and stated that there was a lack of convincing evidence that death penalty deters the commission of crimes.72 The Philippines penal system favored restorative justice.73 The Court in People v. Echegaray discussed the meaning of the term “heinous.” The Court first pointed to Republic Act No. 7659. The preamble to that Act characterizes heinous crimes as acts which are “grievous, odious and hateful offenses and which, by reason of their inherent or manifest wickedness, viciousness, atrocity and perversity are repugnant and outrageous to the common standards and norms of decency and morality in a just, civilized and ordered society.”74 The Court also considered Justice Santiago Kapunan's definition of heinous in his dissenting opinion in People v. Alicando.75 He traced the etymological root of the word “heinous” to the Early Spartans’ word, haineus, meaning, hateful and abominable, which, in turn, was from the Greek prefix haton, denoting acts “so hatefully or shockingly evil”.76 The Supreme Court also agreed with this definition. The Court in People v Echegaray also ruled that the elements of heinousness and compulsion are inseparable and are interspersed with each other. It concluded that an “alarming upsurge of such crimes” as stated in R.A. No. 7659 is immaterial and irrelevant in the act of Congress in the same for it was never intended by said law to be the yardstick to determine the existence of compelling reasons involving heinous crimes.77 Neither is it necessary to show statistical data on higher incidences of crimes to constitute “compelling reasons” to re-impose death penalty.78 It follows that the domestic understanding of the phrase “heinous crimes” should be interpreted narrowly, in the same manner as the international law interpretation of the phrase “the most serious crimes”. Since, as shown above, the Constitution must be read consistently with the international legal obligations of the Philippines, the proposed laws fail to comply with the limitation within Section 19 of the Constitution, providing additional grounds for their rejection by Congress. Conclusion Article III, Section 19 of the 1987 Philippine Constitution purporting to permit the reimposition of the death penalty in the Philippines for “compelling reasons” involving “heinous crimes” notwithstanding, it is doubtful whether the Philippines may be allowed to reimpose the death penalty, in view of the absolute nature of the obligations of the Philippines in international law. The ratification of the Second Optional Protocol by the 72 JOAQUIN G. BERNAS, SJ, THE 1987 PHILIPPINE CONSTITUTION: A COMPREHENSIVE REVIEWER 173 (2006). Id. 74 An Act to Impose the Death Penalty on Certain Heinous Crimes, amending for the Purpose the Revised Penal Laws, as amended, other Special Penal Laws, and for Other Purposes [DEATH PENALTY LAW], Republic Act No. 7659 (1993). 75 G.R. No. 117487, Dec. 12, 1995. 76 People v. Echegaray, G.R. No. 117427 (Feb. 07, 1997). 77 Id. 78 Id. 73 Page 22 of 23