Case Summary (G.R. No. 27484)
Procedural History
Lorenzo filed a writ of habeas corpus in the Court of First Instance of Manila, admitting his condition as a leper but contending the law mandating segregation is unconstitutional. The trial court upheld Section 1058, denied the writ, and refused to receive evidence on the contagiousness of leprosy. Lorenzo appealed, seeking reversal of the judgment and an opportunity to prove that leprosy is non-infectious.
Issue Presented
Does Section 1058 of the Administrative Code, authorizing compulsory segregation of lepers, violate the constitutional guarantee of due process by presuming leprosy to be an infectious disease without permitting judicial inquiry into the medical evidence?
Applicable Law
• Section 1058, Administrative Code (Philippines): Empowers health authorities to apprehend, detain, isolate, or confine leprous persons for the protection of public health.
• Principle of police power: Legislative authority to enact measures for public health and safety.
• Due process guarantee: Requires that laws depriving individuals of liberty be enacted through procedures that are not arbitrary or oppressive.
Analysis
1. Police Power and Public Health
The Legislature enacted Section 1058 under its police power to address leprosy as a serious health threat. Compulsory segregation of lepers reflects a long-recognized global practice supported by medical authorities and judicial precedents, including Jacobson v. Massachusetts (1904), which defer to legislative findings in matters of public health.
2. Legislative Fact-Finding and Judicial Deference
In statutes enacted for public health, disputed factual questions—including disease transmissibility—fall within the Legislature’s province. If a statute has any probable basis for its factual premise, courts will sustain it without re-examining conflicting scientific theories.
3. Due Process Considerations
Procedural safeguards in the statute—medical inspection, diagnostic confirmation by bacteriological methods, and the availability of confinement facilities—satisfy due process. There is no requirement for the judiciary to receive additional expert testimony to challenge the Legislature’s health-related determinations.
4. Judicial Precedents
The Court takes judicial notice that leprosy is commonly regarded as infectious
Case Syllabus (G.R. No. 27484)
Facts
- Angel Lorenzo, a diagnosed leper, was confined at the San Lazaro Hospital in Manila by health authorities.
- Lorenzo filed a petition for a writ of habeas corpus in the Court of First Instance of Manila, admitting his leprosy but contending that:
- His confinement violated his constitutional rights.
- Leprosy is not an infectious disease and therefore segregation is unwarranted.
Procedural History
- The trial court received the petition and issued the writ in its usual form.
- The Director of Health returned the writ, admitting lawful confinement under section 1058 of the Administrative Code and denying all other factual allegations not expressly admitted.
- Lorenzo did not traverse the facts admitted in the return; the court treated the uncontroverted return as conclusive on its face.
- The lower court upheld the segregation law as constitutional and denied the petition for habeas corpus.
- Lorenzo appealed to the Supreme Court en banc, seeking to compel the trial court to receive evidence on the contagiousness of leprosy.
Applicable Statutory Provision
- Article XV, chapter 37, Administrative Code (section 1058):
- Empowers the Director of Health and authorized agents to apprehend, isolate, detain, or confine all leprous persons in the Philippines.
- Provides for medical inspection, diagnostic procedures (including bacteriological confirmation), establishment of hospitals