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DR. JOY MARGATE LEE v. P/SUPT. NERI A. ILAGAN

FACTS:

Respondent Police Superintendent Neri A. Ilagan filed a petition for the issuance of the writ of habeas data against petitioner Dr. Joy Margate Lee. Ilagan alleged that Lee reproduced a sex video involving him without his consent and threatened to distribute the video. Ilagan claimed that this violated his right to privacy, life, liberty, and security.

In response, Lee admitted to reproducing the video but stated that she only did so to use it as evidence in the cases she filed against Ilagan. She argued that the petition should be dismissed because she was not engaged in gathering, collecting, or storing data about Ilagan.

The Regional Trial Court (RTC) issued a writ of habeas data in favor of Ilagan, ordering Lee to turn over the video and enjoining her from further reproducing it. The RTC found that Lee's actions violated Ilagan's right to privacy and caused him humiliation and mental anguish.

ISSUES:

  1. Whether or not the RTC correctly extended the privilege of the writ of habeas data in favor of Ilagan.

RULING:

  1. No, the Supreme Court found that Ilagan was not able to sufficiently allege that his right to privacy in life, liberty, or security was or would be violated through the supposed reproduction and threatened dissemination of the subject sex video. Hence, the petition for the writ of habeas data was dismissed for lack of merit.

PRINCIPLES:

  • Habeas Data Rule (A.M. No. 08-1-16-SC): This rule provides a remedy for individuals 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.

  • Right to Informational Privacy: The right to control the collection, maintenance, use, and dissemination of data about oneself.

  • Nexus Requirement: There must be a clear connection between the violation or threat to one's privacy rights and the right to life, liberty, or security.

  • Substantial Evidence Requirement: The allegations in a habeas data petition must be supported by substantial evidence showing an actual or threatened violation of the right to privacy in life, liberty, or security.

  • Limitation Clause: The writ of habeas data will not issue for purely property or commercial concerns, nor when the grounds invoked in support are vague and doubtful.