Case Digest (G.R. No. 169364)
Facts:
People of the Philippines v. Evangeline Siton y Sacil and Krystel Kate Sagarano y Mefania, G.R. No. 169364, September 18, 2009, Supreme Court Third Division, Ynares‑Santiago, J., writing for the Court.Respondents Evangeline Siton and Krystel Kate Sagarano were separately charged with vagrancy under paragraph (2) of Article 202 of the Revised Penal Code via Informations dated November 18, 2003 (Criminal Cases Nos. 115,716‑C‑2003 and 115,717‑C‑2003). The Informations alleged that on or about November 14, 2003 they “wandered and loitered” around certain streets “without any visible means to support herself nor lawful and justifiable purpose.” Respondents moved to quash both Informations, asserting that Article 202(2) is vague and overbroad and that it violates due process and equal protection.
The Municipal Trial Court in Cities denied the motions to quash by order dated April 28, 2004, and directed respondents to file counter‑affidavits; the court justified the vagrancy law as a police‑power measure and noted that the arresting officer’s affidavit showed prior surveillance. Respondents then filed an original petition for certiorari and prohibition before the Regional Trial Court (Branch 11) of Davao City (Special Civil Case No. 30‑500‑2004), directly challenging the constitutionality of Article 202(2) on void‑for‑vagueness and equal‑protection grounds.
On July 29, 2005 the Regional Trial Court granted the petition, set aside the municipal court’s order, dismissed the criminal cases, and declared Article 202(2) unconstitutional. The R.T.C. relied heavily on the U.S. Supreme Court decision in Papachristou v. City of Jacksonville to conclude that the provision (as applied and on its face) failed to give fair notice and invited arbitrary enforcement, and it also held that the statute impermissibly discriminated against the poor and unemployed.
The People, through the Office of the Solicitor General, sought review in the Supreme Court by way of a petition for review on certiorari, arguing principally that Article 202(2) is presumptively constitutional, that vague...(Subscriber-Only)
Issues:
- Is paragraph (2) of Article 202 of the Revised Penal Code void for vagueness in violation of due process?
- Does paragraph (2) of Article 202 violate the equal protection clause by discriminating against the poor an...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)