The Supreme Court (SC) has reiterated that it is the duty of the State to provide clean, safe, and properly equipped detention facilities for persons deprived of liberty.
In a decision dated 24 January 2024, penned by Associate Justice Antonio T. Kho Jr., the SC’s Second Division upheld the Ombudsman’s dismissal of a complaint filed by the Commission on Human Rights (CHR) against police officers from Raxabago Police Station 1 in Tondo, Manila. The officers were accused of operating a “secret detention cell.”
The CHR reported discovering three men and nine women crammed into a small, dirty room concealed behind a wooden shelf. A video of the area was submitted as evidence, which the CHR claimed showed a secret cell.
Police explained the station was overcrowded at the time — housing 96 detainees in a facility built for only 50, prompting them to use a small room as a temporary holding area. They denied it was a secret cell, saying the room was accessible and had its entrances.
The Ombudsman found the evidence insufficient, noting that the video only showed a dark room with a urinal. It also acknowledged the reality of overcrowding in jails.
The Supreme Court agreed, ruling that there was no violation of the Anti-Torture Act of 2009 (RA 9745), which prohibits hidden or solitary detention cells. It also found no bad faith on the part of the officers due to the lack of alternative space.
However, the Court emphasized that poor jail conditions must not be tolerated.
“The improvement of penal facilities may be restricted by a budget which only Congress can provide,” the Court said. “But this does not mean detainees lose their right to a decent life while in custody.”
The SC warned that if relevant agencies continue to fail, the Court may intervene to uphold detainees’ rights when properly petitioned.
It further reminded law enforcement that even temporary detention spaces must be clean, sanitary, and properly maintained.
In a dissenting opinion, Senior Associate Justice Marvic M.V.F. Leonen disagreed with the ruling, arguing that the CHR’s inspection exposed a secret cell and that the squalid conditions could amount to cruel, inhuman, and degrading treatment.