Case Digest (G.R. No. L-32613-14) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Hon. Simeon N. Ferrer, Feliciano Co, and Nilo S. Tayag (150–C Phil. 551, En banc, Dec. 27, 1972), two criminal complaints were filed in 1970 in the Court of First Instance of Tarlac under Republic Act No. 1700 (the Anti-Subversion Act). On March 5, 1970, respondent Feliciano Co was charged with serving as an officer or instructor of the outlawed Communist Party of the Philippines (“CPP”) and its military arm. He moved to quash, alleging the statute was a bill of attainder. On May 25, 1970, respondent Nilo S. Tayag and others were charged for organizing and leading subversive associations, including Kabataang Makabayan, and for inciting armed revolution. Tayag likewise moved to quash on grounds of legislative overreach, vagueness, multiplicity of subject, and unequal protection. On September 15, 1970, the trial court declared RA 1700 void as a bill of attainder, vague, and overbroad, and dismissed both informations. The Government appealed by cert Case Digest (G.R. No. L-32613-14) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings against Feliciano Co
- On March 5, 1970, a complaint under section 4 of the Anti-Subversion Act was filed in the CFI of Tarlac, Branch I, charging Co with knowingly and willfully being an officer/ranking leader of the Communist Party of the Philippines (CPP) from May to December 1969, acting as instructor at Mao Tse Tung University (NPA training school).
- After a preliminary investigation on March 10, 1970, findings of prima facie guilt led to the filing of a twice-amended information alleging aggravating circumstances (contempt of public authorities, band commission, aid of armed men).
- Proceedings against Nilo S. Tayag
- On May 25, 1970, a complaint was filed charging Tayag and others with violating the Anti-Subversion Act by organizing, joining, and remaining as officers/ranking leaders of Kabataang Makabayan (KM), a subversive association, and recruiting for the NPA, with overt acts from March 1969 onward.
- The amended information detailed meetings, speeches inciting armed revolution, formation of KM chapters, recruitment of armed cadres, and alleged use of craft, fraud, or disguise.
- Motions to quash and trial court resolution
- Co moved to quash the information as the Act was a bill of attainder. Tayag moved on grounds of bill of attainder, vagueness, multiple subjects, and denial of equal protection.
- By resolution of September 15, 1970, the trial court declared the Anti-Subversion Act void (bill of attainder; vague and overbroad) and dismissed both informations. The Government appealed via certiorari.
Issues:
- Whether the Anti-Subversion Act is a bill of attainder in violation of Art. III, Sec. 1(11) of the Constitution.
- Whether the Act violates due process through vagueness or overbreadth.
- Whether the Act infringes freedom of expression and association.
- Whether the Act violates the single-subject requirement of the Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)