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Case#5 PEOPLE Vs DACUYCUY

1) Private respondents were charged with violating the Magna Carta for Public School Teachers. They argued the penal provision under Section 32 was unconstitutional. 2) Section 32 provides for an indeterminate period of imprisonment without setting a minimum or maximum duration, giving courts wide discretion to set the term. 3) The Supreme Court held Section 32 unconstitutional as it vests courts with essentially legislative powers by allowing imprisonment durations ranging from minimal to life without standards, violating separation of powers.

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107 views1 page

Case#5 PEOPLE Vs DACUYCUY

1) Private respondents were charged with violating the Magna Carta for Public School Teachers. They argued the penal provision under Section 32 was unconstitutional. 2) Section 32 provides for an indeterminate period of imprisonment without setting a minimum or maximum duration, giving courts wide discretion to set the term. 3) The Supreme Court held Section 32 unconstitutional as it vests courts with essentially legislative powers by allowing imprisonment durations ranging from minimal to life without standards, violating separation of powers.

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Rio Tolentino
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PEOPLE OF THE PHILIPPINES

vs

HON. JUDGE AUXENCIO DACUYCUY, CELESTINO MATONDO, SEGUNDINO CAVAL and CIRILO ZANORIA

G.R. NO. L-45127 : May 5, 1989

REGALADO, J.

Facts:

Herein private respondents were charged for violation of RA No. 4670, the Magna Carta for Public
School Teachers. The private respondents moved to quash the complaint for lack of jurisdiction over the
offense charged but denied by the municipal court. Subsequently, they filed a motion for
reconsideration but was also denied. Hence, the petition for certiorari. The private respondents
contends that the facts charged do not constitutes an offense since the penal provision under Sec 32 of
RA No. 4670 is unconstitutional for the following reasons: (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 as if the latter were the legislative department of the
Government.

Issue:

Whether Sec 32 of RA No. 4670 is unconstitutional.

Held:

Yes. Section 32 of Republic Act No. 4670 provides for an indeterminable period of imprisonment, with
neither a minimum nor a maximum duration having been set by the legislative authority. The courts are
thus given a wide latitude of discretion to fix the term of imprisonment, without even the benefit of any
sufficient standard, such that the duration thereof may range, in the words of respondent judge, from
one minute to the life span of the accused. Irremissibly, this cannot be allowed. It vests in the courts a
power and a duty essentially legislative in nature and which, as applied to this case, does violence to the
rules on separation of powers as well as the non-delegability of legislative powers. 

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