Right Against Excessive Fines, and Cruel and Inhuman Punishments (Bill of Rights - Philippine Constitution)

The right against excessive fines, and cruel, degrading, or inhuman punishment is enshrined in the 1987 Philippine Constitution under Article III, Section 19, which states:

Section 19. (1) Excessive fines shall not be imposed, nor cruel, degrading or inhuman punishment inflicted. Neither shall the death penalty be imposed, unless, for compelling reasons involving heinous crimes, the Congress hereafter provides for it. Any death penalty already imposed shall be reduced to reclusion perpetua.

Section 19. (2) The employment of physical, psychological, or degrading punishment against any prisoner or detainee or the use of substandard or inadequate penal facilities under subhuman conditions shall be dealt with by law.

Key Aspects of the Right

1. Prohibition Against Excessive Fines

The prohibition against excessive fines ensures that any financial penalty imposed by the state or the courts must be proportional to the offense committed. A fine is considered "excessive" if it is grossly disproportionate to the nature and severity of the crime, the degree of the offender's culpability, and the harm caused by the crime. The court is tasked with ensuring that the fines imposed are fair and just, and aligned with the standards of justice and equity.

Jurisprudence:

In Baisa v. Court of Appeals (1978), the Supreme Court ruled that the imposition of fines must not be arbitrary or disproportionate, and it emphasized the constitutional safeguard against excessive fines. The Court observed that when determining whether a fine is excessive, factors such as the gravity of the offense, the defendant’s financial capacity, and the degree of harm caused must be considered.

2. Prohibition Against Cruel, Degrading, and Inhuman Punishments

The prohibition against cruel, degrading, and inhuman punishments is a safeguard against punishment that goes beyond the mere act of sentencing, into the realm of inflicting suffering that is grossly disproportionate or unnecessary. This includes forms of punishment that are barbaric, torturous, or that involve undue humiliation or debasement of the individual.

This clause is in line with international human rights standards, specifically the prohibition of torture and other cruel, inhuman, or degrading treatment or punishment under international conventions like the Universal Declaration of Human Rights (UDHR) and the International Covenant on Civil and Political Rights (ICCPR), both of which the Philippines is a signatory.

Jurisprudence:

In People v. Echavez (2000), the Supreme Court found that punishments that involve excessive suffering or unnecessary cruelty are unconstitutional. The decision emphasized that the law must serve justice without diminishing the dignity of the offender.
In the case of People v. Dionisio (1994), the Supreme Court held that the imposition of punishment must be in proportion to the crime and that the death penalty in that case did not constitute cruel or inhuman punishment because it was authorized by law for heinous crimes under certain conditions.

3. Death Penalty and its Suspension

The 1987 Constitution originally abolished the death penalty, but with a provision that Congress could reimpose it for heinous crimes, subject to the justification of compelling reasons. In 1993, Congress passed Republic Act No. 7659 (Death Penalty Law), reintroducing capital punishment for crimes such as murder, kidnapping for ransom, and drug-related offenses.

However, in 2006, Republic Act No. 9346 was enacted, which once again abolished the death penalty, converting all existing death sentences to reclusion perpetua (life imprisonment without the possibility of parole).

International Law Context

The Philippines, as a member of the international community, is bound by its treaty obligations, including adherence to the Second Optional Protocol to the International Covenant on Civil and Political Rights, which aims at the abolition of the death penalty. This reflects the country's commitment to international norms prohibiting cruel, inhuman, or degrading punishments.

4. Substandard Penal Facilities and the Treatment of Prisoners

Under Section 19(2), the Constitution explicitly prohibits the use of substandard or inadequate penal facilities that result in subhuman conditions. The government is obliged to ensure that prisoners and detainees are treated with dignity and that detention conditions do not violate basic human rights standards. This provision aligns with international norms against the mistreatment of prisoners, such as those outlined in the United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules).

This section also prohibits physical and psychological abuse of prisoners, recognizing their inherent dignity even while serving a sentence or awaiting trial.

Jurisprudence:

In People v. Domingo (2001), the Supreme Court ruled that conditions in detention must meet basic standards of human decency and that violations of these conditions can be challenged on constitutional grounds.

5. Test for Cruel, Degrading, or Inhuman Punishments

The test for what constitutes cruel, degrading, or inhuman punishment is subjective and has evolved through jurisprudence. In the Philippines, the courts generally apply a proportionality test, where the punishment is weighed against:

The seriousness of the offense,
The level of culpability of the offender,
The penological goals (e.g., retribution, deterrence),
The standards of decency at the time of imposition.

For instance, a sentence of life imprisonment for minor offenses could be deemed unconstitutional if it shocks the sense of fairness or justice.

6. Scope of Application

The prohibition against excessive fines, cruel, degrading, and inhuman punishment applies to:

Criminal proceedings – applicable to penalties and sentences imposed by the courts for crimes;
Civil penalties – in the imposition of administrative fines;
Custodial conditions – prisoners and detainees, ensuring that their confinement does not subject them to inhumane conditions;
Death penalty – restricting its use unless reimposed under very specific legislative and constitutional safeguards.

Conclusion

The constitutional prohibition against excessive fines and cruel, degrading, or inhuman punishment is a key component of the Philippines’ commitment to human rights and justice. It serves to ensure that punishments are proportional, humane, and in accordance with the dignity of every person, regardless of their crimes. Moreover, it aligns Philippine law with international human rights norms and treaties, further strengthening the protection of human dignity within the country’s legal framework.