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CASE 2016-0003: WIGBERTO “TOBY” R. TANADA, JR. VS. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL ET AL (G.R. No. 217012, 01 MARCH 2016, CARPIO JUSTICE) (BRIEF TITLE: TANADA VS. HRET)

 

DISPOSITIVE:

 

“WHEREFORE, we DISMISS the petition and AFFIRM the assailed Resolutions promulgated on 25 September 2014 and 22 January 2015 by the House of Representatives Electoral Tribunal in HRET Case No. 13-018 (EP).

 

SO ORDERED.”

 

SUBJECTS/DOCTRINES/DIGEST:

 

COMELEC RULES PROHIBIT FILING OF MOTION FOR RECONSIDERATION OF AN EN BANC RULING OF THE COMELEC

 

“First, Wigberto filed a prohibited pleading: a motion for reconsideration of a resolution of the COMELEC En Banc. Section 1 ( d), Rule 13 of the COMELEC Rules of Procedure specifically prohibits the filing of a “motion for reconsideration of an en banc ruling, resolution, order or decision except in election offense cases.” Consequently, the COMELEC En Banc ruling became final and executory, 8 precluding Wigberto from raising again in any other forum Alvin John’s nuisance candidacy as an issue.”

 

COMELEC EN BANC RULING BECOMES FINAL AFTER 5 DAYS

 

“Second, Wigberto filed his petition beyond the period provided by the COMELEC Rules of Procedure. The COMELEC En Banc promulgated its resolution on Alvin John’s alleged nuisance candidacy on 25 April 2013. Wigberto filed his petition in G.R. Nos. 207199-200 before this Court on 27 May 2013. By this date, the COMELEC En Bane’s resolution on Alvin John’s alleged nuisance candidacy was already final and executory. Section 3, Rule 37 of the COMELEC Rules of Procedure provides:

 

Section 3. Decisions Final After Five Days. -Decisions in preproclamation cases and petitions to deny due course to or cancel certificates of candidacy, to declare a candidate as nuisance candidate or to disqualify a candidate, and to postpone or suspend elections shall become final and executory after the lapse of five (5) days from their promulgation, unless restrained by the Supreme Court.”

 

HERET HAS NO JURISDICTION TO DETERMINE WHETHER ALVIN JOHN WAS A NUISANCE CANDIDATE BECAUSE THE COMELEC EN BANC RULING HAS ALREADY BECOME FINAL AND EXECUTORY

 

“The HRET did not commit any grave abuse of discretion in declaring that it has no jurisdiction to determine whether Alvin John was a nuisance candidate. If Wigberto timely filed a petition before this Court within the period allotted for special actions and questioned Alvin John’s nuisance candidacy, then it is proper for this Court to assume jurisdiction and rule on the matter. As things stand, the COMELEC En Bane’s ruling on Alvin John’s nuisance candidacy had long become final and executory.”

 

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SCD-2016-0003-TANADA

 

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CASE 2010-0001: MA. SOCORRO CAMACHO-REYES VS.  RAMON REYES (G.R. NO. 185286, 18 AUG 2010, NACHURA J.) SUBJECT/S: PSYCHOLOGICAL INCAPACITY; DECLARATION OF NULLITY OF MARRIAGE (BRIEF TITLE: REYES VS. REYES)

 

DISPOSITIVE:

 

        “WHEREFORE, the petition is GRANTED. The decision of the Court of Appeals in CA -G.R. CV No. 89761 is REVERSED. The decision of the Regional Trial Court, Branch 89, Quezon City in Civil Case No. Q-01-44854 declaring the marriage between petitioner and respondent NULL and VOID under Article 36 of the Family Code is REINSTATED. No costs.

 

SO ORDERED.”

 

SUBJECTS/DOCTRINES/DIGEST:

 

CONCLUSION ON PSYCHOLOGICAL INCAPACITY MAY BE REACHED WITHOUT INTERVIEWING THE PARTY WHO IS PSYCHOLOGICALLY INCAPACITATED.

 

CA REJECTED THE TESTIMONIES OF DOCTORS MAGNO AND VILLEGAS FOR BEING HEARSAY SINCE THEY NEVER PERSONALLY EXAMINED AND INTERVIEWED THE RESPONDENT. WAS CA CORRECT?

 

 

THE TOTALITY OF THE BEHAVIOUR OF RESPONDENT WAS PERSONALLY EXPERIENCED BY PETITIONER. SHE HAD OCCASION TO INTERACT WITH, AND EXPERIENCE, RESPONDENT’S PATTERN OF BEHAVIOR WHICH SHE COULD THEN VALIDLY RELAY TO THE CLINICAL PSYCHOLOGISTS AND THE PSYCHIATRIST. SECONDLY THE FINDINGS OF THE DOCTORS WERE NOT BASED SOLELY ON THE INTERVIEW WITH PETITIONER BUT ALSO ON THE INTERVIEW WITH OTHER INFORMANTS.

 “The lack of personal examination and interview of the respondent, or any other person diagnosed with personality disorder, does not per se invalidate the testimonies of the doctors. Neither do their findings automatically constitute hearsay that would result in their exclusion as evidence.

 

For one, marriage, by its very definition, necessarily involves only two persons. The totality of the behavior of one spouse during the cohabitation and marriage is generally and genuinely witnessed mainly by the other. In this case, the experts testified on their individual assessment of the present state of the parties marriage from the perception of one of the parties, herein petitioner. Certainly, petitioner, during their marriage, had occasion to interact with, and experience, respondents pattern of behavior which she could then validly relay to the clinical psychologists and the psychiatrist.

 

For another, the clinical psychologists and psychiatrists assessment were not based solely on the narration or personal interview of the petitioner. Other informants such as respondents own son, siblings and in-laws, and sister-in-law (sister of petitioner), testified on their own observations of respondents behaviour and interactions with them, spanning the period of time they knew him. These were also used as the basis of the doctors assessments.”

 

WHAT ARE THE GENERAL DIAGNOSTIC CRITERIAL FOR PERSONALITY DISORDERS? 

 

“The recent case of Lim v. Sta. Cruz-Lim,[1][18] citing The Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM IV),[2][19] instructs us on the general diagnostic criteria for personality disorders:

 

  1. An enduring pattern of inner experience and behavior that deviates markedly from the expectations of the individual’s culture. This pattern is manifested in two (2) or more of the following areas:

(1) cognition (i.e., ways of perceiving and interpreting self, other people, and events)

(2) affectivity (i.e., the range, intensity, liability, and appropriateness of emotional response)


(3) interpersonal functioning

        (4) impulse control

 

  1. The enduring pattern is inflexible and pervasive across a broad range of personal and social situations.
  2. The enduring pattern leads to clinically significant distress or impairment in social, occupational or other important areas of functioning.
  3. The pattern is stable and of long duration, and its onset can be traced back at least to adolescence or early adulthood.
  4. The enduring pattern is not better accounted for as a manifestation or a consequence of another mental disorder.
  5. The enduring pattern is not due to the direct physiological effects of a substance (i.e., a drug of abuse, a medication) or a general medical condition (e.g., head trauma).

 

Specifically, the DSM IV outlines the diagnostic criteria for Antisocial Personality Disorder:

 

  1. There is a pervasive pattern of disregard for and violation of the rights of others occurring since age 15 years, as indicated by three (or more) of the following:

 

(1) failure to conform to social norms with respect to lawful behaviors as indicated by repeatedly performing acts that are grounds for arrest

(2)    deceitfulness, as indicated by repeated lying, use of aliases, or conning others for personal profit or pleasure

(3)    impulsivity or failure to plan ahead

(4)    irritability and aggressiveness, as indicated by repeated physical fights or assaults

(5)    reckless disregard for safety of self or others

(6)    consistent irresponsibility, as indicated by repeated failure to sustain consistent work behavior or honor financial obligations

(7) lack of remorse as indicated by being indifferent to or rationalizing having hurt, mistreated, or stolen from another

 

  1. The individual is at least 18 years.

 

  1. There is evidence of conduct disorder with onset before age 15 years.


 

  1. The occurrence of antisocial behavior is not exclusively during the course of schizophrenia or a manic episode.[3][20]”

 

CAN DENIAL BY RESPONDENT THAT HE IS PSYCHOLOGICALLY INCAPACITATED CONTRAVENE DOCTOR’S FINDINGS?

 

  1. A PERSON AFFLCITED WITH A PERSONALITY DISORDER WILL NOT NECESSARILY HAVE PERSONAL KNOWLEDGE THEREOF.

 

“Within their acknowledged field of expertise, doctors can diagnose the psychological make up of a person based on a number of factors culled from various sources. A person afflicted with a personality disorder will not necessarily have personal knowledge thereof. In this case, considering that a personality disorder is manifested in a pattern of behavior, self-diagnosis by the respondent consisting only in his bare denial of the doctors separate diagnoses, does not necessarily evoke credence and cannot trump the clinical findings of experts.”

 

THE CA SAYS THAT THE PSYCHOLOGICAL INCAPACITY OF RESPONDENT IS NOT INCURABLE BECAUSE THE DOCTOR RECOMMENDED THERAPY. IS CA CORRECT?

 

NO.

 

THERAPY IS USUALLY RECOMMENDED ONLY TO MANAGE BEHAVIOUR.

 

“The CA declared that, based on Dr. Dayans findings and recommendation, the psychological incapacity of respondent is not incurable.

 

The appellate court is mistaken.

 

A recommendation for therapy does not automatically imply curability. In general, recommendations for therapy are given by clinical psychologists, or even psychiatrists, to manage behavior. In Kaplan and Saddocks textbook entitled Synopsis of Psychiatry,[4][21] treatment, ranging from psychotherapy to pharmacotherapy, for all the listed kinds of personality disorders are recommended. In short, Dr. Dayans recommendation that respondent should undergo therapy does not necessarily negate the finding that respondents psychological incapacity is incurable.”

 

IN THIS CASE WHAT WERE THE MANIFESTATIONS ON RESPONDENT’S PATTERN OF BEHAVIOR WHICH BECAME BASIS FOR THE FINDING ON HIS PSYCHOLOGICAL INCAPACITY?

 

 “In sum, we find points of convergence & consistency in all three reports and the respective testimonies of Doctors Magno, Dayan and Villegas, i.e.: (1) respondent does have problems; and (2) these problems include chronic irresponsibility; inability to recognize and work towards providing the needs of his family; several failed business attempts; substance abuse; and a trail of unpaid money obligations.”

…………………………………….

 

        In the instant case, respondents pattern of behavior manifests an inability, nay, a psychological incapacity to perform the essential marital obligations as shown by his: (1) sporadic financial support; (2) extra-marital affairs; (3) substance abuse; (4) failed business attempts; (5) unpaid money obligations; (6) inability to keep a job that is not connected with the family businesses; and (7) criminal charges of estafa.”

 

WHAT IS THE GENERAL RULE ON DIAGNOSES MADE BY CLINICAL PSYCHOLOGISTS OR PSYCHIATRISTS?

THESE FINDINGS ARE NOT AUTOMATICALLY BELIEVED BY THE COURT.

 

 

 

“It is true that a clinical psychologists or psychiatrists diagnoses that a person has personality disorder is not automatically believed by the courts in cases of declaration of nullity of marriages. Indeed, a clinical psychologists or psychiatrists finding of a personality disorder does not exclude a finding that a marriage is valid and subsisting, and not beset by one of the parties or both parties psychological incapacity.

 

On more than one occasion, we have rejected an experts opinion concerning the supposed psychological incapacity of a party.[5][24] In Lim v. Sta. Cruz-Lim,[6][25] we ruled that, even without delving into the non-exclusive list found in Republic v. Court of Appeals & Molina,[7][26] the stringent requisites provided in Santos v. Court of Appeals[8][27] must be independently met by the party alleging the nullity of the marriage grounded on Article 36 of the Family Code. We declared, thus:

 

It was folly for the trial court to accept the findings and conclusions of Dr. Villegas with nary a link drawn between the “psychodynamics of the case” and the factors characterizing the psychological incapacity. Dr. Villegas’ sparse testimony does not lead to the inevitable conclusion that the parties were psychologically incapacitated to comply with the essential marital obligations. Even on questioning from the trial court, Dr. Villegas’ testimony did not illuminate on the parties’ alleged personality disorders and their incapacitating effect on their marriage x x x.

 

Curiously, Dr. Villegas’ global conclusion of both parties’ personality disorders was not supported by psychological tests properly administered by clinical psychologists specifically trained in the tests’ use and interpretation. The supposed personality disorders of the parties, considering that such diagnoses were made, could have been fully established by psychometric and neurological tests which are designed to measure specific aspects of people’s intelligence, thinking, or personality.

 

x x x x

 

The expert opinion of a psychiatrist arrived at after a maximum of seven (7) hours of interview, and unsupported by separate psychological tests, cannot tie the hands of the trial court and prevent it from making its own factual finding on what happened in this case. The probative force of the testimony of an expert does not lie in a mere statement of his theory or opinion, but rather in the assistance that he can render to the courts in showing the facts that serve as a basis for his criterion and the reasons upon which the logic of his conclusion is founded.”

 

 

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SC-2010-0001-AUGUST-2010-REYES

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[1][18]     G.R. No. 176464, February 4, 2010.

[2][19]     Quick Reference to the Diagnostic Criteria from DSM IV-TR, American Psychiatric Association, 2000.

[3][20]     See Kaplan and Saddock’s Synopsis of Psychiatry and Psychology Behavioral Sciences/Clinical Psychiatry (8th ed.), p. 785.

[4][21]     See Kaplan and Saddock’s Synopsis of Psychiatry and Psychology Behavioral Sciences/Clinical Psychiatry (8th ed.), 1998.

 

[5][24]     Padilla-Rumabaua v. Rumbaua, G.R. No. 166738, August 14, 2009, 596 SCRA 157; Paz v. Paz, G.R. No. 166579, February 18, 2010.

[6][25]     Supra note 18.

[7][26]     Supra.

[8][27]     Supra note 11.

WHO IS MIRIAM DEFENSOR SANTIAGO?

From Wikipedia, the free encyclopedia

 

 

Senator of the Philippines
Incumbent
Assumed office
June 30, 2004
In office
June 30, 1995 – June 30, 2001
Secretary of Agrarian Reform
In office
July 20, 1989 – January 4, 1990
President Corazon Aquino
Preceded by Philip Juico
Succeeded by Florencio Abad
Personal details
Born Miriam Palma Defensor
June 15, 1945 (age 70)
Iloilo City, Philippines
Political party People’s Reform Party
Spouse(s) Narciso Santiago, Jr.
Alma mater University of the Philippines, Visayas (BA)
University of the Philippines, Diliman (BL)
University of Michigan, Ann Arbor (ML)
Maryhill School of Theology
Religion Roman Catholicism
Website Official website

Miriam Defensor Santiago (born June 15, 1945) is a Filipino politician, notable for having served in all three branches of the Philippine government – judicial, executive, and legislative. Santiago was named one of The 100 Most Powerful Women in the World in 1997 by The Australian magazine.[1] In 1988, she was named laureate of the Ramon Magsaysay Award for government service, with a citation “for bold and moral leadership in cleaning up a corrupt-ridden government agency.”[2][3][4][5] She ran in the 1992 presidential elections but was defeated in an election marred by allegations of impropriety by the victor.[6]

In 2012, she became the first Filipina and the first Asian from a developing country to be elected a judge of the International Criminal Court.[7][8] She later resigned the post, citing chronic fatigue syndrome, which turned out to be lung cancer.[9][10] In 2016, Santiago was invited to be part of the International Advisory Council of the International Development Law Organization (IDLO), an intergovernmental body that promotes the rule of law.[11] She has also written books covering topics in law and the social sciences. She has served three terms in the Philippine Senate.

 

Early life

Santiago was born in Iloilo City to a judge and a dean. She is the eldest of seven children. Santiago was a child prodigy, winning the high school spelling bee as a freshman and then for the next three years. She graduated valedictorian in grade school, high school, undergraduate school, and law school in the Diliman campus (at that time separate from the Manila campus).[12]

In 1965, Santiago graduated with a Bachelor of Arts degree in Political Science, magna cum laude from the University of the Philippines Visayas. After graduation, she was elected to the Pi Gamma Mu and Phi Kappa Phi honor societies.[13]

Santiago proceeded to the University of the Philippines College of Law. There, she was champion in numerous oratorical contests and debates.[1] She became the first female editor of the student newspaper, The Philippine Collegian, and was twice appointed ROTC muse.[14][15]

She graduated Bachelor of Laws, cum laude, from the University of the Philippines College of Law. Santiago went on a fellowship to the United States, and earned the degrees Master of Laws and Doctor of Juridical Science degrees at the University of Michigan, Ann Arbor. She finished both degrees in a period of only one and a half years.[16] Following school she took a position as special assistant to the justice secretary. She also taught political science at the Trinity University of Asia. She was law professor at the University of the Philippines, teaching evening classes for some ten years.[17][18]

She has studied at several universities, including Oxford and Harvard law summer schools; Cambridge; and The Hague Academy of International Law. She earned the degree Master of Religious Studies (without thesis) at the Maryhill School of Theology.[1]

In Oxford, Cambridge, she was a Research Fellow at St. Hilda’s College. She also took a summer program in law at St. Edmund’s Hall, Oxford. At Cambridge, she was a Research Fellow at the Lauterpacht Research Centre for International Law.

In 1970, she married Narciso Yap Santiago. They had two sons, but one died in college. They have five grandchildren.

Legal career

United Nations lawyer

After a stint of ten years at the justice department, Santiago served as Legal Officer of the UN High Commissioner for Refugees at Geneva, Switzerland. She was assigned to the Conferences and Treaties Section. She became skilled at treaty negotiation and drafting. She resigned her position when her father in the Philippines developed prostate cancer.[19]

Quezon City judge

Santiago was appointed judge of the Regional Trial Court of Quezon City, Metro Manila by President Ferdinand Marcos – the youngest judge appointed to Metro Manila. Further, she was exempted from the practice of first serving as a judge outside Metro Manila.[5]

As RTC judge, she quickly proclaimed a “no postponement” policy. At that time, cases were tried in segments that were usually a month apart, resulting in trials that took years to finish. Lawyers were prone to seek postponement of trial. As a result, trial judges scheduled ten or fifteen cases a day, so that they could make up for cases postponed.

Santiago scheduled only five cases a day, and heard each case, and disposed of the highest number of cases in her first year in office.

She became nationally famous when she issued perhaps the first decision to rule against martial law. At that time, alleged illegal public assemblies were declared as crimes and were punishable by death. A large group of activist students from the University of the Philippines and Ateneo, as well as activists in the film industry, staged a rally in a central business district, and denounced the First Lady for her excesses. To retaliate, Marcos issued a Preventive Detention Action order which authorized the military to hold suspects indefinitely, without bail. The students faced the dire prospect of missing their final exams and, for many of them, missing graduation.

Santiago suspended hearings on all other pending cases, and conducted whole-day trials. In the end, ordered the military to allow the students to post bail. After promulgating her decision at the end of the day, Santiago drove herself to the state university, where she was teaching law.

The Philippine Jaycees, the Philippine Lions, and the YMCA Philippines all gave her awards for judicial excellence.[1]

Political career

Aquino cabinet

After martial law, in 1988, President Corazon Aquino appointed Santiago as commissioner of immigration and deportation.[1] At that time, the Commission (CID) was one of the most corrupt government agencies in Southeast Asia. Santiago declared the Philippines as “the fake passport capital of the world,” and directed raids against criminal syndicates, including the Yakuza. She filled the CID detention center with alien criminals, and ordered construction of another detention center. She extended to legal aliens protection from widespread extortion by requesting President Aquino to issue an executive order that authorized the “alien legalization program.”[20]

She received serious death threats, but proclaimed: “I eat death threats for breakfast.”[1][21] A member of the House of Representatives delivered a privilege speech and denounced her raids against pedophile communities in Central Luzon ran by alien pedophiles. Santiago responded by calling him “fungus face.”[1][22]

The Rockefeller Foundation named her a laureate of the Magsaysay Award for government service – “for bold and moral leadership in cleaning up a graft-ridden government agency.” The Magsaysay Award is the Asian equivalent of the Nobel Prize.[2][3][4][5]

President Corazon Aquino promoted Santiago to member of her cabinet, as secretary of the Secretary of Agrarian Reform.[23][24] Under a controversial law passed by Congress and signed by President Aquino, all agricultural landholdings were taken by the government and divided among the farmers. Each landowner was allowed to keep only five hectares, and each farmer received three hectares. Payment was in bonds of the Land Bank.

To subvert the law, big landowners applied for conversion of the classification of their land as agricultural, to classification as commercial, residential, or industrial. The process became the widespread “conversion scandal of agrarian reform.” The DAR officials themselves were the biggest culprits, because they sold conversion permits for bribes on a market rate set at certain amounts per hectare involved in the conversion.

Santiago stopped the conversion scandal, and appeased the landowners by enhancing the incentives for voluntary offers by the landowners for the sale of their landholdings, which entitled them to an additional five percent cash payment.

When asked if the hacienda belonging to the president’s family should be covered by agrarian reform, Santiago replied that the family’s hacienda should be distributed among the farmers. Shortly thereafter President Aquino accepted Santiago’s resignation.[25]

Election, 1992

Santiago organized the People’s Reform Party (PRP) and ran with a senatorial ticket during the 1992 presidential campaign.

While campaigning on April 28, 1991, Santiago was severely injured in car crash,[26] which she described as assassination attempt.[27] She was wearing a white bush jacket, which became splattered with blood that gushed from a wound in her head. On orders of President Aquino, she was airlifted from Tarlac to a Manila hospital. She underwent surgery on the jaw, and at one point a Catholic priest administered the last rites of the dying. Two months later, she was back on the campaign trail.[28]

Santiago was leading the canvassing of votes for the first five days.[6] Following a string of power outages, the tabulation concluded, and Ramos was declared president-elect. Santiago filed a protest before the Supreme Court as electoral tribunal, citing the power outages during the counting of votes as evidence of massive fraud. Her election protest was eventually dismissed on a technicality.[1][21][23][29][30]

The public outrage over the presidential results prompted Newsweek to feature her and her rival on the cover with the question: “Was the Election Fair?” In another cover story, Philippines Free Press magazine asked: “Who’s the Real President?”[1]

Senate

She was first elected senator in 1995.[31] During her three terms, she served as chair mostly of the foreign relations committee and the constitutional amendments committee. She was elected as official candidate of her People’s Reform Party, hence she also served as chair of the foreign affairs committee of the Commission on Appointments.

Select laws authored

  • Reproductive Health Act of 2012[32]
  • Sin Tax Law[33]
  • Climate Change Act of 2009[34]
  • Renewable Energy Act of 2008[35]
  • Philippine Act on Crimes Against International Humanitarian Law[36]
  • Magna Carta of Women[37]
  • Cybercrime Act of 2012[38]
  • Archipelagic Baselines Act of 2009[39]

Election, 2016

Main article: Miriam Defensor Santiago presidential campaign, 2016

In October 2015, Santiago announced her intention to run for presidency in the 2016 Philippine presidential elections.[28][40] She later confirmed that Senator Bongbong Marcos would serve as her running mate for Vice President.[41]

Awards and honors

  • Magsaysay Award for Government Service, 1988, Asian equivalent of the Nobel Prize, Magsaysay Awards Foundation[5]
  • TOYM Award for Law, 1985 (The Outstanding Young Men) Opened to Women 1984, Philippine Jaycees
  • TOWNS Award for Law, 1986 (The Outstanding Women in the Nation’s Service), Philippine Lions
  • Philippine Judges’ Hall of Fame, 2015, Philippine Judges Association[42]
  • Most Outstanding Alumna in Law, University of the Philippines, 1988[13]
  • Gold Vision Triangle Award for government service, 1988, YMCA Philippines
  • Republic Anniversary Award for law enforcement, 1988, Civic Assembly of Women of the Philippines
  • Golden Jubilee Achievement Award for public service, 1990, Girl Scouts of the Philippines
  • Celebrity Mother Award, 1991, Gintong Ina Awards Foundation
  • Spain – Grand Cross of the Order of Civil Merit (November 30, 2007) [43]

Writings

Santiago has written at least 30 books, many of which are about law and social sciences.[1] Among her works is the Code Annotated Series Project 2000, a series of books about laws passed by the Philippine Congress and Supreme Court decisions. The Code Annotated Series is the main part of Santiago’s Legal Outreach Program.[44] During her initial battle with cancer, she continued to work on the 2014 edition of all her law books.[45] These were published as the 2015 edition of her Code Annotated Series, by Rex Bookstore.[46]

The doctoral dissertation Santiago wrote for the University of Michigan was published as a book named Political Offences in International Law.[47] Santiago has also written two autobiographies, Inventing Myself[48] and Cutting Edge: The Politics of Reform in the Philippines.[49]

Santiago also published a joke book in 2014 entitled Stupid is Forever, a collection of jokes, comebacks, one-liners, and pick-up lines she used in speeches.[50] A sequel entitled Stupid is Forevermore was published a year later. Both books were published by ABS-CBN Publishing.[51] The first book was named the best-selling book of 2014, selling about 110,000 copies in one month.[52]

References

  1. “Sen. Miriam’s ‘stupid’ book now a bestseller”. GMA News. 25 January 2015. Retrieved 10 February 2016.