ALN has released a statement condemning all violence against lawyers, prosecutors, and judges in the Philippines and recommending that the government take more effective measures to end the violence and the labeling and red-tagging of lawyers that incites it. You can read the full statement below and a pdf version here.  

Rights lawyer Maria Saniata Alzate, killed on 14 September 2023 

More must be done in the Philippines to Prevent Attacks on Lawyers

23 February 2024

Since Bongbong Marcos Jr. became president of the Philippines in 2022, at least nine lawyers have been physically attacked for their legal work, three of whom were killed (Danny Pondevilla, Elmer Mape, and Maria Saniata Alzate) and six severely injured (Ariff Lao, Karen Quinanola-Gonzales, Alexander Lacaba, Hamilcar Bigornia, Gerome Tubig, and Maria R.M. Melendez). The co-chair of the International Association of People's Lawyers (IAPL) Monitoring Committee on Attacks on Lawyers, Gill Boehringer, has recently given a short description of each lawyer, the conditions of their attack, and the rights-related work for which they were targeted.[1]

To give one example, on 14 September 2023, the rights lawyer Maria Saniata Alzate was shot at least eight times and killed by an unidentified gunmen from a motorcycle.[2] The police asked for assistance from the public and the National Bureau of Investigation later reported identifying the suspects. However, for more than five months after the shooting no one was arrested, until on 16 February 2024, the acting provincial prosecutor for Abra finally recommended filing charges.[3]

The victim, Alzate, was the former president of the Integrated Bar of the Philippines (IBP) Abra chapter and chair of its Bar Discipline and Legal Aid committees.[4] She also regularly defended poor clients on a pro bono basis and was the wife of a former regional judge.

As a rights lawyer, during the Duterte administration, Alzate assisted victims of extrajudicial attacks and killings by the police as part of Duterte’s illegal drug war at a time when dozens of lawyers were being murdered per year for similar work.[5] In January 2023, she provided legal assistance to a victim of illegal abduction, detention and torture by Philippine National Police, which resulted in an amparo order (a judicial remedy for a violation of rights) and a protection order issued by the Abra Regional Trial Court, ordering police to stay away from the man and his mother.[6] In September 2022 Alzate defended a trans woman teacher who was allegedly murdered by the chairperson of a small district over a land dispute.[7]

Several lawyer organizations condemned Alzate’s killing and urged government authorities to, in the IBP’s words, “act swiftly in the apprehension of the perpetrators.”[8] Following the murder, which occurred less than a month after the murder of another lawyer, Elmer Mape on Aug. 22 in Leyte, National Union of Peoples’ Lawyers (NUPL) President Ephraim Cortez captured the longstanding frustration by the Philippines' legal community with the government’s apparent inaction or insufficient action in the face of repeated violence against rights lawyers by expressing concern that, even after the Supreme Court issued a joint statement to address the issue of attacks on lawyers and a Rule on the Use of Body Worn Cameras,

no other positive action was made to address the issue on the attacks on the members of the legal profession. Several lawyers have since been killed, harassed and intimidated…. Time and again, we have called the attention of authorities to do something about these killings. We have been knocking on doors till the morning light so to speak.[9]

A similar point could be made about other measures that exist on paper to protect lawyers that have proven to be clearly ineffective in actually protecting lawyers. Many of these measures were described in a response by the Philippines government In April 2022 to a Human Rights Council survey requesting information from states about legal measures to protect lawyers, which included constitutional, legal, and administrative measures in the Philippines, as well as the work of the Integrated Bar of the Philippines.[10]

However, consistent with Cortez’s statement, the statistics listed below clearly demonstrate that these measures have been ineffective. Attacks on lawyers, prosecutors, and judges are part of a longstanding pattern in the Philippines under every administration since at least Marcos Sr., with the number of lawyers killed greatly escalating after 2001.[11]

As mentioned above, one of the most troubling aspects of this historical trend is the pattern of failures by state institutions to protect lawyers, prevent violence against them, or reliably seek justice following attacks. This pattern includes a spectrum of problematic official responses from President Duterte’s direct incitement of attacks on lawyers to a lack of serious investigation by police and prosecutions of attackers by prosecutors. During Duterte’s administration, extrajudicial killings of lawyers and civilians such as human rights defenders, including by vigilante groups with ties to the police, were rampant and met with almost total impunity.[13] Investigation and prosecution of perpetrators were typically denied, and even after Duterte’s administration ended, they have remained rare or delayed.  

Beyond this pattern of physical attacks, there is also a consistent practice of so-called red-tagging and (more recently) terrorist-tagging of lawyers, also called labeling, in which lawyers are labeled as communists or terrorists after defending or working with left-leaning (or perceived left-leaning) organizations, activists, or clients.[14] Labeling makes lawyers, prosecutors, and judges targets of violence. Lawyers have also faced other forms of harassment under the shadow of labeling, including (death) threats, intimidation, interference with their work, surveillance, and other forms of attacks.[15]

Needless to say, the threats against lawyers posed by attacks, incitements, red-tagging,[16] terrorist-tagging,[17] and harassment have had a severe chilling effect, impeding the work of lawyers involving politically sensitive persons or issues. As a spokesperson for Philippine’s Commission on Human Rights noted, “Continuous harm, vilification, intimidation, and red tagging of lawyers and judges, if left unaddressed, may result in sending a chilling message to those who remain faithful in the performance of their legal duties.”[18]

Attacks on lawyers are a violation of several of their rights, including their rights to life, freedom from ill treatment, and freedom of expression, as well as a flagrant violation of the standard set by the Basic Principles on the Role of Lawyers, which call on states to guarantee the security and physical integrity of lawyers and to prevent the practice of red/terrorist-tagging and labeling under principles 17 and 18.

Despite the long history of violence against lawyers in the Philippines, its continuation into Bongbong Marcos’s administration demonstrates that the practice did not end with Duterte’s administration, and more must be done to eliminate the practice for good, as well the practice of labeling which incites violence and harassment. Most importantly, any measures taken by the state must be effective in actually preventing incitement and violence against lawyers.


ALN condemns all violence against lawyers, prosecutors, and judges in the Philippines and recommends that the government take more effective measures to end the practice, including penalties for labeling of lawyers that incites violence, public education programs on the value of the work of rights lawyers, and measures to prevent possible complicity in violence by police, prosecutors, or public officials.


[1] Gill Boehringer, "From Marcos to Marcos: Lawyers murderously attacked", Bulatlai, 13 Feb. 2024,

[2] James Relativo, Malacañang vows justice for slain Abra human rights lawyer, Philstar, 16 Sept. 2023,

[3] IAPL Monitoring Committee on Attacks on Lawyers, "The Philippines: Murder case recommended vs suspect in slay of lawyer who aided drug war victims", 16 Feb. 2024,

[4] Sherwin De Vera, "Abra governor, IBP condemn killing of lawyer", Rappler, 15 Sept. 2023,; Relativo, above, note 2.

[5] Salman Khan, "Justice Denied: The Assassination of Maria Saniata Liwliwa Gonzales Alzate and the Ongoing Violence Against Legal Advocates in the Philippines", BNN, 16 Feb. 2024,

[6] Anne Umil, "Lawyers condemn killing of colleague in Abra", Bulatlai, 15 Sept. 2023,; De Vera, above, note 4.

[7] Relativo, above, note 2;  Amelia Hansford, "Elected official ‘masterminded’ murder of trans woman, suspect says", PinkNews, 3 Oct. 2022,

[8] Umil, above, note 6.

[9] Id.

[10] OHCHR, “Contribution from the Republic of the Philippines to the Thematic Report on the Protection of Lawers in the Free and Independent Exercise of the Legal Profession (Pursuant to HRC Resolution 44/8)”, April 2022,

[11] Id.

[12] Jodesz Gavilan, "LIST: Judges, prosecutors, lawyers killed under Duterte gov’t", Rappler, 8 Nov. 2018, (Judges killed as of 2020).

[13] Amnesty, "Philippines: UN must intensify pressure to end killings as impunity reigns", 25 Sept. 2020,; Amnesty, "Philippines: Surge in killings of lawyers and judges shows justice system 'in deadly danger' ", 26 Mar. 2021,

[14] Mong Palatino, "Philippine Judges and Lawyers Push Back Against Red-Tagging", Diplomat, 4 Oct. 2022,

[15] Freedom House, "Joint Statement: Philippines: Attacks Against Lawyers Escalating", 19 Sept. 2019,

[16] Jodesz Gavilan, "CHR: Red-tagging of Mandaluyong judge sends ‘chilling message’ to lawyers", Rappler, 17 Mar. 2021,

[17] Kristine Joy Patag, "Justices ask: Has the anti-terrorism law 'chilled' petitioners into silence?", Philstar, 9 Feb. 2021,

[18] Gavilin, above, note 16.