Cases for Human Rights Law

1. Laguna Lake Devt Authority vs CA 231 SCRA 202

2. Kaisahan ng Manggagawa v. Gotamco Saw Mill

(GR No. L-1573, 29 March 1948)
Facts: The Kaisahan ng Manggagawa ng Kahoy sa Pilipinas declared a strike against Gotamco
Saw Mill because the latter did not accede to the formers request of a salary increase. While the
case was being heard by the Court of Industrial Relations, the parties reached a temporary wage
arrangement and the workers were ordered to go back to work while the saw mill was ordered to
increase the salaries of the workers by P2.00, let them take home small pieces of lumber to be
utilized as firewood, and was enjoined from laying-off, suspending, or dismissing any laborer
affiliated with the petitioning union. Conversely, the workers were enjoined from staging walk-outs
or strikes during the pendency of the hearing. Gotamco Saw Mill subsequently filed an urgent
motion asking that the petitioning union be held in contempt of court for having staged a strike
during the pendency of the main case, for picketing on the premises of the saw mill, and for grave
threats which prevented the remaining laborers from working. The union alleged that one of its
representatives conferred with the management of the saw mill, but instead of entertaining their
grievances, the saw mill ordered the stoppage of the work and employed four new Chinese
laborers without express authority of the court and in violation of Section 19 of Commonwealth Act
No. 103. The CIR ruled that there was a violation of the previous order of the CIR by the union,
which warranted the commencement of contempt proceedings and that the saw mill did not
violate Section 19 of CA 103.
Issue: W/N Section 19 of CA 103 is unconstitutional for being in violation of the
organic proscription of involuntary servitude.
Ruling: NO. Section 19 of CA 103 does not offend against the constitutional inhibition proscribing
involuntary servitude. The provisions of CA 103 were inspired by the constitutional injunction
making it the concern of the State to promote social justice to insure the well-being and economic
security of all the people. In order to attain this object, Section 19 was promulgated which grants to
labor what it grants to capital and denies to labor what it denies to capital. Among other things,
Section 19 lays down the implied condition that when any dispute between the employer or
landlord and the employee, tenant or laborer has been submitted to the CIR for settlement or
arbitration, pursuant to the provisions of the Act, and pending award or decision by it, the
employee, tenant or laborer shall not strike or walk out of his employment when so joined by the
court after hearing and when public interest so requires, and if he has already done so, that he
shall forthwith return to it, upon order of the court, which shall be issued only after hearing when
public interest so requires or when the dispute cannot, in its opinion, be promptly decided or
settled. Thus, the voluntariness of the employees entering into such a contract of employment he
has a free choice between entering into it or not with such an implied condition, negatives the
possibility of involuntary servitude ensuing.
Issue: W/N the previous order of the CIR, which ordered the union laborers to go back to work,
is unconstitutional for being in violation of the organic proscription of involuntary servitude.

Ruling: NO. The order of the court was for the striking workers to return to their work. That order
was made after hearing, and Section 19 of CA 103 authorizes such order when the dispute
cannot in its opinion be promptly decided or settled. The very impossibility of prompt decision or
settlement of the dispute confers upon the CIR the power to issue the order for the reason that the
public has an interest in preventing undue stoppage or paralyzation of the wheels of industry.

Several laws promulgated which apparently infringe the human rights of individuals were
subjected to regulation by the State basically in the exercise of its paramount police power.
From Justice Perfectos concurring and dissenting opinion: If the laborers should feel that they are
compelled against their will to perform something which is repugnant to their conscience or dignity,
they need not resort to any court action to seek judicial settlement of the controversy, as they can
resign from their work and there is no power that can compel them to continue therein.
3. People v. Galit
(GR No. L-51770, 20 March 1985)
Facts: Francisco Galit was picked up by the Montalban police on suspicion for the killing of Mrs.
Natividad Francisco, a widow. After he was taken by the Montalban police, the case was referred
to the National Bureau of Investigation in view of the alleged limited facilities of the Montalban
police station. Accordingly, Galit was brought to the NBI where he was investigated by a team
headed by NBI Agent Carlos Flores. The following day, Galit voluntarily executed a Salaysay
admitting participation in the commission of the crime, also implicating Juling and Pabling Dulay as
his companions in its commission. As a result, he was charged with the crime of Robbery with
Homicide before the Circuit Trial Court of Pasig. During trial, a witness stated that he overheard
Galit quarrelling with his wife about his intention to leave their residence immediately because he
and his two companions robbed and killed Natividad Fernando. On the other hand, Galit denied
participation in the commission of the crime and also assailed the admissibility of the extrajudicial
confession extracted from him through torture, force and intimidation. He recounted that he was
mauled and tortured by the NBI officers by covering his face with a rag and pushing his face into a
toilet bowl full of human waste. He had no counsel when the confession was extracted from him.
He admitted what the investigating officers wanted him to admit and he signed the confession they
prepared. Later, against his will, he posed for pictures as directed by his investigators, purporting it
to be a re-enactment. This notwithstanding, the trial court found Galit guilty and sentenced him to
suffer the death penalty.
Issue: W/N Francisco Galit should be acquitted on the ground that his extrajudicial confession is
inadmissible.
Ruling: YES. The evidence presented by the prosecution does not support a conviction. In fact,
the findings of the trial court relative to the acts attributed to the accused are not supported by
competent evidence. There were no eyewitnesses, no property recovered from the accused, no
state witnesses, and not even fingerprints of the accused at the scene of the crime. The only

evidence against the accused is his alleged confession. The alleged confession and the pictures
of the supposed re-enactment are inadmissible as evidence because they were obtained in a
manner contrary to law. Galit acquitted.
Issue: How is the inadmissibility of the extrajudicial confession shown?
Ruling: Through the statement itself. The first question was a very long Tagalog question followed
by a monosyllabic answer. It does not satisfy the requirements of the law that the accused be
informed of his rights under the Constitution and our laws. Instead, there should be several short
and clear questions and every right explained in simple words in a dialect or language known to
the person under investigation. The accused is from Samar and there is no showing that he
understands Tagalog. Moreover, at the time of his arrest, the accused was not permitted to
communicate with his lawyer, a relative, or a friend. In fact, his sisters and other relatives did not
know that he had been brought to the NBI for investigation and it was only about two weeks after
he had executed the Salaysay that his relatives were allowed to visit him. His statement does
not even contain any waiver of right to counsel and yet during the investigation he was not assisted
by one. At the supposed reenactment, again accused was not assisted by the counsel of his
choice. These constitute gross violation of his rights.

The correct procedure for peace officers to follow when making an arrest and in conducting a
custodial investigation, according to Morales v. Ponce Enrile: At the time the person is
arrested, it shall be the duty of the arresting officer to inform him of the reason of the
arrest and he must be shown the warrant of arrest, if any. He shall be informed of his
constitutional right to remain silent and to counsel, and that any statement he might make could be
used against him. The person arrested shall have the right to communicate with his lawyer, a
relative, or anyone he chooses by the most expedient meansby telephone if possibleor by letter
or messenger. It shall be the duty of the arresting officer to see that this is accomplished. No
custodial investigation shall be conducted unless it be in the presence of counsel engaged by the
person arrested, by any person on his behalf, or appointed by the court upon petition either of the
detainee himself or by anyone on his behalf. The right to counsel may be waived but the waiver
shall not be valid unless made with the assistance of counsel. Any statement obtained in violation
of the procedure herein laid down, whether exculpatory or inculpatory, in whole or in part, shall be
inadmissible in evidence.
4. VICTOR BOROVSKY VS. THE COMMISSIONER OF IMMIGRATION AND THE
DIRECTOR OF PRISONS (G.R. No. L-4352 September 28, 1951)
FACTS: Victor A. Borovsky, petitioner, claims to be a stateless citizen, born in
Shanghai, China, of Russian parentage. He came to the Philippines in 1936 and had
resided herein ever since, if the period of his detention be included.
On June 24, 1946, by order of the Commissioner of immigration of the Philippines
the petitioner was arrested for investigation as to his past activities. A warrant for
deportation was issued by the Deportation Board on the grounds that he has been
found to be an undesirable alien, a vagrant and habitual drunkard.

Petitioner was deported to China but he was not provided with an entry visa because
he was not a a national of China. He was therefore brought back to Manila and was
confined to the new Bilibid Prison in Muntinlupa. On December 8, 1947, was granted
provisional release by the President through Secretary of Justice for a period of six
months. Before the expiration of that period, the Immigration department rearrested
him and brought him to Cebu for the purpose of placing him on board a Russian
vessel carrying out the deportation order issued against him. However, said
deportation failed to materialize as the captain of the ship refused to take him on
board without permission from the Russian government. As such, petitioner was
again detained. The Immigration Officials however alleged that while in detention,
they have been taking steps regarding the disposition of those foreigners subject to
deportation while awaiting availability of transportation or arrangements to the place
where they may be sent.
Petitioner then filed for a writ of habeas corpus to which the court denied as mainly
on the ground that such detention was merely temporary. Over two years had
elapsed since the decision was promulgated, but still the Government had not found
ways and means of removing the petitioner out of the country. Hence this second
petition for writ of habeas corpus.
ISSUE: WON petitioner be continuously detained without a fix period pending
deportation
HELD: NO.
Aliens illegally staying in the Philippines have no right of asylum therein (Soewapadji
vs. Wixon, Sept. 13, 1946, 157 F. ed., 289, 290), even if they are "stateless," which
the petitioner claims to be. Foreign nationals, not enemy, against whom no criminal
charges have been formally made or judicial order issued, may not indefinitely be
kept in detention. The protection against deprivation of liberty, without due process
of law and except for crimes committed against the laws of the land is not limited to
Philippine citizens but extends to all residents, except enemy aliens, regardless of
nationality. Whether an alien who entered the country in violation of its immigration
laws may be detained for as long as the Government is unable to deport him, is
beside the point and we need not decide. There is no allegation that the petitioner's
entry into the Philippines was not lawful; on the contrary, the inference from the
pleadings and the Deportation Board's findings is that he came to and lived in this
country under legal permit.
Moreover, by its Constitution (Art. II, sec. 3) the Philippines "adopts the generally
accepted principles of international law as part of the law of Nation." And in a
resolution entitled "Universal Declaration of Human Rights" and approved by the

General Assembly of the United Nations of which the Philippines is a member, at its
plenary meeting on December 10, 1948, the right to life and liberty and all other
fundamental rights as applied to all human beings were proclaimed. lt was there
resolved that "All human beings are born free and equal in degree and rights" (Art.
1); that "Everyone is entitled to all the rights and freedom set forth in this
Declaration, without distinction of any kind, such as race, colour, sex, language,
religion, political or other opinion, nationality or social origin, property, birth, or other
status (Art. 2) ; that "Everyone has the right to an effective remedy by the competent
national tribunals for acts violating the fundamental rights granted him by the
Constitution or by law" (Art. 8); that "No one shall be subjected to arbitrary arrest,
detention or exile" (Art. 9) etc.