Facts:

• Gloria R. Abrera is the petitioner and appellant.
• Ludolfo V. Munoz, the Justice of the Peace of Oas, Albay, and Corazon A. Flordeliza are the respondents and appellees.
• Corazon A. Flordeliza filed a complaint for serious oral defamation against Abrera in the Justice of the Peace Court.
• A preliminary investigation was conducted, resulting in a warrant of arrest for Abrera, who was later admitted to bail.
• The preliminary investigation had two stages; during the second stage, Abrera's counsel requested to cross-examine prosecution witnesses, which was denied by the Justice of the Peace.
• Abrera began presenting her evidence by testifying on her own behalf.
• The prosecution sought to cross-examine Abrera after her testimony, but her counsel objected.
• On May 5, 1956, the Justice of the Peace allowed the prosecution to cross-examine Abrera and her witnesses.
• Abrera's motion for reconsideration was denied, leading her to file a petition for certiorari in the Court of First Instance of Albay.
• The lower court dismissed her petition, stating that the accused does not have an absolute right to cross-examine witnesses before arrest.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the lower court's order, dismissing Abrera's petition for certiorari.
• The Court ruled that the Justice of the Peace did not exceed his jurisdiction in allowing the prosecution to cross-e...(Unlock)

Ratio:

• The Supreme Court reasoned that the Justice of the Peace's refusal to allow Abrera to cross-examine prosecution witnesses prior to her arrest does not prevent the prosecution from cross-examining defense witnesses.
• The preliminary investigation aims to determine if there are sufficient ground...continue reading