In this day and age, video surveillance cameras are installed practically everywhere for the protection and safety of everyone. The installation of these cameras, however, should not cover places where there is reasonable expectation of privacy, unless the consent of the individual, whose right to privacy would be affected, was obtained Bill and Victoria, spouses, filed a Complaint for Inunction and !amages with prayer for issuance of a "rit of Preliminary Inunction against #le$ander and #llan% #ccording to them, they own the lot adacent to the lots owned &y #ldo !evelopment and Resources, where #le$ and #llan are stoc'holders% (he corporation &uilt an auto)shop &uilding on Lot *+,,)C adacent to the lot owned &y Bill and Victoria% In #pril, -,,., #ldo filed a case for inunction and damages against Bill and Victoria claiming that they were constructing a fence without a valid permit and the construction would destroy its &uilding% (he court denied the application &y #ldo for preliminary inunction for failure to su&stantiate its allegations% (o gather evidence against the spouses, #ldo illegally set)up on the &uilding of #ldo two video surveillance camera facing petitioners party and through their employees and without the consent of spouses too' pictures of their on)going construction/ thus it violates their right to privacy% (he spouses prayed that #le$ander and #llan &e ordered to remove their video)cameras and stopped from conducting illegal surveillance% #nswering, #le$ander and #llan claimed that they did not install the cameras, nor ordered their employees to ta'e pictures of the spouse0s construction/ they also averred that they are mere stoc'holders of #ldo/ (he Regional (rial Court granted the prayer for temporary restraining order and directed #le$ander and #llan to remove their video cameras and install them elsewhere where the spouse0s property will no longer &e viewed% #le$ander and #llan filed a petition for certiorari with the Court of #ppeals, which granted their petition% Bill and Victoria elevated the case to the 1upreme Court: 2(he right to privacy is enshrined in our Constitution and in our laws% It is defined as 2the right to &e free from unwarranted e$ploitation of one0s person or from intrusion into one0s private activities in such a way as to cause humiliation to a person0s ordinary sensi&ilities%3 It is the right of an individual 2to &e free from unwarranted pu&licity, or to live without unwarranted interference &y the pu&lic in matters in which the pu&lic is not necessarily concerned%3 1imply put, the right to privacy is 2the right to &e let alone%3 (he Bill of Rights guarantees the people0s right to privacy and protects them against the 1tate0s a&use of power% In this regard, the 1tate recogni4es the right of the people to &e secure in their houses% 5o one, not even the 1tate, e$cept 2in case of overriding social need and then only under the stringent procedural safeguards,3 can distur& them in the privacy of their homes%3 $ $ $ 26ur Code specifically mentions 2prying into the privacy of another0s residence%3 (his does not mean, however, that only the residence is entitled to privacy, &ecause the law covers also 2similar acts%3 # &usiness office is entitled to the same privacy when the pu&lic is e$cluded therefrom and only such individuals as are allowed to enter may come in% $ $ $7 89mphasis supplied: (hus, an individual0s right to privacy under #rticle -;8*: of the Civil Code should not &e confined to his house or residence as it may e$tend to places where he has the right to e$clude the pu&lic or deny them access% (he phrase 2prying into the privacy of another0s residence,3 therefore, covers places, locations, or even situations which an individual considers as private% #nd as long as his right is recogni4ed &y society, other individuals may not infringe on his right to privacy% (he C#, therefore, erred in limiting the application of #rticle -;8*: of the Civil Code only to residences%3 $ $ $ In ascertaining whether there is a violation of the right to privacy, courts use the 2reasona&le e$pectation of privacy3 test% (his test determines whether a person has a reasona&le e$pectation of privacy and whether the e$pectation has &een violated% In 6ple v% (orres, we enunciated that 2the reasona&leness of a person0s e$pectation of privacy depends on a two)part test: 8*: whether, &y his conduct, the individual has e$hi&ited an e$pectation of privacy/ and 8-: this e$pectation is one that society recogni4es as reasona&le%3 Customs, community norms, and practices may, therefore, limit or e$tend an individual0s 2reasona&le e$pectation of privacy%3 <ence, the reasona&leness of a person0s e$pectation of privacy must &e determined on a case)to)case &asis since it depends on the factual circumstances surrounding the case% In this day and age, video surveillance cameras are installed practically everywhere for the protection and safety of everyone% (he installation of these cameras, however, should not cover places where there is reasona&le e$pectation of privacy, unless the consent of the individual, whose right to privacy would &e affected, was o&tained% 5or should these cameras &e used to pry into the privacy of another0s residence or &usiness office as it would &e no different from eavesdropping, which is a crime under Repu&lic #ct 5o% =-,, or the #nti) "iretapping Law% 2(he concept of li&erty would &e emasculated if it does not li'ewise compel respect for 7one0s> personality as a uni?ue individual whose claim to privacy and 7non>)interference demands respect%3 @%R% 5o% *A+AB;, Cune -;, -,*B, 1P6D191 BILL #5! VIC(6RI# <I5@, P9(I(I659R1, V1% #L9E#5!9R C<6#C<DF, 1R% #5! #LL#5 C<6#C<DF, R91P65!95(1% Li'e this: