Case Digest (G.R. No. L-62992)
Facts:
In Arlene Babst et al. v. National Intelligence Board (217 Phil. 302, September 28, 1984), the petitioners—Arlene Babst, Odette Alcantara, Ceres P. Doyo, Jo-Ann Q. Maglipon, Domini Torrevillas-Suarez, Lorna Kalaw-Tirol, Cielo Buenaventura, Sylvia Mayuga, Sheila S. Coronel and others—were columnists, feature writers and reporters for various local publications. Beginning July 1980, several received “letters of invitation” (styled as subpoenas) from Special Committee No. 2 of the National Intelligence Board (NIB), chaired by Retired Brig. Gen. Wilfredo C. Estrada, summoning them to Fort Bonifacio for questioning on their work, beliefs, associations and private lives. On December 20, 1982, petitioner Babst was asked to appear on two days’ notice “to shed light on confidential matters,” under threat that failure to appear “shall be considered as a waiver.” During questioning, military officers probed her personal and professional background for over three hours, directing repeated wCase Digest (G.R. No. L-62992)
Facts:
- Parties
- Petitioners: Arlene Babst, Odette Alcantara, Ceres P. Doyo, Jo-Ann Q. Maglipon, Domini Torrevillas-Suarez, Lorna Kalaw-Tirol, Cielo Buenaventura, Sylvia Mayuga, Sheila S. Coronel, et al., all media practitioners (columnists, feature writers, reporters).
- Respondents: National Intelligence Board (NIB) Special Committee No. 2 (predominantly AFP officers, incl. Brig. Gen. Wilfredo Estrada (Ret.) as chairman), plus Brig. Gen. Artemio Tadiar, Jr., and Gen. Fabian Ver (Director General, NIB).
- Underlying Events
- Since July 1980, several petitioners received “invitations” (styled subpoenas) by military authorities to appear for “dialogues”/interrogations on their publications, beliefs, associations, and private lives.
- Typical letter (Dec 20, 1982) to Arlene Babst: summoned to Fort Bonifacio on Dec 22, with warning that failure to appear “shall be considered as a waiver” and committee “will be constrained to proceed in accordance with law.”
- On Feb 9, 1983, Brig. Gen. Tadiar filed a libel complaint (P10 million claimed damages) against Torrevillas-Suarez and Doyo before the City Fiscal, later filed with the RTC.
- Petition and Reliefs Sought
- Original petition (Jan 25, 1983) for prohibition with preliminary injunction to bar respondents from:
- Issuing further “subpoenas”/“invitations” or interrogating petitioners;
- Filing libel suits on matters subject to NIB inquiry.
- Amended and supplemental petition (Mar 3, 1983) added allegations of intimidation by Tadiar’s libel suit and sought to prohibit same.
- Respondents’ Position and Termination of Proceedings
- Respondents contended invitations were voluntary dialogues, not compulsory subpoenas, and that no jurisdictional overreach occurred.
- They argued libel suit by Tadiar was in his personal capacity and not pending before NIB.
- On Jan 19, 1983, NIB Chairman Ver ordered termination of Special Committee No. 2’s proceedings, rendering interrogations moot.
Issues:
- Did the NIB Special Committee’s letters of invitation and interrogations violate petitioners’ constitutional rights to free expression, free press, and personal liberty?
- Was the issuance of said invitations and interrogations within the jurisdiction of the NIB or an abuse of discretion warranting prohibition?
- Is the filing (or threatened filing) of libel suits by Brig. Gen. Tadiar on matters previously inquired into by the NIB subject to prohibition or injunctive relief?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)