Title
Supreme Court
Southern Hemisphere Engagement Network, Inc. vs. Anti-Terrorism Council
Case
G.R. No. 178552
Decision Date
Oct 5, 2010
Petitions challenging RA 9372's constitutionality dismissed; certiorari deemed improper remedy, no actual controversy yet. Substantive issues left unresolved.

Case Digest (G.R. No. 178552)
Expanded Legal Reasoning Model

Facts:

  • Enactment and Content of R.A. 9372
    • R.A. 9372, the Human Security Act of 2007, was enacted on March 6, 2007 and took effect on July 15, 2007.
    • It defines “terrorism” by reference to predicate crimes (e.g., rebellion, murder, kidnapping) and enhances penalties when such acts “sow and create a condition of widespread and extraordinary fear and panic among the populace” or aim “to coerce the government to give in to an unlawful demand.”
    • It establishes the Anti-Terrorism Council (ATC) and provides for judicial proscription of terrorist organizations.
  • Petitions and Parties
    • Six petitions (G.R. Nos. 178552, 178554, 178581, 178890, 179157, 179461) were filed between July and September 2007, challenging the constitutionality of R.A. 9372 by petitions for certiorari and prohibition.
    • Petitioners included NGOs (e.g., Southern Hemisphere Engagement Network), labor federations (KMU, NAFLU-KMU), mass organizations (BAYAN, GABRIELA, etc.), human rights coalitions (Karapatan), legal associations (IBP, CODAL), and regional chapters (BAYAN-ST, etc.).
    • Respondents comprised the ATC officers (Executive Secretary as Chair; Secretaries of Justice, National Defense, Foreign Affairs, Interior and Local Government, Finance; National Security Adviser), the President, AFP and PNP Chiefs, and related enforcement agencies.

Issues:

  • Procedural and Jurisdictional
    • Is certiorari under Rule 65 the proper remedy against executive-branch bodies like the ATC?
    • Do the petitioners have locus standi, and is there a justiciable case or controversy?
  • Merits of Constitutionality
    • Are the definitions and penalty provisions of R.A. 9372 unconstitutionally vague or overbroad?
    • Do the void-for-vagueness and overbreadth doctrines apply to ordinary penal legislation outside the free speech context?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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