Case Summary (G.R. No. 132601)
Content of RA 8177 and Its Implementing Rules
RA 8177 amended Article 81 of the Revised Penal Code to prescribe lethal injection and mandated training of personnel, action by the Director of Corrections to ensure instantaneous death, and promulgation of rules by the Secretary of Justice, in coordination with the Secretary of Health and the Director. The implementing rules detailed inmate services, confinement, notification, execution procedures, witnesses, secrecy of executioners’ identity, disposition of the body, among other provisions.
Petitioner’s Constitutional Challenges
Petitioner contended that lethal injection is:
- Cruel, degrading and inhuman punishment (Art. III, Sec. 19[1]).
- A violation of due process and arbitrary or unreasonable.
- In breach of international treaty obligations under the ICCPR.
- An undue delegation of legislative power to executive officials.
- Discriminatory under equal protection.
- Grounds for injunctive relief to prevent irreparable harm.
Cruel, Degrading or Inhuman Punishment Under Article III, Section 19
Court held that the death penalty per se is not cruel or inhuman and that lethal injection—administered by trained personnel, under statutory time limits, and subject to executive clemency—does not inherently inflict lingering pain. The method was compared with U.S. jurisprudence upholding lethal injection under evolving standards of decency and legislative adoption as evidence of societal acceptance.
International Covenant on Civil and Political Rights
Court recognized Article 6 of the ICCPR permitting capital punishment for “most serious crimes,” subject to fair trial and finality requirements. The Philippines ratified ICCPR and its Optional Protocol but not the Second Optional Protocol aiming at abolition. The petition’s reliance on the latter was misplaced and did not bar the domestic imposition or mode of capital punishment.
Delegation of Legislative Power and Separation of Functions
Court found RA 8177 sufficiently complete, setting policy, standards, conditions for execution, bodies with rule-making authority and limiting directives. Delegation to administrative agencies for procedural details was proper given the expertise required, and the Administrative Code’s assignment of prison administration to the Department of Justice justified the Secretary’s supervisory role.
Invalid Provisions in the Implementing Rules: Sections 17 and 19
Court struck down Section 17 (suspension period for women within three years of sentence) as inconsistent
...continue readingCase Syllabus (G.R. No. 132601)
Facts
- Petitioner Leo Echegaray was convicted by the Regional Trial Court of Quezon City, Branch 104, for rape of his common-law spouse’s 10-year-old daughter and sentenced to death.
- On June 25, 1996, the Supreme Court en banc affirmed his conviction and the imposition of the death penalty.
- Republic Act No. 7659 reinstated capital punishment for heinous crimes, effective December 31, 1993.
- Congress later enacted Republic Act No. 8177 (March 20, 1996), changing the method of execution from electrocution to lethal injection.
Procedural History
- Petitioner filed a Motion for Reconsideration and a Supplemental Motion raising factual issues and the constitutionality of RA 7659; both were denied on February 7, 1998.
- RA 8177’s implementing rules were promulgated by the Secretary of Justice and a Lethal Injection Manual drafted by the Bureau of Corrections.
- On March 2, 1998, petitioner sought prohibition, injunction, and/or a temporary restraining order to enjoin execution by lethal injection under RA 8177 and its rules.
- Petitioner moved to amend his petition to invoke equal protection and implead trial-court judges; the Court granted leave to amend and required respondents to comment.
- The Solicitor General filed a Comment defending the death penalty law and lethal injection; the Commission on Human Rights sought to intervene as amicus curiae.
- Petitioner filed a Reply; after due course, the Supreme Court en banc resolved the petition on the merits on October 12, 1998.
Issues Presented
- Whether execution by lethal injection under RA 8177 and its rules constitutes “cruel, degrading or inhuman punishment” prohibited by Article III, Section 19(1) of the 1987 Constitution.
- Whether the reimposition of the death penalty and lethal injection method violate the Philippines’ obligations under the International Covenant on Civil and Political Rights.
- Whether RA 8177 unduly delegates legislative power to the Secretary of Justice and the Director of the Bureau of Corrections.
- Whether the Secr