Title
Bautista vs. Dannug-Salucon
Case
G.R. No. 221862
Decision Date
Jan 23, 2018
Atty. Maria Catherine Dannug-Salucon secures a favorable ruling from the Court of Appeals for the writs of amparo and habeas data, addressing threats and surveillance by military and police, mandating their protection of her and her family.
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Case Digest (A.M. No. 1312-CFI)

Facts:

  • A petition for review on certiorari was filed by high-ranking officials of the Armed Forces of the Philippines (AFP) and the Philippine National Police (PNP) against Atty. Maria Catherine Dannug-Salucon.
  • Petitioners included Gen. Emmanuel Bautista, Gen. Eduardo AAo, Gen. Hernando Iriberri, Gen. Benito Antonio T. De Leon, and PC/Supt. Miguel de Mayo Laurel.
  • The case stemmed from a March 12, 2015 decision by the Court of Appeals, which granted Atty. Salucon the writs of amparo and habeas data.
  • Atty. Salucon, a human rights lawyer and co-founder of the National Union of People’s Lawyers (NUPL), defended political detainees and human rights advocates.
  • On March 24, 2014, during a meeting with relatives of a political prisoner, Atty. Salucon learned from her paralegal, William Bugatti, that they were under surveillance.
  • Bugatti was later fatally shot, prompting Atty. Salucon to report being monitored by military and police operatives.
  • Atty. Salucon filed for writs of amparo and habeas data, claiming threats to her life, liberty, and security due to surveillance and harassment.
  • Petitioners denied the allegations, asserting that Atty. Salucon's evidence was hearsay and lacked merit.
  • The Court of Appeals ruled in favor of Atty. Salucon, leading to the petitioners' appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition for review on certiorari, upholding the Court of Appeals' decision.
  • The Court found Atty. Salucon's evidence sufficient to justify the issuance of the writs of amparo and habeas data.
  • The admission of hearsay evidence was deemed appropriate under the c...(Unlock)

Ratio:

  • The Supreme Court highlighted the challenges in cases of enforced disappearances and extrajudicial killings, where direct evidence is often hard to obtain.
  • A totality of evidence standard was adopted, allowing hearsay testimony if consistent with other admissible evidence.
  • This approach is necessary to address state-sponsored threats against individuals, ...continue reading

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