Case Digest (G.R. No. 234608) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 17, 2017, Horacio Tomas T. Castillo III, a first-year law student at the University of Santo Tomas, died allegedly due to hazing by members of the Aegis Juris Fraternity. Two days later, Senate Resolution No. 504 was filed directing the Senate Committees on Public Order and Dangerous Drugs, Justice and Human Rights, and Constitutional Amendments and Revision of Codes to investigate the death *in aid of legislation*. Petitioner Arvin R. Balag, identified in fraternity records as AJ Fraternity president, was subpoenaed to testify on October 18, 2017. During the hearing, he invoked his right against self-incrimination when asked whether he was fraternity president. Following motions by Senators Poe, Villanueva, and Zubiri, the Committee on Public Order cited him in contempt, ordering his arrest and detention by the Senate Sergeant-at-Arms until he “purges himself” by answering truthfully. Petitioner filed before the Supreme Court a petition for certiorari and prohibiti Case Digest (G.R. No. 234608) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Antecedents
- Petitioner: Arvin R. Balag, member of Aegis Juris (AJ) Fraternity at the University of Santo Tomas.
- Respondents: Senate of the Philippines, Senate Committees on Public Order and Dangerous Drugs; Justice and Human Rights; Constitutional Amendments and Revision of Codes; Senate Sergeant-at-Arms.
- Horacio Tomas Castillo III (first-year law student at UST) died on September 17, 2017, allegedly due to hazing by the AJ Fraternity.
- Senate Inquiry and Contempt Proceedings
- Senate Resolution No. 504 (filed September 19, 2017) directed a joint legislative inquiry in aid of legislation on hazing.
- Petitioner was subpoenaed to testify on September 25 and October 18, 2017. In the October 18 hearing, he was asked twice whether he was AJ Fraternity president; he invoked his right against self-incrimination each time.
- Senators Poe, Lacson, Villanueva, and Zubiri moved to cite him in contempt for false and evasive testimony. The Committee ordered his arrest and detention by the Sergeant-at-Arms “until such time that he gives his true testimony or purges himself of contempt.”
- Judicial Proceedings and Subsequent Developments
- Petitioner filed a petition for certiorari and prohibition with prayer for TRO/preliminary injunction before the Supreme Court.
- December 12, 2017: SC issued interim resolution for immediate release of petitioner.
- January 23, 2018: Committees submitted Reports Nos. 232 and 233 recommending approval of Senate Bill No. 1662 in substitution of earlier bills.
- February 12, 2018: Senate passed the “Anti-Hazing Act of 2018” (Senate Bill No. 1662) on third reading, effectively terminating the inquiry.
Issues:
- Whether the Senate Committees gravely abused their discretion in conducting the inquiry in aid of legislation and citing petitioner in contempt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)