G.R. No. L-2110; July 22, 1948
GODOFREDO DIZON, petitioner, vs. THE COMMANDING GENERAL OF THE PHILIPPINE RYUKUS COMMAND, UNITED STATES ARMY, respondent.

FACTS

Petitioner Godofredo Dizon was prosecuted, convicted, and sentenced by a U.S. Army General Court Martial for an offense allegedly committed at the main storage area, Philrycom Engineer Depot, U.S. Army, located in Quezon City. This area was a U.S. military installation existing before the signing of the Philippines-U.S. Military Bases Agreement on March 14, 1947. Dizon filed a petition for habeas corpus, contending that the court martial lacked jurisdiction because the offense was not committed within a base as defined in the Agreement, and that even if it was, the Agreement is unconstitutional for depriving Philippine courts of jurisdiction and violating constitutional guarantees of due process and equal protection.

ISSUE

1. Whether the U.S. Army General Court Martial had jurisdiction over the offense committed at the Quezon City installation.
2. Whether the Philippines-U.S. Military Bases Agreement of March 14, 1947, is unconstitutional for diminishing the jurisdiction of Philippine courts and violating constitutional rights.

RULING

The Supreme Court dismissed the petition, upholding the jurisdiction of the U.S. court martial and the constitutionality of the Agreement.
1. On Jurisdiction: The Court held that the installation, while not listed in the Annexes of the Agreement, qualified as a “temporary installation” under Article XXI. Since it was located outside Manila, the terms of the Agreement pertaining to bases applied. Under Article XIII, the U.S. had jurisdiction over offenses committed within such a base, as the exceptions (where both parties are Philippine citizens not in the U.S. armed forces, or the offense is against Philippine security) did not apply to Dizon’s case.
2. On Constitutionality: The Court ruled that the Agreement did not violate the Constitution. It cited the well-settled principles of international law, adopted as part of Philippine law under the Constitution, which grant immunity from local jurisdiction to a foreign army stationed in a country with the host government’s permission. The rights granted by the Agreement were consistent with, and not broader than, these principles. Therefore, the jurisdictional concession was a valid exercise of sovereignty and not an unconstitutional diminution of the judicial power of Philippine courts.

DISSENTING OPINION (Perfecto, J.): Justice Perfecto dissented, arguing that the Agreement’s grant of extraterritorial jurisdiction to the U.S. military violated Philippine sovereignty and constitutional mandates on judicial power, due process, and equal protection. He viewed it as an affront to national dignity and a dangerous precedent that compromised the Republic’s sovereignty.

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