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Article I: National Territory

Reagan v. Commissioner, 30 SCRA 968


Facts: Petitioner William C. Reagan, a former civilian employee of the an American
Corporation providing technical assistance to the United States Air Force in the Philippines, is
charged by Respondent, the Commissioner of nternal Reven!e for income ta"es. #he ta" is
assessed by the respondent on the sale of an a!tomobile by the petitioner to a member of the
United State $arine Corps. #he transaction occ!rred in Clar% Field Air &ase at Pampanga.
Petitioner disp!te that the po'er to ta" cannot be imposed as the sale 'as made o!tside the
Philippine territory and the state has no (!risdiction over the place.
Isse: Whether or not the sale 'as made o!tside the (!risdiction of Philippine
territory and therefore cannot be ta"ed by the state.
!el": #he Co!rt held that the Philippines being independent and sovereign, can e"ercise
its po'er over its territorial domains. #he arg!ment of the petitioner that the Air Field is of
foreign soil does not hold beca!se the gro!nd occ!pied by a foreign embassy does not
encompass s!ch to be a foreign state. #h!s, the action of the State to collect ta"es is an act of
sovereignty over its territory and the commission shall not a)rm of the re*!ested ref!nd of the
petitioner.
Article I: National Territory
#eo$le v. %o&o, '3 SCRA ()6
Facts: +oreta ,o-o, appellant, see%s to revo%e the decision of the Co!rt of First
nstance, convicting her of a violation of a City .rdinance of .langapo, /ambales. #he ordinance
re*!ires those 'ho shall constr!ct, modify, alter or demolish any b!ilding in the city to have a
permit ta%en from the m!nicipal mayor. #he appellant *!estions the validity of s!ch permit for
her ho!se 'as constr!cted 'ithin the territory of a naval based leased to American armed forces.
With the !nderstanding that s!ch territory is not !nder the (!risdiction of the state, the appellant
see%s to devitali-e the sovereign rights of the state by stating that the latter cannot e"ercise
administrative (!risdiction therein.
Isse: Whether or not the state co!ld e"ercise its administrative (!risdiction 'ithin a
naval base leased by the Philippines to the American armed forces.
!el": #he Co!rt a)rms of the decision of the previo!s co!rt. #he Philippines did not
resign over its sovereignty over the territory nor did it dispossess of the (!risdiction therein. #he
e"ercise of administrative (!risdiction is a granted right to the State. #h!s, the appellants re*!est
for revocation is denied.
Article I: National Territory
*agallona v. +rmita 6'' SCRA ()6
Facts: Petitioners $agallona et al move to *!estion the validity of Rep!blic Act 0122
or the 3e' &aselines +a' of 2440. #he said Rep!blic Act amends the former &aseline +a's to
comply 'ith the the terms of the United 3ations Convention on the +a' of the Sea 5U3C+.S 6.
#he ammendment shortened one baseline ca!sing certain islands, s!ch as the 7alayaan slands
and the Scarboro!gh Shoal, to be classi8ed as 9Regime slands:. #hese islands generate their
o'n applicable maritime -one. Petitioners arg!e that the proclamation of the said islands as
9Regime slands: has presented a loss in maritime territory and has violated the constit!tion.
Isse: Whether or not the 3e' &aseline +a' is violated the constit!tion thro!gh
delineating Philippine territory.
!el": #he Co!rt holds that the 3e' &aseline +a' does not present any violation to the
constit!tion partic!larly to Article ;. #he &aseline +a's serve as stat!tory mechanism that
delimits 'ith precision the maritime -one of the co!ntry. Also, the petitioners arg!ment 'ith
regards to the constit!tional provision states that the state recorgni-e the 'aters embraced
therein as part of the territory 'o!ld not s!)ce. #he reason for s!ch is that the 3e' &aseline
+a' is the only 'ay that the state 'o!ld conform 'ith U3C+.S . #h!s, RA 0122 is not an
instr!ment for the ac*!isition or dimm!nation of territory b!t an act to conform 'ith U3C+. .
Article II: ,eclaration o- #rinci$les an" State #olicies
.egal /ale o- Article II
Ton"o *e"ical v. Cort o- A$$eals, '0) SCRA )(6
Facts: Petitioners #ondo $edical et al 8led for Petition of Revie' on Certiorari,
assailing the decision of the Co!rt of Appeals after the latter have denied the petition for the
n!lli8cation of the <ealth Sector Reform Agenda 5<SRA6 Philippines ;000=244> of the
?epartment of <ealth. Petitioners *!estioned the 8rst reform agenda of the <SRA involving the
8scal a!tonomy of government hospitals, speci8cally the collection of sociali-ed fees and
corporate restr!ct!ring government hospitals. Petitioners arg!ed that it is stated in the
constit!tion it shall promote 9social (!stice: and that s!ch collection 'o!ld impose additional
b!rden to the economically disadvantaged citi-ens. #h!s, the petitioners allege the <SRA has
violated the constit!tion.
Isses: Whether or not the constit!tional provisions need legislation to be
enforceable.
!el": #he Co!rt held a)rmation to the decision r!led over by the Co!rt of Appeals.
#ho!gh as a general r!le, constit!tional provisions are self=e"ec!ting there are certain provisions
that are categori-ed to need legislation. #he cited constit!tional provisions, partic!larly those on
Article 2, need legislation to be e@ectively enforceable.
Article II: ,eclaration o- #rinci$les an" State #olicies
.egal /ale o- Article II
1ases Conversion an" ,evelo$ment At2ority v. Commission on A"it, '80 SCRA 09'
Facts: Rep!blic Act A22A created the &ases Conversion and ?evelopment A!thority.
Section 0 and ;4 of Rep!blic Act A22A states that the &ases Conversion and ?evelopment
A!thority shall be governed by the &C?A &oard of ?irectors and that the &oard shall have the
po'er to develop a compensation scheme for the organi-ation. #he &oard then patterned the
compensation scheme similar to the &SPBs compensation scheme. n ;00C, the organi-ation
absorbed of the policy of giving a ;4,444 year=end compensation to the employees. n ;000, the
&SP increased of their year=end compensation to D4,444 then the &C?A follo'ed the same. #he
Commission on A!dit then barred the &C?A from this beca!se of the violation it presented to the
national b!dget. #he &C?A contends that s!ch increase is valid beca!se of the consistency it
presents 'ith vario!s provisions in the constit!tion.
Isse: Whether or not the increase is adheres to the constit!tion
!el": #he co!rts disagree 'ith the &C?A as for the increase in compensation on the basis
of the constit!tional provisions presented in Article 2. Certain provisions, partic!larly the bro!ght
!p Sections 1 and ;2, are primarily considered that cannot be self=e"ec!ting. #h!s, legislation is
needed for s!ch to be enforced properly.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
In re: .etter o- Associate 5stice Reynato S. #no, 039 SCRA '88
Facts: #he ascendancy to presidency of the A*!ino administration 'as considered to
be a violation of the previo!s constit!tional process. #ho!gh achieved thro!gh violation, the
ne'ly=instit!ted government met little resistance evidenced thro!gh A*!inoBs designation of
cabinet members. #h!s, the obedience of the people to the previo!s constit!tion ceased to e"ist.
Isses: Whether or not the A*!inoBs administration is a legitimate government.
!el": #he S!preme Co!rt ans'ers that the revol!tionary government is valid and
legitimate. t is classi8ed as a de jure as it is established by a!thority of the legitimate sovereign
thro!gh practice of a peacef!l revol!tion of the people. #he A*!inoBs government is ta%en from
9a direct e"ercise of the po'er of the Filipino people:. #h!s, the A*!ino administration is
legitimate and that it is a revol!tionary government classi8ed as de jure.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
Re$4lic v. San"igan4ayan, %R No. 30()68, 5ly 03, 0003
Facts: #he Rep!blic, being represented by the Presidential Commission on ,ood
,overnance 5PC,,6, 8led a petition for revie' on certiorari see%ing to ignore the Resol!tions of
the Sandiganbayan on the dismissal of the case and ret!rn of the con8scated items to Eli-abeth
?imaano. Aside from con8scated items, the raiding team of PC Command of &atangas sei-ed
money to the amo!nt of 2,FA4,444 pesos and 14,444 US ?ollars. Get, the search 'arrant
presented to ?imaano 'as in connection only to 'eapons and not money. #h!s, the
Sandiganbayan moved to the dismissal of the case on gro!nds that it 'as an illegal search and
sei-!re of the items. For this, the petitioner aims to revo%e the decision of the Sandiganbayan of
reason that s!ch search occ!rred 8ve days after the s!ccessf!l E?SA revol!tion and that the
right from illegal sei-!res ta%es e@ect only on Febr!ary 2, ;0FA, the rati8cation of the
constit!tion.
Isses: ;6 Whether or not the ;0AD constit!tional rights 'ere in e@ect at the time of
the interregn!m or the period after the act!al ta%e=over by the revol!tionary government !p to
adopting the Provisional Constit!tion on $arch 2>, ;0FC. 26 Whether or not the protection given
!nder the nternational Covenant on Civil and Political Rights and the Universal ?eclaration of
<!man Rights remained e@ective d!ring the interregn!m.
!el": #he co!rt holds that the ;0AD &ill of Rights are ine@ective d!ring the interregn!m
b!t the Covenant and ?eclaration are held e@ective. ?!e to the absence of the &ill of Rights,
actions done by done by the government agencies are valid as long as they do not e"ceed the
a!thority granted by the revol!tionary government. <o'ever, 'ith the admission of the
limitation of the 'arrants and the p!rposely sei-!res of !nlisted items, it co!ld be reali-ed that
the PC,, e"ceeded the a!thority given to them. #herefore, the sei-!res of the items are void
and m!st be ret!rned.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
Co 6im C2am v. /al"e& Tan 6e2., )' #!I. 333 739('8
Facts: Prior to the liberation of $anila, Co 7im Cham has a pending civil case. After
the liberation and d!ring the occ!pation of the Americans, the (!dge of the lo'er co!rt ignored of
the case and ref!sed its contin!ation. #he gro!nd asserted by the respondent (!dge is that a
proclamation of ,en. ?o!glas $acArth!r pertaining to the n!lli8cation of all (!dicial (!dgment on
co!rts of the Hapanese=established Rep!blic of the Philippines ma%es s!ch complaint void. n
contention, the respondent (!dge stated that governments established d!ring the Hapanese
occ!pation cannot be classi8ed as de facto governments.
Isse: Whether or not the governments established d!ring the Hapanese .cc!pation
are de facto governments.
!el": #he S!preme Co!rt holds that the t'o governments established d!ring the
Hapanese .cc!pation, namely the Philippine E"ec!tive Commission and the Rep!blic of the
Philippines, are both de facto government of the second %ind. &oth governments 'ere a!thori-ed
by the Hapanese $ilitary and 'ere government imposed by la's of 'ar.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
ACCFA v. C9%:, 30 SCRA 6(9 739698
Facts: Petitioner Agric!lt!ral Credit and Cooperative Financing Administration
5ACCFA6 signed a collective bargaining 'ith the ACCFA S!pervisorsB Association 5ASA6 and the
ACCFA Wor%ersB Association 5AWA6. ?!e to Rep!blic Act 3o. DF>>, the ACCFA 'as reorgani-ed
and 'as renamed as Agric!lt!ral Credit 5ACA6. #he ASA and AWA, referred to as the Unions, are
!nder a mother organi-ation named Confederation of Unions in ,overnment Corporations and
.)ces 5CU,C.6. CU,C. then 8led a complaint as to the non=compliance of ACCFA to the
bargaining agreement, speci8cally, the discrimination 'hen on employees 'hen it comes to
promotions. #h!s, CU,C. as%s the Co!rt of nd!strial Relations 5CR6 to entertain the petition
and ta%e (!risdiction over the case. Petitioner arg!ed that the CR cannot invo%e (!risdiction as
the organi-ation is performing governmental f!nctions.
Isse: Whether or not the actions of the ACCFA presented governmental or
proprietal f!nctions.
!el": #he co!rt holds that the actions done by the ACCFA are government f!nctions and
that the CR cannot hold (!risdiction over the C&A. #he reformation of the ACCFA to the ACA d!e
to Rep!blic Act 3o. DF>> holds that the ACA as a government agency performing government
f!nctions.
Article II. ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
#!!C v. Cort o- In"strial Relations, 3'0 SCRA 096
Facts: #he Philippine government signed an agreement 'ith the World Food
Program 5WFP6 to a pro(ect 'herein the parties 'o!ld develop the Sapang Palay resettlement
area. #he Philippine <omesite <o!sing Corporation 5P<<C6 proposed a self=help pro(ect to
constr!ct t'o earth dams in the area. #he participants of the pro(ect, the members of the
s*!atters family, 'o!ld be given by the WFP of food ration and 8fty centavos as compensation
for the dayBs 'or%. #he participants 8lled a complaint to the Co!rt of nd!strial Relations 5CR6. n
response to the complaint 8lled, the CR iss!ed a notice to the P<<C regarding 8ndings on the
violation of the organi-ation 'ith regards to the minim!m 'age la' and anno!nced the
s!spension of 'or%. #h!s, P<<C is contending the action of CR as the agency 'as performing
government f!nctions.
Isses: Whether or not the P<<C 'as performing governmentIconstit!ent f!nctions.
!el": #he co!rt helds that the P<<C, being a government body aimed to mass ho!sing
and resettlement, meets the constit!ent f!nctions of the state. #h!s, the P<<C is a government
agency performing government f!nctions.
Article II. ,eclaration o- #rinci$les an" State #olicies
Section 3. #2ili$$ines as a ,emocratic an" Re$4lican State
S$oses Fontanilla v. !on. *alaiman, %R Nos. ''963, Fe4rary 0), 3993
Facts: #he son of the petitioner drove a bicycle at aro!nd C:D4pm on A!g!st 2;,
;0AC 'hen he 'as b!mped by a pic%=!p o'ned and operated by the 3ational rrigation Agency,
a government agency. #he son of the petitioner died after a fe' days and the accident 'as
primarily considered as the ca!se of death. 3A arg!ed that it is not liable to pay for the
damages inc!rred d!ring the accident as it 'as, being a government agency, performing a
government f!nction and not a mere proprietorship action.
Isse: Whether or not the 3ational rrigation Agency 'as performing a government
f!nction.
!el": #he Co!rt holds that the 3ational rrigation Agency 'as performing a proprietorship
f!nction. #he 3ational rrigation Agency is a government agency yet is governed by Corporation
+a' beca!se of its principal f!nction of irrigation of lands. #h!s, 3A is a government agency
performing proprietary f!nctions and is held liable for damages inc!rred by its employees.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
Agstin v. +", 88 SCRA 39'
Facts: #he petitioner o'ns a vol%'agen beetle, model ;D4D1. #he petition *!estion
the validity of +etter of nstr!ction 220, 'herein motor vehicles are re*!ired to have
9reJectori-ed triang!lar early 'arning devices:. Petitioner arg!es that s!ch e"ec!tive order is
oppresive to an ordinary motorist and that s!ch instr!ction is !nconstit!tional.
Isses: Whether or not the +etter of nstr!ction is valid.
!el": #he Co!rt holds that the +etter of nstr!ction is valid. S!ch letter of nstr!ction is not
considered to be !nconstit!tional b!t an e"ample of valid !se of police po'er by the state. Also,
it is !nderstood that the +etter of nstr!ction is constit!tional d!e to it being an action done in
relation to the ;0CF Kienna Convention on Road Signs and Signals 'herein the Philippines is a
signatory of. #h!s, the +etter of nstr!ction is rendered constit!tional for it is an valid action of
police po'er and it come from internationally accepted principles accepted by the state as a r!le
of the land.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
51. Reyes v. 1agatsing, %R No. 6'366, :cto4er 0', 3983
Facts: Petitioner H&+ Reyes, in behalf of the Anti=&ases Coalition, applied for a permit
to a 9peacef!l: rally in a p!blic par% near the US embassy in the o)ce of the City of $anila. S!ch
permit 'as denied by the City of $anila. Stated by the $ayor of the City, s!ch assembly 'o!ld
be violative of .rdinance A201, 'hich prohibits the staging of rallies 'ithin 144 feet of foreign
embassies.
Isse: Whether or not s!ch City .rdinance violates the cla!se on freedom of
e"pression by the constit!tion.
!el": #he Co!rt holds that s!ch ordinance is of relevant relation to the Kienna Convention
on ?iplomatic Relations and does not violate any constit!tional provisions. #he Philippines is a
signatory of the said Convention and the adoption of 'hich is consistent 'ith the second section
of article 2 in 'hich the Philippines adopt generally accepted principle of international la' as r!le
of the land. #h!s, the City .rdinance does not violate the freedom of e"pression b!t adheres to
generally accepted principles of international la'.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
Tana"a v. Angara, 0)0 SCRA 38
Facts: Petitioners arg!e that the World #rade .rgani-ation Agreement entered
thro!gh the Final Act Embodying the Res!lts of the Ur!g!ay Ro!nd of $!ltilateral 3egotiations
signed by the Philippines is !nconstit!tional. S!ch agreement deprives the normal Filipino
b!sinessman of competition for it in the agreement it 'ill be on e*!al competing gro!nds 'ith
foreign prod!cts.
Isse: Whether or not the W#. agreement is !nconstit!tional.
!el": #he co!rt holds that the agreement has revol!tioni-ed international b!siness and
economic relations among states. t promotes liberali-ation in b!sinesses and an increase in
economic globali-ation. $oreover, the petitioners cannot arg!e of the constit!tional principles for
s!ch principles need legislation to 'or% properly. #he constit!tion is not a set of permanent
policies and it ad(!st to dynamics of social needs.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
1ayan v. <amora, %R 338')0, :cto4er 30, 0000
Facts: With the denial of the e"tension of the $ilitary &ases Agreement bet'een the
United States and the Philippines, Former President Ramos approved of the Kisiting Forces
Agreement. S!ch agreement states that the Philippines and United States 'o!ld e"change
military strategies on complementing areas bet'een the t'o. A fe' months later, the ne'
President Estrada, thro!gh the Secretary of Foreign A@airs, moved for the rati8cation of the KFA.
#he petitioners arg!e that the agreement violates the constit!tion.
Isses: Whether or not the KFA is a generally accepted principle of international la'
that sho!ld be considered as la' of the land.
Whether or not the KFA violates the prohibition of n!clear 'eapons stated in the
constit!tion.
!el": #he co!rt holds that since the agreement is considered to be a treaty bet'een the
t'o co!ntries, it sho!ld be adhered as a la' of the land. As the co!rt recogni-es the phrase
9recogni-ed as a treaty: as stated by the US ambassador, means that the other party
ac%no'ledges s!ch agreement as a treaty. With this, 'e apply the Kienna Convention on +a's of
#reaties, in 'hich the state is a signatory to.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
.im v. +=ective Secretary, %R 3'3((', A$ril 33, 0000
Facts: #he Petitioners see% to restraint the entry of American troops thro!gh the
&ali%atan 42=;. #he &ali%atan is the largest (oint e"ercise bet'een the Philippines and the United
States armed forces thro!gh the Kisiting Forces Agreement. Petitioners contend the
constit!tionality of the said e"ercise and see% its revocation d!e to the negative e@ects that
people of $indanao e"periences.
Isse: Whether or not the &A+7A#A3 sho!ld be restrained beca!se of constit!tional
violation.
!el": #he co!rts hold the dismissal of the petition for the e"ercises does not present any
violation to the constit!tion. $oreover, the state adheres to those principles applicable to most
international state. #he agreement, being a treaty, is considered as an obligation of the state to
the other state. #h!s, the &A+7A#A being part of the KFA is a constit!tional action in f!l8lling an
international obligation that is part of a treaty.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
*i>ares v. Rana"a, %R 33930', A$ril 30, 000'
Facts: Petitioners are victims of h!man rights ab!se d!ring the martial la' era. #hey
have 8lled for a complaint 'ith regards to the ab!se in a US ?istrict Co!rt, ?istrict of <a'aii
against the estate of the then president $arcos.
#he US ?istrict Co!rt came to a decision favoring the petitioners and re*!iring the estate
of $arcos to pay damages costing L;,0C>,441,F10.0. #he petitioners proceeded to the
Philippines to have the decision enforced. #he R#C and Co!rt of Appeals move to dismiss the
case in order 'itho!t pre(!dice.
Isse: Whether or not the US ?istrict Co!rt decision is enforceable in the Philippines.
!el": #he co!rts grant the petition of the n!lli8cation of the order. #here is no obligatory r!le
derived from treaties or conventions that re*!ires the Philippines to recogni-e foreign (!dgments, or allo'
a proced!re for the enforcement thereof. <o'ever, generally accepted principles of international la', by
virt!e of the incorporation cla!se of the Constit!tion, form part of the la's of the land even if they do not
derive from treaty obligation.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
S2angri?.a v. ,evelo$ers, %R 3'9938, *arc2 33, 0006
Facts: #he petitioners see% the n!lli8cation of the previo!s co!rt decision. #he case
started 'hen the defendant 8led a complaint for the !se of Shargri=+a of the registered logo of
?,C in the Philippines. ?,C accordingly patented the design 'ith the &!rea! of Patents,
#rademar%s and #echnology #ransfer on ;0F2. <o'ever, the petitionerBs claim that they have
been !sing the trademar% since ;0C2, 'hich 'as even before they have entered b!siness in the
Philippines. #he petitioners no' !ses the international treaty 'hich is the Paris Convention as a
defense.
Isse: Whether or not the petitioners are entitled to protection !nder the Paris
Convention for the Protection of nd!strial Property.
!el": #he Co!rt holds that even tho!gh the Philippines is a signatory of the said
convention, the petitioners cannot see% defense from it. #he S!preme Co!rt states that o!r
m!nicipal la' on trademar%s regarding the re*!irement of act!al !se in the Philippines m!st
s!bordinate an international agreement. <o'ever, 'ith violations to the local la's of trademar%
by the defendant, the petition for n!lli8cation is granted.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 0. %enerally Acce$te" #rinci$les o- International .a;
#2armacetical v. ,:!, %R 3)303(, :ctor4er 9, 000)
Facts: Petitioners see%s the n!lli8cation of the $il% Code, 'hich 'as iss!ed by President
Cora-on A*!ino on .ctober 2F, ;0FC by virt!e of the legislative po'ers granted to the president
!nder the Freedom Constit!tion. .ne of the preamb!lar cla!ses of the $il% Code states that the
la' see%s to give e@ect to Article ;; of the nternational Code of $ar%eting of &reastmil%
S!bstit!tes 5C$&S6, a code adopted by the World <ealth Assembly 5W<A6 in ;0F;.
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 3. Civilian S$remacy an" AF# Role
I1# v. <amora, 338 SCRA 83
Article II: ,eclaration o- #rinci$les an" State #olicies
Section 30. Family .i-e@ *ot2er@ 9n4orn
Roe v. Aa"e, (30 9S 333
Facts: Petitioners arg!e the constit!tionality of the #e"an abortion la's. #he said
la's only allo' abortion at a prescription of a medical a!thority if the motherBs life is endangered
by the pregnancy and does not give the right to for the mother to p!rs!e abortion.
Isse: Whether or not the #e"an abortion la's violates the American Constit!tion
!el": #he co!rt held that the abortion la's are vag!e and void. #he said la's violate the
d!e process cla!se of the fo!rteen amendment of the American constit!tion. ?!e to the lac% of
timeline for the legality of abortion and its availability only on critical moments of the motherBs
life, the la's therefore violate the constit!tion.
3.#ESM
#<S S #<E REAS.3 F.R #<E P<RASE 9A# #<E #$E .3 C.3CEP#.3: .3 AR#C+E 2 SEC#.3
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