Crispina

M. Reynera Law I CECILIA ZULUETA VS. COURT OF APPEALS and ALFREDO MARTIN G.R. NO. 107383 CASE ANALYSIS CLAIM/ISSUE: Whether or not the injunction declaring the privacy of communication and correspondence to be inviolable apply even to the spouse of the aggrieved party. WARRANT/RULE: The privacy of communication and correspondence shall be inviolable except upon lawful order of the court, or when public safety or order requires otherwise as prescribed by law. (Art. III, Sec 3 (1), Bill of Rights) Any evidence obtained in violation of this or the preceding section shall be inadmissible for any purpose in any proceeding. (Art. III, Sec 3 (2), Bill of Rights) FACTS: Cecilia Zulueta, the wife of Alfredo Martin, forcibly opened drawers and cabinets of her husband and was able to seize 157 documents containing private correspondence between Dr. Martin and his alleged paramours. The said documents were seized for use in evidence in a case of legal separation and disqualification from practice of medicine. Dr. Martin filed a Motion to Return and Suppress the documents ANALYSIS: The documents seized are clearly in violation of the Constitutional provision on freedom of communication and correspondence. There are exceptions to this provision though but in this case, the wife undoubtedly violated the privacy of the husband. Thus, the documents are considered to be inadmissible in evidence. Applying Sec 3, Par 2 of the Bill of Rights, evidence obtained in violation of paragraph 1 of Sec 3 of the Bill of Rights, these documents are inadmissible in any proceedings. It is not enough justification that the intimacies of the husband and the wife would warrant any one of them in breaking the drawers and cabinets of the other just to get evidence of the infidelity of the other.

Crispina M. Reynera Law I CONCLUSION: The wife evidently violated the right to privacy of the husband; thus, the documents seized could not be used in any proceeding, either by the appeal for legal separation or for the disqualification of the practice of medicine. Thus, the petition for review of the wife was denied for lack of merit.