Case Digest (G.R. No. 152398) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leo Echegaray y Pilo vs. The Secretary of Justice and the Director of the Bureau of Corrections et al. (G.R. No. 132601, October 12, 1998), petitioner Leo Echegaray was convicted by the Regional Trial Court of Quezon City, Branch 104, for the rape of his common-law spouse’s ten-year-old daughter and sentenced to death. On June 25, 1996, this Court affirmed his conviction and the imposition of the death penalty under Republic Act No. 7659. Petitioner’s motions for reconsideration were denied on February 7, 1998. Meanwhile, Congress enacted Republic Act No. 8177, changing the method of execution from electrocution to lethal injection. The Secretary of Justice promulgated implementing rules, and the Bureau of Corrections prepared a confidential manual. On March 2, 1998, petitioner filed a petition for prohibition, injunction, and/or temporary restraining order to enjoin his execution by lethal injection, alleging that RA 8177 and its rules were unconstitutional on grounds includ Case Digest (G.R. No. 152398) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Crime, Conviction and Appeals
- In 1994, petitioner Leo Echegaray was convicted by the RTC of rape of his 10-year-old common-law daughter and sentenced to death.
- On June 25, 1996, the Supreme Court en banc affirmed the conviction and death penalty (People v. Echegaray).
- Petitioner filed a Motion for Reconsideration raising factual issues, and a Supplemental Motion contesting the constitutionality of RA 7659 (Death Penalty Law).
- Legislative and Executive Developments
- February 7, 1998: SC denied both motions, upholding RA 7659’s constitutionality.
- Meanwhile, Congress enacted RA 8177, substituting lethal injection for electrocution as the death-penalty method.
- Secretary of Justice issued implementing Rules and Regulations; the Director of the Bureau of Corrections prepared a confidential Lethal Injection Manual.
- Petition for Prohibition and Related Pleadings
- March 2, 1998: Petitioner sought prohibition/injunction/ T RO against carrying out his execution by lethal injection, alleging:
- cruel, degrading and inhuman punishment;
- arbitrariness and due-process violation;
- treaty- and delegation-of-power violations;
- unlawful usurpation and discrimination.
- March 3 – 17, 1998: Motions to amend for equal-protection claim; OSG Comment; petitioner’s Reply; CHR’s motion to intervene as amicus.
- The Court gave due course to the petition and resolved it on the merits.
Issues:
- Whether death by lethal injection under RA 8177 and its Rules is cruel, degrading or inhuman punishment (Art. III, Sec. 19(1), 1987 Const.).
- Whether RA 8177 or the death penalty generally violates the Philippines’ obligations under the ICCPR or other treaties.
- Whether RA 8177 unduly delegates legislative power to the Secretary of Justice or the Director of the Bureau of Corrections.
- Whether the Secretary of Justice unlawfully further delegated that power to the Director.
- Whether Sections 17 (reprieve/discrimination) and 19 (confidential Manual) of the implementing Rules are invalid or discriminatory.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)