Case Digest (G.R. No. 160506) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 525 Phil. 110 (June 22, 2006), En Banc (A.M. No. P-02-1651), Alejandro Estrada filed on July 27, 2000 a sworn complaint with Judge Jose F. Caoibes Jr., presiding in Branch 253 of the Regional Trial Court in Las Piñas City, against Soledad S. Escritor, a court interpreter, for “living with a man not her husband” and bearing a child in that arrangement. Estrada alleged that this cohabitation—conduct proscribed as “disgraceful and immoral” under Book V, Title I, Chapter VI, Sec. 46(b)(5) of the Revised Administrative Code—tarnished the image of the judiciary. Escritor, a widow since 1998, admitted she had lived with Luciano D. Quilapio, Jr. for over twenty years while both were married to others and that they executed in 1991 a Declaration of Pledging Faithfulness in accordance with the tenets of Jehovah’s Witnesses, approved by congregation elders and recorded with the Watch Tower Central Office. In its August 4, 2003 decision, the Supreme Court held that religious-freedom clai Case Digest (G.R. No. 160506) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and administrative charge
- On July 27, 2000, Alejandro Estrada, likewise a court interpreter, filed a sworn‐letter complaint against Soledad S. Escritor, interpreter of Branch 253, RTC Las Piñas City, for living with a man not her husband and bearing a child from that live‐in arrangement.
- Escritor was charged administratively with “disgraceful and immoral conduct” under Book V, Title I, Chapter VI, § 46(b)(5) of the Revised Administrative Code.
- Respondent’s marital status and religious arrangement
- Escritor, a widow since 1998, had lived with Luciano D. Quilapio, Jr.—who remained married to another woman—without civil marriage for over twenty years and had a son with him.
- As a Jehovah’s Witness, she executed on July 28, 1991 a “Declaration of Pledging Faithfulness,” approved and recorded by her congregation, allowing abandoned spouses to form binding unions pending legal impediments; the impediment on her part ended in 1998 but Quilapio’s subsisting marriage kept the declaration in force.
- Initial Supreme Court decision and remand
- In Estrada v. Escritor (Aug 4, 2003), the Court held:
- Philippine religion clauses rest on “benevolent neutrality” or accommodation.
- Claims under the Free Exercise Clause should be judged by the “compelling state interest” (strict scrutiny) test.
- The Court remanded to OCA to allow the State to:
- Probe the sincerity and centrality of Escritor’s belief.
- Present evidence of a more compelling state interest against exempting her conduct.
- Show that the means chosen were the least restrictive.
- Remand proceedings and evidence adduced
- The OSG intervened, submitting:
- A letter and notarized certification by the Watch Tower legal representative, confirming the sincerity of Escritor’s beliefs and the internal nature of the declaration.
- The OSG argued the State’s interests in:
- Protecting marriage and the family as basic social institutions (Constitution, Art II, § 12; Family Code, Art 149).
- Preserving public morality and the integrity of the judiciary.
- The OSG produced no evidence demonstrating a compelling interest or the least restrictive means of regulation.
Issues:
- Does the Free Exercise Clause of the 1987 Constitution exempt Respondent from administrative liability for her live‐in arrangement sanctioned by her faith but condemned by civil and penal law?
- Has the State shown a compelling interest—and used the least restrictive means—strong enough to override Respondent’s claim to religious freedom?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)