Case Digest (G.R. No. L-24646)
Facts:
The case involves Faustina Callanta as the petitioner against Hon. Felipe Villanueva, the City Judge of Dagupan City, and private respondents Cornelia Jimenez and Pastora David Jimenez. The events leading to this case began with the filing of two complaints for grave oral defamation against Callanta. On June 20, 1977, the petitioner contested the validity of the warrants of arrest issued by Judge Villanueva, arguing that the City Fiscal should have conducted the preliminary examination instead. Callanta's counsel claimed that this procedural misstep constituted a jurisdictional infirmity. Despite the issuance of the warrants, Callanta posted bail amounting to P600.00, which allowed her provisional liberty. The respondents, in their answer, indicated that the City Fiscal had indeed shown intent to prosecute Callanta, having conducted a preliminary examination and referred the complaints to his office as early as February 25, 1965. The arraignment was postponed on March 4, ...
Case Digest (G.R. No. L-24646)
Facts:
Background of the Case:
The case arose from the denial by respondent City Judge Felipe Villanueva of Dagupan City to grant motions to quash two complaints for grave oral defamation against petitioner Faustina Callanta. The petitioner contested the validity of the issuance of the warrants of arrest, arguing that the City Fiscal, not the City Judge, should have conducted the preliminary examination.Posting of Bail:
After the warrants of arrest were issued with bail fixed at P600.00, the petitioner posted the required bail bonds, securing her provisional liberty.Role of the City Fiscal:
Respondents asserted that the City Fiscal had shown intent to prosecute the petitioner. The City Fiscal conducted a preliminary examination, and the cases were referred to him. He appeared at the proceedings, indicating readiness for trial, and did not request further reinvestigation, suggesting agreement with the complaints filed.Petitioner’s Argument:
The petitioner claimed a jurisdictional infirmity, arguing that only the City Fiscal could conduct the preliminary examination.
Issue:
- Whether the issuance of the warrants of arrest by the City Judge was valid, given the petitioner’s claim that only the City Fiscal could conduct the preliminary examination.
- Whether the petitioner’s posting of bail constituted a waiver of any irregularities in the arrest process.
Ruling:
The Supreme Court dismissed the petitions for certiorari. It held that:
- The petitioner’s posting of bail constituted a waiver of any irregularities in the arrest process, including the alleged jurisdictional infirmity.
- The City Fiscal’s active involvement in the investigation and prosecution of the case demonstrated compliance with procedural requirements, even if the preliminary examination was conducted by the City Judge.
- The City Court of Dagupan City had the authority to conduct preliminary investigations under its charter, rendering the petitioner’s reliance on inapplicable precedents misplaced.
Ratio:
Waiver of Irregularities by Posting Bail:
The Court reiterated the doctrine that posting bail constitutes a waiver of any irregularities in the arrest process. This principle, established in cases like Zacarias v. Cruz and Luna v. Plaza, applies here. By posting bail, the petitioner estopped herself from contesting the validity of her arrest.Authority of the City Judge to Conduct Preliminary Investigations:
The Court emphasized that the City Court of Dagupan City, under its charter, had the authority to conduct preliminary investigations for any offense, regardless of the limits of punishment. This authority was explicitly granted by law, distinguishing the case from precedents like Sayo v. Chief of Police of Manila, which involved different jurisdictional contexts.City Fiscal’s Role and Compliance with Procedure:
The Court noted that the City Fiscal’s active participation in the case, including his appearance at the proceedings and readiness for trial, demonstrated compliance with procedural requirements. This further undermined the petitioner’s claim of jurisdictional infirmity.
Conclusion:
The Supreme Court dismissed the petitions, lifted the restraining order, and ruled that the petitioner’s posting of bail and the City Judge’s authority to conduct preliminary investigations rendered her claims untenable. Costs were imposed against the petitioner.