Title
Spouses Santiago vs. Tulfo
Case
G.R. No. 205039
Decision Date
Oct 21, 2015
A physical altercation at NAIA led to threats and a petition for a writ of amparo, dismissed as it lacked government involvement and fell outside the writ's scope.

Case Summary (G.R. No. 205039)

Factual Background and Incident

On May 6, 2012, at approximately 11:40 a.m., petitioners Rozelle Raymond Martin and Claudine Margaret Santiago had just arrived at Ninoy Aquino International Airport Terminal 3 (NAIA 3) on a Cebu Pacific Airlines flight from a vacation. While addressing a complaint about their offloaded baggage at the airline’s complaint desk, a man later identified as Ramon "Mon" Tulfo took photos of Claudine without consent using his cell phone. Upon confrontation, Mon allegedly physically attacked Raymart and Claudine, leading to a physical altercation involving petitioners, Mon, and a third party, Edoardo Benjamin Atilano. The airport security intervened and transferred the parties to the Airport Police Department for investigation.

Following the altercation, respondents Raffy, Ben, and Erwin Tulfo—the brothers of Mon—broadcasted derogatory comments and threats against petitioners via their television program, provoking fear and prompting the petitioners to file a petition for writ of amparo on May 11, 2012.

Petition for Writ of Amparo and RTC Proceedings

Petitioners sought protection from respondents alleging violations and threats against their rights to life, liberty, and security. On May 23, 2012, respondent Erwin Tulfo filed a Manifestation and Motion to Deny Issuance of a Protection Order or Dismiss the Petition, which petitioners opposed as a prohibited pleading. The then presiding Judge Bayani Vargas issued a Temporary Protection Order (TPO) on May 24, 2012, but later retired. On July 11, 2012, Judge Maria Filomena Singh assumed jurisdiction.

In a Resolution dated August 6, 2012, the RTC dismissed the amparo petition and dissolved the TPO, reasoning that the petition did not fit the proper scope of a writ of amparo, which is designed solely for cases involving extrajudicial killings, enforced disappearances, or threats thereof. The court ruled that it lacked authority to issue the writ in favor of petitioners as the case did not fall within the parameters set by the Amparo Rule. The RTC considered that while the May 23 motion was a prohibited pleading, the court held discretionary authority to dismiss the case motu proprio to prevent prolonged and futile proceedings.

Petitioners' motion for reconsideration was denied on January 7, 2013, prompting the appeal to the Supreme Court.

Issue Presented

Whether the RTC erred in dismissing the petitioners’ writ of amparo petition on grounds that it was improperly filed outside the scope of cases qualifying for relief under the writ of amparo rules.

Petitioners' Contentions

Petitioners argued that the writ of amparo is not limited exclusively to extrajudicial killings, enforced disappearances, or their threats. They asserted that violations or threats to the rights to life, liberty, and security, even absent these specific conditions, should be protectable under the writ of amparo. They insisted on the impropriety of the May 23, 2012 motion as a prohibited pleading that should not have been entertained by the court.

Supreme Court’s Legal Analysis and Ruling

The Court upheld the dismissal of the amparo petition, referring principally to its landmark ruling in Secretary of National Defense v. Manalo, which clarified the scope and nature of the writ of amparo as formulated in A.M. No. 07-9-12-SC. Under this procedural rule, the writ of amparo is exclusively designed to redress and prevent extrajudicial killings and enforced disappearances, or threats thereto.

The Court elaborated on the legal nature of the writ, tracing its origin to Mexican constitutional law, emphasizing its intent as a special and extraordinary remedy narrowly confined to safeguarding constitutional rights against grave abuses, particularly those implicating the State’s direct or indirect participation.

It cited the statutory definition under Republic Act No. 9851 for enforced disappearances, emphasizing that an essential element is the involvement or acquiescence of the State or political organization with a refusal to acknowledge the deprivation of liberty. Similarly, the concept of extrajudicial killings implicates State responsibility.

The Court explained that to invoke a writ

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