Case Digest (G.R. No. 242257) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sanchez v. Darroca, G.R. No. 242257, petitioner Vivian A. Sanchez and her minor children sought a writ of amparo against respondents PSupt. Marc Anthony D. Darroca (Chief of Police, San Jose MPS), PSSupt. Leo Irwin D. Agpangan (Provincial Director, PNP–Antique), PCSupt. John C. Bulalacao (Regional Director, PNP–Region VI) and their subordinates, alleging that as the widow and children of a deceased man suspected of New People’s Army membership, they were subjected to surreptitious surveillance, aggressive questioning and threats of arrest for obstruction of justice when they visited St. Peter’s Funeral Home to identify the body. The Regional Trial Court denied relief, accepting the respondents’ contention that their actions were part of a legitimate investigation. On October 15, 2019, this Court, applying the 1987 Constitution, granted the petition, issuing a permanent protection order against any further monitoring or surveillance. Respondents then filed a motion for reconsi Case Digest (G.R. No. 242257) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- On August 15, 2018, police engaged suspected NPA members, resulting in petitioner’s husband’s death.
- On August 16–17, petitioner Vivian A. Sanchez and her children visited the funeral home, where police:
- Questioned them brusquely and photographed them without consent.
- Threatened to charge petitioner with obstruction of justice and allegedly placed them under surveillance (drive-bys, tailing, circulating her image).
- Proceedings below
- October 15, 2019: The Supreme Court granted the writ of amparo, finding substantial evidence of real threats, upholding spousal/filial privileges, condemning surreptitious surveillance, and issuing a Permanent Protection Order (PPO) barring PNP monitoring.
- Respondents’ Motion for Reconsideration argued that:
- The writ of amparo is confined to extrajudicial killings/enforced disappearances; this case involved ordinary police investigation.
- Spousal/filial privileges apply only in judicial proceedings.
- Petitioner failed to present substantial evidence of threats or abusive conduct; respondents denied conducting surveillance.
Issues:
- Whether the writ of amparo applies to threats and rights violations outside extrajudicial killings and enforced disappearances.
- Whether the constitutional right to privacy and spousal/filial privileges extend to police investigations.
- Whether petitioner presented substantial evidence of real threats to life, liberty, or security.
- Whether respondents’ surveillance and interview tactics fell within lawful, regular police procedures.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)