G.R. No. 93833 September 1995 (Ramirez v Court of Appeals and Garcia)

Question 1

Who filed the petition for this case?

Answer 1

Socorro D. Ramirez

Question 2

Where did the petitioner file this case?

Answer 2

Regional Trial Court of Quezon City

Question 3

What was the petition filed by Socorro D. Ramirez?

Answer 3

A civil case for damages in a confrontation in Garcia’s office.

Question 4

What happened to Socorro that prompted her to file the case?

Answer 4

Socorro was allegedly vexed, insulted and humiliated in a “hostile and furious mood” and in a manner offensive to her dignity and personality, “contrary to morals, good customs and public policy.”

Question 5

How did Socorro prove her claim?

Answer 5

She produced a verbatim transcript of the event and sought moral damages, attorney’s fees and other expenses of litigation (P610,000) from a tape recorder.

Question 6

Who is the private respondent of this case?

Answer 6

Ester Garcia

Question 7

What did the private respondent do as a response to the petition filed by Socorro?

Answer 7

Ester Garcia filed a criminal case against Socorro for violating R.A. 4200.

Question 8

What is R.A. 4200?

Answer 8

It is “An Act to Prohibit and Penalize Wiretapping and Other Related Violations of Private Communication and Other Purposes”

Question 9

What did the petitioner do, upon arraignment, in lieu of the plea?

Answer 9

The petitioner filed a Motion to Quash the Information.

Question 10

What was the ground for the Motion to Quash the Information?

Answer 10

The facts charged do not constitute an offense particularly a violation of R.A. 4200.

Question 11

What was the decision of the trial court on the Motion to Quash the Information filed by the petitioner?

Answer 11

The trial court granted the petition.

(1) The facts charged do not constitute an offense under R.A. 4200
(2) the violation punished by R.A. 4200 refers to the taping of a communication by a person other than a participant to the communication.

Question 12

What did the private responded do after the trial court granted the petition of Socorro?

Answer 12

She filed a Petition for Review on Court of Appeals.

Question 13

What was Court of Appeals’ decision on the petition filed by the private respondent?

Answer 13

Court of Appeals declared that the trial court’s decision was null and void. COA indicate that the allegations sufficiently constitute an offense punishable under Section 1 of R.A. 4200.

Question 14

What are the issues of this case?

Answer 14

Whether or not

(1) R.A. applies to taping of a private conversation by one of the parties to a conversation
(2) the substance must be alleged in the information
(3) R.A. 4200 applies to private conversation

Question 15

What was the decision of the Court?

Answer 15

The petition was denied.

Question 16

What was the basis of the Court’s decision?

Answer 16

(1) Legislative intent is determined principally by the language of the statute (the statute is clear and unambiguous)
(2) The nature of the conversation is immaterial to a violation of the statute (the mere allegation that an individual made a secret recording would suffice to constitute an offense under Section 1 of R.A. 4200)
(3) The petitioner’s contention to the phrase “private communication” in Section 1 does not include “private conversations”. It narrows the ordinary meaning of the word “communication” to a point of absurdity.

Question 17

What was the doctrine learned in this case?

Answer 17

Legislative intent is determined principally from the language of the statute.