Article III, Section 19 guarantees that: "Excessive fines shall not be imposed, nor cruel, degrading or inhuman punishmentinflicted. Neither shall death penalty be imposed unless, for compelling reasons involving heinous crimes, the Congress hereafter provides for it. Any death penalty already imposed shall he reducedto reclusion perpetua." Likewise, Republic Act No. 9346 prohibits the imposition of the death penalty in the country. This only demonstrate the Philippines’ progressive compliance with international obligations on humanrights. As can be deduced from theaforecited provisions of the international human rights instruments, the fundamental law ofthe land andrelevantlegislation, the life of a personis sacred; therightto life of a person is absolute, be he/she a criminal or not. As such, the deprivation oflife is at all times culpable, regardless of who the perpetrator is — a private individual or a State authority or an agent of a person in authority. Moreover, the death penalty constitutes the ultimate form of torture. Resurrecting the death penalty in Philippine setting will inevitably defy the principle of inviolability of life and dignity of the humanbeing. It will constitute deliberate killing, licensed by the State, of those covered by the proposedlegislation on anti-salvaging. The spate of extrajudicial killings and appalling criminal acts resulting in the deaths of several persons in the country cannot serve to justify any movefrom Congressto considerthe revival of the death penalty. Besides, there is no study with conclusive findings, showing that death penalty serves as a deterrence of crimes. Moreover, there is a grave danger that such permanent and irreparable penalty wouldlikely result in the execution of innocent people dueto the country's imperfect justice system whichis vulnerableto errors - errors, such as the imposition andexecutionofdeath penalty, which could neverberectified. Third, on Section 3 of House Bill 566.—It is suggested that the proposed law should identify the elements of the act/s of salvaging or extrajudicial killing sought to be defined and penalized as a crime, in order to distinguish it from the common crime of homicide or murder under the Revised Penal Code. If the primary intentis to penalize extrajudicial killings as political killings, then the factors in the determination ofpolitical killings as set forth in Administrative Order No. 35-2007 issued by the Supreme Court should be considered. Fourth, on Section 4 which speaks of definition of the terms "salvaging" and "extrajudicial killings" - Specifically, Section 4(a) defines "Salvaging" as (T)hekilling of any person by any public officer, person in authority or agent of a person in authority. Section 4(b) defines ' 'Extrajudicial killing" as (A)nykilling other than that imposed by the state pursuant to the provisions of the Constitution on heinous crimes; ‘extrajudicial killing' means a deliberated killing not authorized by a previous judgment pronounced by a regularly constituted court affording all the judicial guarantees which are recognized as indispensablebycivilized people. Correlating Section 3 with Section 4, it would seem that Section 3 proviso jibes with the definition of "salvaging" as laid down in Section 4(a), but not with the definition of "extrajudicial killing” under Section 4(b). Fifth, Section 5 imposes the death penalty upon any public officer, person in authority or agentof a person in authority for any salvaging or extrajudicial killing as defined in the proposedlegislation. Again, it should be noted that the definition of 47