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LEO ECHEGARAY Y PILO v. SECRETARY OF JUSTICE

FACTS:

On June 25, 1996, the Court affirmed the conviction of Leo Echegaray for the crime of raping the 10-year-old daughter of his common-law spouse and imposed upon him the death penalty. Echegaray filed a Motion for Reconsideration raising factual issues, as well as a Supplemental Motion for Reconsideration alleging the unconstitutionality of Republic Act No. 7659, the death penalty law, and the imposition of the death penalty for rape.

On February 7, 1998, the Court denied Echegaray's motions and ruled that Congress complied with the requirements for the reimposition of the death penalty, hence, the death penalty law is constitutional.

Afterwards, Congress passed Republic Act No. 8177, changing the mode of execution from electrocution to lethal injection. The Secretary of Justice promulgated the implementing rules for RA 8177, and the Director of the Bureau of Corrections prepared the Lethal Injection Manual.

On March 2, 1998, Echegaray filed a Petition for Prohibition, Injunction, and/or Temporary Restraining Order to stop the execution by lethal injection under RA 8177 and its implementing rules, claiming their unconstitutionality and violation of various rights.

On March 3, 1998, the Court required respondents to comment on the petition, while maintaining the status quo prevailing at the time of the filing of the petition.

On March 10, 1998, the Court granted Echegaray's Motion for Leave of Court to Amend and Supplement the Petition, and required respondents to comment within ten days.

On March 16, 1998, Echegaray filed a Very Urgent Motion to clarify the status quo order and for the issuance of a temporary restraining order to stop the execution.

On March 16, 1998, the Solicitor General filed a comment stating that the death penalty law is constitutional and that lethal injection is a more humane method of execution.

On March 17, 1998, the Court required Echegaray to file a reply to the Solicitor General's comment.

On March 25, 1998, the Commission on Human Rights filed a motion to intervene and/or appear as amicus curiae, arguing that the death penalty imposed under RA 7659 and implemented by RA 8177 is cruel and degrading, and in violation of international covenants and human rights principles.

ISSUES:

  1. Whether death by lethal injection constitutes cruel, degrading, and inhuman punishment, thus violating the Constitution.

  2. Whether the reimposition of the death penalty violates the International Covenant on Civil and Political Rights.

  3. Whether Republic Act No. 8177 constitutes an undue delegation of legislative power to the Secretary of Justice and the Director of the Bureau of Corrections.

  4. Whether specific sections of the Rules and Regulations to Implement Republic Act No. 8177 are unconstitutional, particularly Section 17 and Section 19.

RULING:

  1. Death by lethal injection: The Court ruled that death by lethal injection does not constitute cruel, degrading, and inhuman punishment under Section 19, Article III of the 1987 Constitution. The Court found that lethal injection is a constitutional way of executing the death penalty, satisfying both humane and legal standards.

  2. International Covenant on Civil and Political Rights: The Court held that the reimposition of the death penalty does not violate the International Covenant on Civil and Political Rights. The Covenant allows for the death penalty for the most serious crimes, and the Philippines did not sign the Second Optional Protocol, aiming at the abolition of the death penalty.

  3. Delegation of legislative power: The Court found that Republic Act No. 8177 does not constitute an undue delegation of legislative power. The provisions in R.A. No. 8177 were within the competence and discretion of administrative officials and did not violate the principle of non-delegation of legislative powers.

  4. Sections of the implementing rules: The Court declared Sections 17 and 19 of the Rules and Regulations to Implement Republic Act No. 8177 invalid. Section 17 was invalidated for being discriminatory and contravening Article 83 of the Revised Penal Code as amended by Section 25 of Republic Act No. 7659. Section 19 was invalidated because it failed to provide for the review and approval of the Lethal Injection Manual by the Secretary of Justice and unjustifiably kept the manual confidential.

PRINCIPLES:

  1. Constitutionality of Methods of Execution: The death penalty per se is not considered cruel, degrading, or inhuman punishment. Execution methods are constitutional as long as they do not involve torture or unnecessary pain.

  2. International Law: International treaties and covenants, such as the International Covenant on Civil and Political Rights, provide guidelines but allow for the imposition of the death penalty for the most serious crimes.

  3. Non-Delegation Doctrine: Legislative powers may be delegated to administrative bodies provided there are sufficient standards laid out in the enabling law to guide the execution of such powers.

  4. Administrative Rules and Regulations: Administrative rules must align with the legislative act they enforce and cannot override or contradict statutory provisions.