Case Summary (G.R. No. 211362)
Key Dates
- July 2011: Ilagan notices his digital camera missing after visiting Lee’s residence.
- August 23, 2011: Lee confronts Ilagan with the sex video.
- June 22, 2012: Ilagan files a petition for the writ of habeas data.
- June 25, 2012: RTC issues the writ, directing Lee to produce the camera’s memory card and video copies.
- August 30, 2012: RTC grants the writ, orders return of video copies, and enjoins further reproduction.
- October 8, 2014: Supreme Court renders decision on petition for review.
Applicable Law
- 1987 Philippine Constitution, Article III, Section 3 (right to privacy) and Section 1 (due process).
- A.M. No. 08-1-16-SC (Rule on the Writ of Habeas Data), defining the remedy for violations of informational privacy by public or private entities engaged in collecting, storing, or disseminating personal data.
Procedural History
- Ilagan petitions the Regional Trial Court (RTC) for issuance of the writ of habeas data, alleging violation of his right to privacy by Lee’s reproduction and threatened dissemination of the video.
- RTC issues the writ, compelling Lee to produce the original and copies of the video.
- Lee’s verified return admits possession and reproduction of the video solely as evidence in criminal (RA 9262) and administrative complaints against Ilagan, and contends the writ was sought to suppress adverse evidence.
- RTC, finding a prima facie violation of Ilagan’s informational privacy, grants relief and enjoins further reproduction of the video.
- Lee appeals via petition for review on certiorari before the Supreme Court.
Issue
Whether the RTC correctly extended the privilege of the writ of habeas data in favor of Ilagan by ordering the return of the video and memory card.
Court’s Analysis
Nature and Scope of the Writ
- Habeas data protects the right to confidentiality and control over personal data, requiring a petition to allege an unlawful act or omission affecting life, liberty, or security through data collection, storage, or dissemination.
Nexus Requirement
- The petition must demonstrate how the threatened or actual processing of data (the subject video) infringes on the petitioner’s life, liberty, or security, beyond mere privacy interest.
Substantial Evidence
- Section 6 of the Habeas Data Rule mandates that allegations be supported by substantial evidence, not merely self-serving statements, to prove an illicit or threatening act by the respondent.
Application to the Case
- Ilagan failed to explain how Lee’s reproduction or threatened use of the video jeopardized his life, liberty, or security.
- No overt acts or credible threats were shown to support an imminent or actu
Case Syllabus (G.R. No. 211362)
Facts
- Dr. Joy Margate Lee and Police Superintendent Neri A. Ilagan were former common-law partners from 2003 until August 2011.
- In July 2011, Ilagan visited Lee’s condominium, rested, then left for work; upon arrival at his office, he discovered his digital camera was missing.
- On August 23, 2011, Lee confronted Ilagan at his office with a purported sex video retrieved from the camera, allegedly showing Ilagan and another woman; Ilagan denied its authenticity and demanded the camera’s return.
- During the office confrontation, Ilagan allegedly slammed Lee’s head against a wall before departing.
- Lee retained the camera’s memory card, reproduced the sex video, and subsequently used it to file:
- A criminal complaint under Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004) before the Makati City Prosecutor.
- An administrative complaint for grave misconduct with the National Police Commission (NAPOLCOM).
Petition for Writ of Habeas Data
- On June 22, 2012, Ilagan filed a Petition for Issuance of the Writ of Habeas Data in the Regional Trial Court (RTC) of Quezon City, Branch 224.
- He alleged that Lee’s reproduction and threatened dissemination of the video violated his rights to life, liberty, security, and privacy—and likewise infringed on the privacy of the other woman depicted.
RTC Proceedings and Decision
- The RTC found the petition prima facie meritorious and, on June 25, 2012, issued th