Constitutional Limitations on the Power of Congress to Enact Penal Laws:

Excessive Fines, Cruel, Degrading, or Inhuman Punishment

The Constitution of the Philippines imposes significant limitations on the power of Congress to enact penal laws. These limitations are designed to uphold human dignity and ensure that punishments are fair, just, and humane. Specifically, Section 19, Article III (Bill of Rights) of the 1987 Philippine Constitution addresses these issues:

1. Prohibition of Cruel, Degrading, or Inhuman Punishment

The Constitution provides:
"Excessive fines shall not be imposed, nor cruel, degrading or inhuman punishment inflicted."

A. Cruel, Degrading, or Inhuman Punishment Defined

Cruel punishment: Inflicts unnecessary or excessive suffering disproportionate to the offense.
Degrading punishment: Humiliates or demeans the dignity of a person.
Inhuman punishment: Causes unnecessary pain, physical or psychological, and violates basic human decency.

B. Jurisprudence

The Philippine Supreme Court has clarified this principle through various decisions:

People v. Echegaray (1999): The Court upheld the constitutionality of the death penalty at the time, stating that death by lethal injection was not "cruel, degrading, or inhuman" because it caused immediate and relatively painless death. However, the Death Penalty Law (RA 7659) was later repealed by RA 9346 in 2006, reflecting a broader interpretation of "inhuman punishment."
People v. Siton (2013): The Court held that punishment must be proportionate to the crime and consistent with human dignity. Disproportionate penalties violate this constitutional prohibition.

C. International Standards

The Philippines, as a state party to international treaties such as the International Covenant on Civil and Political Rights (ICCPR), has obligations to ensure compliance with global norms. The prohibition against torture and other cruel, inhuman, or degrading treatment or punishment is non-derogable under international law.

2. Prohibition of Excessive Fines

The imposition of excessive fines is explicitly prohibited, ensuring that penalties are proportionate to the offense and do not impose undue financial burdens on offenders.

A. Standards for Determining Excessiveness

Nature of the offense: Fines must correspond to the gravity of the crime.
Economic capacity of the offender: Courts may consider the ability of the individual to pay the fine.
Jurisprudence: In Tiu v. Court of Appeals (2001), the Court emphasized that excessive fines undermine the principle of justice and equity.

B. Examples of Excessive Fines

Fines grossly disproportionate to the offense, especially in cases involving minor infractions.
Fines intended to punish rather than rehabilitate.

C. Judicial Scrutiny

Courts have the authority to review the constitutionality of fines imposed under penal statutes. If a fine is deemed excessive, it can be invalidated.

3. Relation to Legislative Power

While Congress has broad authority to enact penal laws under the police power of the State, this power is not absolute. Constitutional limitations ensure that:

Laws must promote the general welfare and public order.
Penal provisions must not violate constitutional protections, including:
- The prohibition against cruel, degrading, or inhuman punishment.
- The prohibition against excessive fines.
Penal laws must be clear and not overly broad or vague to avoid arbitrary enforcement.

A. Void-for-Vagueness Doctrine

Laws that are unclear or ambiguous violate due process and may lead to punishments that are inconsistent with constitutional protections.

B. Separation of Powers

The judiciary serves as the final arbiter in determining whether penal laws enacted by Congress comply with constitutional limitations.

4. Practical Applications

A. Criminal Justice Reform

Advocacy for proportionate penalties to address prison overcrowding and unjust punishment.
Emphasis on rehabilitation over retribution in sentencing policies.

B. Role of the Judiciary

Ensuring penalties comply with constitutional safeguards.
Striking down laws or punishments that violate the prohibition against excessive fines or inhuman punishment.

C. Human Rights Perspective

Penal laws must reflect the commitment to uphold human rights and dignity.
The constitutional prohibitions align with international human rights law, emphasizing fairness, proportionality, and humane treatment.

Conclusion

The constitutional prohibitions against excessive fines, cruel, degrading, or inhuman punishment reflect the commitment of the Philippine legal system to uphold the dignity of every individual. Congress is mandated to respect these limitations when crafting penal laws, ensuring that the principles of proportionality, fairness, and humanity are preserved. The judiciary plays a crucial role in safeguarding these constitutional guarantees, ensuring that justice is not only served but also tempered with compassion and respect for human rights.