Primary Holding

The suspension of the privilege of habeas corpus does not bar a civil action for damages resulting from illegal arrests, searches, and other violations of constitutional rights. Superior officers can be held liable for such violations if they are found to be directly or indirectly responsible.

Background

The case arose from alleged illegal searches, seizures, arrests, and torture committed by the Armed Forces of the Philippines' Task Force Makabansa (TFM) under the command of General Fabian Ver, purportedly targeting communist-terrorist underground houses.

Facts

• 1. General Ver ordered Task Force Makabansa to conduct preemptive strikes against alleged communist-terrorist underground houses.
• 2. TFM members raided several places, often using defective search warrants.
• 3. Personal items were confiscated, and individuals were arrested without proper warrants.
• 4. Detainees were allegedly denied access to lawyers and relatives.
• 5. Interrogations involved threats, torture, and other forms of violence to extract information.

Arguments of the Petitioners

• 1. The suspension of habeas corpus does not eliminate the right to sue for damages caused by illegal actions.
• 2. Article 32 of the Civil Code provides a cause of action for violations of constitutional rights.
• 3. Superior officers should be held liable for the actions of their subordinates.
• 4. The motion to set aside the order of dismissal was filed on behalf of all plaintiffs.

Arguments of the Respondents

• 1. The suspension of habeas corpus bars judicial inquiry into the circumstances of detention through a damage suit.
• 2. Government officials are immune from liability for acts done in the performance of their official duties.
• 3. The complaint did not state a cause of action against the defendants.
• 4. Respondents were merely performing their constitutional duties to suppress lawless violence, insurrection, rebellion and subversion pursuant to Proclamation No. 2045.

Issues

• 1. Does the suspension of the privilege of the writ of habeas corpus bar a civil action for damages due to illegal searches and other violations of constitutional rights?
• 2. Can superior officers be held liable for the acts of their subordinates who violate constitutional rights?
• 3. Was the trial court correct in dismissing the complaint with respect to some plaintiffs based on the alleged failure to file a motion for reconsideration?

Ruling

• 1. The suspension of habeas corpus does not bar a civil action for damages for violations of constitutional rights.
• 2. Superior officers can be held liable under Article 32 of the Civil Code if they are directly or indirectly responsible for the violations.
• 3. The trial court erred in dismissing the complaint with respect to some plaintiffs based on a technicality regarding the motion for reconsideration.

Doctrines

• 1. State Immunity from Suit: This doctrine protects public officers from liability for acts done within the scope of their official duties; however, the court found that it does not apply when constitutional rights are violated.
• 2. Respondeat Superior: This doctrine holds an employer liable for the torts of an employee; the court found that the relationship between superior military officers and their subordinates does not fall under this doctrine.
• 3. Article 32 of the Civil Code: Public officers or private individuals are liable for damages if they directly or indirectly obstruct, defeat, violate, or impede constitutional rights and liberties.

Key Excerpts

• 1. "In times of great upheaval or of social and political stress...it is necessary to remind ourselves that certain basic rights and liberties are immutable and cannot be sacrificed to the transient needs or imperious demands of the ruling power."
• 2. "The Constitution remains the supreme law of the land to which all officials, high or low, civilian or military, owe obedience and allegiance at all times."
• 3. "Democracy cannot be a reign of progress, of liberty, of justice, unless the law is respected by him who makes it and by him for whom it is made."

Precedents Cited

• 1. Forbes v. Chuoco Tiaco: Distinguished, noting that the present case involves violations of constitutional rights beyond the scope of official duty.

Statutory and Constitutional Provisions

• 1. Article 32 of the Civil Code: Basis for the cause of action for damages due to violations of constitutional rights.
• 2. P.D. No. 1755: Recognizes the right and cause of action for damages arising from acts of public officers involving the exercise of powers arising from Martial Law.
• 3. Proclamation No. 2045: Lifting martial law but continuing the suspension of the privilege of the writ of habeas corpus.