Angel Lorenzo v. The Director of Health

The Petitioner, who suffered from leprosy (Hansen’s disease), was confined in the San Lazaro Hospital in Manila in conformity with §1058 of the Administrative Code, which empowered the Director of Health and his authorized agents “to cause to be apprehended, and detained, isolated, or confined, all leprous persons in the Philippine Islands.” The Petitioner brought a petition for habeas corpus, alleging that §1058 was unconstitutional.

The Court of First Instance of Manila sustained §1058 and denied the petition for habeas corpus. The petitioner appealed this judgment, arguing that the trial court was required to receive evidence to determine whether or not leprosy was a contagious disease.

The Court held that Article XV of Chapter 37, §1058 of the Administrative Code was constitutional. Section 1058 of the Administrative Code was a legitimate exercise of a police power that extended to the protection of the public health and leprosy undoubtedly qualified as a serious public health problem. Leprosy was commonly believed to be an infectious disease and scientific authority supported segregation of lepers as a means of preventing the spread of the disease. The local legislature had regarded leprosy as a contagious disease and had authorized lawful measures to control its spread. Whether or not this determination was correct, it had been decided according to due process of law, and was not open to the Court to review.

“The methods provided for the control of leprosy plainly constitute due process of law. The assumption must be that if evidence was required to establish the necessity for the law, that it was before the legislature when the act was passed. In the case of a statute purporting the have been enacted in the interest of the public health, all questions relating to the determination of matters of fact are for the legislature. If there is probable basis for sustaining the conclusion reached, its findings are not subject to judicial review. Debatable questions are for the Legislature to decide. The courts do not sit to resolve the merits of conflicting theories.”

“Similarly, the local legislature has regarded leprosy as a contagious disease and has authorized measures to control the dread scourge. To that forum must the petitioner go to reopen the question. We are frank to say that it would require a much stronger case than the one at bar for us to sanction admitting the testimony of expert or other witnesses to show that a law of this character may possibly violate some constitutional provision.”