The Decision is a stark departure from jurisprudence concerning the fundamental rights to life, liberty, and security. As held in Deduro, the right to security exists independently of the right to liberty and it not only prohibits the State from arbitrarily depriving liberty, but also imposes a positive duty on the State to afford protection for the right.

His statements only reinforce the reasonable belief that he is most responsible for crimes against humanity committed in the Philippines in the context of the “war on drugs”. And that in effect, he intends to deprive victims of their chance at accountability for thousands of killings.

Let us set the record straight: the conviction of the four Caloocan City police officers is the culmination of a long and arduous struggle for justice within an entrenched architecture of impunity in the Philippines.