Case Digest (G.R. No. 122866) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pedro S. Agcaoili, Jr. et al. v. House Committee on Good Government and Public Accountability (G.R. No. 232395, July 3, 2018), six employees of the Ilocos Norte provincial government (Agcaoili, Jr., Gaor, Calajate, Jambaro, Battulayan, Tabulog), collectively dubbed the “Ilocos 6,” and co-petitioner Governor Maria Imelda Josefa “Imee” Marcos filed an Omnibus Petition before the Supreme Court. They sought three remedies: (1) assumption of jurisdiction over a Habeas Corpus petition that had been raffled to the Court of Appeals, challenging their detention by the House Sergeant-at-Arms; (2) issuance of a Writ of Prohibition to halt a legislative inquiry under House Resolution No. 882 into the Provincial Government’s alleged misuse of tobacco tax shares for vehicle purchases; and (3) a Writ of Amparo to protect their rights to liberty and security. House Resolution No. 882, introduced on March 14, 2017, directed the Committee on Good Government and Public Accountability to investi Case Digest (G.R. No. 122866) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and context
- Petitioners Pedro S. Agcaoili, Jr., Encarnacion A. Gaor, Josephine P. Calajate, Genedine D. Jambaro, Eden C. Battulayan and Evangeline C. Tabulog (collectively, “Ilocos 6”), employees of the Provincial Government of Ilocos Norte.
- Co-petitioner Maria Imelda Josefa “Imee” R. Marcos, Governor of Ilocos Norte.
- Respondents Representative Rodolfo C. Fariñas, Representative Johnny T. Pimentel, Chairman and members of the House Committee on Good Government and Public Accountability, Lt. Gen. Roland Detabali (Ret.), Sergeant-at-Arms of the House, and the Committee itself.
- House Resolution No. 882 and legislative inquiry
- HR No. 882 (introduced March 2017) alleged misuse of Ilocos Norte’s shares in excise taxes on Virginian-type cigarettes, totaling ₱66,450,000 for vehicle purchases, in violation of RA 7171, RA 9184 and PD 1445.
- Invitation letters (April 6, 2017) summoned petitioners as resource persons for hearings (May 2, 2017); petitioners requested deferral pending instructions from Governor Marcos.
- Subpoenas ad testificandum (May 3) set testimony for May 16; petitioners sought clarification and additional preparation time; failed to appear.
- Contempt citations and detention
- Show Cause Orders issued for failure to obey subpoenas; petitioners notified of next hearing (May 29).
- On May 29, petitioners allege threats, leading questions, intimidation and contempt citations by Rep. Fariñas when memory lapses occurred; ordered detained.
- Respondents maintain petitioners were evasive and unprepared, knowing original documents were unavailable.
- Court of Appeals proceedings
- Petitioners filed a habeas corpus petition (CA SP No. 151029) against Detabali; CA issued writ, ordered production (June 2).
- Detabali failed to appear; Deputy Secretary General explained his absence; CA denied motion to dissolve writ and granted provisional release upon bond (June 9).
- House Committee issued contempt order against CA justices and threatened the CA; justices referred incidents to the Supreme Court.
- House lifted contempt, petitioners released July 25; CA dismissed habeas petition as moot (Aug 31).
- Omnibus Petition before the Supreme Court
- Filed July 13, 2017, praying for:
- Assumption of jurisdiction over the CA’s habeas corpus petition.
- Writ of prohibition to enjoin House inquiry under HR 882.
- Writ of Amparo to protect rights to liberty and security.
- Temporary restraining order/preliminary injunction against further hearings.
Issues:
- Whether the Omnibus Petition is rendered moot by the petitioners’ release.
- Whether the Supreme Court can assume jurisdiction over the habeas corpus petition pending before the Court of Appeals.
- Whether a writ of prohibition lies to enjoin the legislative inquiry on HR 882.
- Whether the petition states a valid cause for the issuance of a writ of Amparo.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)