Case Summary (G.R. No. 203478)
RTC’s Denial of Dismissal and Reconsideration
On April 23 and July 31, 2012, the RTC denied petitioners’ motion to dismiss and the subsequent motion for reconsideration. The trial court concluded that the Supreme Court had not definitively ruled on RA 9372’s constitutionality in Southern Hemisphere, and that respondents’ petition met declaratory relief requirements given their personal and substantial interests and the law’s paramount impact.
Issue on Grave Abuse of Discretion
The Supreme Court framed the central question: whether the RTC gravely abused its discretion in denying the motion to dismiss. Grave abuse of discretion implies a capricious or whimsical exercise of judgment tantamount to lack of jurisdiction. Errors of law or fact do not per se constitute grave abuse; the discretion must be patently or grossly abused.
Constitutionality Determination in Southern Hemisphere Cases
The Court observed that Southern Hemisphere did not address RA 9372’s merits. The consolidated certiorari petitions were dismissed on procedural grounds—improper remedy (certiorari), lack of locus standi, and absence of an actual case or controversy. Thus, the Supreme Court had not yet passed upon RA 9372’s constitutionality.
Requisites for Declaratory Relief
Under Rule 57, the requisites for declaratory relief are:
- The subject is a written instrument, statute, or regulation;
- Its terms or validity are doubtful and require judicial construction;
- No breach of the subject document;
- An actual justiciable controversy or “ripening seeds” of one between adverse interests;
- The issue is ripe for judicial determination;
- No adequate relief is available by other means.
Analysis of Requisites Four and Five
The Court found that while the first three requisites were present, respondents failed to establish the fourth and fifth:
• Fourth Requisite (Justiciable Controversy): Respondents articulated only speculative, generalized fears based on public remarks, without any specific threat or impending enforcement against them. Absent a real or imminent injury, no justiciable controversy or “ripening seed” existed.
• Fifth Requisite (Ripeness): The possibility of future abuse remained conjectural. A controversy is ripe only when a challenged act has directly and adversely affected the challenger; here, responde
Case Syllabus (G.R. No. 203478)
Facts of the Case
- On July 17, 2007, respondents filed a Petition for declaratory relief in RTC Quezon City, Branch 92, assailing the constitutionality of Sections 3, 7, 18, 26, and 27 of Republic Act No. 9372 (Human Security Act of 2007).
- Alleged infirmities included voidness for vagueness (Sec. 3), violation of privacy and priest-penitent privilege (Sec. 7), denial of due process and ex post facto prohibition (Sec. 18), infringement of right to travel (Sec. 26), and unreasonable searches and seizures (Sec. 27).
- Petitioners (the State, represented by the Executive Secretary, Secretaries of Justice, Foreign Affairs, National Defense, Interior and Local Government, Finance, Budget and Management, the National Security Adviser, the Treasurer, the AFP Chief of Staff, and the PNP Chief) moved to suspend RTC proceedings in deference to pending Supreme Court petitions on the same law.
Procedural History
- The RTC granted the suspension order on October 19, 2007.
- On October 5, 2010, the Supreme Court dismissed the consolidated Southern Hemisphere Engagement Network petitions on procedural grounds without ruling on constitutionality.
- Petitioners filed a motion to dismiss the RTC action on February 27, 2012, contending that (a) declaratory relief requisites were not met and (b) RA 9372 had been upheld with finality.
- Respondents opposed, arguing that the SC dismissal was technical only and that all requirements for declaratory relief were fulfilled.
- The RTC denied the motion to dismiss on April 23, 2012, and likewise denied reconsideration on July 31, 2012, finding respondents had personal and substantial interest and that an early determination served public interest.
- Petitioners elevated the matt