This particular entry was just added to the 2022 Political Law bar syllabus, particularly under the Bill of Rights (even if I think it’s better suited for Remedial Law). Does that mean that it’s going to come up? Probably, but I think the question won’t focus too much on the procedure.
So let’s talk about the substance of these remedies and their connection to the Bill of Rights.
Writ of habeas corpus
The writ of habeas corpus is a remedy in connection with a person’s right to liberty.
Basically, we use it whenever a person is illegally detained/unlawfully restrained. It can also be used to recover the custody of a person (but this purpose is likely irrelevant to Poli Law).
Sec. 1. To what habeas corpus extends. – Except as otherwise expressly provided by law, the writ of habeas corpus shall extend to all cases of illegal confinement or detention by which any person is deprived of his liberty, or by which the rightful custody of any person is withheld from the person entitled thereto.
-Rule 102
Here is an elucidating excerpt from a 2000 case:
“The high prerogative writ of habeas corpus, whose origin is traced to antiquity, was devised and exists as a speedy and effectual remedy to relieve persons from unlawful restraint, and as the best and only sufficient defense of personal freedom. It secures to a prisoner the right to have the cause of his detention examined and determined by a court of justice, and to have the issue ascertained as to whether he is held under lawful authority.”
–Feria v. CA, 2000
“Restraint that is lawful and pursuant to a court process cannot be inquired into through habeas corpus.
x x x
The object of the writ of habeas corpus is to inquire into the legality of the detention, and, if the detention is found to be illegal, to require the release of the detainee. Equally well-settled however, is that the writ will not issue where the person in whose behalf the writ is sought is out on bail, or is in the custody of an officer under process issued by a court or judge with jurisdiction or by virtue of a judgment or order of a court of record”
–Mangila v. Pangilinan, 2013
What’s tricky is how do we determine “unlawful restraint” or “illegal detention”? Let’s take a look at some cases to find out.
1. A maid being morally restrained (ergo, not physically) from leaving her employer’s house is the proper subject of a habeas corpus proceeding:
“An employment agency, regardless of the amount it may advance to a prospective employee or maid, has absolutely no power to curtail her freedom of movement. The fact that no physical force has been exerted to keep her in the house of the respondent does not make less real the deprivation of her personal freedom of movement, freedom to transfer from one place to another, freedom to choose one’s residence. Freedom may be lost due to external moral compulsion, to founded or groundless fear, to erroneous belief in the existence of an imaginary power of an impostor to cause harm if not blindly obeyed, to any other psychological element that may curtail the mental faculty of choice or the unhampered exercise of the will. If the actual effect of such psychological spell is to place a person at the mercy of another, the victim is entitled to the protection of courts of justice as much as the individual who is illegally deprived of liberty by duress or physical coercion.”
–Caunca v. Salazar, 1949
2. A person convicted of political crimes during a belligerent occupation is a proper subject of a habeas corpus proceeding once the legitimate government is restored:
“…the judgments of such court, like those of the courts which were continued during the Japanese occupation, were good and valid and remain good and valid, and therefore enforceable now after the liberation or occupation of the Philippines, provided that such judgments do not have a political complexion.”
–Alcantara v. Director of Prisons, 1945
3. Is there an unlawful restraint of liberty when a Mayor orders hundreds of alleged prostitutes to be transported away? The answer is yes:
“A prime specification of an application for a writ of habeas corpus is restraint of liberty. The essential object and purpose of the writ of habeas corpus is to inquire into all manner of involuntary restraint as distinguished from voluntary, and to relieve a person therefrom if such restraint is illegal. Any restraint which will preclude freedom of action is sufficient. The forcible taking of these women from Manila by officials of that city, who handed them over to other parties, who deposited them in a distant region, deprived these women of freedom of locomotion just as effectively as if they had been imprisoned. Placed in Davao without either money or personal belongings, they were prevented from exercising the liberty of going when and where they pleased. The restraint of liberty which began in Manila continued until the aggrieved parties were returned to Manila and released or until ithey freely and truly waived this right.”
–Villavicencio v. Lukban, 1919
4. Is habeas corpus proper when a person is arrested but the crime has already prescribed? NO. Always go back to “unlawful restraint.” If the reason for the restraint is there (warrant of arrest, valid warrantless arrest, etc.), habeas corpus is not the answer, even if the offense has prescribed. The proper remedy is a motion to quash:
“The defense of prescription of the offense charged in the information should be pleaded in the criminal action otherwise it would be deemed waived (U.S. vs. Serapio, 23 Phil. 584, 598 citing Aldeguer vs. Hoskyn, 2 Phil. 500; Domingo vs. Osorio, 7 Phil. 405; Maxilom vs. Tabotabo, 9 Phil. 390; Harty vs. Luna, 13 Phil. 31; Sunico vs. Ramirez, 14 Phil. 500). It is a proper ground for a motion to quash which should be filed before the arraignment of the accused (Secs. 1 & 2, Rule 117, 1985 Rules of Criminal Procedure; People vs. Castro, L-6407, July 29, 1954) for whether the crime may still be prosecuted and penalized should be determined in the criminal case not in a special proceeding of habeas corpus.”
–Paredes v. Sandiganbayan, 1991
5. What happens if a person was illegally arrested (no warrant of arrest and no grounds for warrantless arrest)? Can habeas corpus be proper? YES. But can he be arrested again? YES, if the judge issues a warrant for the arrest. Such is what happened with the infamous Paco Larranaga:
“The case has, indeed, become moot and academic inasmuch as the new warrant of arrest complies with the requirements of the Constitution and the Rules of Court regarding the particular description of the person to be arrested. While the first warrant was unquestionably void, being a general warrant, release of the petitioner for that reason will be a futile act as it will be followed by her immediate re-arrest pursuant to the new and valid warrant, returning her to the same prison she will just have left. This Court will not participate in such a meaningless charade.”
–Larranaga v. CA, 1998
In other words, even if you are illegally arrested, you can’t avail of the remedy of habeas corpus if subsequently there was a legal process that justifies your detention (warrant of arrest, filing of information, commitment order, etc.).
6. What about if there is already a conviction? Can habeas corpus be a proper remedy? Generally, no. But, there are exceptions:
“Concomitantly, if a person’s liberty is restrained by some legal process, the writ of habeas corpus is unavailing. The writ cannot be used to directly assail a judgment rendered by a competent court or tribunal which, having duly acquired jurisdiction, was not ousted of this jurisdiction through some irregularity in the course of the proceedings.
However, jurisprudence has recognized that the writ of habeas corpus may also be availed of as a post-conviction remedy when, as a consequence sentence as to circumstance of a judicial proceeding, any of the following exceptional circumstances is attendant: 1) there has been a deprivation of a constitutional right resulting in the restraint of a person; 2) the court had no jurisdiction to impose the sentence; or 3) the imposed penalty has been excessive, thus voiding the sentence as such excess. Here, petitioner is invoking the first circumstance.”
–In Re: The Writ of Habeas Corpus for Abellana v. Paredes, 2019
What can we learn from this case?
1. The Writ of Habeas Corpus is a remedy to relieve persons from unlawful restraint
2. Thus, it is not available as a post-conviction remedy because incarceration resulting from conviction is a lawful RESTRAINT (or a restraint by LAWFUL PROCESS).
3. However, there are exceptions. The writ of habeas corpus may be availed of as a post-conviction remedy if any of the exceptional circumstances is present:
1) there has been a deprivation of a constitutional right resulting in the restraint of a person;
2) the court had no jurisdiction to impose the sentence; or
3) the imposed penalty has been excessive, thus voiding the sentence as such excess
Take note of the 3 exceptions above. They’re great sources of questions. An example of #1 is when an accused’s constitutional right to speedy trial is violated.
The same can be said when an accused’s right to competent counsel is violated. This means that the counsel has to not only be negligent, but grossly negligent:
“In sum, the negligence and mistakes of the counsel are binding on the client, unless the counsel has committed gross negligence. For a claim of a counsel’s gross negligence to prosper, nothing short of clear abandonment of the client’s cause must be shown. As well, the gross negligence should not be accompanied by the client’s own negligence or malice.”
–In Re: The Writ of Habeas Corpus for Abellana v. Paredes, 2019
The next question is, who may file the petition?
The answer is ANYONE.
“…in a habeas corpus proceeding, any person may apply for the writ on behalf of the aggrieved party.”
–Boac v. Cadapan, 2011
This answer can be found in Sec. 3 of Rule 102.
Sec. 3. Requisites of application therefor. – Application for the writ shall be by petition signed and verified either by the party for whose relief it is intended, or by some person on his behalf, and shall set forth:
(a) That the person in whose behalf the application is made is imprisoned or restrained of his liberty;
x x x
You’ll see later on that while anyone can file the habeas corpus petition, the rules are stricter for the other extraordinary remedies.
I think that’s enough habeas corpus, the rest are mostly remedial and can be easily understood here in Rule 102.
Let’s move on to the writ of kalikasan.
Writ of kalikasan
What constitutional right does this extraordinary remedy address? The constitutional right to a balanced and healthful ecology. Is this right found in the Bill of Rights? Not particularly, but oh well.
Let’s look at probably the only legal basis we’ll need when faced with a question about the writ of kalikasan.
SECTION 1. Nature of the writ. — The writ is a remedy available to a natural or juridical person, entity authorized by law, people’s organization, non-governmental organization, or any public interest group accredited by or registered with any government agency, on behalf of persons whose constitutional right to a balanced and healthful ecology is violated, or threatened with violation by an unlawful act or omission of a public official or employee, or private individual or entity, involving environmental damage of such magnitude as to prejudice the life, health or property of inhabitants in two or more cities or provinces.
-Rule 7, Section 1 of the Rules of Procedure for Environmental Cases
Let’s break Rule 7, Section 1 down into three parts. These are actually the REQUISITES for the writ:
(1) there is an actual or threatened violation of the constitutional right to a balanced and healthful ecology
(2) the actual or threatened violation arises from an unlawful act or omission of a public official or employee, or private individual or entity
(3) the actual or threatened violation involves or will lead to an environmental damage of such magnitude as to prejudice the life, health or property of inhabitants in two or more cities or provinces
Pretty vague right? That’s intentional because the SC wants the courts to decide the gravity of the environmental damage on a case-to-case basis.
What’s important though is that the degree of environmental damage must be sufficiently grave, in terms of the territorial scope (two or more cities or provinces) of such damage, so as to call for the grant of this extraordinary remedy.
This “two or more cities or provinces” requirement is probably the easiest to incorporate into a bar problem. Requirement #2 may also be a good source of questions. Note that the violation must arise from an unlawful act or omission of a public official/employee or private individual/entity. If the act is lawful, then the petition for the writ of kalikasan will not prosper.
A possible bar question: Is an irregular issuance of an Environmental Compliance Certificate (ECC) regarded as an “unlawful act or omission” and can thus be the basis for the filing of a petition for the writ? YES! But that only satisfies the 2nd requisite, the first and third should also be satisfied. Thus, the irregular ECC issuance must be connected to the actual or threatened violation:
“A party, therefore, who invokes the writ based on alleged defects or irregularities in the issuance of an ECC must not only allege and prove such defects or irregularities, but must also provide a causal link or, at least, a reasonable connection between the defects or irregularities in the issuance of an ECC and the actual or threatened violation of the constitutional right to a balanced and healthful ecology of the magnitude contemplated under the Rules.”
–Paje v. Casiño, 2015
Now, who can file a petition for the writ of kalikasan? Virtually anyone:
1. natural or juridical person
2. entity authorized by law
3. people’s organization
4. non-governmental organization
5. any public interest group accredited by or registered with any government agency
But take note of #5! The public interest group has to be accredited or registered with any government agency. This can be a simple but tricky bar question. It was also highlighted in a case.
In a 2019 case, the SC (through Justice Leonen), reminded environmental advocates to always SUBSTANTIATE their petitions for the writ of kalikasan. This may also be a good source of questions for the bar. If a petition is not substantiated, remember this:
“The imminence or emergency of an ecological disaster should not be an excuse for litigants to do away with their responsibility of substantiating their petitions before the courts. As with any special civil action for extraordinary writs, parties seeking the writ of kalikasan must be ready with the evidence required to prove their allegations by the time the petition is filed. Hasty slipshod petitions, filed in the guise of environmental advocacy, only serve to undermine that advocacy.”
–Abogado v. DENR, 2019
Check out the case above if you want a thorough lecture on the writ of kalikasan.
You can also check out the Rules of Procedure for Environmental Cases for the rest of the remedial aspect of the writ. I think they won’t be essential for Poli purposes, but it doesn’t hurt to read more.
Writ of amparo
We’ll first tackle amparo before habeas data.
The writ of amparo gained notoriety during a past bar exam (I can’t remember the year, but it was in the 1990s) when it shocked the bar takers. It was not in the syllabus (if there was a syllabus at that time), it was not discussed in law school, and it was not even implemented in our jurisdiction.
Luckily for batch 2022, we’re warned ahead of time, so let’s take advantage of that.
The basis for our following discussion will only be two things: The Rule on the Writ of Amparo (A.M. No. 07-9-12-SC) and jurisprudence.
Let’s start with Sec. 1 of the Rule:
SECTION 1. Petition. – The petition for a writ of amparo is a remedy available to any person whose right to life, liberty and security is violated or threatened with violation by an unlawful act or omission of a public official or employee, or of a private individual or entity. The writ shall cover extralegal killings and enforced disappearances or threats thereof.
Section 1 talks about the coverage of the writ. In short, it answers the question, “When is it available?”
If I’m a bar examiner, I’ll take my question from this section. Why? It’s basic but can also be a little confusing, perfect for the so-called “rigor” promised by Justice Caguioa.
Anyway, let’s break it down into three (3) parts:
1. The right to life, liberty, and security is violated or threatened
2. by an unlawful act or omission of a public official or employee, or of a private individual or entity
3. The writ shall cover extralegal killings and enforced disappearances or threats thereof
We’ll need these in case the question is: Will the writ of amparo prosper?
The first requisite is understandable: THE RIGHT TO LIFE, LIBERTY, AND SECURITY IS VIOLATED OR THREATENED. If there’s a question related to this, most probable it will involve a danger posed to a person’s property. In that case, we can already know that the writ of amparo will not prosper. What about the violation of the right to travel? It does fall under the right to liberty, right? We’ll know the answer later.
The second requisite is a little confusing. We can understand the first clause (by an unlawful act or omission of a public official or employee) as one where the violator is a state actor. But what about the second clause (or of a private individual or entity)? Does it mean that the writ of amparo can prosper if brought against private individuals in their private capacity? The SC answered NO. Our basis is jurisprudence, specifically the case between the Santiagos and the Tulfo brothers.
Simply put, a petition for a writ of amparo must show GOVERNMENT PARTICIPATION, direct or indirect:
“Their petition is merely anchored on a broad invocation of respondents’ purported violation of their right to life and security, carried out by private individuals without any showing of direct or indirect government participation. Thus, it is apparent that their amparo petition falls outside the purview of A.M. No. 07-9-12-SC and, perforce, must fail.”
–Sps. Santiago v. Tulfo, 2015
The third part is also confusing if we only look at the letter of the law. “The writ shall cover extralegal killings and enforced disappearances or threats thereof,” does this mean that the writ of amparo is limited to extralegal killings and enforced disappearances? Or are these two cases only an example of the writ’s coverage? These are legitimate questions.
The SC has categorically said that it is limited to the two situations mentioned. It was first pronounced in the 2008 case of Secretary of National Defense of National Defense v. Manalo. Then, the 2015 case of Mison v. Gallegos which said:
“This pronouncement on the coverage of the writ was further cemented in the latter case of Lozada, Jr. v. Macapagal-Arroyo where this Court explicitly declared that as it stands, the writ of amparo is confined only to cases of extrajudicial killings and enforced disappearances, or to threats thereof.”
That’s at least three pieces of jurisprudence telling us the limitation of amparo‘s coverage. But wait, Justice Leonen, the maverick that he is, offered a different interpretation in a 2019 case:
“The writ of amparo is, thus, an equitable and extraordinary remedy primarily meant to address concerns such as, but not limited to, extrajudicial killings and enforced disappearances, or threats thereof.”
–IN THE MATTER OF PETITION FOR WRIT OF AMPARO OF VIVIAN A. SANCHEZ, 2019
Justice Leonen just had to insert that “but not limited to” lol. I’m inclined to follow his interpretation, but the case above just had too many dissents and we have tons of cases before that spoke of amparo‘s limited coverage. In short, it’s safer to stick with the stricter interpretation. Maybe in the future Justice Leonen’s liberal interpretation becomes the norm. But I think it will not be today.
The limited coverage is the reason why amparo cannot protect the right to travel (Hold Departure Order case, for example) even if it falls under the right to liberty.
If there is no extralegal killing or enforced disappearance involved, then sorry na lang. There are other remedies available, it will just not be the writ of amparo.
To recap, for a writ of amparo to prosper:
1. You need a violation or a threat to the right to LIFE, LIBERTY, or SECURITY
2. You need GOVERNMENT PARTICIPATION, direct or indirect
3. You need to have a connection to EXTRALEGAL KILLINGS or ENFORCED DISAPPEARANCES or threats thereof
How do you identify if there is an extralegal killing or an enforced disappearance?
Extralegal killing is easy.
“‘Extralegal killings’ are ‘killings committed without due process of law, i.e., without legal safeguards or judicial proceedings.'”
–Secretary of National Defense v. Manalo, 2008
Now, what about enforced disappearance?
“Meaning, in probing enforced disappearance cases, courts should read A.M. No. 07-9-12-SC in relation to RA No. 9851. From the statutory definition of enforced disappearance, thus, we can derive the following elements that constitute it:
(a) that there be an arrest, detention, abduction or any form of deprivation of liberty;
(b) that it be carried out by, or with the authorization, support or acquiescence of, the State or a political organization;
(c) that it be followed by the State or political organization’s refusal to acknowledge or give information on the fate or whereabouts of the person subject of the amparo petition; and,
(d) that the intention for such refusal is to remove subject person from the protection of the law for a prolonged period of time.”
–Navia v. Pardico, 2012
What’s important in the above definition is the “refusal to acknowledge or give information on the fate or whereabouts of…” This is an issue in the case of Mison v. Gallegos (2015):
“Indeed, Ku was arrested by agents of the BI, but there was no refusal on the part of the BI to acknowledge such arrest nor was there any refusal to give information on the whereabouts of Ku. Neither can it be said that the BI had any intention to remove Ku from the protection of the law for a prolonged time.”
Let’s now move on to WHO MAY FILE.
SECTION 2. Who May File. The petition may be filed by the aggrieved party or by any
qualified person or entity in the following order:
(a) Any member of the immediate family, namely: the spouse, children and parents of
the aggrieved party;
(b) Any ascendant, descendant or collateral relative of the aggrieved party within the
fourth civil degree of consanguinity or affinity, in default of those mentioned in the
preceding paragraph; or
(c) Any concerned citizen, organization, association or institution, if there is no known
member of the immediate family or relative of the aggrieved party.
The filing of a petition by the aggrieved party suspends the right of all other authorized parties to file similar petitions. Likewise, the filing of the petition by an authorized party on behalf of the aggrieved party suspends the right of all others, observing the order established herein.
Section 2 is a clear-cut provision. Take note of the order. It should be observed, or else the petition will get thrown out.
“Indeed, the parents of Sherlyn and Karen failed to allege that there were no known members of the immediate family or relatives of Merino. The exclusive and successive order mandated by the above-quoted provision must be followed. The order of priority is not without reason – ‘to prevent the indiscriminate and groundless filing of petitions for amparo which may even prejudice the right to life, liberty or security of the aggrieved party.’“
–Boac v. Cadapan, 2011
This is unlike habeas corpus proceedings where anyone can file the petition:
“…in a habeas corpus proceeding, any person may apply for the writ on behalf of the aggrieved party.”
–Boac v. Cadapan, 2011
As for the rest of the amparo rules, you can just check it out here. I’m not going to discuss it because that may be a better fit for Remedial Law. The substance of the writ of amparo for Political Law purposes (in my opinion) can be found in Sec. 1.
And for a matrix of comparison for Habeas Data v. Habeas Corpus v. Amparo, check out this link.
Writ of habeas data
If the writ of amparo is concerned about the right to life, liberty, and security, the writ of habeas data is concerned about the right to privacy.
“The writ of habeas data was conceptualized as a judicial remedy enforcing the right to privacy, most especially the right to informational privacy of individuals. The writ operates to protect a person’s right to control information regarding himself, particularly in the instances where such information is being collected through unlawful means in order to achieve unlawful ends.”
–IN THE MATTER OF THE PETITION FOR THE WRIT OF AMPARO AND THE WRIT OF HABEAS DATA IN FAVOR OF MELISSA C. ROXAS, 2010
But just like the writ of amparo, habeas data‘s requisites involve life, liberty, and security. It’s just that it is focused on the violation of privacy in these three rights and not a violation of the rights themselves.
Section 1. Habeas Data. – The writ of habeas data is a remedy available to any person
whose right to privacy in life, liberty or security is violated or threatened by an unlawful act or omission of a public official or employee, or of a private individual or entity engaged in the gathering, collecting or storing of data or information regarding the person, family, home and correspondence of the aggrieved party.
–The Rule on the Writ of Habeas Data, A. M. No. 08-1-16-SC, 2008
Section 1 gives us the requisite, but it’s not going to be a list. Rather, just remember this:
“Thus, in order to support a petition for the issuance of such writ, Section 6 of the Habeas Data Rule essentially requires that the petition sufficiently alleges, among others, “[t]he manner the right to privacy is violated or threatened and how it affects the right to life, liberty or security of the aggrieved party.”
In other words, the petition must adequately show that there exists a nexus between the right to privacy on the one hand, and the right to life, liberty or security on the other.”
–Lee v. Ilagan, 2014
Thus, even if there may be a violation of a person’s right to privacy, the violation (or threat of violation) has to be connected with the right to life, liberty, or security.
In the case above, it involves a couple of live-in partners. One found a digital camera with sex videos of the other. The one who found it won’t return the camera. Thus, the other one filed a petition for a writ of habeas data. As we can see, even if the right to privacy was violated, there seems to be no nexus between the violation and the right to life, liberty, or security of the other. But this is because there seems to be no substantial evidence. It may have been another story if there was enough proof that the one who found the sex videos threatened to spread them to destroy the other’s reputation.
But one important question is: If life, liberty, or security, is involved, does it mean that the writ of habeas data is confined only to extralegal killings and enforced disappearances just like amparo?
The answer is NO! This can be inferred from Section 2.
Sec. 2. Who May File. – Any aggrieved party may file a petition for the writ of habeas data. However, in cases of extralegal killings and enforced disappearances, the petition may be filed by:
(a) Any member of the immediate family of the aggrieved party, namely: the spouse, children and parents; or
(b) Any ascendant, descendant or collateral relative of the aggrieved party within the fourth civil degree of consanguinity or affinity, in default of those mentioned in the preceding paragraph. (emphasis supplied)
“Had the framers of the Rule intended to narrow the operation of the writ only to cases of extralegal killings or enforced disappearances, the above underscored portion of Section 2, reflecting a variance of habeas data situations, would not have been made.”
–Vivares v. St. Theresa’s College, 2014
And since we’re already on Section 2, note that the order of “who may file” should be followed ONLY if the case involves extralegal killings or enforced disappearances. If it does not fall under these two categories, ANYONE can file. This can also be a good, simple, tricky bar question.
This is basically the substance of the writ of habeas data. Any other matter is more suited for Remedial Law and I’m sure you have your reviewers for that.
So that’s it for these extraordinary writs. Just remember the basics and read the cases mentioned because these may be the basis for bar exam questions. Also, don’t forget the matrix we linked at the end of the amparo discussion.
To Recap:
1. Habeas corpus: Right to liberty, specifically unlawful restraint.
-If there is no unlawful restraint (warrant of arrest, valid warrantless arrest, invalid warrantless arrest but with a proper warrant later on issued, court order, etc.), the petition will not prosper.
-Cannot be a post-conviction remedy, except if there is 1) a deprivation of a constitutional right resulting in the restraint of a person, 2) the court had no jurisdiction to impose the sentence, 3) the imposed penalty has been excessive.
2. Kalikasan: Right to a balanced and healthful ecology.
-Three requisites:
(1) there is an actual or threatened violation of the constitutional right to a balanced and healthful ecology
(2) the actual or threatened violation arises from an unlawful act or omission of a public official or employee, or private individual or entity
(3) the actual or threatened violation involves or will lead to an environmental damage of such magnitude as to prejudice the life, health or property of inhabitants in two or more cities or provinces
3. Amparo: Right to life, liberty, security
Requisites
1. You need a violation or a threat to the right to LIFE, LIBERTY, or SECURITY
2. You need GOVERNMENT PARTICIPATION, direct or indirect
3. You need to have a connection to EXTRALEGAL KILLINGS or ENFORCED DISAPPEARANCES or threats thereof
4. Habeas data: Right to privacy in life, liberty, security
-There must be a nexus between the actual or threatened violation of the right to privacy and the right to life, liberty, security
-not confined to extralegal killings or enforced disappearances
Next, instead of continuing with the Legislative Department, I’ll first make a survey of Labor Law bar exam questions from 2009-2019.
The Bartender 
Thank you, Atty. for this matterial.
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