Case Digest (G.R. No. 69863-65) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lino Brocka, et al. vs. Juan Ponce Enrile, et al. (270 Phil. 271, December 10, 1990), petitioners Lino Brocka, Benjamin Cervantes, Cosme Garcia and Rodolfo Santos (collectively “Brocka, et al.”), together with other media practitioners, were arrested on January 28, 1985 by elements of the Northern Police District following the dispersal of a jeepney strike demonstration in Quezon City. They were charged with Illegal Assembly (Art. 146, RPC) before Branch 108, Regional Trial Court (RTC), Quezon City, where bail of ₱3,000 was granted to the co-defendants but denied to Brocka, et al. A trial court order dated February 9, 1985 directed their provisional release upon posting of bail, yet they remained in detention under an alleged Preventive Detention Action (PDA) issued January 28, 1985. Without notice to counsel, the City Fiscal filed three separate informations on February 11, 1985 for “Inciting to Sedition” (Art. 142, RPC) against Brocka, et al., recommending no bail. Petition Case Digest (G.R. No. 69863-65) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and Relief Sought
- Original petition filed on February 13, 1985 for habeas corpus and to enjoin the City Fiscal of Quezon City from investigating “Inciting to Sedition” charges against Lino Brocka, et al.
- Supplemental petition filed on February 19, 1985 to implead the Presiding Judge and to enjoin prosecution of Criminal Cases Nos. Q-38023, Q-38024, and Q-38025, including issuance of arrest warrants and arraignment.
- Arrest, Initial Charges, and Bail
- Petitioners arrested on January 28, 1985 after violent dispersal of a demonstration supporting the ACTO jeepney strike; charged with Illegal Assembly in Criminal Cases Nos. 37783, 37787, and 37788 before RTC Branch 108, Quezon City.
- All petitioners except Brocka, et al. released on bail of ₱3,000; Brocka, et al. denied bail as alleged leaders. RTC ordered provisional release on February 9, 1985, but respondents invoked a Preventive Detention Action (PDA) allegedly issued January 28, 1985, which was never produced.
- Second Round of Charges and Release
- On February 11, 1985, despite no notice to counsel, new informations for Inciting to Sedition (Art. 142, RPC) were filed as Criminal Cases Nos. Q-38023 to Q-38025, recommending no bail. The preliminary investigation was alleged to be a sham.
- Petitioners released provisionally on February 14, 1985 by order of President Marcos; habeas corpus issue rendered moot, leaving only the legality of enjoining sedition prosecution.
- Allegations of Bad Faith and Multiplicity
- Petitioners claimed state actors colluded to split a single act into two offenses to avoid bail and subject them to continued detention.
- Alleged violations: failure to produce PDA, denial of counsel’s request for time to confer, hasty filing of sedition charges based on same utterances used in illegal assembly cases, and persecution rather than legitimate prosecution.
Issues:
- Whether the criminal prosecution for Inciting to Sedition may be lawfully enjoined by injunction.
- Whether the sedition charges constitute double jeopardy or improper splitting of a single act into two offenses.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)