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SPS. BILL v. ALEXANDER CHOACHUY

FACTS:

Petitioner-spouses Bill and Victoria Hing filed a Complaint for Injunction and Damages against respondents Alexander Choachuy, Sr. and Allan Choachuy before the Regional Trial Court (RTC) of Mandaue City. They claimed that they are the registered owners of a parcel of land and that respondents constructed an auto-repair shop building adjacent to their property. They also alleged that respondents illegally installed video surveillance cameras on the building, which violated their right to privacy. The RTC granted the application for a Temporary Restraining Order (TRO) and denied the motion for reconsideration filed by respondents. Dissatisfied with the RTC's ruling, respondents filed a Petition for Certiorari before the Court of Appeals (CA). The CA annulled and set aside the RTC's orders, ruling that petitioners failed to show a clear and unmistakable right to an injunctive writ. The CA also held that since respondents were not the owners of the building, they cannot be held liable for the installation of the surveillance cameras. Petitioners filed a Petition for Review before the Supreme Court, arguing that their right to privacy was violated and that respondents are the proper parties to the suit. Respondents, however, maintain that they had nothing to do with the installation of the cameras and were wrongfully impleaded in the case.

ISSUES:

  1. Whether the installation of a revolving camera by the respondents, which spans a portion of the land owned by the petitioners, violates the right to privacy of the petitioners.

  2. Whether the installation of video surveillance cameras without the consent of the property owners is a violation of their right to privacy.

  3. Whether the respondents are the proper parties to the suit.

RULING:

  1. Yes, the installation of the revolving camera violates the right to privacy of the petitioners.

  2. The Supreme Court ruled that the installation of video surveillance cameras without the consent of the property owners is a violation of their right to privacy. The Court upheld the Regional Trial Court's (RTC) decision that the issuance of a preliminary injunction was justified to protect the petitioners' right to privacy. The Court stated that the owner of a thing cannot make use thereof in a manner that would injure the rights of a third person.

  3. The Supreme Court also ruled that the respondents are the proper parties to the suit. The Court held that a real party defendant is one who has a correlative legal obligation to redress a wrong done to the plaintiff. Despite not being the registered owners of the building, the respondents were held to be the proper parties because they caused the installation of the video surveillance cameras. The Court found that the respondents, through their actions and involvement in the case, were merely using the corporate fiction of Aldo, a family-owned corporation managed by the Choachuy family, as a shield to protect themselves from the suit.

PRINCIPLES:

  • The right to privacy is the right to be let alone.

  • The right to privacy is enshrined in the Constitution and defined as the right to be free from unwarranted exploitation or intrusion into one's private activities.

  • The right to privacy includes the right of an individual to be free from unwarranted publicity or interference by the public in matters in which the public is not necessarily concerned.

  • The State recognizes the right of the people to be secure in their houses and no one, including the State, can disturb them in the privacy of their homes, except in case of overriding social need under stringent procedural safeguards.

  • Article 26(1) of the Civil Code protects an individual's right to privacy and provides a legal remedy against abuses committed by other individuals.

  • The phrase "prying into the privacy of another's residence" in Article 26(1) of the Civil Code covers places where the public is excluded and only certain individuals are allowed to enter and that an individual's right to privacy should not be confined to his house or residence.

  • The "reasonable expectation of privacy" test is used to determine whether there is a violation of the right to privacy, which considers whether the individual has exhibited an expectation of privacy and whether society recognizes it as reasonable.

  • Video surveillance cameras should not cover places where there is a reasonable expectation of privacy, unless consent is obtained, and should not be used to pry into the privacy of another's residence or business office.

  • Eavesdropping, which is similar to prying into another's privacy, is a crime under Republic Act No. 4200 or the Anti-Wiretapping Law.

  • The owner of a thing cannot make use thereof in such a manner as to injure the rights of a third person.

  • A real party defendant is one who has a correlative legal obligation to redress a wrong done to the plaintiff by reason of the defendant's act or omission which had violated the legal right of the former.