Case Digest (G.R. No. 27484) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Angel Lorenzo v. Director of Health, decided on September 1, 1927 (50 Phil. 595, G.R. No. 27484), the petitioner Angel Lorenzo, a confirmed leper, was detained in San Lazaro Hospital in Manila under Section 1058 of the Administrative Code, which empowered the Director of Health to apprehend and isolate leprous persons. Lorenzo filed a petition for the writ of habeas corpus in the Court of First Instance of Manila, admitting his condition but contending that his confinement violated his constitutional rights and asserting that leprosy is not an infectious disease. The health authorities’ return admitted compliance with Section 1058 and denied all other allegations. Lorenzo did not traverse the return, and the trial court sustained the law’s validity and denied relief, prompting this appeal.Issues:
- Whether Section 1058 of the Administrative Code, authorizing the
Case Digest (G.R. No. 27484) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for Habeas Corpus
- Angel Lorenzo, admitted as a leper, filed a petition for habeas corpus alleging that his confinement in San Lazaro Hospital, Manila, under compulsion of law, violated his constitutional rights.
- The petition contended that leprosy is not an infectious disease and, therefore, segregation under the law was unwarranted without proof.
- Return and Statutory Basis
- The Director of Health returned the writ, stating that Lorenzo’s detention conformed with Administrative Code, Article XV, chapter 37, section 1058, which empowers health authorities “to apprehend, and detain, isolate, or confine, all leprous persons in the Philippine Islands.”
- The return appended a general denial of all unadmitted allegations; the Supreme Court treated only the statutory compliance averment as legally relevant.
- Proceedings Below
- The Court of First Instance of Manila (Judge Concepcion) sustained the constitutionality of the segregation law and denied the petition without receiving evidence on the contagiousness of leprosy.
- Counsel for Lorenzo sought to compel the trial court to hear expert proof that leprosy is non-contagious, but the trial court and later the Supreme Court declined.
Issues:
- Validity of Mandatory Segregation
- Whether Administrative Code § 1058, authorizing the isolation of leprous persons, is a valid exercise of the police power for public health under due process.
- Whether a habeas corpus petitioner may require judicial fact-finding (e.g., expert testimony) on the contagiousness of leprosy before lawful detention under the statute.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)