Seminar III
Fundamental Moral Principles
(Insights and their application to certain cases and jurisprudence)
Submitted to:
Dr. James Piscos
Submitted by:
Audris Bulatao
November 8, 2013
“Laws and principles are not for the times when there is no temptation: they are for such
moments as this, when body and soul rise in mutiny against their rigour ... If at my convenience
I might break them, what would be their worth?”
― Charlotte Brontë, Jane Eyre
THE FUNDAMENTAL MORAL PRINCIPLES
VALUE OF LIFE PRINICIPLE
Life should not be taken for granted. You could either go as “Life is too short” or “Life is the
longest thing you would ever have in this world.” I know some people who get annoyed with the
saying that life is too short because in reality, it is the opposite. What could have been more
important than life itself? What Is Life1 is a 1944 non-fiction science book written for the lay
reader by physicist Erwin Schrödinger. He focused on one important question: "how can the
events in space and time which take place within the spatial boundary of a living organism be
accounted for by physics and chemistry?" In lay man’s definition, it is about the cause and
effect.
Some of us are trying to know reality without admitting it is a mystery. I remember the good
movie I have watched this year; it is the Life of Pi. It is a fantasy adventure novel by Yann Martel
published in 2001. The protagonist, Piscine Molitor "Pi" Patel, a Tamil boy from Pondicherry,
explores issues of spirituality and practicality from an early age. He survives 227 days after a
shipwreck while stranded on a lifeboat in the Pacific Ocean with a Bengal tiger named Richard
Parker2. Life of Pi, according to Yann Martel, can be summarized in three statements- "Life is a
story... You can choose your story... A story with God is the better story."3 Religion, philosophy,
and all human thought is just that, human thought. It is the product of human consciousness.
We humans cannot know what “real” fact is nor be sure of it. Therefore myth and story is of the
1 Margulis, Lynn. & Sagan, Dorion. (1995). What Is Life? (pg. 1). Berkeley: University of California Press.2 "Life of Pi", http://en.wikipedia.org/wiki/Life_of_pi#Life_is_a_story accessed 10/31/20133 Renton, Jennie. "Yann Martel Interview". Textualities. Retrieved 19 May 2013.
greatest importance to how we survive in our lives. Religions are cultural phenomena. Every
successful culture needs at least one successful religion and has at least one.
Self-preservation is behavior that ensures the survival of an organism. Fear causes the
organism to seek safety and may cause a release of adrenaline. 4
As the Court pointed out in People v. Gadia5: "Where an accused invokes self-defense, the
burden is shifted to him to prove that he killed the victim to save his life. For this reason he must
rely on his own evidence and not on the weakness of the evidence for the prosecution, for such
can no longer be disbelieved after the accused admits the killing. He must prove the presence
of all the requisites of self-defense, namely: (1) unlawful aggression on the part of the victim; (2)
reasonable necessity of the means employed to prevent or repel it; (3) lack of sufficient
provocation on the part of the person defending himself. Of these requisites, the most decisive
is that the victim was guilty of unlawful aggression. This is because the theory of self-defense is
based on the necessity on the part of the person being attacked to prevent or repel the
aggression. Hence, absent evidence of prior unlawful and unprovoked attack by the victim, the
claim of self-defense cannot prosper."
An accused-appellant's allegation of self-defense when established solely by his testimony, and
the he fail to corroborate his claim of self-preservation with evidence other than his own
testimony, his plea of self-defense cannot be justifiably entertained where it is not only
uncorroborated by any separate competent evidence but is also extremely doubtful in itself.
Succinctly stated, the Court will rule that it is a tal too riddled with loopholes to be believed. The
Court has consistently held that to be credible, testimonial evidence should not only come from
4 Henry Gleitman, Alan J. Fridlund and Daniel Reisberg (2004). Psychology (6 ed.). W. W. Norton & Company. ISBN 0-393-97767-6.5 G.R. No. 132384, 21 September 2001, pp. 17-18 (People v. Gadia)
the mouth of a credible witness but it should also be credible, reasonable and in accord with
human experience. It is a well-settled rule that testimonial evidence to be believed must not only
proceed from the mouth of a credible witness but must foremost be credible in itself. The test to
determine the value or credibility of testimony of a witness is whether or not such is in
conformity with common knowledge and consistent with the experience of mankind6.
Another point of view that received critics is the mercy killing. There was an interesting article
entitled Man shoots sick wife in alleged 'mercy killing’7. Is it really mercy killing or just plain
murder? Euthanasia is categorized in different ways, which include voluntary, non-voluntary, or
involuntary. Voluntary euthanasia is legal in some countries and U.S. states. Non-voluntary
euthanasia is illegal in all countries. Involuntary euthanasia is usually considered murder.
The word "euthanasia" was first used in a medical context by Francis Bacon in the 17th century,
to refer to an easy, painless, happy death, during which it was a "physician's responsibility to
alleviate the 'physical sufferings' of the body." Bacon referred to an "outward euthanasia"—the
term "outward" he used to distinguish from a spiritual concept—the euthanasia "which regards
the preparation of the soul.8 Physician-assisted suicide is thus not classified as euthanasia by
the US State of Oregon, where it is legal under the Oregon Death with Dignity Act, and despite
its name, it is not legally classified as suicide either. Unlike physician-assisted suicide,
withholding or withdrawing life-sustaining treatments with patient consent (voluntary) is almost
unanimously considered, at least in the United States, to be legal. The use of pain medication in
order to relieve suffering, even if it hastens death, has been held as legal in several court
decisions.
6 G.R. Nos. 140557-58. December 5, 2001 (People v. Herrera)7 Murder or Mercy (http://foxnewsinsider.com/2013/08/29/kentucky-man-ernest-chris-chumbley-claims-he-shot-wife-end-cancer-suffering)8 Francis Bacon: the major works By Francis Bacon, Brian Vickers pp 630.
Some governments around the world have legalized voluntary euthanasia but generally it
remains as a criminal homicide. In the Netherlands and Belgium, where euthanasia has been
legalized, it still remains homicide although it is not prosecuted and not punishable if the
perpetrator (the doctor) meets certain legal exceptions9 There is a thin line between murder and
mercy killing. However, as some of the jurisprudence says, each decision is particular to each
case.
Ernest Chris Chumbley of London, Kentucky, openly admits to shooting his wife, and
even called 911 Wednesday to report his actions. Now, he is facing murder charges for
her death. Chumbley, 48, has pleaded not guilty and says his wife, Virginia, wanted to
die. She had been battling breast cancer for a few years. He reportedly shot her multiple
times with a handgun, killing her in their home. (Note: The trial is on going.)
Principle of Goodness or Rightness
To keep us sane in this world, we need values and principles to guide us along the way. We
choose to be good because we believe in karma. We believe that if we do something good,
something’s better is coming our way. There is no harm in believing in that. As long as you are
not hurting anyone or yourself, you are good to go.
This principle operates between shall and will. The difference between the two is that "Shall" is
a formal way to express intended future action. The traditional rule is that to express a simple
9 Oluyemisi Bamgbose (2004). "Euthanasia: Another Face of Murder". International Journal of Offender Therapy and Comparative Criminology 48 (1)
future tense shall is used after the first person. On the other hand, "Will" (in its verb form) is
used to indicate future action for second or third-person.
Everything we do in life is a choice, and I think most of us realize that. But what most people
don’t seem to realize is that everything we don’t do in life is also a choice. Every day we choose
to do some things and to not do other things. We all know that we can change our life whenever
we want to. But just wanting to change is not enough. We must make the choice to change.
Many of us choose to do nothing but wish things would change. Consequently, nothing ever
changes.
Such occurrences could result in a state of confusion but one should remember that we could
always control our reactions. We are in complete control of our responses and decide what
value any event has in our lives.
In a prosecution for libel with the publication of defamatory matter, in the absence of proof to the
contrary, malice is always presumed. The burden of proving justifiable motives is upon the
person responsible for the publication of the libel. Goodness of intention is not always sufficient
to justify the publication of an injurious allegation of fact. The question of justifiable motive is one
which must be decided by taking into consideration not only the intention but all the
circumstances connected with the particular case. Another example is in People v. Agustin10,
therein appellant argued that she could not be convicted of illegal recruitment because in
introducing the complainants to the alleged recruiters, she merely acted "out of the goodness of
her heart." In resolving said case, the Court ruled: The testimonial evidence hereon show that
she indeed further committed acts constitutive of illegal recruitment. All four prosecution
witnesses testified that it was Agustin whom they initially approached regarding their plans of
10 317 Phil. 897 (1995) (People v Agustin)
working overseas. It was from her that they learned about the fees they had to pay, as well as
the papers that they had to submit. It was after they had talked to her that they met the accused
spouses who owned the placement agency. As such, the Court concluded that appellant was an
employee of the Goce spouses, as she was actually making referrals to the agency. She was,
therefore, engaged in recruitment activities.
The term beneficence connotes acts of mercy, kindness, and charity. It is suggestive of altruism,
love, humanity, and promoting the good of others11. In ordinary language, the notion is broad,
but it is understood even more broadly in ethical theory to include effectively all forms of action
intended to benefit or promote the good of other persons. The language of a principle or rule of
beneficence refers to a normative statement of a moral obligation to act for the others' benefit,
helping them to further their important and legitimate interests, often by preventing or removing
possible harms.
Under Article 1274, of the Civil Code of 1889, liberality of the donor is deemed causa only in
those contracts that are of "pure" beneficience that is to say, contracts designed solely and
exclusively to procure the welfare of the beneficiary, without any intent of producing any
satisfaction for the donor; contacts, in other words, in which the idea of self-interest is totally
absent on the part of the transferor. For this very reason, the same Article 1274 provides that in
remuneratory contracts, the consideration is the service or benefit for which the remuneration is
given; causa is not liberality in these cases because the contract or conveyance is not made out
of pure beneficience, but "solvendi animo".
Principle of Justice and Fairness
11 Gert, Bernard, 2005, Morality, New York: Oxford University Press.
Under this principle, I want to share some inspiring and latest jurisprudence about how justice
and fairness was applied in some interesting cases.
THE INTENT OF THE STATUTE IS THE LAW. The intent of a statute is the law. If a statute is
valid it is to have effect according to the purpose and intent of the lawmaker. The intent is the
vital part, the essence of the law, and the primary rule of construction is to ascertain and give
effect to the intent. The intention of the legislature in enacting a law is the law itself, and must be
enforced when ascertained, although it may not be consistent with the strict letter of the statute.
Courts will not follow the letter of a statute when it leads away from the true intent and purpose
of the legislature and to conclusions inconsistent with the general purpose of the act. Intent is
the spirit which gives life to a legislative enactment. In construing statutes the proper course is
to start out and follow the true intent of the legislature and to adopt that sense which harmonizes
best with the context and promotes in the fullest manner the apparent policy and objects of the
legislature.- PANGANIBAN CJ. .in Philippine National Bank v. Office of the President12
JUDICIAL ETHICS, JUDGES; ADMINISTRATION OF JUSTICE SHOULD BE SPEEDY BUT
CAREFUL. The Court exists to promote justice and, thus, aid in securing the contentment and
happiness of the people. To this end, the judge should organize his or her court with a view to a
prompt and convenient dispatch of business, especially those cases which the law requires to
be expeditiously heard and decided. On the other hand, a judge should not decide cases with
undue haste, especially when their nature and complexity require in-depth study and research.
A fast-tracking in the disposition of cases to achieve popularity at the expense of mature and
careful deliberation is anathema to justice and fairness. The administration of justice should be
12 322 Phil. 6, 14, January 18, 1996
speedy but, at the same time, careful. - Kapunan J. in UNITED BF HOMEOWNERS v.
Gutierrez13
CONFLICT OF EVIDENCE; PRESUMPTION OF INNOCENCE; ACQUITTAL. — When a
marked conflict exists between the evidence of the prosecution and that of the defense, to such
an extent that the mind is perplexed and very uncertain as to the innocence or the guilt of the
accused, their responsibility not having been thoroughly established, and in case a reasonable
doubt exists, the accused are entitled to an acquittal. - TORRES, J in US. v. Magno14
CRIMINAL PROCEDURE; ARRESTS, SEARCHES AND SEIZURES; WARRANT REQUIRED;
EXCEPTIONS; NOT PRESENT IN CASE AT BAR. — The general rule as regards arrests,
searches and seizures is that a warrant is needed in order to validly effect the same. The
Constitutional prohibition against unreasonable arrests, searches and seizure refers to those
effected without a validly issued warrant, subject to certain exceptions found in Section 5, Rule
113 of the Rules of Court, which reads: "Section 5. Arrest without warrant; when lawful — A
peace officer or a private person may, without a warrant, arrest a person: a) When, in his
presence the person to be arrested has committed, is actually committing, or is attempting to
commit an offense; b) When an offense has in fact just been committed, and he has personal
knowledge of facts indicating that the person to be arrested has committed it; and c) When the
person to be arrested is a prisoner who has escaped . . . ." Not one of the above exceptions
attended the arrest of appellants. Hence, the raid conducted on the premises by the police
without any search warrant or warrant of arrest was illegal. Since the warrantless arrests were
invalid, the search conducted on the premises was not one which is incidental to a lawful
warrantless arrest. Thus, the search in the motel, without the benefit of a search warrant, was
13 A.M. No. CA-99-30. September 29, 1999 (United BF Homeowners v. Gutierrez)14 G.R. No. L-3517. August 7, 1907
clearly illegal and the shabu allegedly seized thereat are inadmissible in evidence against
appellants.- Austria-Martinez J. in People v. Lim15
EVIDENCE; DISCOVERY PROCEDURES IN CRIMINAL CASES; TO STRENGTHEN THE
CONSTITUTIONAL RIGHT OF ACCUSED TO DUE PROCESS. — I write this opinion to
complement the learned opinion of our Chief Justice. Thus, this Court has given an expensive
interpretation of the right of an accused to discovery procedure. In the first Webb case, we held:
". . . This failure to provide discovery procedure during preliminary investigation does not,
however, negate its use by a person under investigation when indispensable to protect his
constitutional right to life; liberty and property. Preliminary investigation is not too early a stage
to guard against any significant erosion of the constitutional right to due process of a potential
accused. . . . We uphold the legal basis of the right of petitioners to demand from their
prosecutor, the NBI, the original copy of the April 28, 1995 sworn statement of Alfaro and the
FBI Report during their preliminary investigation considering their exculpatory character, and
hence, unquestionable materiality to the issue of their probable guilt. The right is rooted on the
constitutional protection of due process which we rule to be operational even during the
preliminary investigation to a potential accused. . . ." Upon assumption of office, our present
Chief Justice vowed to have a court that is pro-active, a stance that will surely promote rights
more than authority. I am sure such a stance will quicken moves to liberalize further our rules on
criminal procedure on the matter of discovery and deposition taking as to strengthen the
constitutional right to due process of an accused. PUNO, J., concurring opinion: People v.
Webb16
Principle of Truth Telling
15 G.R. No. 141699. August 7, 2002
16 G.R. No. 132577. August 17, 1999
We all grew up watching fairy tales and reading Charles Dickens’ Short stories about being a
good person and a reward of good life thereafter. Who could forget the famous Pinocchio who is
known for having a short nose that becomes longer when he is under stress, especially while
lying?
“The Paradoxical Commandments17
People are illogical, unreasonable, and self-centered.Love them anyway.
If you do good, people will accuse you of selfish ulterior motives.Do good anyway.
If you are successful, you will win false friends and true enemies.Succeed anyway.
The good you do today will be forgotten tomorrow.Do good anyway.
Honesty and frankness make you vulnerable.Be honest and frank anyway.
The biggest men and women with the biggest ideas can be shot down by the smallest men and women with the smallest minds.Think big anyway.
People favor underdogs but follow only top dogs.Fight for a few underdogs anyway.
What you spend years building may be destroyed overnight.Build anyway.
People really need help but may attack you if you do help them.Help people anyway.
Give the world the best you have and you'll get kicked in the teeth.Give the world the best you have anyway.”
I just love how the Paradoxical Commandments was written. It is about forgiveness, happiness,
honesty, and goodness all in one. Honesty and frankness make you vulnerable. Be honest and
17 Kent M. Keith, The Silent Revolution: Dynamic Leadership in the Student Council
frank anyway. Sometimes, we hide our true selves and emotions because it makes us look
weak, and exposed. But on the contrary, being honest shows strength and a lot of character.
In a different light, the conduct and behavior of everyone connected with an office charged with
the dispensation of justice, from the presiding judge to the lowliest clerk, should be
circumscribed with the heavy burden of responsibility. The strictest standard of honesty and
integrity in the public service is required of those involved in the administration of justice. A court
employee, being a public servant, must exhibit the highest sense of honesty and integrity not
only in the performance of his official duties but in his personal and private dealings with other
people, to preserve the court's good name and standing. Every employee of the judiciary should
be an example of integrity, uprightness and honesty.
In the credibility of witnesses, minor matters do not impair the essential integrity of the
prosecution evidence as a whole nor do they reflect on the witnesses' honesty. Differences in
the recollection of details relating to the same incident may be expected from the several
persons testifying thereon; but as long as there is basic agreement on the main points of the
incident, their respective declarations may not be rejected as totally untrue.
Lawyers must conduct themselves, especially in their dealings with their clients and the public at
large, with honesty and integrity in a manner beyond reproach. "To say that lawyers must at all
times uphold and respect the law is to state the obvious, but such statement can never be
overemphasized. Considering that, 'of all classes and professions, [lawyers are] most sacredly
bound to uphold the law,' it is imperative that they live by the law. Accordingly, lawyers who
violate their oath and engage in deceitful conduct have no place in the legal profession. "18
18 Citing Ex parte Wall, 107 U.S. 265, cited in Malcolm, Legal and Judicial Ethics, p. 214.
Principle of Individual Freedom
A judgment of conviction requires that the accused be shown to have been the perpetrator of
the crime charged in the information by proof beyond reasonable doubt. Unless the accused is
identified as the doer of the crime by such proof, the charge against the accused must be
dismissed for the constitutional presumption of innocence has not then been overcome. In all
criminal prosecutions, the accused shall be presumed to be innocent until the contrary is
proved19.
Freedom means being able to think, choose, and act independently without constraint and is
arguably one of the basic human rights. Total freedom of the individual, without a sense of
responsibility or self-restraint, soon infringes on the freedom of others and therefore freedom of
the individual in a society involves some measure of regulation and boundaries
Where a circumstance may yield two or more inferences, one consistent with the presumption of
innocence and the other compatible with the finding of guilt, the Court must rule in favor of the
accused. As shown in People v. Valdez20, Accused-appellant was found guilty by the trial court
of simple rape for sexually abusing a seven-year old girl. He was sentenced to suffer the penalty
of reclusion perpetua. Hence, the appeal. The Supreme Court held that the victim had actually
been raped considering that she was suffering from a sexually transmitted disease. The
absence of a laceration on her hymen does not negate rape. Nonetheless, the Court held that
the evidence did not establish the identity of accused-appellant as the culprit. Whether or not
accused-appellant was suffering from venereal disease is crucial to the case for the prosecution
in view of its theory that appellant infected the victim with the disease when he raped her. In
19 Section 1 [17], Article III of the 1987 Constitution20 G.R. No. 145503. August 20, 2002
fact, the victim admitted that she had been raped only after she had been examined and pus
had been found in her private parts. In this case, Dr. Llamas' testimony is not only that appellant
was not suffering from gonorrhea but that he found no trace of it from an examination of
appellant. Where a circumstance may yield two or more inferences, one consistent with the
presumption of innocence and the other compatible with the finding of guilt, the Court must rule
in favor of the accused. The Court is convinced that the victim had indeed been raped, but it is
equally not convinced that it was accused-appellant who raped her. Appellant was acquitted on
ground of reasonable doubt. The Supreme Court acquitted appellant on the ground of
reasonable doubt.
Where the evidence on an issue of fact is in equipoise or there is doubt on which side the
evidence preponderates, the party having the burden of proof fails upon that issue. Therefore,
as neither party was able to make out a case, neither side could establish its cause of action
and prevail with the evidence it had. They are thus no better off than before they proceeded to
litigate, and, as a consequence thereof, the courts can only leave them as they are. In such
cases, courts have no choice but to dismiss the complaints/petitions.
Briefly stated, the needed quantum of proof to convict the accused of the crime charged when
found lacking; he must be declared innocent and set free. This is how our Constitution and
criminal laws protects the rights of an accused.
It is the long standing policy of the Court that when the guilt of the accused has not been proven
with moral certainty, the constitutional presumption of innocence of the accused must be
favored and his exoneration granted as a matter of right regardless of the weakness or even the
absence of his defense.
Principle of Double Effect and Principle of Proportionality
The principle of double effect is a set of ethical criteria which Christians, and some others, use
for evaluating the permissibility of acting when one's otherwise legitimate act may also cause an
effect one would normally be obliged to avoid. Double-effect originates in Thomas Aquinas's
treatment of homicidal self-defense, in his work Summa Theologiae21.
An action that is good in itself that has two effects, first is the intended and otherwise not
reasonably attainable good effect, and second, the an unintended yet foreseen evil effect--is
licit, provided there is a due proportion between the intended good and the permitted evil.
When there is a clash between the two universal norms of "do good" and "avoid evil," the issue
arises as to whether or not the obligation to avoid evil requires one to abstain from a good
action in order to prevent a foreseen but merely permitted evil effect.
Classical formulations of the principle of double effect require that four conditions be met if the
conduct in question is to be ethically permissible. First: the action contemplated by the agent be
in itself either ethically good or ethically indifferent (the principle of respect for the agent's
autonomy). Second: that the evil consequence not be directly intended by the agent (the
principle of nonmalfeasance). Third: the good result not be a direct causal result of the evil
result (the principle of beneficence). Fourth: the good result must be "proportionate to" the evil
result (the principle of justice).
An example would be the case wherein a pregnancy may need to be terminated in order to
preserve the life of the mother. The principle of double effect is alleged to allow the removal of
21 Summa Theologiae, IIa-IIae Q. 64, art. 7
a life-threatening cancerous uterus, even though this procedure will bring the death of a fetus,
on the grounds that in this case the death of the fetus is not "directly" intended.
Jurisprudence holds that, when the accused admits committing the crime but invokes self-
defense to escape criminal liability, the burden of proof shifts to him. It necessarily follows that
he must now rely on the strength of his own evidence and not on the weakness of that of the
prosecution, for even if the latter's evidence is weak, it cannot be disbelieved after the accused
has admitted the killing. He must then prove the following elements of self-defense: unlawful
aggression on the part of the victim; reasonable necessity of the means employed to prevent or
repel it and lack of sufficient provocation on the part of the one resorting to self-defense. Of
these requisites, the most indispensable is unlawful aggression on the part of the victim. If there
is no unlawful aggression, there is nothing to prevent or repel. And for unlawful aggression to be
appreciated, there must be a strong and positive act of real aggression, not merely a threat or
an intimidating stance. Thus, the accused who claims self-defense must positively establish that
there was an actual, sudden and unexpected attack, or imminent danger thereof, by the victim.
In Jayme v. People22, In acquitting the petitioner of the charge of frustrated homicide, the
Supreme Court held that petitioner acted in legitimate self-defense. The Court found that the
petitioner had duly proved all the essential elements of self-defense. It ruled that petitioner
employed reasonable means to repel the sudden unprovoked attack of which he was the victim.
Under the above-mentioned situation, in the darkness of the night, with the element of surprise
in the assault, and his perception that the aggressor was armed with a knife and together with
three or more persons was ganging up on him, it was reasonable for petitioner to use a knife to
disable his adversary. His knife was his only means of defense, and under the circumstances of
the case there was clearly a reasonable necessity for him to make use of it. It cannot be said
22 G.R. No. 124506. September 9, 1999
with any certainty that his life was not in danger. Reasonable necessity does not mean absolute
necessity. It is not the indispensable need but the rational necessity, which the law requires.
The rule of reasonable necessity is not ironclad in its application; it depends upon the
circumstances of the particular case. One who is assaulted does not have the time nor sufficient
tranquility of mind to think, calculate and choose the weapon to be used. The reason is obvious,
in emergencies of this kind, human nature does not act upon processes of formal reason but in
obedience to the instinct of self-preservation; and when it is apparent that a person has
reasonably acted upon this instinct, it is the duty of the courts to sanction the act and to hold the
actor irresponsible in law for the consequences.
Bibliography
Cases:
317 Phil. 897 1995 People v Agustin
322 Phil. 6, 14, January 18, 1996 Philippine National Bank v. Office of the President
A.M. No. CA-99-30. September 29, 1999 United BF Homeowners v. Gutierrez
G.R. No. 132384, 21 September 2001, pp. 17-18 People v. Gadia
G.R. No. 140557-58. December 5, 2001 People v. Herrera
G.R. No. 124506. September 9, 1999 Jayme v. People
G.R. No. L-3517. August 7, 1907 US. v. Magno
G.R. No. 141699. August 7, 2002 People v. Lim
G.R. No. 132577. August 17, 1999 People v. Webb
G.R. No. 145503. August 20, 2002 People v. Valdez
Others:
Citing Ex parte Wall, 107 U.S. 265, cited in Malcolm, Legal and Judicial Ethics, p. 214.
Francis Bacon: the major works By Francis Bacon, Brian Vickers pp 630.
Gert, Bernard, 2005, Morality, New York: Oxford University Press.
Henry Gleitman, Alan J. Fridlund and Daniel Reisberg (2004). Psychology (6 ed.). W. W. Norton
& Company. ISBN 0-393-97767-6.
Kent M. Keith, The Silent Revolution: Dynamic Leadership in the Student Council
"Life of Pi", http://en.wikipedia.org/wiki/Life_of_pi#Life_is_a_story accessed 10/31/2013
Margulis, Lynn. & Sagan, Dorion. (1995). What Is Life? (pg. 1). Berkeley: University of California
Press.
Murder or Mercy (http://foxnewsinsider.com/2013/08/29/kentucky-man-ernest-chris-chumbley-
claims-he-shot-wife-end-cancer-suffering)
Offender Therapy and Comparative Criminology 48 (1)
Oluyemisi Bamgbose (2004). "Euthanasia: Another Face of Murder". International Journal of
Offender
Therapy and Comparative Criminology 48 (1)
Section 1 [17], Article III of the 1987 Constitution
Summa Theologiae, IIa-IIae Q. 64, art. 7
Renton, Jennie. "Yann Martel Interview". Textualities. Retrieved 19 May 2013
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