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    People V. Dacuycuy

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    Joycee Armillo
    This case discusses the constitutionality of Section 32 of Republic Act No. 4670, which punishes interference with teachers' rights. The Supreme Court held that: 1) The indefinite penalty of imprisonment in the statute does not constitute cruel and unusual punishment under the Constitution. Punishments are unconstitutional only if they are unknown to law or shock the moral sense. 2) However, allowing courts unlimited discretion in setting the prison term would be an undue delegation of legislative power. The legislature must provide limits for the term. 3) Therefore, the penalty of imprisonment in Section 32 was declared unconstitutional, but the rest of the statute remains valid due to the separability clause.

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    © All Rights Reserved
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    People V. Dacuycuy

    Uploaded by

    Joycee Armillo
    84 views2 pages
    This case discusses the constitutionality of Section 32 of Republic Act No. 4670, which punishes interference with teachers' rights. The Supreme Court held that: 1) The indefinite penalty of imprisonment in the statute does not constitute cruel and unusual punishment under the Constitution. Punishments are unconstitutional only if they are unknown to law or shock the moral sense. 2) However, allowing courts unlimited discretion in setting the prison term would be an undue delegation of legislative power. The legislature must provide limits for the term. 3) Therefore, the penalty of imprisonment in Section 32 was declared unconstitutional, but the rest of the statute remains valid due to the separability clause.

    Original Title

    (458) People V. Dacuycuy

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    This case discusses the constitutionality of Section 32 of Republic Act No. 4670, which punishes interference with teachers' rights. The Supreme Court held that: 1) The indefinite penalty of imprisonment in the statute does not constitute cruel and unusual punishment under the Constitution. Punishments are unconstitutional only if they are unknown to law or shock the moral sense. 2) However, allowing courts unlimited discretion in setting the prison term would be an undue delegation of legislative power. The legislature must provide limits for the term. 3) Therefore, the penalty of imprisonment in Section 32 was declared unconstitutional, but the rest of the statute remains valid due to the separability clause.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    84 views2 pages

    People V. Dacuycuy

    Uploaded by

    Joycee Armillo
    This case discusses the constitutionality of Section 32 of Republic Act No. 4670, which punishes interference with teachers' rights. The Supreme Court held that: 1) The indefinite penalty of imprisonment in the statute does not constitute cruel and unusual punishment under the Constitution. Punishments are unconstitutional only if they are unknown to law or shock the moral sense. 2) However, allowing courts unlimited discretion in setting the prison term would be an undue delegation of legislative power. The legislature must provide limits for the term. 3) Therefore, the penalty of imprisonment in Section 32 was declared unconstitutional, but the rest of the statute remains valid due to the separability clause.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    Excessive fines and cruel, degrading and inhuman punishment

    People V. Dacuycuy

    G.R. No. L-45127 | May 5, 1989

    Facts:

    Private respondents Celestino S. Matondo, Segubdini A. Caval, and Cirilo M, Zanoria, public school
    officials, were charged for violation of R.A. No. 4670, where it states, “A person who shall wilfully interfere
    with, restrain or coerce any teacher in the exercise of his right guaranteed by this Act or who shall in any
    manner commit any act to defeat any of the provisions of this Act shall, upon conviction, be punished by a
    fine of not less than one hundred pesos nor more than one thousand pesos, or by imprisonment, in the
    discretion of the Court.” Private respondents are assailing the constitutionality of the said Sec. 32 of the
    republic act because; (1) It imposes a cruel and unusual punishment, the term of imprisonment being
    unfixed and may run to reclusion perpetua; and (2) It also constitutes an undue delegation of legislative
    power, the duration of the penalty of imprisonment being solely left to the discretion of the court if the
    latter were the legislative department of the Government. Respondent judge held that R.A. No. 4670 is
    valid and constitutional and later denied motion for reconsideration hence, this petition.

    Issue:

    Whether Section 32 of Republic Act No. 4670 is constitutional.

    Held:

    The contention that R.A. No. 4670 is unconstitutional on the ground that the imposable but indefinite
    penalty of imprisonment provided therein constituted a cruel and unusual punishment, in defiance if the
    express mandate of Constitution is inaccurate and should be rejected. The rule is established beyond
    question that a punishment authorized by statute is not cruel or unusual or disproportionate to the nature
    of the offense unless it is a barbarous one unknown to the law or so wholly disproportionate to the nature
    of the offense as to shock the moral sense of the community. The Constitution directs that 'Excessive
    fines shall not be imposed, nor cruel and unusual punishment inflicted.' The prohibition of cruel and
    unusual punishments is generally aimed at the form or character of the punishment rather than its
    severity in respect of duration or amount, and apply to punishments which never existed in America, or
    which public sentiment has regarded as cruel or obsolete, for instance there inflicted at the whipping post,
    or in the pillory, burning at the stake, breaking on the wheel, disemboweling, and the like. Fine and
    imprisonment would not thus be within the prohibition.

    On the argument of private respondents that the entire penal provision in question should be invalidated
    as an 49 "undue delegation of legislative power, the duration of penalty of imprisonment being solely left
    to the discretion of the court as if the latter were the legislative department of the government, the
    respondent judge erroneously assumed that since the penalty of imprisonment has been provided for by
    the legislature, the court is endowed with the discretion to ascertain the term or period of imprisonment.
    We cannot agree with this postulate. It is not for the courts to fix the term of imprisonment where no
    points of reference have been provided by the legislature. What valid delegation presupposes and
    sanctions is an exercise of discretion to fix the length of service of a term of imprisonment which must be
    encompassed within specific or designated limits provided by law, the absence of which designated limits
    well constitute such exercise as an undue delegation, if not-an outright intrusion into or assumption, of
    legislative power. Therefore, by virtue of the separability clause in Section 34 of Republic Act No. 4670,
    the penalty of imprisonment provided in Section 32 is declared unconstitutional.
    Excessive fines and cruel, degrading and inhuman punishment

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