SECOND DIVISION

[G.R. No. 83598. March 7, 1997]

LEONCIA BALOGBOG and GAUDIOO BALOGBOG, petitioners,
vs. !ONORABLE COUR" O# A$$EAL, RAMONI"O BALOGBOG and
GENEROO BALOGBOG, respondents.
D E C I I O N
MENDO%A, J.&
This is a petition for review of the decision
[1]
of the Court of Appeals a!r"in# the
decision of the Court of $irst Instance of Ce%u Cit& '(ranch I)* declarin# private
respondents heirs of the deceased (asilio and +enoveva (alo#%o# entitled to
inherit fro" the",
The facts are as follows, -etitioners .eoncia and +audioso (alo#%o# are the
children of (asilio (alo#%o# and +enoveva Arni%al who died intestate in 1/01 and
1/11 respectivel&, The& had an older %rother +avino %ut he died in 1/20
predeceasin# their parents,
In 1/13 private respondents 4a"onito and +eneroso (alo#%o# %rou#ht an action
for partition and accountin# a#ainst petitioners clai"in# that the& were the
le#iti"ate children of +avino %& Catalina 5%as and that as such the& were entitled
to the one6third share of +avino in the estate of their #randparents,
In their answer petitioners denied 7nowin# private respondents, The& alle#ed that
their %rother +avino died sin#le and without issue in their parents8 residence at Ta#6
a"a7an Asturias Ce%u, In the %e#innin# the& clai"ed that the properties of the
estate had %een sold to the" %& their "other when she was still alive %ut the&
later withdrew this alle#ation,
-rivate respondents presented -riscilo 9, Tra:o
[;]
then 31 &ears old "a&or of the
"unicipalit& of Asturias fro" 1/;3 to 1/2< who testi=ed that he 7new +avino and
Catalina to %e hus%and and wife and 4a"onito to %e their =rst child, On
crosse>a"ination Tra:o e>plained that he 7new +avino and Catalina %ecause the&
perfor"ed at his ca"pai#n rallies Catalina as ?%alitaw@ dancer and +avino
(alo#%o# as her #uitarist, Tra:o said he attended the weddin# of +avino and
Catalina so"eti"e in 1/;/ in which 4ev, $ather E"iliano Ao"ao6as o!ciated and
E#"idio Banuel then a "unicipal councilor acted as one of the witnesses,
The second witness presented was Batias -o#o&
[2]
a fa"il& friend of private
respondents who testi=ed that private respondents are the children of +avino and
Catalina, Accordin# to hi" the weddin# of +avino and Catalina was sole"ni:ed in
the Catholic Church of Asturias Ce%u and that he 7new this %ecause he attended
their weddin# and was in fact as7ed %& +avino to acco"pan& Catalina and carr& her
weddin# dress fro" her residence in Ca"anaol to the po%lacion of Asturias %efore
the weddin# da&, Ce testi=ed that +avino died in 1/20 in his residence at O%o#on
(ala"%an Ce%u in the presence of his wife, 'This contradicts petitioners8 clai"
"ade in their answer that +avino died in the ancestral house at Ta#6a"a7an
Asturias,* -o#o& said he was a carpenter and he was the one who had "ade the
co!n of +avino, Ce also "ade the co!n of the couple8s son -etronilo who died
when he was si>,
Catalina 5%as testi=ed concernin# her "arria#e to +avino,
[<]
She testi=ed that after
the weddin# she was handed a ?receipt@ presu"a%l& the "arria#e certi=cate %&
$r, Ao"ao6as %ut it was %urned durin# the war, She said that she and +avino lived
to#ether in O%o#on and %e#ot three children na"el& 4a"onito -etronilo and
+eneroso, -etronilo died after an illness at the a#e of si>, On crosse>a"ination she
stated that after the death of +avino she lived in co""on law relation with a "an
for a &ear and then the& separated,
-rivate respondents produced a certi=cate fro" the O!ce of the .ocal Civil
4e#istrar 'E>h, -* that the 4e#ister of Barria#es did not have a record of the
"arria#e of +avino and Catalina another certi=cate fro" the O!ce of the Treasurer
'E>h, .* that there was no record of the %irth of 4a"onito in that o!ce and for this
reason the record "ust %e presu"ed to have %een lost or destro&ed durin# the
war and a certi=cate %& the -arish -riest of Asturias that there was li7ewise no
record of %irth of 4a"onito in the church the records of which were either lost or
destro&ed durin# the war, 'E>h, B*
On the other hand as defendant %elow petitioner .eoncia (alo#%o# testi=ed
[0]
that
+avino died sin#le at the fa"il& residence in Asturias, She denied that her %rother
had an& le#iti"ate children and stated that she did not 7now private respondents
%efore this case was =led, She o%tained a certi=cate 'E>h, 1D* fro" the .ocal Civil
4e#istrar of Asturias to the eEect that that o!ce did not have a record of the na"es
of +avino and Catalina, The certi=cate was prepared %& Assistant Bunicipal
Treasurer Auan Baran#a who testi=ed that there was no record of the "arria#e of
+avino and Catalina in the (oo7 of Barria#es %etween 1/;0 to 1/20,
[1]
Fitness Aose Narvasa testi=ed
[G]
that +avino died sin#le in 1/20 and that Catalina
lived with a certain Eleuterio Heriado after the war althou#h he did not 7now
whether the& were le#all& "arried, Ce added however that Catalina had children
%& a "an she had "arried %efore the war althou#h he did not 7now the na"es of
the children, On crosse>a"ination Narvasa stated that .eoncia (alo#%o# who
reIuested hi" to testif& was also his %onds"an in a cri"inal case =led %& a certain
Br, Cu&os,
4a"onito (alo#%o# was presented
[3]
to re%ut .eoncia (alo#%o#8s testi"on&,
On Aune 10 1/G2 the Court of $irst Instance of Ce%u Cit& rendered Jud#"ent for
private respondents 'plaintiEs %elow* orderin# petitioners to render an accountin#
fro" 1/1D until the =nalit& of its Jud#"ent to partition the estate and deliver to
private respondents one6third of the estate of (asilio and +enoveva and to pa&
attorne&8s fees and costs,
-etitioners =led a "otion for new trial andKor reconsideration contendin# that the
trial court erred in not #ivin# wei#ht to the certi=cation of the O!ce of the Bunicipal
Treasurer of Asturias 'E>h, 1D* to the eEect that no "arria#e of +avino and Catalina
was recorded in the (oo7 of Barria#es for the &ears 1/;061/20, Their "otion was
denied %& the trial court as was their second "otion for new trial andKor
reconsideration %ased on the church records of the parish of Asturias which did not
contain the record of the alle#ed "arria#e in that church,
On appeal the Court of Appeals a!r"ed, It held that private respondents failed to
overco"e the le#al presu"ption that a "an and a wo"an deportin# the"selves as
hus%and and wife are in fact "arried that a child is presu"ed to %e le#iti"ate and
that thin#s happen accordin# to the ordinar& course of nature and the ordinar&
ha%its of life,
[/]
Cence this petition,
Fe =nd no reversi%le error co""itted %& the Court of Appeals,
First. -etitioners contend that the "arria#e of +avino and Catalina should have
%een proven in accordance with Arts, 02 and 0< of the Civil Code of 133/ %ecause
this was the law in force at the ti"e the alle#ed "arria#e was cele%rated, Art, 02
provides that "arria#es cele%rated under the Civil Code of 133/ should %e proven
onl& %& a certi=ed cop& of the "e"orandu" in the Civil 4e#istr& unless the %oo7s
thereof have not %een 7ept or have %een lost or unless the& are Iuestioned in the
courts in which case an& other proof such as that of the continuous possession %&
parents of the status of hus%and and wife "a& %e considered provided that the
re#istration of the %irth of their children as their le#iti"ate children is also
su%"itted in evidence,
This Court noted lon# a#o however that Arts, <; to 1DG of the Civil Code of 133/ of
Spain did not ta7e eEect havin# %een suspended %& the +overnor +eneral of the
-hilippines shortl& after the e>tension of that code to this countr&,
[1D]
ConseIuentl&
Arts, 02 and 0< never ca"e into force, Since this case was %rou#ht in the lower
court in 1/13 the e>istence of the "arria#e "ust %e deter"ined in accordance with
the present Civil Code which repealed the provisions of the for"er Civil Code
e>cept as the& related to vested ri#hts
[11]
and the rules on evidence, 5nder the
4ules of Court the presu"ption is that a "an and a wo"an conductin# the"selves
as hus%and and wife are le#all& "arried,
[1;]
This presu"ption "a& %e re%utted onl&
%& co#ent proof to the contrar&,
[12]
In this case petitioners8 clai" that the
certi=cation presented %& private respondents 'to the eEect that the record of the
"arria#e had %een lost or destro&ed durin# the war* was %elied %& the production of
the (oo7 of Barria#es %& the assistant "unicipal treasurer of Asturias, -etitioners
ar#ue that this %oo7 does not contain an& entr& pertainin# to the alle#ed "arria#e
of private respondents8 parents,
This contention has no "erit, In Pugeda v. Trias
[1<]
the defendants who Iuestioned
the "arria#e of the plaintiEs produced a photostatic cop& of the record of
"arria#es of the Bunicipalit& of 4osario Cavite for the "onth of Aanuar& 1/11 to
show that there was no record of the alle#ed "arria#e, Nonetheless evidence
consistin# of the testi"onies of witnesses was held co"petent to prove the
"arria#e, Indeed althou#h a "arria#e contract is considered pri"ar& evidence of
"arria#e
[10]
the failure to present it is not proof that no "arria#e too7 place, Other
evidence "a& %e presented to prove "arria#e,
[11]
Cere private respondents proved
throu#h testi"onial evidence that +avino and Catalina were "arried in 1/;/L that
the& had three children one of who" died in infanc&L that their "arria#e su%sisted
until 1/20 when +avino diedL and that their children private respondents herein
were reco#ni:ed %& +avino8s fa"il& and %& the pu%lic as the le#iti"ate children of
+avino,
Neither is there "erit in the ar#u"ent that the e>istence of the "arria#e cannot %e
presu"ed %ecause there was no evidence showin# in particular that +avino and
Catalina in the presence of two witnesses declared that the& were ta7in# each
other as hus%and and wife,
[1G]
An e>chan#e of vows can %e presu"ed to have %een
"ade fro" the testi"onies of the witnesses who state that a weddin# too7 place
since the ver& purpose for havin# a weddin# is to e>chan#e vows of "arital
co""it"ent, It would indeed %e unusual to have a weddin# without an e>chan#e
of vows and Iuite unnatural for people not to notice its a%sence,
The law favors the validit& of "arria#e %ecause the State is interested in the
preservation of the fa"il& and the sanctit& of the fa"il& is a "atter of constitutional
concern, As stated in Adong v. Cheong Seng GeeM
[13]
The %asis of hu"an societ& throu#hout the civili:ed world is that of
"arria#e, Barria#e in this Jurisdiction is not onl& a civil contract %ut it is a new
relation an institution in the "aintenance of which the pu%lic is deepl&
interested, ConseIuentl& ever& intend"ent of the law leans toward le#ali:in#
"atri"on&, -ersons dwellin# to#ether in apparent "atri"on& are presu"ed in the
a%sence of an& counter6presu"ption or evidence special to the case to %e in fact
"arried, The reason is that such is the co""on order of societ& and if the parties
were not what the& thus hold the"selves out as %ein# the& would %e livin# in the
constant violation of decenc& and of law, A presu"ption esta%lished %& our Code of
Civil -rocedure is ?that a "an and a wo"an deportin# the"selves as hus%and and
wife have entered into a lawful contract of "arria#e,@ 'Sec, 22< No, ;3* Semper
praesumitur pro matrimonio Alwa&s presu"e "arria#e, '5,S, vs, Villafuerte and
4a%ano [1/D0] < -hil, <G1L Son Cui vs, +uepan#co supraL 5,S, vs, Be"oracion and
5ri [1/11] 2< -hil, 122L Teter vs, Teter [133<] 1D1 Ind, 1;/,*
Second, -etitioners contend that private respondents8 reliance solel& on testi"onial
evidence to support their clai" that private respondents had %een in the continuous
possession of the status of le#iti"ate children is contrar& to Art, ;10 of the Civil
Code which provides that such status shall %e proven %& the record of %irth in the
Civil 4e#ister %& an authentic docu"ent or %& =nal Jud#"ent, (ut in accordance
with Arts, ;11 and ;1G in the a%sence of titles indicated in Art, ;10 the =liation of
children "a& %e proven %& continuous possession of the status of a le#iti"ate child
and %& an& other "eans allowed %& the 4ules of Court or special laws, Thus the
Civil Code providesM
A4T, ;11, In the a%sence of the titles indicated in the precedin# article the =liation
shall %e proved %& the continuous possession of status of a le#iti"ate child
A4T, ;1G, In the a%sence of a record of %irth authentic docu"ent =nal Jud#"ent or
possession of status le#iti"ate =liation "a& %e proved %& an& other "eans allowed
%& the 4ules of Court and special laws,
-etitioners contend that there is no Justi=cation for presentin# testi"onies as to the
possession %& private respondents of the status of le#iti"ate children %ecause the
(oo7 of Barria#es for the &ears 1/;361/;/ is availa%le,
Fhat is in issue however is not the "arria#e of +avino and Catalina %ut the
=liation of private respondents as their children, The "arria#e of +avino and
Catalina has alread& %een shown in the precedin# discussion, The treasurer of
Asturias Ce%u certi=ed that the records of %irth of that "unicipalit& for the &ear
1/2D could not %e found presu"a%l& %ecause the& were lost or destro&ed durin#
the war 'E>h, .*, (ut Batias -o#o& testi=ed that +avino and Catalina %e#ot three
children one of who" -etronilo died at the a#e of si>, Catalina testi=ed that
private respondents 4a"onito and +eneroso are her children %& +avino
(alo#%o#, That private respondents are the children of +avino and Catalina
(alo#%o# cannot therefore %e dou%ted,
Boreover the evidence in the record shows that petitioner +audioso (alo#%o#
ad"itted to the police of (ala"%an Ce%u that 4a"onito is his nephew, As the
Court of Appeals foundM
Ironicall& it is appellant +audioso hi"self who supplies the clincher that tips the
%alance in favor of the appellees, In an investi#ation %efore the -olice Investi#atin#
Co""ittee of (ala"%an Ce%u held on Barch 3 1/13 conducted for the purpose of
inIuirin# into a co"plaint =led %& 4a"onito a#ainst a patrol"an of the (ala"%an
police force +audioso testi=ed that the co"plainant in that ad"inistrative case is
his nephew, E>cerpts fro" the transcript of the proceedin#s conducted on that date
'E>hs, ?N@ ?N61@ ?N6;@ ?N62@ and ?N6<@* readM
?Att&, Hia"co 6 Ba& it please this investi#ative %od&,
?N,6 Do &ou 7now the co"plainant in this Ad"inistrative Case No, 1O
?A,6 9es I 7now,
?N,6 Fh& do &ou 7now hi"O
?A,6 I 7now %ecause he is "& nephew,
?N,6 Are &ou in #ood ter"s with &our nephew the co"plainantO
?A,6 9es,
?N,6 Do &ou "ean to sa& that &ou are close to hi"O
?A,6 9es, Fe are close,
?N,6 Fh& do &ou sa& &ou are closeO
?A,6 Fe are close %ecause aside fro" the fact that he is "& nephew we were also
leavin# 'sic* in the sa"e house in (utuan Cit& and I even %arrow 'sic* fro" hi"
"one& in the a"ount of -2DD,DD when I return to (ala"%an Ce%u,
> > > > > > > > >
?N,6 Fh& is 4a"onito (alo#%o# &our nephewO
?A,6 (ecause he is the son of "& elder %rother,@
This ad"ission of relationship is ad"issi%le a#ainst +audioso althou#h "ade in
another case, It is considered as a relia%le declaration a#ain66st interest '4ule 12D
Section ;;*, Si#ni=cantl& +audioso did not tr& to oEer an& e>planation to %lunt the
eEects of that declaration, Ce did not even testif& durin# the trial, Such silence can
onl& "ean that 4a"onito is indeed the nephew of +audioso the for"er %ein# the
son of +avino,
'!ERE#ORE the decision appealed fro" is A##IRMED,
O ORDERED.
Regalado, (Chairman), Romero, Puno, and Torres, r., ., concur
-lot Overview
(
In the "idst of a ra#in# war a plane evacuatin# a #roup of school%o&s fro" (ritain
is shot down over a deserted tropical island, Two of the %o&s 4alph and -i##&
discover a conch shell on the %each and -i##& reali:es it could %e used as a horn to
su""on the other %o&s, Once asse"%led the %o&s set a%out electin# a leader and
devisin# a wa& to %e rescued, The& choose 4alph as their leader and 4alph
appoints another %o& Aac7 to %e in char#e of the %o&s who will hunt food for the
entire #roup,
4alph Aac7 and another %o& Si"on set oE on an e>pedition to e>plore the island,
Fhen the& return 4alph declares that the& "ust li#ht a si#nal =re to attract the
attention of passin# ships, The %o&s succeed in i#nitin# so"e dead wood %&
focusin# sunli#ht throu#h the lenses of -i##&8s e&e#lasses, Cowever the %o&s pa&
"ore attention to pla&in# than to "onitorin# the =re and the Pa"es Iuic7l& en#ulf
the forest, A lar#e swath of dead wood %urns out of control and one of the &oun#est
%o&s in the #roup disappears presu"a%l& havin# %urned to death,
At =rst the %o&s enJo& their life without #rown6ups and spend "uch of their ti"e
splashin# in the water and pla&in# #a"es, 4alph however co"plains that the&
should %e "aintainin# the si#nal =re and %uildin# huts for shelter, The hunters fail in
their atte"pt to catch a wild pi# %ut their leader Aac7 %eco"es increasin#l&
preoccupied with the act of huntin#,
Fhen a ship passes %& on the hori:on one da& 4alph and -i##& notice to their
horror that the si#nal =reQwhich had %een the hunters8 responsi%ilit& to "aintainQ
has %urned out, $urious 4alph accosts Aac7 %ut the hunter has Just returned with
his =rst 7ill and all the hunters see" #ripped with a stran#e fren:& reenactin# the
chase in a 7ind of wild dance, -i##& critici:es Aac7 who hits -i##& across the face,
4alph %lows the conch shell and repri"ands the %o&s in a speech intended to
restore order, At the "eetin# it Iuic7l& %eco"es clear that so"e of the %o&s have
started to %eco"e afraid, The littlest %o&s 7nown as ?littluns@ have %een trou%led
%& ni#ht"ares fro" the %e#innin# and "ore and "ore %o&s now %elieve that there
is so"e sort of %east or "onster lur7in# on the island, The older %o&s tr& to
convince the others at the "eetin# to thin7 rationall& as7in# where such a "onster
could possi%l& hide durin# the da&ti"e, One of the littluns su##ests that it hides in
the seaQa proposition that terri=es the entire #roup,
Not lon# after the "eetin# so"e "ilitar& planes en#a#e in a %attle hi#h a%ove the
island, The %o&s asleep %elow do not notice the Pashin# li#hts and e>plosions in
the clouds, A parachutist drifts to earth on the si#nal6=re "ountain dead, Sa" and
Eric the twins responsi%le for watchin# the =re at ni#ht are asleep and do not see
the parachutist land, Fhen the twins wa7e up the& see the enor"ous silhouette of
his parachute and hear the stran#e Pappin# noises it "a7es, Thin7in# the island
%east is at hand the& rush %ac7 to the ca"p in terror and report that the %east has
attac7ed the",
The %o&s or#ani:e a huntin# e>pedition to search for the "onster, Aac7 and 4alph
who are increasin#l& at odds travel up the "ountain, The& see the silhouette of the
parachute fro" a distance and thin7 that it loo7s li7e a hu#e defor"ed ape, The
#roup holds a "eetin# at which Aac7 and 4alph tell the others of the si#htin#, Aac7
sa&s that 4alph is a coward and that he should %e re"oved fro" o!ce %ut the
other %o&s refuse to vote 4alph out of power, Aac7 an#ril& runs awa& down the
%each callin# all the hunters to Join hi", 4alph rallies the re"ainin# %o&s to %uild a
new si#nal =re this ti"e on the %each rather than on the "ountain, The& o%e& %ut
%efore the& have =nished the tas7 "ost of the" have slipped awa& to Join Aac7,
Aac7 declares hi"self the leader of the new tri%e of hunters and or#ani:es a hunt
and a violent ritual slau#hter of a sow to sole"ni:e the occasion, The hunters then
decapitate the sow and place its head on a sharpened sta7e in the Jun#le as an
oEerin# to the %east, .ater encounterin# the %lood& P&6covered head Si"on has a
terri%le vision durin# which it see"s to hi" that the head is spea7in#, The voice
which he i"a#ines as %elon#in# to the .ord of the $lies sa&s that Si"on will never
escape hi" for he e>ists within all "en, Si"on faints, Fhen he wa7es up he #oes
to the "ountain where he sees the dead parachutist, 5nderstandin# then that the
%east does not e>ist e>ternall& %ut rather within each individual %o& Si"on travels
to the %each to tell the others what he has seen, (ut the others are in the "idst of a
chaotic revelr&Qeven 4alph and -i##& have Joined Aac78s feastQand when the& see
Si"on8s shadow& =#ure e"er#e fro" the Jun#le the& fall upon hi" and 7ill hi" with
their %are hands and teeth,
The followin# "ornin# 4alph and -i##& discuss what the& have done, Aac78s hunters
attac7 the" and their few followers and steal -i##&8s #lasses in the process, 4alph8s
#roup travels to Aac78s stron#hold in an atte"pt to "a7e Aac7 see reason %ut Aac7
orders Sa" and Eric tied up and =#hts with 4alph, In the ensuin# %attle one %o&
4o#er rolls a %oulder down the "ountain 7illin# -i##& and shatterin# the conch
shell, 4alph %arel& "ana#es to escape a torrent of spears,
4alph hides for the rest of the ni#ht and the followin# da& while the others hunt hi"
li7e an ani"al, Aac7 has the other %o&s i#nite the forest in order to s"o7e 4alph out
of his hidin# place, 4alph sta&s in the forest where he discovers and destro&s the
sow8s head %ut eventuall& he is forced out onto the %each where he 7nows the
other %o&s will soon arrive to 7ill hi", 4alph collapses in e>haustion %ut when he
loo7s up he sees a (ritish naval o!cer standin# over hi", The o!cer8s ship noticed
the =re ra#in# in the Jun#le, The other %o&s reach the %each and stop in their trac7s
at the si#ht of the o!cer, A"a:ed at the spectacle of this #roup of %loodthirst&
sava#e children the o!cer as7s 4alph to e>plain, 4alph is overwhel"ed %& the
7nowled#e that he is safe %ut thin7in# a%out what has happened on the island he
%e#ins to weep, The other %o&s %e#in to so% as well, The o!cer turns his %ac7 so
that the %o&s "a& re#ain their co"posure,
Lord o) *h+ #,-+. /00ar1
Cow It All +oes Down
Fhen !ord o" the Flies opens a plane carr&in# a #roup of (ritish %o&s a#es 1 to 1;
has crashed on a deserted island in the -aci=c Ocean, Oops, 'Also apparentl& the
world is at war, This "atters,* Fith no adults around the %o&s are left to fend for
and #overn the"selves, Thin#s start out o7a&, The %o&s use a conch shell as a
tal7in# stic7 and 4alph one of the older %o&s %eco"es Rchief,R
And then trou%le %e#ins, The&Sre afraid of a R%eastR so"ewhere on the island and
then the& decide to %uild a si#nal =re usin# the #lasses of a %o& na"ed -i##& 'who
is a portl& fellow and also the "ost lo&al friend to 4alph*, (ut Aac7 Jealous of
4alphSs power decides the %o&s should devote their ener#ies to huntin# food
'na"el& pi#s* instead of "aintainin# the =re, The lon#er the&Sre on the island the
"ore sava#e he %eco"es, Beanwhile our other 7e& pla&er a wise and philosophical
%o& na"ed Si"on wor7s with 4alph to %uild shelters,
Eventuall& these latent conPicts %eco"e not so latent and the %o&s who are
supposed to %e tendin# the =re s7ip out on their duties to 7ill a pi#, The %lood and
#ore of the hunt is all ver& e>citin# until the& reali:e that while the& were out %ein#
%loodthirst& %o&s the =re went out and a ship passed %& without noticin# the",
Aac7 has also "ana#ed to punch -i##& in the face and %rea7 one lens of his #lasses,
Not #ood,
4i#ht a%out this ti"e a dead "an attached to a parachute %lows inBar&6-oppins6
st&le to the island, The "&sterious parachutin# creature is "ista7en for the %east
and the %o&s %e#in a "assive hunt to 7ill it, Onl& Si"on 'and letSs face it the
audience* is s7eptical %elievin# instead the&Sre reall& Just afraid of the"selves, Ce
#oes oE into the woods to conte"plate the situation while Aac7 and 4alph ascend
the "ountain and =nd the %eastQ%ut donSt stic7 around lon# enou#h to see that it
is in fact onl& a dead "an,
(ac7 in the #roup Aac7 decides 4alph shouldnSt %e chief an&"ore, Ce secedes and
invites whoever wants to co"e with hi" and 7ill thin#s 'li7e "ore pi#s and "a&%e
so"e people if the& feel li7e it*, Bost of the older 7ids #o with hi" and Si"on
hidin# watches Aac7 and Co, hunt a pi#, This ti"e the& slau#hter a fat "other pi#
'in a scene descri%ed so"ewhat as a rape* cut oE her head and Ja" it onto a stic7
in the #round, Nice,
Si"on stares at the head which he calls Rthe .ord of the $liesR as it tells hi" 'heSs
hallucinatin# %& the wa&* that it is the %east and that it is part of hi" 'Si"on*,
Si"on passes out #ets a %lood& nose and wa7es up covered in sweat %lood and
other #enerall& dis#ustin# thin#s, Despite all this he decides to continue up the
"ountain to face the %east i,e, dead #u&, Then he vo"its and sta##ers down the
"ountain,
(& now 4alph and -i##& '%oth rather ravenous* are attendin# 'with all the other
%o&s* a %i# feastKpart& that Aac7 'decorated li7e an idol* is throwin#, ItSs all a
fren:ied reenact"ent of the pi# hunt until Si"on still %lood& sweat& and covered
in pu7e stu"%les down into the center of the cra:ed %o&s, Ce tries to tell the"
a%out the %east %ut he is unreco#ni:a%le and the %o&s Ja% at hi" with their spears
until heSs dead, Oops, Si"onSs %od& is washed out to sea that ni#ht and the wind
carries oE the %od& of the dead parachutin# "an while 4alph and -i##& convince
the"selves the& didnSt ta7e part in "urderin# Si"on,
ItSs all downhill fro" here, Aac7Ss crew attac7s 4alph and -i##& and steals -i##&Ss
e&e#lasses to "a7e =re on their own, Fhen 4alph and -i##& decide to cal"l& tal7 it
out with the Rsava#esR 4o#er pushes a hu#e %oulder oE a cliE 7illin# -i##&, 4alph
ends up runnin# for his life =nds out that thereSs a head6on6stic7 future planned for
hi" and at last "a7es it to the shore of the island where he runs intoT an o!cer of
the (ritish Nav&, The %o&s are rescued fro" their "oc7 war %ut weSre left with the
i"a#e of the Nav&Ss Rtri" cruiserR fro" the real war of the adults,
E>traJudicial 7illin#s and forced disappearances in the -hilippines
E2*ra3/d-c-a, 4-,,-n5. and )orc+d d-.a66+aranc+. -n *h+ $h-,-66-n+. are
ille#al liIuidations unlawful or felonious 7illin#s and forced disappearances in
the -hilippines,
[1]
These are for"s ofe>traJudicial punish"ent and include
e>traJudicial e>ecutions su""ar& e>ecutions ar%itrar& arrest and detentions and
failed prosecutions due to political activities of leadin# political trade union
"e"%ers dissident andKor social =#ures left6win# political parties non6
#overn"ental or#ani:ations political Journalists outspo7en cler#& anti6"inin#
activists a#ricultural refor" activists "e"%ers of or#ani:ations that are allied or
le#al fronts of the co""unist "ove"ent li7e R(a&an #roupR or suspected
supporters of the N-A and its political win# the Co""unist -art& of the
-hilippines 'C--*
[;][2]
%& either the state #overn"ent state authorities li7e the ar"ed
forces and police 'as in .i%eria under Charles +, Ta&lor* or %& cri"inal out=ts such
as the Italian Ba=a,
[citation needed]
E>traJudicial 7illin#s 'EAHs* is also s&non&"ous with the ter" Re>trale#al 7illin#sR
'E.Hs*, E>traJudicialK e>trale#al 7illin#s 'EAHsK E.Hs* and enforced disappearances
'EDs* are uniIue in the -hilippines in as "uch as it is pu%licl& and co""onl& 7nown
to %e co""itted also %& non6state ar"ed #roups 'NA+s* such as the New -eoples
Ar"& 'N-A* and the Boro Isla"ic .i%eration $ront 'BI.$*, Thou#h cases have %een
well docu"ented with conservative esti"ates of EAHsK E.Hs and EDs co""itted %&
the N-As nu"%erin# to a%out /DD61DDD victi"s %ased on the discover& of
nu"erous "ass #rave sites all over countr& le#al "echanis"s for accounta%ilit& of
non6state actors have %een wea7 if not wholl& non6e>istent,
Aside fro" the -hilippines e>traJudicial 7illin#s death
sIuads and desaparecidos were co""on in South and Central A"erica durin# the
cold war, It is also currentl& co""on in the Biddle East,
Nature[edit source U edit%eta]
-hilippine e>traJudicial 7illin#s are politicall& "otivated "urders co""itted %&
#overn"ent o!cers punished %& local and international law or convention, The&
include assassinationsL deaths due to stra=n# or indiscri"inate =rin#L
"assacreL su""ar& e>ecution is done if the victi" %eco"es passive %efore the
"o"ent of death 'i,e, a%duction leadin# to death*L assassination "eans forthwith
or instant 7illin# while "assacre is a7in to #enocide or "ass e>ter"inationL thus
7illin#s occurred in "an& re#ions or places throu#hout the -hilippines in diEerent
ti"es 6 121 7illin#s in Southern Ta#alo# re#ion were recorded %& hu"an ri#hts
#roup Harapatan fro" ;DD1 to Ba& 1/ ;DD1,
[<][0][1]
A forced disappearance 'desaparecidos* on the other hand as for" of e>traJudicial
punish"ent is perpetrated %& #overn"ent o!cers when an& of its pu%lic o!cers
a%ducts an individual to vanish fro" pu%lic view resultin# to "urder or
plain seIuestration, The victi" is =rst 7idnapped then ille#all& detained
in concentration ca"ps often tortured and =nall& e>ecuted and the corpse hidden,
In Spanish and -ortu#uese Rdisappeared peopleR are called desaparecidos a ter"
which speci=call& refers to the "ostl& South A"erican victi"s of state
terroris" durin# the 1/GDs and the 1/3Ds in particular concernin# Operation
Condor, In the International Convention for the -rotection of All -ersons fro"
Enforced Disappearance REnforced disappearanceR is de=ned in Article ; of
the 5nited Nations Convention A#ainst Torture as Rthe arrest detention a%duction
or an& other for" of deprivation of li%ert& %& a#ents of the State or %& persons or
#roups of persons actin# with the authori:ation support or acIuiescence of the
State followed %& a refusal to ac7nowled#e the deprivation of li%ert& or %&
conceal"ent of the fate or wherea%outs of the disappeared person which place
such a person outside the protection of the law,R
[G][3]
Even if -hilippine 4epu%lic Act No, G<23
[/]
provides for the ri#hts of persons
arrested detained it does not punish acts of enforced disappearances, Thus on
Au#ust ;G (a&an Buna '-eople $irst* +a%riela Fo"enSs -art& '+F-*
and Ana7pawis 'Toilin# Basses* =led Couse (ill ;;12 6 ?An act de=nin# and
penali:in# the cri"e of enforced or involuntar& disappearance,@ Sen, Ain##o&
Estrada also =led last Aune 2D ;DDG Senate (ill No, G 6 ?An Act -enali:in# the
Co""ission of Acts of Torture and Involuntar& Disappearance of -ersons Arrested
Detained or 5nder Custodial Investi#ation and +rantin# Aurisdiction to the
Co""ission on Cu"an 4i#hts to Conduct -reli"inar& Investi#ation for Violation of
the Custodial 4i#hts of the Accused A"endin# for this -urpose Sections ; 2 and <
of 4A G<23 and for Other -urposes,@
[1D][11][1;]
For e#tra$udicial e#ecutions see also Assassination
(ac7#round[edit source U edit%eta]
Marco. r+5-0+[edit source U edit%eta]
In 1//0 1DDDD $ilipinos won a 5,S, class6suit a#ainst the $erdinand Barcos estate,
The char#es were =led %& victi"s or their survivin# relatives for torture e>ecution
and disappearances,
[12]
Cu"an ri#hts #roups placed the nu"%er of victi"s of
e>traJudicial 7illin#s under "artial law at 10DD and over 3DD
a%ductionsL Harapatan 'a local hu"an ri#hts #roupSs* records show G0/ involuntaril&
disappeared 'their %odies never found*, Bilitar& historian Alfred BcCo& in his %oo7
RCloser than (rothersM Banhood at the -hilippine Bilitar& Acade"&R and in his
speech RDar7 .e#ac&R cites 2;0G e>traJudicial 7illin#s 20DDD torture victi"s and
GDDDD incarcerated durin# the Barcos &ears,
[1<][10]
The newspaper R(ulatlatR places
the nu"%er of victi"s of ar%itrar& arrest and detention at 1;DDDD,
[11][1G][13]
Alfred F,
BcCo& '%, 1/<0* is a historian and a -rofessor of Cistor& at the 5niversit& of
FisconsinVBadison, Ce earned his (achelor of Arts fro" Colu"%ia Colle#e
[1/]
and
his -h,D in Southeastern Asian histor& fro" 9ale 5niversit&,
The New -eopleSs Ar"& 'N-A* #roups 7nown as RSparrow 5nitsR were active in the
"id61/3Ds 7illin# #overn"ent o!cials police personnel "ilitar& "e"%ers and
an&one else the& tar#eted for eli"ination, The& were also part of an N-A operation
called RA#aw Ar"asR '$ilipino for RStealin# FeaponsR* where the& raided
#overn"ent ar"ories as well as stealin# weapons fro" slain "ilitar& and police
personnel, A low level civil war with south Bosle"s Al6Naeda s&"pathi:ers
and co""unist insur#ents has led to a #eneral %rea7 down of law and order,
The -hilippines #overn"ent has pro"ised to cur% the 7illin#s %ut is itself i"plicated
in "an& of the 7illin#s,
[;D][;1][;;]
Since 1/G0 the Ar"ed $orces of the -hilippines 'A$-* was deepl& concerned in
politics, (ecause of the ar"ed conPict the "ilitar& continued its ca"pai#n versus
the New -eople8s Ar"& of the Co""unist -art& of the -hilippines 'C--*, Since 1/1/
it ai"ed to esta%lish a Bar>ist re#i"e with ar"ed re%ellion a#ainst the #overn"ent,
On top of all these chaos left6win# non6#overn"ental or#ani:ations 'N+Os*
wereKare critical of the +loria Bacapa#al6Arro&oad"inistration, The "e"%ers who
associated with the C-- and N-A had %een tar#eted as victi"s in the spate of
political 7illin#s, Cu"an 4i#hts Fatchinvesti#ated e>traJudicial "urders in the
-hilippines in Septe"%er ;DDG,
[;2][;<][;0]
-hilip Alston
Three "aJor investi#ation #roups were co""issioned and their =nal reports had
%een su%"itted and pu%lishedM the +loria Bacapa#al6Arro&o #overn"ent6appointed
%odiesM a* Tas7 $orce 5si# created %& her on Au#ustL as a special police %od& it was
assi#ned to solve 1D cases of 7illin#sL it clai"ed havin# solved ;1 cases %&
initiatin# court cases %ut onl& 1; suspects were arrestedL %* the Belo Co""ission
'chaired %& Supre"e Court Associate Austice Aose Belo* with "e"%ers National
(ureau of Investi#ation Director Nestor Bantarin# Chief State -rosecutor Aovencito
WuXo (ishop Auan de dios -ue%los and Nelia Torres +on:alesL its =nal report statesM
RThere is no o!cial or sanctioned polic& on the part of the "ilitar& or its civilian
superiors to resort to what other countries euphe"isticall& call ?alternative
procedures@Q"eanin# ille#al liIuidations, Cowever there is certainl& evidence
pointin# the =n#er of suspicion at so"e ele"ents and personalities in the ar"ed
forces in particular +eneral Aovito -alparan as responsi%le for an undeter"ined
nu"%er of 7illin#s %& allowin# toleratin# and even encoura#in# the 7illin#s,R 'Belo
Co""ission report p, 02*
[;1]
and c* the 5nited Nations Special 4apporteur on
E>traJudicial E>ecutions '$e%ruar& 1; to ;1 ;DDG*
4e"edies[edit source U edit%eta]
Ma,aca7an58. 6+ac+ ./00-* and $/no8. 4-,,-n5. ./00-*[edit
source U edit%eta]
(ecause of the "a#nitude of -hilippine 7illin#s and desaparecidos
;;nd Chief Austice 4e&nato -uno of the Supre"e Court of the
-hilippines called a National Consultative Su""it on e>traJudicial 7illin#s on
Aul& 11 and 1G ;DDG at the Banila Cotel, Invited representatives fro" the
%ranches of the #overn"ent participated 'includin# the Ar"ed $orces of the
-hilippines the -N- Co""ission on Cu"an 4i#hts '-hilippines*
"edia acade"e civil societ& and other sta7eholders*, On the other hand
the BalacaXan#6sponsored RBindanao -eace and Securit& Su""itR 'Aul& 3V
1D ;DDG at Ca#a&an de Oro Cit&* concentrated on the anti6terror law or the
Cu"an Securit& Act 'CSA* of ;DDG to "a7e it "ore accepta%le to the pu%lic,
[;G][;3]
At the Aul& 11 su""it 4e&nato -uno stated that he Co""ission on
Cu"an 4i#hts reported the nu"%er of victi"s at <D2 fro" ;DD1 to Ba& 21
;DDG while Harapatan reported 312 deaths
[;/]
until ;DDG and "ore than /DD
as of Ba& ;DD3 and "ost of the" were "e"%ers of left win# #roups,
Harapatan further o!ciall& placed the nu"%er of victi"s of hu"an ri#hts
violationsM forced evacuations or displace"ent at G<<; %& indiscri"inate
=rin# with 0<0/ victi"s and food and econo"ic %loc7ade with 2D<;,
[2D]
The
ri#hts #roup Desparecidos o!ciall& reported as of Ba& 10 ;DD3 1/< victi"s
of enforced disappearances under the Arro&o ad"inistration with the latest
a%duction of National De"ocratic $ront political consultant for Ca#a&an
Valle& activist 4and& $eli> Bala&ao 2/ a volunteer wor7er,
[21]
Counsels for the Defense of .i%erties 'CODA.* -hilippines a law&ers8
or#ani:ation stated that since ;DD1 ;1 law&ers and 1D Jud#es were 7illed
due to their professionsL G00 civilians had %een 7illed e>traJudiciall& while
20/ survived attac7s %ut 13< persons were still "issin#,
[2;]
(ishop Deo#racias IXi#ue: stated that on the C(C-KCatholic ChurchSs count
the nu"%er of victi"s of e>traJudicial 7illin#s is GG3 while survivors of
Rpolitical assassinationsR reached 2GDL ;D2 R"assacreR were victi"s 131
"issin# or involuntaril& disappeared 0D; tortured or ille#all& arrested,
IXi#ue: denounced the #overn"entSs i"ple"entation of its Oplan (anta&
.a&a I and II,
[22][2<][20][21][2G]
$ro0/,5a*-on o) 'r-*. o) A06aro and !a9+a. Da*a[edit source U edit%eta]
(ecause of the ine!cac& and insu!cienc& of the -hilippines Frit of Ca%eas Corpus
on Septe"%er ;0 ;DDG Chief Austice 4e&nato -uno si#ned and released the Frit of
A"paroM RThis rule will provide the victi"s of e>trale#al 7illin#s and enforced
disappearances the protection the& need and the pro"ise of vindication for their
ri#hts, This rule e"powers our courts to issue reliefs that "a& %e #ranted throu#h
Judicial orders of protection production inspection and other relief to safe#uard
oneSs life and li%ert& The writ of a"paro shall hold pu%lic authorities those who too7
their oath to defend the constitution and enforce our laws to a hi#h standard of
o!cial conduct and hold the" accounta%le to our people, The soverei#n $ilipino
people should %e assured that if their ri#ht to life and li%ert& is threatened or
violated the& will =nd vindication in our courts of JusticeS,R
[23][2/][<D][<1]
-uno e>plained
the interi" reliefs under a"paroM te"porar& protection order 'T-O* inspection order
'IO* production order '-O* and witness protection order 'F-O 4A 1/31*,
[<;]
As
supple"ent to A"paro on Au#ust 2D ;DDG -uno 'at Silli"an
5niversit& in Du"a#uete Cit& Ne#ros Oriental* pro"ised to release also the %rit o"
ha&eas data '?&ou should have the idea@ or ?&ou should have the data@* another
new le#al re"ed& to solve the e>traJudicial 7illin#s and enforced disappearances,
-uno e>plained that the %rit o" amparo denies to authorities defense of si"ple
denial and ha&eas data can =nd out what infor"ation is held %& the o!cer rectif&
or even the destro& erroneous data #athered, (ra:il used the writ followed
%& Colo"%ia -ara#ua& -eru Ar#entina and Ecuador,
[<2]
On Dece"%er 2 ;DDG 4e&nato S, -uno stated that the writ released onl&
three victi"s 'includin# .uisito (usta"ante Davao Cit&* since a"paro was
enforced on Octo%er ;<M RI would li7e to thin7 that after the enact"ent and
eEectivit& 'of the writ* the nu"%er of e>traJudicial 7illin#s and
disappearances have #one down,R
[<<]
On Dece"%er 1G ;DDG Iloilo re#ional trial court Aud#e Narciso A#uilar
#ranted a writ of a"paro a#ainst -resident +loria Bacapa#al6Arro&o and /
"ilitar& and police o!cials to release Nilo Arado and Baria .uisa -osa6
Do"inado activists a%ducted on April 1;,
[<0]
On Dece"%er 1/ ;DDG Dra, Edita (ur#os petitioned the -hilippine Court of
Appeals to issue a writ of a"paro a#ainst Ar"ed $orces chief +en,
Cer"o#enes Esperon Ar and Ar"& chief .t, +en, Ale>ander 9ano re#ardin# her
son AonasSs a%duction on April ;3,
[<1]
On Dece"%er ;G ;DDG the ;nd Division Court of Appeals 2D6pa#e decision
penned %& Associate Austice .ucas (ersa"in #ranted the writ of a"paro =led
%& 4e&naldo and 4a&"ond Banalo a%ducted activists,
[<G]
For other legal remedies see also 'rit o" Amparo and (a&eas )ata (Philippines)
In*+rna*-ona, 5ro/6.8 :;;< and :;;8 6ro9+ o) 4-,,-n5.[edit source U edit%eta]
In ;DD1 the Dutch .aw&ers for .aw&ers $oundation and .aw&ers without (orders
with the support of the Netherlands (ar Association the A"sterda" (ar Association
and the International Association of De"ocratic .aw&ers created a fact6=ndin#
"ission in diEerent parts of the -hilippines, The international #roups conducted
interviews of various le#al sectors fro" Aune 10 to Aune ;D ;DD1,
$ro" Nove"%er <V1; ;DD3 the Dutch .aw&ers for .aw&ers $oundation will conduct
a follow6up veri=cation and fact =ndin# "ission 'IV$$B* in Banila and Bindanao
with the National Cost Co""ittee National 5nion of -eoplesS .aw&ers 'N5-.* and
the Counsels for the Defense of .i%erties 'CODA.*, This tea" is co"posed of 3
Jud#es and law&ers fro" (el#iu" and Netherlands who had dialo#ue with 4e&nato
-uno on the pro%e of 7illin#s,
[<3]

[</][0D]
In*+rna*-ona, cr-*-c-.0[edit source U edit%eta]
On Septe"%er ;3 ;DDG the Asian Cu"an 4i#hts Co""ission 'AC4C* critici:ed
the Frit of A"paro and Ca%eas Data '-hilippines* for %ein# insu!cientM RThou#h it
responds to practical areas it is still necessar& that further action "ust %e ta7en in
addition to this, The le#islative %odies Couse of 4epresentatives and Senate should
also initiate its own actions pro"ptl& and without dela&, The& "ust enact laws which
ensure protection of ri#htsQlaws a#ainst torture and enforced disappearance and
laws to aEord adeIuate le#al re"edies to victi"s,R AC4C o%Jected since
the writfailed to protect non6witnesses even if the& too face threats or ris7 to their
lives,
[01]
International reports 6 the root cause of 7illin#s[edit source U edit%eta]
A,.*on UN r+6or*[edit source U edit%eta]
-hilip Alston su%"itted his =nal report on the 7illin#sL he found that the
Ar"ed $orces of the -hilippines 7illed left6win# activists to #et rid of
co""unist insur#entsM Rthe e>ecutions had ?eli"inated civil societ& leaders
includin# hu"an ri#hts defenders trade unionists and land refor" advocates
inti"idated a vast nu"%er of civil societ& actors and narrowed the countr&8s
political discourse,@ Alston denied for lac7 of "erit the #overn"entSs clai"
that 7illin#s were perpetrated %& co""unists to e>ter"inate spies and to
"a7e ne#ative propa#anda versus #overn"ent, Alston on $e%ruar& ;DDG
stated that the "ilitar& "ade ali%is or denials on its role a%out 3DD deaths of
activists and Journalists since ;DD1, Alston %la"ed ?i"punit&@ which caused
the e>ecutions of Journalists and leftist activistsM ?the priorities of the cri"inal
Justice s&ste" had %een ?distorted@ and had ?increasin#l& focused on
prosecutin# civil societ& leaders rather than their 7illers,@ (ut Alston noted
the #overn"entSs creation of 6 special courts to tr& e>traJudicial 7illin#s the
Belo Co""ission and the -hilippine National -olice8s Tas7 $orce 5si#,
[0;][02]
In
the Nove"%er 5,N, Alston report 6 the 7illin#s in ;DDG was onl& 13 hu#e drop
fro" the ;D/ "urdered in ;DD1, Harapatan pu%lished its report however
listin# 32D victi"s of e>traJudicial 7illin#s since ;DD1 under +loria
Bacapa#al6Arro&o,
[0<]
On Barch 1 ;DDG the Supre"e Court of the
-hilippines issued Ad"inistrative Order No, ;06;DDG which created %&
desi#nation // re#ional trial courts to tr& cases of 7illin#s and desaparecidos,
[00]
#a-,+d -n=+.*-5a*-on. and 6ro.+c/*-on.[edit source U edit%eta]
The 5nited Nations Special 4apporteur on E>traJudicial E>ecution found that
Just on paper trails cases are =ledL %ut Alston o!ciall& concluded that ?there
is a passivit& %orderin# on an a%dication of responsi%ilit& which aEects the
wa& in which 7e& institutions and actors approach their responsi%ilities in
relation to such hu"an ri#hts concernsL prosecutors refused to ta7e a role in
#atherin# evidence and instead %ein# purel& passive waitin# for the police
to present the" with a =leL the O"%uds"an8s o!ce did al"ost nothin# in
recent &ears in this re#ard failin# to act in an& of the << co"plaints alle#in#
e>traJudicial e>ecutions attri%uted to State a#ents su%"itted fro" ;DD; to
;DD1,R '?-reli"inar& note on the visit of the Special 4apporteur on
e>traJudicial su""ar& or ar%itrar& e>ecutions -hilip Alston to the
-hilippines '1;V;1 $e%ruar& ;DDG*@ AKC4CK<K;DKAdd,2 Barch ;; ;DDG p, <,
etc,*
[01][0G]
"h+ Er-c G. >ohn and G. E/5+n+ Mar*-n *+.*-0on-+.[edit source U edit%eta]
On Barch 1< ;DDG Eric +, Aohn Deput& Assistant Secretar& for East Asian
and -aci=c AEairs testi=ed %efore the 5SA Senate Su%co""ittee on $orei#n
4elations at Fashin#ton D,C, Aohn su%"itted his written state"entM a* the
increase in e>traJudicial 7illin#s %* the ?Cu7 4e%ellion@ in the 1/<Ds and 0Ds
causin# thousands of "urdered victi"sL c* the co""unist New -eople8s Ar"&
'N-A* which was listed in the 5,S, State Depart"ent list of $orei#n Terrorist
Or#ani:ations ca"pai#ned to overthrow the #overn"ent since 1/13L d*
E>traJudicial 7illin#s %& the securit& forces the N-A etc, durin# the Barcos
re#i"e were lessL and e* noted the report of 5N Special 4apporteur Alston
which su%"itted the -hilippine +overn"ent8s reco#nition of the #ravit& of the
pro%le" e>presses concern a%out the views of the Ar"ed $orces of the
-hilippines 'A$-* re#ardin# the pro%le" %ut "uch had to su%"itted that the
refor"s "ade did not and will not resolve the 7illin#s, Br, AlstonSs Barch
report stated that Rthe Iuestion of resources or technical e>pertise will partl&
resolve the 7illin#s %ut the stron# ris7 is that these "easures will treat onl&
so"e of the s&"pto"s of the crisis and will fail to address "eanin#full& two
of the "ost i"portant underl&in# causes of a #reat "an& of the 7illin#s,R
'AKC4CK<K;DKAdd,2 Barch ;; ;DDG* Alston na"ed two root causes of the
7illin#sM '1* Svili=cationS Sla%elin#8 or #uilt %& association@ 6 Rcharacteri:ation
of "ost #roups on the left of the political spectru" as Yfront or#ani:ations8 for
ar"ed #roups whose ai" is to destro& de"ocrac&R "a7in# the #roups
Rconsidered to %e le#iti"ate tar#etsL and ';* the +overn"ent8s counter6
insur#enc& strate#&Ss e>tent of facilitatin# 7illin#s of activists and others,
[03]
[0/]
+, Eu#ene Bartin speci=call& e>panded the ; causes of the violence and
7illin#sM a* wea7 political and social institutions corrupt and ineEective
Judicial s&ste" resultin# to failure to o%tain Justice fro" corrupt -hilippine
courtsL and %* the le#ac& of the $erdinand Barcos re#i"eL Bartial law caused
the corrupt s&ste" where soldiers police Jud#es and prosecutors %eca"e
principals of oEenses li7e e>trale#al arrest detention incarceration
disappearances and 7illin#s 'salva#in#* all per"itted or allowed, Ce traced
the spate of violence and 7illin#s to political insta%ilit& of -resident Arro&o
#overn"entL while she created the Independent Co""ission to Address
Bedia and Activist Hillin#s Belo Co""ission she had no capa%ilit& to end
the 7illin#s due to her political la"eness %ecause of the ;DD< election
controvers&,
[0/][0/][1D]
#ID! r+6or*[edit source U edit%eta]
Three e>perts fro" the International $ederation for Cu"an
4i#hts 'a%%reviated F*)(* Br, Na%eel 4aJa% '(ahrain* Br, Bouloud
(ou"#har '$rance* and Br, $rZdZric Ceuppens '(el#iu"* ca"e to the
-hilippines on Au#ust 12 to ;2 ;DDG, Their $IDC "ission report stated that
torture and ill6treat"ent was widespread versus suspected ?terrorists@, The
$ilipino #overn"ent is a si#nator& to the International Covenant on Civil and
-olitical 4i#hts 'ICC-4* and the 5N Convention a#ainst Torture 'CAT*, The
$IDC dis"issed the -hilippines #overn"entSs clai" dou%ts that "echanis"s
were placed to stop the 7illin#s as it Iuestioned the e!cienc& of 6 the corrupt
Judiciar& the #overn"ent ?Fitness -rotection -ro#ra""e@ L also Jud#es and
law&ers were victi"s the"selves of 7illin#s, It also found the -hilippine anti6
terroris" law ' ?Cu"an Securit& Act@* to result in "ore torture and
e>traJudicial 7illin#s as a =#ht a#ainst terroris",
[11]
:;;8 U D+6ar*0+n* o) *a*+ r+6or*[edit source U edit%eta]
On Barch 11 ;DD3 the 5S Depart"ent of State reported that Rar%itrar& unlawful
arrests and e>traJudicial and political 7illin#s continued to %e a "aJor pro%le" in the
-hilippines in ;DDG,
[1;]
Fashin#ton stated that R"an& of these 7illin#s went unsolved
and unpunished despite intensi=ed eEorts of the #overn"ent to investi#ate and
prosecute these cases,R
[12]
>/d-c-a, corr/6*-on[edit source U edit%eta]
On Aanuar& ;0 ;DD0 and on Dece"%er 1D ;DD1 -hilippines Social Feather
Stations released the results of its two surve&s on corruption in the Judiciar&L it
pu%lished thatM a* li7e 1//0 1K< of law&ers said "an&Kver& "an& Jud#es are corrupt,
(ut '</[* stated that a Jud#es received %ri%es Just 3[ of law&ers ad"itted the&
reported the %ri%er& %ecause the& could not prove it, [Ta%les 36/]L Jud#es however
said Just G[ call "an&Kver& "an& Jud#es as corrupt[Ta%les 1D611]L%* RAud#es see
so"e corruptionL proportions who said 6 "an&Kver& "an& corrupt Jud#es or JusticesM
1G[ in reference to 4TC Jud#es 1<[ to BTC Jud#es 1;[ to Court of Appeals
Justices <[ i to ShariSa Court Jud#es <[ to Sandi#an%a&an Justices and ;[ in
reference to Supre"e Court Justices [Ta%le 10],
[1<][10]
Ma5/-ndanao 0a..acr+[edit source U edit%eta]
S&"%olic SI"puni6treeS planted for 2rd anniversar& of Ba#uindanao
"assacre'5niversit& of the -hilippines Colle#e of Bass Co""unication 5- Dili"an*,
In the Ba#uindanao "assacre in the -hilippines on Nove"%er ;2 ;DD/ 0G people
were 7illed while en route to =le an electoral certi=cate of candidac& for Es"ael
Ban#udadatu vice "a&or of (uluan town in upco"in# #u%ernatorial elections
for Ba#uindanao province,
[11]
The dead included Ban#udadatuSs wife his two
sisters Journalists law&ers aides and "otorists who were witnesses, At least 1/3
suspects were char#ed with "urder includin# incu"%ent #overnor Andal A"patuan
Sr, and his son Andal A"patuan Ar, who was to %e a candidate to succeed hi",
[1G]
On Nove"%er 11 ;D1D the international non6#overn"ental or#ani:ation Cu"an
4i#hts Fatch issued a /1 pa#e report titled RThe& Own the -eopleR chartin# the
A"patuans8 rise to power includin# their use of violence to e>pand their control
and eli"inate threats to the fa"il&8s rule,
[13]
Events[edit source U edit%eta]
In $e%ruar& ;DDG The 5,S, a"%assador to the -hilippines has %ro7en her
silence and called on Banila to end e>traJudicial 7illin#s, On $e%, ;GHristie
Henne& 5,S, a"%assador to the -hilippines alerted Brs, Arro&o as she voiced
her call to end these 7illin#sM R.etSs %eef up the hu"an ri#hts in the Ar"ed
$orces of the -hilippines and "a7e ever& eEort to investi#ate prosecute
those responsi%le [and] e>onerate the innocent,R
[1/]
In Au#ust ;DDG the International Da& of the Disappeared Asian Cu"an
4i#hts Co""ission 'AC4C* ran7ed the -hilippines a"on# the top ei#ht
countries in Asia where forced disappearances of activists are not Just
ra"pant %ut are done with i"punit&, Sri .an7a heads the list 'state"ent
posted on its we%site 'www,ahrch7,net*, The activists too7 part in the recent
Cu"an 4i#hts School Session of the AC4C for ;DDG, The AC4C listed the
other countries where forced disappearances ta7e place with
i"punit&M -a7istan Indonesia (an#ladesh Nepal Thailand -hilippines and
parts of India,
[GD]
In Septe"%er ;DDG Barie Cilao6EnriIue: Harapatan secretar&6#eneral
for"all& petitioned the 5nited Nations Cu"an 4i#hts Council '5NC4C* to
direct the -hilippine #overn"ent to stop the e>traJudicial 7illin#s, She =led
the report on 1D cases 7illin#s have %een recorded %& Harapatan fro" Aanuar&
to Aune ;DDG alone with 1G cases of disappearances 1; of torture and 112
of ille#al arrests,
[G1][G;]
On Octo%er 2 ;DDG at Tarlac Cit& 1/6&ear6old (ishop Al%erto 4a"ento of the
I#lesia $ilipina Independiente 'I$I* or -hilippine Independent Church and a
vocal critic of 7illin#s under the Arro&o #overn"ent was sta%%ed G ti"es and
7illed,
[G2]
The Dece"%er 11 ;DD1 -hilippines National -olice8s Tas7 $orce 5si#
su%"itted 110 cases of ?slain part& list K"ilitant "e"%ers@ since ;DD1 and
;1 cases of ?"edia"en@, The Philippine )ail+ *n,uirer pu%lished ;// 7illin#s
fro" Octo%er ;DD1 and April ;DDG 'See e,#, Alcuin -apa ?2 5S solons to -N-M
4espect hu"an ri#hts@ -hilippine Dail& InIuirer April 13 ;DDG*
[G<]
The Dece"%er ;DDG &ear end report of Harapatan 'Alliance for the Advance
of -eople8s 4i#hts* noted onl& 13 e>traJudicial 7illin#s vis6a6vis &ear ;DD1 ;D/
victi"s, Harapatan also reported 112DG hu"an ri#hts violations Just for ;DDG
'which include 7illin#s to forci%le displace"ent of co""unities*, Therefore
aside fro" the 33G 7illin#s since ;DD1 under Brs, Arro&o Harapatan Just for
;DDG underscored 20 victi"s of political 7illin#sL ;1 of enforced or
involuntar& disappearanceL 3 of a%ductionL ;/ of tortureL 1;/ of ille#al
arrestL 111 of ille#al detentionL 22D of threat harass"ent and inti"idationL
G0<; of forci%le evacuation or displace"ent 21DD of ?ha"lettin#@
interalia, As onl& solution it petitioned the resi#nation of Brs, Arro&o,
[G0]
'with
201 left6win# activists "urdered*, The -hilippines ar"ed forces %attled the
Co""unists since 1/1/ with a%out <DDDD victi"s 7illed and it had to ward
oE 7illin#s %& Busli" radicals,
[G1]
Cowever Austice 5ndersecretar& 4icardo
(lancaPor head of Tas7 $orce on -olitical Violence contradicted HarapatanSs
su%"ission onl& on the nu"%er of 7illin#s, -N-Ss Tas7 $orce 5si# accordin# to
(lancaPor noted onl& 1<1 cases of which onl& 11< are part& list "e"%ers or
leftist activists,
[GG]
On Dece"%er 12 ;DDG -hilippine Cu"an 4i#hts Co""issioner Do"inador
Cala"%a III at the -hilippine For7in# +roup for an Asean Cu"an 4i#hts
Bechanis" foru" denounced the failure of the #overn"ent in its treat&
reportin# to the 5nited Nations due to R12 reports overdueR 'reports due on
i"ple"entation of international covenants si#ned %& the -hilippines to solve
discri"ination forced disappearances and e>traJudicial 7illin#s*, Cala"%a
reported 232 7illin#s =led with the CC4 of which 1<0 were e>traJudicial or
political in for",
[G3]
On Aanuar& 1 ;DD3 the National 5nion of Aournalists 'N5A* paid tri%ute to 1G1
Journalists 7illed in ;DDG, Citin# data pu%lished %& International $ederation of
AournalistsM IraI was nu"%er one with 10 deathsL in the -hilippines 1
Journalists 7illed on ;DDG were Cernani -astolero 'Sultan Hudarat* Car"elito
-alacios 'Nueva EciJa* Dodie Nune: 'Cavite* +eruncio ROscarR BondeJar
'Bandaue* Vicente Su"alpon# 'Tawi6Tawi* and $ernando R(at"anR .intuan
'Davao Cit&*L 0< Journalists were "urdered under the ad"inistration of
-resident +loria Bacapa#al6Arro&o, In ;DD1 INSI stated that the -hilippines
was the ;nd "ost dan#erous countr& for Journalists ne>t to IraI listin# 10
wor76related Journalists "urdered,
[G/]
On Aanuar& < ;DD3 the International
$ederation of Aournalists 'I$A* Asia6-aci=c director AacIueline -ar7 denounced
the "urders of %roadcasters $ernando .intuan in Davao Cit& and for"er
Journalist 4o"elito Oval Ar, It petitioned the -hilippine #overn"ent to full&
investi#ate ;DDG JournalistsS 7illin#sM R0 Journalists as well as Oval were 7illed
in the -hilippines in ;DDG which is shoc7in# and reveals the e>tre"e dan#ers
that Journalists face ever& da& in tr&in# to carr& out their wor7, There will %e
no press freedo" in the -hilippines until this 'situation* chan#es,R
[3D]
On Aanuar& < ;DD3 Ana7pawis 4ep, Crispin (eltran =led Couse 4esolution
;// with the Couse of 4epresentatives of the -hilippines to investi#ate the
"urders and harass"ent of trade unionKla%or leaders in the -hilippines, Ce
cited the ;DDG annual Surve& of Trade 5nion 4i#hts Violations of
the International Trade 5nion ConfederationM R22 of the total 1<< cases of
trade union 7illin#s worldwide happened in the -hilippinesL and 3DD cases of
%eatin#s and torture of trade unionists in the countr&,R
[31][3;]
On Aanuar& / ;DD3 -N- Tas7 $orce 5si# announced that 2 police"en 11
soldiers and 2 "ilitia"en had %een arrested or na"ed suspects in 7illin#s of
"edia "en and "ilitants since ;DD1, Director AeEerson -, Soriano su%"itted
the report with the 1G na"es to -N- chief Avelino 4a:on, As of Dece"%er 1D
T$ 5si# prosecuted 112 7illin#s cases of part&6list "e"%ers leftist activists
and ;G Journalists,
[32]
Twin horri%le deaths happened onKcirca the sa"e da& last &ear Aanuar& 10
;DDG that the Supre"e Court of the -hilippinesS 'lo#o or seal* was
"&steriousl& %urned into halves %& an al"ost one hour afternoon =re,
[3<]
[30]
Despite diEerent appeals %& local and international #roups the spate of
e>traJudicial 7illin#s in the -hilippines continued, On Aanuar& 10
;DD3 4e&nato -unoconde"ned the "urder of Aud#e 4o%erto Navidad
4e#ional Trial Court (ranch 2; Cal%a&o# Cit& Sa"ar the 10th Jud#e to %e
a"%ushed since Aul& ;D 1/// the 1<th under the Arro&o #overn"ent, Aust
startin# his en#ine %lac7 Nissan -atrol S5V 'T-.6/11* Natividad was shot in
the faceKleft e&e at GM1D p,", Bonda& %& a lone #un"an 08<R tall and
"ediu"6%uilt wearin# %lac7 Jac7et usin# a <0 cali%er pistol,
[31]
On Tuesda&
Catholic "issionar& 4e& 4oda O%lates of Barr& I""aculate 'OBI* 0< was
shot dead at 3M2D p,", when he resisted a%duction atte"pt %& unidenti=ed
1D ar"ed "en in a chapel at i7ud Ta%awan villa#e South 5%ian Tawi6Tawi
South 5%ian, In $e%ruar& 1//G another OBI leader (ishop (enJa"in de Aesus
was shot dead in front of the Aolo cathedral,
[3G]
In ;DD1 the Asian Cu"an
4i#hts Co""ission stated that there had %een ;1 priests pastors and
church"en who were liIuidate or were victi"s of violence under the +loria
Bacapa#al6Arro&o ad"inistration since ;DD1,
[33]
This includes 2 priests who
were reported 7illed Just in ;DDGM (asilio (autista of the I#lesia $ilipina 4efor"
+roup inSuri#ao del Sur Indonesian priest $ransis7us Badhu in Halin#a
province and Catholic priest $lorante 4i#onan in Ilocos Norte,
[3/]
On Aanuar&
1/ ;DD3 the Catholic (ishops Conference of the -hilippines 'Iuotin# fro" a
letter of Vatican Secretar& of State Cardinal Tarciso (ertone* announced that
-ope (enedict )VI Rpraised the coura#e of and was saddened over the %rutal
and tra#ic 7illin# of $r, 4e&naldo 4oda in his "inistr& as head of Notre Da"e
School,R The -ope wrote Aolo (ishop An#elito .a"ponM Rcalls upon the
perpetrators to renounce the wa&s of violence and to pla& their part in
%uildin# a Just and peaceful societ& where all can live to#ether in
har"on&,R
[/D]
On Aanuar& 11 ;DD3 the New 9or76%ased international de"ocrac&
watchdo# $reedo" Couse dropped or rele#ated the Rfreedo" statusR of the
-hilippines to partiall& free fro" a list of totall& free countries, It %ased its
-hilippine status down#rade on the spate of political 7illin#s Rspeci=call&
tar#etin# left6win# political activists in the countr& freedo" in the sloped
downward,R
[/1]
On Aanuar& 13 ;DD3 the Hilusan# Ba#%u%u7id n# -ilipinas 'HB-* led %& HB-
chair"an 4afael RHa -aen#R Bariano 'president of the Ana7pawis*
conde"ned the Aanuar& 1; 7idnappin# and Aanuar& 11 e>traJudicial 7illin#
and torture of their far"er and local leader Teldo 4e%a"onte <0 Bas%ate
-eople8s Or#ani:ation 'who was supposed to Join the co""e"oration of the
Bendiola Bassacre* in (aran#a& Na%asa#an Concepcion in Claveria (urias
Island Bas%ate,
[/;]
On Aanuar& ;2 Harapatan announced that the two latest victi"s of
e>traJudicial 7illin#s wereM Tildo 4e%a"onte <0
a Claveria Bas%ate carpenter who was #unned down on Aanuar& 11 four
da&s after he was alle#edl& 7idnapped %& the -hilippine National -olice8s
4e#ional Bo%ile +roupL and e>6political prisoner 4onald SendriJas 20 who
was shot dead in Ta#%ilaran Cit& (oholon Aanuar& 1G,
[/2]
On Aanuar& ;2 ;DD3 'or in Just nine da&s after the "urder of a priest* -astor
$elicisi"o Cata"%is 1D of the 5nited Church of Christ in the -hilippines
'5CC-* in Catu#an (aran#a& 'villa#e* (alucawe .e&te town was shot dead
%& a still un7nown assailant,
[/<]
On Barch 1< ;DD3 $ilipino law&er Edre Olalia 'lead o!cer of the National
5nion of -eoples8 .aw&ers and the Counsels for the Defense of .i%erties*
%rou#ht the -hilippine case and appealed to the 5nited Nations Cu"an 4i#hts
Council '5NC4C* in its Gth +eneva session Rto stop the e>traJudicial 7illin#s
and a%ductions in the -hilippinesR, -hilippines 7illin#s will %e e>a"ined in the
=rst 5NC4C session periodic review fro" April G to 13 alon# with those in 10
others of 1/; "e"%er6countries,
[/0]
Deepa7 O%hrai -arlia"entar& Secretar& to the Binister of $orei#n AEairs in a
state"ent at CanadaSs Couse of Co""ons co""ended Rthe lauda%le role of
the Supre"e Court in the preservation of hu"an ri#hts and in the pursuit of
Justice,R Canadian A"%assador 4o%ert DesJanis sent the docu"ent to Chief
Austice 4e&nato -uno Rto underline the value that the #overn"ent of Canada
attaches to &our eEorts in this re#ard as well as to our continued
colla%oration in the Austice 4efor" Initiatives Support -roJect,R
[/1]
In the Barch ;DD3 5S Depart"ent of State ;DDG Countr& 4eports on Cu"an
4i#hts -ractices the 5S found that e>traJudicial and political 7illin#s
includin# those of Journalists %& "e"%ers of the "ilitar& police Co""unist
re%els and other terrorist #roups K perpetrators continue to %e a "aJor
pro%le" in the -hilippines, The report added that ?despite intensi=ed eEorts
%& the -hilippine #overn"ent to investi#ate and prosecute these cases "an&
went unsolved and unpunished,@
[/G]
The dele#ates to the 1th Con#ress of the National 5nion of Aournalists of the
-hilippines 'N5A-* led %& chair"an Aose Torres Ar, renewed calls to an end to
una%ated "edia 7illin#, It reported that the list of Journalists "urdered
swelled fro" 1D in ;DD1 to /1 in ;DD3, The "ost recent victi"s were #unned
down local radio %roadcasters of 4adio Bindanao Networ7 Dennis Cuesta
fro"+eneral Santos Cit& and Bartin 4o>as of 4o>as Cit& Capi:,
[/3]
The N5A-
declared Au#ust ;D a RNational Da& of Bournin#R as Journalists wore %lac7 in
protest as the& paid tri%ute to slain "edia practitioners at the (anta&o# n#
"#a (a&ani in Nue:on Cit&,
[//]
E2*ra3/d-c-a, 4-,,-n5. r+0a-n /n6ro.+c/*+d -n $!
(9 BUENA BERNAL
-OSTED ON D0K;2K;D1; 2M1G -B U 5-DATED D0K;<K;D12 /M<D AB
Co""e
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19
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.in7ed
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;
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Shar
e
CA.. $O4 A5STICEM $a"ilies and friends of the victi"s of the Ba#uindanao Bassacre
#ather at Bendiola for a pra&er6rall& su""onin# the hi#h court for an end to
i"punit&, $ile photo %& Elaine Tiu,
BANI.A -hilippines 6 Coldin# people accounta%le for the cri"es the& co""itted
has never %een harder than in cases of e>traJudicial 7illin#s in the -hilippines,
Despite tireless eEorts of victi"s8 fa"ilies and their supporters onl& < cases of
politicall&6"otivated "urders have %een successfull& prosecuted in the countr& over
the last < &ears,
In an interview Elaine -earson deput& director of the Cu"an 4i#hts Fatch Asia
Division e>plained how the lac7 of political will on the part of the AIuino
ad"inistration "irrors a low priorit& it accords to hu"an ri#hts,
5pon his assu"ption of o!ce AIuino inherited an esti"ated 10D cases of
e>traJudicial 7illin#s fro" the Arro&o ad"inistration, A -hilippine hu"an ri#hts
watchdo# Harapatan pe#s this nu"%er at 1;DD,
None of the perpetrators however has %een convicted under AIuino8s leadership,
?Fhile AIuino8s lan#ua#e has %een stron# he has not i"ple"ented the s&ste"ic
refor"s necessar& to stop the 7illin#s and hold perpetrators accounta%le@ a report
fro" New 9or76%ased Cu"an 4i#hts Fatch sa&s,
D+@+c*-on
Althou#h the nu"%er of 7illin#s has #one down hu"an ri#hts advocates are not
i"pressed %& the pro#ression of retri%ution thus far,
In the latest issue of Harapatan Bonitor the #roup stressed AIuino8s failure ?to
render Justice to the victi"s of hu"an ri#hts violations 'C4V* under the 5S6Arro&o
re#i"e,@
A report prepared %& the -residential Cu"an 4i#hts Co""ittee Secretariat with the
assistance of the Depart"ent of $orei#n AEairs 'D$A* and the Depart"ent of Austice
'DOA* records a nu"%er of tas7 forces and hu"an ri#hts "onitorin# tea"s set up
under the AIuino ad"inistration, These tea"s supposedl& involve the participation
%& the "ilitar&,
Still -earson said these tas7 forces dePect fro" the issue of Justice and prosecution
which should %e the top priorit& of the ad"inistration ri#ht now,
A"on# the #reatest hurdles in the eEective prosecution of e>traJudicial 7illin#s and
enforced disappearances in the countr& are the "ilitar&8s failure to cooperate in
investi#ations and the li"itations of the -hilippine cri"inal Justice s&ste" -earson
added,
Even if convicted "ilitar& "e"%ers are held in "ilitar& ca"ps which are far fro"
the eIuivalent of life in prison cells,
-earson said the a%sence of clear directives fro" the -resident to #overn"ent
institutions li7e the "ilitar& is one indication of lac7 of political will,
?Fe si"pl& haven8t seen that stron# state"ent co"in# fro" the top@ she said,
$ro*+c*-on o) *ho.+ ,+)* 9+h-nd
Accordin# to Aose Banuel Dio7no of the $ree .e#al Assistance +roup '$.A+* the
failure to protect witnesses is a "aJor i"pedi"ent in the deliver& of Justice,
An e>pedient Judicial process is inhi%ited %ecause possi%le witnesses fear for their
lives, This is especiall& so in political 7illin#s where the perpetrator is usuall& a
person with power and position,
The Ba#uindanao Bassacre of ;DD/ is one such case, ?Fe 7now that this is not an
isolated case@ said -earson,
The "assacre V which resulted in "ore than 0D civilians 7illed %& a hundred ar"ed
"en V also %rou#ht the countr&8s hu"an ri#hts condition under close scrutin&,
In a separate report Cu"an 4i#hts Fatch called on the -resident to issue an
e>ecutive order %annin# all para"ilitar& and "ilitia forces,
"h+ 6ro9,+0 o) +2*ra3/d-c-a, 4-,,-n5.
In ;D11 alone there have %een 1D docu"ented cases of 7illin#s and
disappearances attri%uted to securit& forces, Not one has %een eEectivel& tried in a
civilian court,
The latest report released last Aul& ;D11 %& the Cu"an 4i#hts Fatch concluded that
pro"pt action in investi#ation and prosecution are needed in view of the recorded
7illin#s perpetrated %& alle#ed "e"%ers of the state "ilitar&,
$urther"ore there is a need to delineate co"%atants fro" civilian activists,
?The "ilitar& still fails V %oth in its words and actions V to diEerentiate %etween the
ar"ed N-A 'New -eople8s Ar"&* and N+Os and political parties that "a& espouse
so"e ele"ents of co""unist or other leftist ideolo#&@ the report reads,
Un-=+r.a, $+r-od-c R+=-+A BU$RC
On Ba& ;/ all e&es will %e on the -hilippines as the 5nited Nations Cu"an 4i#hts
Council '5NC4C* convenes in +eneva to conduct its 5niversal -eriodic 4eview '5-4*
of the countr&,
The council will assess the pro#ress of the -hilippine #overn"ent %ased on previous
reco""endations and will hold it accounta%le for co""it"ents "ade, 5N "e"%er
states "a& also issue speci=c ti"e6%ound reco""endations,
A livestrea" of the discussion will %e held at the Co""ission on Cu"an 4i#hts
o!ce while a si"ultaneous we%cast can %e viewed at the 5nited Nations
"ulti"edia we%site 'httpMKKwww,un"ulti"edia,or#KtvKwe%castKcKun6hu"an6ri#hts6
council,ht"l* fro" 2 to 1M2D p" Banila Ti"e,
The 5-4 is held ever& < &ears durin# which the hu"an ri#hts record of a countr& is
put under the spotli#ht, This is the second ti"e that the -hilippines will %e
reviewed, D Ra66,+r.co0