The Bill of Rights was intended to protect private individuals against government intrusions. Hence, its provisions are not applicable between and amongst private individuals. (People v. Marti).
While the case of "Zulueta v. Court of Appeals", (Zulueta) may appear to carve out an exception to the abovementioned rule by recognizing the rule on "inadmissibility of evidence" between spouses when one obtains evidence in violation of his/her spouse's right to privacy, "such a pronouncement is a mere obiter dictum" that cannot be considered as a binding precedent.
This is because the petition brought to the Court in Zulueta simply asked for the return of the documents seized by the wife and thus, pertained to the ownership of the documents therein. Moreover, documents were declared inadmissible because of the injunction order issued by the trial court and not on account of Art. III, Sec. 3 of the Constitution.
At any rate, [violation] of the right to privacy between individuals is properly governed by the provisions of the: Civil Code; the Data Privacy Act (DPA); and other pertinent laws, while [admissibility] shall be governed by the rules on: relevance; materiality; authentication of documents; and the exclusionary rules under the Rules on Evidence.
Read the full case here: https://bit.ly/3f5QA6M
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