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CECILIA ZULUETA v. CA

## FACTS:

Petitioner, Cecilia Zulueta, forcibly entered her husband's clinic and took 157 documents consisting of private correspondence, greetings cards, canceled checks, diaries, and photographs without her husband's knowledge and consent. The documents were seized for use as evidence in a case for legal separation and disqualification from the practice of medicine that petitioner had filed against her husband. Private respondent, Dr. Alfredo Martin, filed a complaint for recovery of the documents and papers and for damages against petitioner. The trial court ruled in favor of Dr. Martin and ordered petitioner to return the properties and pay damages. The Court of Appeals affirmed the decision.

ISSUES

  1. Whether the Court of Appeals erred in affirming the decision of the trial court which ordered the petitioner to return the documents taken from the private respondent's clinic, and enjoined her from using them as evidence.

RULING

The Supreme Court denied the petition for review, holding that the petitioner did not have the right to take the documents from the private respondent's clinic without his consent nor the authority to use them as evidence. The court emphasized the constitutional protection on the privacy of communication and correspondence, which also applies to the relations between husband and wife. Thus, any evidence obtained in violation of this provision is considered inadmissible in any proceeding.

PRINCIPLES

  1. The constitutional injunction that declares "the privacy of communication and correspondence [to be] inviolable" applies universally, including within the marital relationship.

  2. Evidence obtained in violation of the constitutional right to privacy of communication and correspondence is inadmissible for any purpose in any proceeding.

  3. The norms surrounding privileged communication between spouses are upheld, prohibiting one spouse from testifying against the other or disclosing confidential communications without consent, preserving the integrity and privacy rights of individuals even within marriage.