Title
Lee vs. Ilagan
Case
G.R. No. 203254
Decision Date
Oct 8, 2014
Former partners dispute over a sex video; Lee used it as evidence in legal cases, while Ilagan claimed privacy violation. SC ruled for Lee, finding no unlawful intent.

Case Digest (G.R. No. 186720)
Expanded Legal Reasoning Model

Facts:

  • Relationship and discovery of the subject video
    • Dr. Joy Margate Lee and P/Supt. Neri A. Ilagan were former common-law partners from 2003 until August 2011. In July 2011, Ilagan visited Lee’s condominium; upon returning to his office, he found his digital camera missing.
    • On August 23, 2011, Lee confronted Ilagan at his office with a sex video (“subject video”) purportedly recorded on the missing camera. Ilagan denied the video’s authenticity, demanded the camera’s return, and allegedly slammed Lee’s head against a wall when she refused.
  • Legal actions initiated by Lee
    • Lee filed a criminal complaint for violation of R.A. No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) before the Office of the City Prosecutor of Makati, using the subject video as evidence.
    • Lee also lodged an administrative complaint for grave misconduct against Ilagan before the National Police Commission (NAPOLCOM).
  • Petition for the writ of habeas data and RTC preliminary proceedings
    • On June 22, 2012, Ilagan petitioned the RTC of Quezon City (Branch 224) for a writ of habeas data, alleging that Lee’s reproduction and threatened dissemination of the video violated his and the other woman’s rights to life, liberty, security, and privacy.
    • Finding the petition prima facie meritorious, the RTC issued the writ on June 25, 2012, directing Lee to produce the camera, the original video, and all copies, and to file a verified return within five working days.
  • Lee’s verified return and RTC decision
    • In her July 2, 2012 return, Lee admitted keeping the memory card and reproducing the video solely to use as evidence, asserted that the petition aimed to suppress her evidence, and denied engaging in data gathering or storage.
    • On August 30, 2012, the RTC granted the writ, ordered Lee to turn over video copies to Ilagan, and enjoined further reproduction, holding that Lee’s acts violated Ilagan’s privacy and caused humiliation and mental anguish, notwithstanding her justification as evidentiary use.

Issues:

  • Whether the RTC correctly extended the privilege of the writ of habeas data in favor of P/Supt. Ilagan.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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