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Philippine court declares missing Indigenous rights advocates victims of enforced disappearance

The Court of Appeals declared missing indigenous rights advocates Dexter Capuyan and Gene Roz Jamil “Bazoo” De Jesus as victims of enforced disappearance, citing strong indications of state agents’ involvement.

The court recently granted the privileges of the Writ of Amparo to the two activists, whose families have been searching for them since their abduction in Taytay town in Rizal province on April 28, 2023.

In a decision dated August 12, 2025, the appellate court found “egregious shortcomings” in the Philippine National Police’s (PNP) investigation and said there were “deliberate efforts to conceal key evidence.” 



It noted that police had located and interviewed the tricycle driver who witnessed the incident but withheld the information from both the petitioners and the court.

According to the witness, Capuyan and De Jesus were taken at gunpoint by armed men who identified themselves as members of the Criminal Investigation and Detection Group (CIDG). 

The court said this account was “suspiciously concealed and misrepresented” by the police, who claimed the victims voluntarily went with the men.

“This marks a significant step in our search for Dexter and Bazoo,” said Atty. Ben Galil Te of La Viña Zarate & Associates (LVZ Law), co-counsel for the victims’ families. 

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The lawyer said the court ruling offers hope that the two missing advocates may be found if authorities follow the directives. 

He added that, while the struggle ahead remains difficult, the decision marks a victory not only for their families but also for indigenous rights advocates and human rights defenders.

Atty. Anton Rodriguez, also co-counsel for the petitioners, said the State “failed to discharge its duty to prevent and investigate the disappearance of Bazoo and Dexter.”

“Whether the Respondents faithfully comply with the Court’s firm directives is a matter we will still have to closely monitor — and we will do just that,” he added. 

Capuyan, 56, was an activist leader based in La Trinidad, Benguet, while De Jesus, 27, worked as an information and communication officer for the Philippine Task Force for Indigenous Peoples Rights. 

Both were University of the Philippines Baguio graduates and former members of the Alliance of Concerned Students.

The petition for the Writ of Amparo was filed exactly a year before the ruling — on August 14, 2024 — by De Jesus’ sister, Idda Alexa C. De Jesus, and Capuyan’s daughter, Gabrielle Chuwaley D. Capuyan. 

The decision follows another recent appellate court ruling granting the privileges of the Writs of Amparo and Habeas Data in the case of missing activist Felix Salaveria, which rights groups say reflects a growing recognition of enforced disappearances in the country.

“We are deeply grateful for the court’s decision to grant our petition for the Writ of Amparo. It’s a powerful message that justice, though delayed, will not be denied. This strengthens our resolve in demanding accountability,” said Idda De Jesus.

The Commission on Human Rights (CHR) earlier urged “exhaustive efforts” to find the missing activists amid allegations they were in state custody. 

The Cordillera Human Rights Alliance claimed the military had placed a ₱1.8-million bounty on Capuyan over allegations linking him to the New People’s Army, a claim the armed forces have not confirmed. 

CHR has stressed that enforced disappearance is a severe human rights violation under Republic Act No. 10353, or the Anti-Enforced or Involuntary Disappearance Act of 2012, and has renewed its call for the Philippines to ratify the International Convention for the Protection of All Persons from Enforced Disappearance.

“We hope the day will soon come when the State’s practice of forcibly disappearing activists with impunity ends — and that all those responsible will finally be brought to justice,” Atty. Te said.

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