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Freedomof Expression Case

Freedomof Expression Case

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Published by: Jolet Paulo Dela Cruz on Mar 15, 2013
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IGLESIA NI CRISTO VS. COURT OF APPEALS [259 SCRA 529; G.R. NO.

119673; 26 JUL 1996] Facts: Petitioner has a television program entitled "Ang Iglesia ni Cristo" aired on Channel 2 every Saturday and on Channel 13 every Sunday. The program presents and propagates petitioner's religious beliefs, doctrines and practices often times in comparative studies with other religions. Petitioner submitted to the respondent Board of Review for Moving Pictures and Television the VTR tapes of its TV program Series Nos. 116, 119, 121 and 128. The Board classified the series as "X" or not for public viewing on the ground that they "offend and constitute an attack against other religions which is expressly prohibited by law." On November 28, 1992, it appealed to the Office of the President the classification of its TV Series No. 128 which allowed it through a letter of former Executive Secretary Edelmiro A. Amante, Sr., addressed for Henrietta S. Mendez reversing the decision of the respondent Board. According to the letter the episode in is protected by the constitutional guarantee of free speech and expression and no indication that the episode poses any clear and present danger. Petitioner also filed Civil Case. Petitioner alleged that the respondent Board acted without jurisdiction or with grave abuse of discretion in requiring petitioner to submit the VTR tapes of its TV program and in x-rating them. It cited its TV Program Series Nos. 115, 119, 121 and 128. In their Answer, respondent Board invoked its power under PD No. 19861 in relation to Article 201 of the Revised Penal Code. The Iglesia ni Cristo insists on the literal translation of the bible and says that our (Catholic) veneration of the Virgin Mary is not to be condoned because nowhere it is found in the bible. The board contended that it outrages Catholic and Protestant's beliefs. RTC ruled in favor of petitioners. CA however reversed it hence this petition. Issue: Whether or Not the "ang iglesia ni cristo" program is not constitutionally protected as a form of religious exercise and expression. Held: Yes. Any act that restrains speech is accompanied with presumption of invalidity. It is the burden of the respondent Board to overthrow this presumption. If it fails to discharge this burden, its act of censorship will be struck down. This is true in this case. So-called "attacks" are mere criticisms of some of the deeply held dogmas and tenets of other religions. RTC’s ruling clearly suppresses petitioner's freedom of speech and interferes with its right to free exercise of religion. “attack” is different from “offend” any race or religion. The respondent Board may disagree with the criticisms of other religions by petitioner but that gives it no excuse to interdict such criticisms, however, unclean they may be. Under our constitutional scheme, it is not the task of the State to favor any religion by protecting it against an attack by another religion. Religious dogmas and beliefs are often at war and to preserve peace among their followers, especially the fanatics, the establishment clause of freedom of religion prohibits the State from leaning towards any religion. Respondent board cannot censor the speech of petitioner Iglesia ni Cristo simply because it attacks other religions, even if said religion happens to be the most numerous church in our country. The basis of freedom of religion is freedom of thought and it is best served by encouraging the marketplace of dueling ideas. It is only where it is unavoidably necessary to prevent an immediate and grave danger to the security and welfare of the community that infringement of religious freedom may be justified, and only to the smallest extent necessary to avoid the danger. There is no showing whatsoever of the type of harm the tapes will bring about especially the gravity and imminence of the threatened harm. Prior restraint on speech, including religious speech, cannot be justified by hypothetical fears but only by the showing of a substantive and imminent evil. It is inappropriate to apply the clear and present danger test to the case at bar because the issue involves the content of speech and not the time, place or manner of speech. Allegedly, unless the speech is first allowed, its impact cannot be measured, and the causal connection between the speech and the evil apprehended cannot be established. The determination of the question as to whether or not such vilification, exaggeration or fabrication falls within or lies outside the boundaries of protected speech or expression is a judicial function which cannot be arrogated by an administrative body such as a Board of Censors." A system of prior restraint may only be validly administered by judges and not left to administrative agencies. US VS. BUSTOS Facts: In the latter part of 1915, numerous citizens of the Province of Pampanga assembled, and prepared and signed a petition to the Executive Secretary(privileged communication) through the law office of Crossfield and O'Brien, and five individuals signed affidavits, charging Roman Punsalan, justice of the peace of Macabebe and Masantol, Pampanga, with malfeasance in office and asking for his removal. The specific charges against the justice of the peace include the solicitation of money from persons who have pending cases before the judge. Now, Punsalan alleged that accused published a writing which was false, scandalous, malicious, defamatory, and libelous against him. Issue: Whether or Not accused is entitled to constitutional protection by virtue of his right to free speech and free press. Held: Yes. The guaranties of a free speech and a free press include the right to criticize judicial conduct. The administration of the law is a matter of vital public concern. Whether the law is wisely or badly enforced is, therefore, a fit subject for proper comment. If the people cannot criticize a justice of the peace or a judge the same as any other public officer, public opinion will be effectively suppressed. It is a duty which every one owes to society or to the State to assist in the investigation of any alleged misconduct. It is further the duty of all who know of any official dereliction on the part of a magistrate or the wrongful act of any public officer to bring the facts to the notice of those whose duty it is to inquire into and punish them. The right to assemble and petition is the necessary consequence of republican institutions and the complement of the part of free speech. Assembly means a right on the part of citizens to meet peaceably for consultation in respect to public affairs. Petition means that any person or group of persons can apply, without fear of penalty, to the appropriate branch or office of the government for a redress of grievances. The persons assembling and petitioning must, of course, assume responsibility for the charges made. All persons have an interest in the pure and efficient administration of justice and of public affairs. Public policy, the welfare of society, and the orderly administration of government have demanded protection for public opinion. The inevitable and incontestable result has been the development and adoption of the doctrine of privilege. All persons have an interest in the pure and efficient administration of justice and of public affairs. The duty under which a party is privileged is sufficient if it is social or moral in its nature and this person in good faith believes he is acting in pursuance thereof although in fact he is mistaken. Although the charges are probably not true as to the justice of the peace, they were believed to be true by the petitioners. Good faith surrounded their action. Probable cause for them to think that malfeasance or misfeasance in office existed is apparent. The ends and the motives of these citizens— to secure the removal from office of a person thought to be venal — were justifiable. In no way did they abuse the privilege. In the usual case malice can be presumed from defamatory words. Privilege destroys that presumption. A privileged communication should not be subjected to microscopic examination to discover grounds of malice or falsity. NATIONAL PRESS CLUB VS. COMELEC [201 SCRA 1; G.R. NO. 1026653; 5 MAR 1992] Facts: Petitioners in these cases consist of representatives of the mass media which are prevented from selling or donating space and time for political advertisements; two (2) individuals who are candidates for office (one for national and the other for provincial office) in the coming May 1992 elections; and taxpayers and voters who claim that their right to be informed of election Issue and of credentials of the candidates is being curtailed. It is principally argued by petitioners that Section 11 (b) of Republic Act No. 66461 invades and violates the constitutional guarantees comprising freedom of expression. Petitioners maintain that the prohibition imposed by Section 11 (b) amounts to censorship, because it selects and singles out for suppression and repression with criminal sanctions, only publications of a particular

without regard to the level of financial resources that one may have at one's disposal. they ask the following questions: 1. After a careful study of this provision and of the arguments of the parties. their qualifications. however. When is the publication to be made? Resolving their own doubts. namely." In our own society. petitioners contend that Section 11 (b) abridges the freedom of speech of candidates. This clause does not mean that the legislature may make the law effective immediately upon approval. Held: Yes. and that. which of course presupposes that the law has been published if the presumption is to have any legal justification at all. it is not unlikely that persons not aware of it would be prejudiced as a result and they would be so not because of a failure to comply with but simply because they did not know of its existence. The limiting impact of Section 11 (b) upon the right to free speech of the candidates themselves is not unduly repressive or unreasonable. Laws shall take effect after fifteen days following the completion of their publication in the Official Gazette. like a law on prescription. By virtue of the operation of Article IX (C) (4) of the Constitution. Publication is indispensable in every case. this time to move for reconsideration/clarification of that decision. he submitted that issuances intended only for the internal administration of a government agency or for particular persons did not have to be 'Published. 5 The subject of contention is Article 2 of the Civil Code providing as follows: ART. In sum. We note at this point the conclusive presumption that every person knows the law. which must also be communicated to the persons they may affect before they can begin to operate. This elicited a Reply 4 refuting these arguments. they shall have no binding force and effect.e. Section 11 (b) does not purport in any way to restrict the reporting by newspapers or radio or television stations of news or news-worthy events relating to candidates. Moreover. In the decision of this case on April 24. media-based election or political propaganda during the election period of 1992. we have come to the conclusion and so hold. 1 Specifically. is clearly an important value. as pointed out by the present Chief Justice in his separate concurrence in the original decision. Must a distinction be made between laws of general applicability and laws which are not? 3." The general rule did not apply because it was "otherwise provided. and unless so published. It seems a modest proposition that the provision of the Bill of Rights which enshrines freedom of speech. TUVERA Due process was invoked by the petitioners in demanding the disclosure of a number of presidential decrees which they claimed had not been published as required by law. without its previous publication. An example. Further. What is meant by "publication"? 4. that publication means complete publication. Came next the February Revolution and the Court required the new Solicitor General to file a Rejoinder in view of the supervening events. Section 11 (b) does not reach commentaries and expressions of belief or opinion by reporters or broadcasters or editors or commentators or columnists in respect of candidates. 2. and that the publication must be made forthwith in the Official Gazette. would bring about a substantial reduction in the quantity or volume of information concerning candidates and Issue in the election thereby curtailing and limiting the right of voters to information and opinion. What is meant by "law of public nature" or "general applicability"? 2. JUAN C. that the clause "unless it is otherwise provided" in Article 2 of the Civil Code meant that the publication required therein was not always imperative. opinions and beliefs are not in fact advertisements for particular candidates covertly paid for. This Code shall take effect one year after such publication. " It is not correct to say that under the disputed clause publication may be dispensed with altogether. the Court hereby orders respondents to publish in the Official Gazette all unpublished presidential issuances which are of general application. the petitioners suggest that there should be no distinction between laws of general applicability and those which are not. Section 26 of the Constitution is the egalitarian demand that "the State shall guarantee equal access to opportunities for public service and prohibit political dynasties as may be defined by law. The Court considers that Section 11 (b) has not gone outside the permissible bounds of supervision or regulation of media operations during election periods. 6 is the Civil Code which did not become effective after fifteen days from its publication in the Official Gazette but "one year after such publication. The reason. the decision under reconsideration was not binding because it was not supported by eight members of this Court. that the clause "unless it is otherwise provided" refers to the date of effectivity and not to the requirement of publication itself." as when the decrees themselves declared that they were to become effective immediately upon their approval. HON. that publication when necessary must be in full and in the Official Gazette. did not have to be made in the Official Gazette. Section 11 (b) as designed to cover only paid political advertisements of particular candidates. this is not true only of penal laws as is commonly supposed. Section 11 (b) is not to be read as reaching any report or commentary other coverage that. Section 11 (b) is limited in the duration of its applicability and enforceability. Responding. Issue: Whether or Not Section 11 (b) of Republic Act No. and. The government argued that while publication was necessary as a rule. he claimed first that the motion was a request for an advisory opinion and should therefore be dismissed. in responsible media. their qualifications. Significantly. It is no less important to remember that Section 6 of the Bill of Rights . but the legislature may in its discretion provide that the usual fifteen-day period shall be shortened or extended. freedom of expression and freedom of the press has to be taken in conjunction with Article IX (C) (4) which may be seen to be a special provision applicable during a specific limited period — i. and that in any case the subject decision was concurred in only by three justices and consequently not binding. and that the suppression of mediabased campaign or political propaganda except those appearing in the Comelec space of the newspapers and on Comelec time of radio and television broadcasts. TAÑADA vs. so long at least as such comments. 1985.. on the merits. of the Rules of Court. both on the original petition and on the instant motion. unless it is otherwise provided.content. and programs and so forth. or on any other date. "during the election period. is that such omission would offend due process insofar as it would deny the public knowledge of the laws that are supposed to govern the legislature could validly provide that a law e effective immediately upon its approval notwithstanding the lack of publication (or after an unreasonably short period after publication). when necessary. is not paid for by candidates for political office. that publication. Section 18. One can think of many non-penal measures. LORENZO M. the Court affirmed the necessity for the publication of some of these decrees. political parties and programs of government. The petitioners are now before us again. It is asserted that the prohibition is in derogation of media's role. it was not so when it was "otherwise provided. function and duty to provide adequate channels of public information and public opinion relevant to election Issue. which cannot in any event be omitted. or whether such act has gone beyond permissible supervision or regulation of media operations so as to constitute unconstitutional repression of freedom of speech and freedom of the press. 2 In the Comment 3 required of the then Solicitor General. under Rule 3. Section 11 (b) is limited in its applicability in time to election periods. declaring in the dispositive portion as follows: WHEREFORE. equality of opportunity to proffer oneself for public office. 6646 constitutional. Where is the publication to be made? 5. One of the basic state policies given constitutional rank by Article II." The essential question is whether or not the assailed legislative or administrative provisions constitute a permissible exercise of the power of supervision or regulation of the operations of communication and information enterprises during an election period.

is that this kind of publication is not the one required or authorized by existing law. that we do not need to examine at this time. At any rate. with sovereignty residing in the people and all government authority emanating from them. Neither is publication required of the so-called letters of instructions issued by administrative superiors concerning the rules or guidelines to be followed by their subordinates in the performance of their duties. We hold therefore that all statutes. and we have no information that it exists. Interpretative regulations and those merely internal in nature. with all the acts of the government subject to public scrutiny and available always to public cognizance. As far as we know. no publication is required of the instructions issued by. or some of the people only. It surely cannot be said that such a law does not affect the public although it unquestionably does not apply directly to all the people. The days of the secret laws and the unpublished decrees are over. The Solicitor General has not pointed to such a law.. or on another date specified by the legislature. the title of such decree. through their freedom of expression and their right of suffrage. 11 It is therefore necessary for the present membership of this Court to arrive at a clear consensus on this matter and to lay down a binding decision supported by the necessary vote. as a requirement for their effectivity after fifteen days from such publication or after a different period provided by the legislature. in accordance with Article 2 of the Civil Code. The term "laws" should refer to all laws and not only to those of general application. which shall begin fifteen days after publication unless a different effectivity date is fixed by the legislature. have a wider readership. say. and indeed especially. This is not even substantial compliance. that is. for strictly speaking all laws relate to the people in general albeit there are some that do not apply to them directly. however. All presidential decrees must be published. In fact. Laws must come out in the open in the clear light of the sun instead of skulking in the shadows with their dark. the publication of laws must be made in the Official Gazett and not elsewhere. this Court is not called upon to rule upon the wisdom of a law or to repeal or modify it if we find it impractical. the supposed date of effectivity. say. it is true that only four justices were categorically for publication in the Official Gazette8 and that six others felt that publication could be made elsewhere as long as the people were sufficiently informed. "with Secretary Tuvera"). the claim of the former Solicitor General that the instant motion is a request for an advisory opinion is untenable. Coming now to the original decision. although not suggested by the parties that a law could be rendered unenforceable by a mere refusal of the executive. of course. like a relative of President Marcos who was decreed instant naturalization. the Minister of Social Welfare on the case studies to be made in petitions for adoption or the rules laid down by the head of a government agency on the assignments or workload of his personnel or the wearing of office uniforms. municipal ordinances are not covered by this rule but by the Local Government Code. This has to be so if our country is to remain democratic. This was the manner. The furtive law is like a scabbarded saber that cannot feint parry or cut unless the naked blade is drawn. we have no choice but to pronounce that under Article 2 of the Civil Code. it is hereby declared that all laws as above defined shall immediately upon their approval. even in the courts of justice. including even. its whereabouts (e. be published in full in the Official Gazette. Consequently. 9 One reserved his vote 10 and another merely acknowledged the need for due publication without indicating where it should be made. and come out regularly. We also hold that the publication must be made forthwith or at least as soon as possible. if he is a proper party. though. We agree that publication must be in full or it is no publication at all since its purpose is to inform the public of the contents of the laws. the mere mention of the number of the presidential decree. WHEREFORE. shall be published as a condition for their effectivity. That is not our function. or as soon thereafter as possible. Although they have delegated the power of legislation. An example is a law granting citizenship to a particular individual. the legislative enactments of the government. directly conferred by the Constitution." and this certainly applies to. the law must invariably affect the public interest even if it might be directly applicable only to one individual.g. Finally. To be valid. even the charter of a city must be published notwithstanding that it applies to only a portion of the national territory and directly affects only the inhabitants of that place. those naming a public place after a favored individual or exempting him from certain prohibitions or requirements. was "published" by the Marcos administration. If it does. they retain the authority to review the work of their delegates and to ratify or reject it according to their lights. to give effect to the law pursuant to the said Article 2. and deserves no further comment. a law without any bearing on the public would be invalid as an intrusion of privacy or as class legislation or as an ultra vires act of the legislature. Mysterious pronouncements and rumored rules cannot be recognized as binding unless their existence and contents are confirmed by a valid publication intended to make full disclosure and give proper notice to the people. no amendment has been made of Article 2 of the Civil Code. This is a matter. The trouble. 7 The evident purpose was to withhold rather than disclose information on this vital law. the laws to the people as such periodicals are more easily available.recognizes "the right of the people to information on matters of public concern. and in a mere supplement of the Official Gazette cannot satisfy the publication requirement. This they cannot do if the acts of the legislature are concealed. to cause its publication as required. among others. . administrative rules and regulations must a also be published if their purpose is to enforce or implement existing law pursuant also to a valid delegation. and t to the public as a whole. Parenthetically. Accordingly. The circulars issued by the Monetary Board must be published if they are meant not merely to interpret but to "fill in the details" of the Central Bank Act which that body is supposed to enforce. at present. to say the least. There is much to be said of the view that the publication need not be made in the Official Gazette. considering its erratic releases and limited readership. including those of local application and private laws. SO ORDERED. to become effective only after fifteen days from their publication. This is once again an open society. newspapers of general circulation could better perform the function of communicating. need not be published. in which the General Appropriations Act for FY 1975. However. deep secrets. for whatever reason. There is that possibility. The subject of such law is a matter of public interest which any member of the body politic may question in the political forums or. Undoubtedly. regulating only the personnel of the administrative agency and not the public. incidentally. it obviously has not yet been published. As correctly pointed out by the petitioners. Covered by this rule are presidential decrees and executive orders promulgated by the President in the exercise of legislative powers whenever the same are validly delegated by the legislature or. Our task is merely to interpret and apply the law as conceived and approved by the political departments of the government in accordance with the prescribed procedure. That function belongs to the legislature. a presidential decree undeniably of general applicability and interest.

Facts:On February 24.) This Court adopted the “direct injury” test in our jurisdiction.) Whether or not the concurrence of Congress is necessary whenever the alarming powers incident to Martial Law are used? Ruling: 1. Also arrested was his companion. may not be sued in any civil or criminal case. Petitioners filed seven (7) certiorari with the Supreme Court and three (3) of those petitions impleaded President Arroyo as respondent questioning the legality of the proclamation. Thus this exception does not infringe upon the constitutional provision on freedom of association but instead reinforces it. GLORIA MACAPAGAL-ARROYO. a professor at the University of the Philippines and newspaper columnist. and there is no need to provide for it in the Constitution or law. Vera. there were extraneous provisions giving the President express or implied power (A) To issue decrees. the union wrote a letter to the company to separate the plaintiff from the service after which he was informed by the company that unless he makes a satisfactory arrangement with the union he will be dismissed from the service.) Whether or not the warantless arrest of Randolf S. are ultra vires and unconstitutional. 2. David and Ronald Llamas and the dispersal of KMU and NAFLU-KMU members during rallies were valid? 3. i.) Under Article XII Section 17 of the 1987 Philippine Constitution. 2006. The union has subsisting closed shop agreement in their collective bargaining agreement with their employer that all permanent employees of the company must be a member of the union and later was amended byRepublic Act No.) It is not proper to implead President Arroyo as respondent. the President may temporarily take over a privately owned public utility or business affected with public interest only if there is congressional authority or approval. ET AL.” Therefore. 4. and (C) To impose standards on media or any form of prior restraint on the press.. The police arrested (without warrant) petitioner Randolf S. 3. 3350 with the provision stating "but such agreement shall not cover members of any religious sects which prohibit affiliation of their members in any such labor organization". Article VII of the Constitution. the absence of legal restraint. 2006.RANDOLF DAVID. the President. invasion or rebellion and violating BP 880. operatives of the Criminal Investigation and Detection Group (CIDG) of the PNP. 5. 1017 is only partly unconstitutional. Ronald Llamas. whereby an employee may join or refrain from joining an association. the court ruled that the petitioners have a locus standi.) The Court finds and so holds that PP 1017 is constitutional insofar as it constitutes a call by the President for the AFP to prevent or suppress lawless violence whenever becomes necessary as prescribe under Section 18.") (B) To direct the AFP to enforce obedience to all laws even those not related to lawless violence as well as decrees promulgated by the President[The absence of a law defining "acts of terrorism" may result in abuse and oppression on the part of the police or military]. during his tenure of office or actual incumbency. The Court also rules that under Section 17. as the nation celebrated the 20th Anniversary of the Edsa People Power I. when the public interest so requires. By his resignation. The union contends that RA 3350 impairs obligation of contract stipulated in their CBA and discriminatorily favors religious sects in providing exemption to be affiliated with any labor unions.) The warrantless arrest of Randolf S. On March 3. or will sustain direct injury as a result. InPeople v. and second. Article XII of the Constitution. are declared unconstitutional because there was no clear and present danger of a substantive evil that the state has a right to prevent.. VICTORIANO V ELIZALDE ROPE WORKERS UNION 59 SCRA 54 (1974) Facts: Plaintiff is a member of the Elizalde Rope Workers Union who later resigned from his affiliation to the said union by reason of the prohibition of his religion for its members to become affiliated with any labor organization. it held that the person who impugns the validity of a statute must have “a personal and substantial interest in the case such that he has sustained. in the absence of legislative legislation. The exceptions provided by the assailed Republic Act is that members of said religious sects cannot be compelled or coerced to join labor unions even when said unions have closed shop agreements with the employers. David and Ronald Llamas. as well as the warrantless search of the Tribune offices and whimsical seizure of its articles for publication and other materials. (" Legislative power is peculiarly within the province of the Legislature. GABRIELA and BAYAN MUNA whom suspected of inciting to sedition and rebellion. The Office of the President announced the cancellation of all programs and activities related to the 20th anniversary celebration of Edsa People Power I. Article VI categorically states that "[t]he legislative power shall be vested in the Congress of the Philippines which shall consist of a Senate and a House of Representatives. president of party-list Akbayan. Held: The court held that what the Constitution and the Industrial Peace Act recognize and guarantee is the "right" to form or join associations which involves two broad notions. alleging that it encroaches the emergency powers of Congress and it violates the constitutional guarantees of freedom of the press.) Whether or not the petitioners have a legal standing in questioning the constitutionality of the proclamation? 5. President Arroyo issued PP 1021 declaring that the state of national emergency has ceased to exist. President Arroyo issued PP 1017 declaring a state of national emergency and call upon the Armed Forces of the Philippines (AFP) and the Philippine National Police (PNP). There must enactment of appropriate legislation prescribing the terms and conditions under which the President may exercise the powers that will serves as the best assurance that due process of law would be observed. Section 1. VS. the dispersal and warrantless arrest of the KMU and NAFLU-KMU members during their rallies are illegal. in times of national emergency. on the basis of PP 1017 and G. namely: first. However.) Whether or not Presidential Proclamation No. the imposition of standards on media or any form of prior restraint on the press. of speech and assembly. whereby an employee may act for himself without being prevented by law. 1017 is unconstitutional? 2.e. David. the PP No. Therefore the right to join a union includes the right to abstain from joining any union. ET AL. No. 2006. that in spite of any closed shop agreement. liberty or freedom. cannot take over privately-owned public utility and private business affected with public interest.O.) Whether or not proper to implead President Gloria Macapagal Arroyo as respondent in the petitions? 4. in the absence of proof that these petitioners were committing acts constituting lawless violence. Issue: 1. members of said religious sects cannot be refused employment or dismissed from their jobs on the sole ground that they are not members of the collective bargaining union. to prevent and suppress acts of terrorism and lawless violence in the country. . raided the Daily Tribune offices in Manila and attempt to arrest was made against representatives of ANAKPAWIS. and revoked the permits to hold rallies issued earlier by the local governments and dispersal of the rallyists along EDSA. In the early morning of February 25. power. 5. Issue: WON RA 3350 impairs the right to form association. for they suffered “direct injury” resulting from “illegal arrest” and “unlawful search” committed by police operatives pursuant to PP 1017. Therefore. Settled is the doctrine that the President.

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