them by Julian Cuison in
1957.
 The heirs of Ijordan argued that the sale was unenforceable against them as
Julian did not have their consent or authority to sell their shares in the
property.
Issue:
 Was the sale of the jointly owned property by one co-owner without the
consent of the others enforceable against the latter?
Ruling:
 The sale of the property by one co-owner without the consent of the others is
unenforceable against the latter.
 The sale is valid and enforceable against the seller.
 The court affirmed the decision of the lower courts, which dismissed MCIAA's
complaint insofar as it pertained to the shares of the respondents in the
property.
 The court declared MCIAA as the owner of 1/22 share of the property.

Ratio:
 The court based its ruling on the principle that a co-owner cannot sell the
whole property without the consent of the other co-owners.
 The sale only affects the share of the co-owner who sold the property and
does not affect the shares of the other co-owners who did not consent to the
sale.
 The court cited Article 1317 of the Civil Code, which states that no one may
contract in the name of another without being authorized by the latter, unless
he has by law a right to represent him.
 The court emphasized the importance of the Torrens System in protecting the
rights of registered owners and preventing adverse possession from depriving
them of their title.
 Therefore, no acquisitive prescription could arise to deprive the registered
owners of their title.

Section 10. No law impairing the obligation of contracts shall be passed.

Section 11. Free access to the courts and quasi-judicial bodies and adequate legal
assistance shall not be denied to any person by reason of poverty.
Section 12. (1) Any person under investigation for the commission of an offense
shall have the right to be informed of his right to remain silent and to have competent
and independent counsel preferably of his own choice. If the person cannot afford
the services of counsel, he must be provided with one. These rights cannot be
waived except in writing and in the presence of counsel.
(2) No torture, force, violence, threat, intimidation, or any other means which vitiate
the free will shall be used against him. Secret detention places, solitary,
incommunicado, or other similar forms of detention are prohibited.
(3) Any confession or admission obtained in violation of this or Section 17 hereof
shall be inadmissible in evidence against him.
(4) The law shall provide for penal and civil sanctions for violations of this section as
well as compensation to the rehabilitation of victims of torture or similar practices,
and their families.
Section 13. All persons, except those charged with offenses punishable by reclusion
perpetua when evidence of guilt is strong, shall, before conviction, be bailable by
sufficient sureties, or be released on recognizance as may be provided by law. The
right to bail shall not be impaired even when the privilege of the writ of habeas
corpus is suspended. Excessive bail shall not be required.
Section 14. (1) No person shall be held to answer for a criminal offense without due
process of law.
(2) 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 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.
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.
Section 16. All persons shall have the right to a speedy disposition of their cases
before all judicial, quasi-judicial, or administrative bodies.
Section 17. No person shall be compelled to be a witness against himself.
Section 18. (1) No person shall be detained solely by reason of his political beliefs
and aspirations.
(2) No involuntary servitude in any form shall exist except as a punishment for a
crime whereof the party shall have been duly convicted.
Section 19. (1) 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.
(2) 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.
Section 20. No person shall be imprisoned for debt or non-payment of a poll tax.
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.
Section 22. No ex post facto law or bill of attainder shall be enacted.
 ARTICLE XII
NATIONAL ECONOMY AND PATRIMONY
Section 1. The goals of the national economy are a more equitable distribution of
opportunities, income, and wealth; a sustained increase in the amount of goods and
services produced by the nation for the benefit of the people; and an expanding
productivity as the key to raising the quality of life for all, especially the
underprivileged.
The State shall promote industrialization and full employment based on sound
agricultural development and agrarian reform, through industries that make full and
efficient use of human and natural resources, and which are competitive in both
domestic and foreign markets. However, the State shall protect Filipino enterprises
against unfair foreign competition and trade practices.
In the pursuit of these goals, all sectors of the economy and all regions of the country
shall be given optimum opportunity to develop. Private enterprises, including
corporations, cooperatives, and similar collective organizations, shall be encouraged
to broaden the base of their ownership.
Section 2. All lands of the public domain, waters, minerals, coal, petroleum, and
other mineral oils, all forces of potential energy, fisheries, forests or timber, wildlife,
flora and fauna, and other natural resources are owned by the State. With the
exception of agricultural lands, all other natural resources shall not be alienated. The
exploration, development, and utilization of natural resources shall be under the full
control and supervision of the State. The State may directly undertake such
activities, or it may enter into co-production, joint venture, or production-sharing
agreements with Filipino citizens, or corporations or associations at least sixty per
centum of whose capital is owned by such citizens. Such agreements may be for a
period not exceeding twenty-five years, renewable for not more than twenty-five
years, and under such terms and conditions as may be provided by law. In cases of
water rights for irrigation, water supply fisheries, or industrial uses other than the
development of water power, beneficial use may be the measure and limit of the
grant.
The State shall protect the nation's marine wealth in its archipelagic waters, territorial
sea, and exclusive economic zone, and reserve its use and enjoyment exclusively to
Filipino citizens.
The Congress may, by law, allow small-scale utilization of natural resources by
Filipino citizens, as well as cooperative fish farming, with priority to subsistence
fishermen and fish- workers in rivers, lakes, bays, and lagoons.
The President may enter into agreements with foreign-owned corporations involving
either technical or financial assistance for large-scale exploration, development, and
utilization of minerals, petroleum, and other mineral oils according to the general
terms and conditions provided by law, based on real contributions to the economic
growth and general welfare of the country. In such agreements, the State shall
promote the development and use of local scientific and technical resources.
The President shall notify the Congress of every contract entered into in accordance
with this provision, within thirty days from its execution.
Oh Cho v. Dir. Of Lands
In the case of Oh Cho v. Director of Lands, the court rules that a Chinese citizen's
purchase of a residential lot is null and void due to their disqualification as an alien
from acquiring public lands, despite their possession of the lot since 1880,
highlighting the nationalistic policy and purpose of the Constitution and laws in
disqualifying aliens from acquiring or holding lands of the public domain.
Facts:
 Oh Cho, an alien, and his predecessors in interest have been in possession of
the lot since 1880.
 Oh Cho applied for the registration of the residential lot located in
Guinayangan, Tayabas.
 The Director of Lands opposed the application on the grounds that Oh Cho
lacks title to the lot and is disqualified as an alien from acquiring public lands.
 Issue:
 Whether an alien is entitled to register and acquire a residential lot in the
Philippines.
Ruling:
 An alien is not entitled to a decree of registration under the provisions of the
Public Land Act.
 The applicant failed to show that he has title to the lot that may be confirmed
under the law.
 The Constitution and laws of the Philippines have a nationalistic policy and
purpose in disqualifying aliens from acquiring or holding lands of the public
domain.
Ratio:
 The phrase "agricultural land" as used in the Constitution includes residential,
commercial, or industrial lots for purposes of their disposition.
 Previous judicial interpretations have classified residential or building lots as
agricultural land, regardless of their actual use, as long as they are
susceptible to cultivation and may be converted into rural estates.
 The applicant, being a Chinese citizen, is disqualified from acquiring or
holding lands of the public domain under the Constitution and laws of the
Philippines.
Conclusion
 The Chinese citizen's purchase of the residential lot is null and void due to
their disqualification as an alien from acquiring public lands.
 The nationalistic policy and purpose of the Constitution and laws are
emphasized in disqualifying aliens from acquiring or holding lands of the
public domain.
Section 3. Lands of the public domain are classified into agricultural, forest or
timber, mineral lands and national parks. Agricultural lands of the public domain may
be further classified by law according to the uses to which they may be devoted.
Alienable lands of the public domain shall be limited to agricultural lands. Private
corporations or associations may not hold such alienable lands of the public domain
except by lease, for a period not exceeding twenty-five years, renewable for not
more than twenty-five years, and not to exceed one thousand hectares in area.
Citizens of the Philippines may lease not more than five hundred hectares, or
acquire not more than twelve hectares thereof, by purchase, homestead, or grant.
Taking into account the requirements of conservation, ecology, and development,
and subject to the requirements of agrarian reform, the Congress shall determine, by
law, the size of lands of the public domain which may be acquired, developed, held,
or leased and the conditions therefor.
Section 4. The Congress shall, as soon as possible, determine, by law, the specific
limits of forest lands and national parks, marking clearly their boundaries on the
ground. Thereafter, such forest lands and national parks shall be conserved and may
not be increased nor diminished, except by law. The Congress shall provide for such
period as it may determine, measures to prohibit logging in endangered forests and
watershed areas.
Section 5. The State, subject to the provisions of this Constitution and national
development policies and programs, shall protect the rights of indigenous cultural
communities to their ancestral lands to ensure their economic, social, and cultural
wellbeing.
The Congress may provide for the applicability of customary laws governing property
rights or relations in determining the ownership and extent of ancestral domain.
Cruz v. Sec. of DENR
The case involves the conflicting claims to certain properties not mentioned in the
will of the deceased Teodoro T. Cruz, which must be resolved in an appropriate
proceeding before their partition can be ordered.
Facts:
 The case involves conflicting claims to certain properties that were not
mentioned in the will of Teodoro T. Cruz.
 The case was brought before the Court of First Instance of Pangasinan.
 The court admitted the will to probate and ordered the summary settlement of
the deceased's estate.
 Some of the heirs filed a motion to eliminate the portion of the decision that
ordered the settlement and distribution of the properties listed in the will.
 They argued that these properties belonged to the conjugal partnership of the
testator and his first deceased wife and could not be disposed of entirely by
the testator.
 They also argued that the dispositions in the will, made in accordance with the
provisions of the old Civil Code, should be altered to conform to the provisions
of the new Civil Code.
 The court denied the motion for reconsideration, stating that the probate of the
will and the settlement of the estate did not vest the properties to the devisees
and legatees mentioned in the will if they did not belong to the testator.
 The court found that the dispositions in the will did not grant more than what
the devisees and legatees would receive or what the testator could dispose
of.
 The court also found that the legitime of the heirs was not impaired.
Issue:
 Whether the estate of the deceased Teodoro T. Cruz could be partitioned
anew, despite the previous summary settlement and distribution of the estate.
Ruling:
 A new partition was not legally feasible and the court set aside the order
approving the project of partition.
 The conflicting claims to the properties not mentioned in the will must be
resolved in an appropriate proceeding before their partition can be ordered.
Ratio:
 The court ruled that the probate of the will and the settlement of the estate did
not vest the properties to the devisees and legatees mentioned in the will if
they did not belong to the testator.
 The court found that the dispositions in the will did not grant more than what
the devisees and legatees would receive or what the testator could dispose
of.
 The court also found that the legitime of the heirs was not impaired.
  The court appointed an administrator to gather all the properties of the
deceased spouses and prepare a project of partition of the estate.
 The court noted that the properties described in the will were not the exclusive
properties of the deceased but were part of the conjugal partnership.
 The court also noted that the three other properties allegedly belonging to the
deceased spouses had not been included in the administration of the estate,
warranting the appointment of an administrator.
 The Court of Appeals affirmed the appointment of the administrator, stating
that the purpose of estate administration is the liquidation and distribution of
the estate, and that the properties not included in the administration should be
brought into the estate.
 The court approved the project of partition, stating that if the appellants
believed that there were properties not included in the partition, they could
resort to court for the partition of those properties.
 The court found that the dispositions in the will, as approved in the previous
decision, were in accordance with the law.
 The court noted that the acceptance of the inheritance by the distributees was
irrevocable and could not be impugned, except in certain circumstances.
 The court set aside the order approving the project of partition, stating that a
new partition with respect to the same properties was no longer legally
feasible.
 The court also noted that the conflicting claims to the properties not
mentioned in the will must be resolved in an appropriate proceeding before
their partition can be ordered.
Section 6. The use of property bears a social function, and all economic agents shall
contribute to the common good. Individuals and private groups, including
corporations, cooperatives, and similar collective organizations, shall have the right
to own, establish, and operate economic enterprises, subject to the duty of the State
to promote distributive justice and to intervene when the common good so demands.
Section 7. Save in cases of hereditary succession, no private lands shall be
transferred or conveyed except to individuals, corporations, or associations qualified
to acquire or hold lands of the public domain.
Section 8. Notwithstanding the provisions of Section 7 of this Article, a natural-born
citizen of the Philippines who has lost his Philippine citizenship may be a transferee
of private lands, subject to limitations provided by law.
Section 9. The Congress may establish an independent economic and planning
agency headed by the President, which shall, after consultations with the appropriate
public agencies, various private sectors, and local government units, recommend to
Congress, and implement continuing integrated and coordinated programs and
policies for national development.
Until the Congress provides otherwise, the National Economic and Development
Authority shall function as the independent planning agency of the government.
Section 10. The Congress shall, upon recommendation of the economic and
planning agency, when the national interest dictates, reserve to citizens of the
Philippines or to corporations or associations at least sixty per centum of whose
capital is owned by such citizens, or such higher percentage as Congress may
prescribe, certain areas of investments. The Congress shall enact measures that will
encourage the formation and operation of enterprises whose capital is wholly owned
by Filipinos.
In the grant of rights, privileges, and concessions covering the national economy and
patrimony, the State shall give preference to qualified Filipinos.
The State shall regulate and exercise authority over foreign investments within its
national jurisdiction and in accordance with its national goals and priorities.
Manila Prince Hotel v. GSIS
The Manila Prince Hotel v. Government Service Insurance System case clarified that
the constitutional provision on national patrimony is self-executing and requires
preference for qualified Filipinos in the grant of rights, privileges, and concessions
covering the national economy and patrimony, resulting in the Supreme Court
ordering the respondents to accept the matching bid of the Manila Prince Hotel to
protect the Manila Hotel as part of the national patrimony.
Facts:
 Petitioner: Manila Prince Hotel
 Respondents: Government Service Insurance System (GSIS), Manila Hotel
Corporation, Committee on Privatization, and Office of the Government
Corporate Counsel
 Date: February 3, 1997
 Place: Philippines
 Brief account of events: The case involves the sale of the controlling shares of
the Manila Hotel Corporation by GSIS to a foreign corporation, Renong
Berhad. Manila Prince Hotel filed a petition to stop the sale, arguing that it
violates the constitutional provision on national patrimony. Manila Hotel is
considered a historic landmark and part of the country's cultural heritage.
 Brief account of the case in the lower court: The lower court ruled in favor of
the respondents, stating that the provision on national patrimony is not self-
executing and requires implementing legislation.
Issue:
 Whether the sale of shares of the Manila Hotel Corporation to a foreign firm
violates the constitutional provision on national patrimony.
 Whether the provision on national patrimony is self-executing or requires
implementing legislation.
Ruling:
 The Supreme Court ruled in favor of the Manila Prince Hotel.
  The Court held that the provision on national patrimony is self-executing and
does not require implementing legislation.
 The Court ordered the respondents to cease the sale to the foreign firm and
accept the matching bid of the Manila Prince Hotel.
Ratio:
 The constitutional provision on national patrimony is self-executing and
requires preference to be given to qualified Filipinos in the grant of rights,
privileges, and concessions covering the national economy and patrimony.
 The Manila Hotel is considered part of the national patrimony and should be
protected.
 The sale should have given preference to qualified Filipinos, and the Court
orders the respondents to accept the matching bid of the Manila Prince Hotel.
Section 11. No franchise, certificate, or any other form of authorization for the
operation of a public utility shall be granted except to citizens of the Philippines or to
corporations or associations organized under the laws of the Philippines, at least
sixty per centum of whose capital is owned by such citizens; nor shall such
franchise, certificate, or authorization be exclusive in character or for a longer period
than fifty years. Neither shall any such franchise or right be granted except under the
condition that it shall be subject to amendment, alteration, or repeal by the Congress
when the common good so requires. The State shall encourage equity participation
in public utilities by the general public. The participation of foreign investors in the
governing body of any public utility enterprise shall be limited to their proportionate
share in its capital, and all the executive and managing officers of such corporation
or association must be citizens of the Philippines.
Section 12. The State shall promote the preferential use of Filipino labor, domestic
materials and locally produced goods, and adopt measures that help make them
competitive.
Section 13. The State shall pursue a trade policy that serves the general welfare
and utilizes all forms and arrangements of exchange on the basis of equality and
reciprocity.
Section 14. The sustained development of a reservoir of national talents consisting
of Filipino scientists, entrepreneurs, professionals, managers, high-level technical
manpower and skilled workers and craftsmen in all fields shall be promoted by the
State. The State shall encourage appropriate technology and regulate its transfer for
the national benefit.
The practice of all professions in the Philippines shall be limited to Filipino citizens,
save in cases prescribed by law.
Section 15. The Congress shall create an agency to promote the viability and
growth of cooperatives as instruments for social justice and economic development.
Section 16. The Congress shall not, except by general law, provide for the
formation, organization, or regulation of private corporations. Government-owned or
controlled corporations may be created or established by special charters in the
interest of the common good and subject to the test of economic viability.
Section 17. In times of national emergency, when the public interest so requires, the
State may, during the emergency and under reasonable terms prescribed by it,
temporarily take over or direct the operation of any privately-owned public utility or
business affected with public interest.
Section 18. The State may, in the interest of national welfare or defense, establish
and operate vital industries and, upon payment of just compensation, transfer to
public ownership utilities and other private enterprises to be operated by the
Government.
Section 19. The State shall regulate or prohibit monopolies when the public interest
so requires. No combinations in restraint of trade or unfair competition shall be
allowed.
Section 20. The Congress shall establish an independent central monetary
authority, the members of whose governing board must be natural-born Filipino
citizens, of known probity, integrity, and patriotism, the majority of whom shall come
from the private sector. They shall also be subject to such other qualifications and
disabilities as may be prescribed by law. The authority shall provide policy direction
in the areas of money, banking, and credit. It shall have supervision over the
operations of banks and exercise such regulatory powers as may be provided by law
over the operations of finance companies and other institutions performing similar
functions.
Until the Congress otherwise provides, the Central Bank of the Philippines operating
under existing laws, shall function as the central monetary authority.
Section 21. Foreign loans may only be incurred in accordance with law and the
regulation of the monetary authority. Information on foreign loans obtained or
guaranteed by the Government shall be made available to the public.
Section 22. Acts which circumvent or negate any of the provisions of this Article
shall be considered inimical to the national interest and subject to criminal and civil
sanctions, as may be provided by law.