Case Digest (A.M. No. 97-2-12-MTC) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mayor “Jong” Amado Corpus, Jr. and Carlito Samonte v. Hon. Judge Ramon D. Pamular, G.R. No. 186403, decided on September 5, 2018 under the 1987 Constitution, the Supreme Court reviewed a petition for certiorari under Rule 65 assailing the February 26, 2009 Order of Branch 33, RTC Guimba, Nueva Ecija. On June 4, 2008, at around 10:30 a.m., Carlito Samonte shot and killed Angelito Espinosa in Cuyapo, Nueva Ecija. Arrested in flagrante, Samonte was charged with murder by information dated June 5, 2008 and pleaded self-defense upon arraignment. During trial the victim’s widow, Priscilla Espinosa, and several witnesses, notably Alexander Lozano, submitted affidavits implicating Corpus as the instigator. After an initial dismissal, OIC Provincial Prosecutor Floro Florendo reversed course on January 26, 2009, finding probable cause to indict Corpus in an amended information alleging “conspiring and confederating together.” Deputy Prosecutor Bonifacio soon reinstated the dismissal, b Case Digest (A.M. No. 97-2-12-MTC) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Incident
- Petitioners Amado “Jong” Corpus, Jr. (Mayor) and Carlito Samonte are accused of murdering Angelito Espinosa on June 4, 2008 at Corpuz Street, Cuyapo, Nueva Ecija.
- Samonte was caught in flagrante delicto with an unlicensed .45-caliber pistol and was arrested; an information for murder was filed June 5, 2008.
- Preliminary Investigation and Affidavits
- Samonte was arraigned, pleaded self-defense, and trial commenced. The victim’s wife, Priscilla Espinosa, filed several affidavits after the prosecution’s second witness, including one by Alexander Lozano implicating Mayor Corpus as instigator.
- The Provincial Prosecutor initially dismissed the complaint (Oct. 7, 2008), but upon reconsideration and review by Officer-in-Charge Floro Florendo, found probable cause and recommended an amended information adding Corpus as co-accused (Jan. 26, 2009).
- Lower Court Proceedings and Amended Information
- Assistant Provincial Prosecutor Bonifacio, however, reinstated dismissal of charges against Corpus. The prosecution filed an undated Motion to Amend Information; petitioners opposed and filed a Petition for Review to the Department of Justice (DOJ).
- RTC Branch 33 Judge Pamular set a hearing (Feb. 13, 2009) and on Feb. 26, 2009 granted the motion, admitted the amended information charging Samonte and Corpus with murder by “conspiring and confederating,” issued a warrant of arrest for Corpus, and denied suspension of proceedings.
- Corpus and Samonte filed a petition for certiorari in the Supreme Court with a prayer for a TRO; SC issued TRO and required comments. DOJ later affirmed probable cause against Corpus (June 26, 2009), then reversed on motion for reconsideration (Sept. 8, 2009).
Issues:
- Whether Judge Pamular gravely abused discretion by proceeding on the amended information and issuing a warrant against Corpus despite pending DOJ review.
- Whether Corpus’s arraignment may proceed after the 60-day maximum suspension under Rule 116, Sec. 11(c), RRCP.
- Whether the addition of Corpus and the “conspiring and confederating” allegation constituted a prohibited, prejudicial substantial amendment after Samonte’s plea.
- Whether Judge Pamular personally determined probable cause as constitutionally required for a warrant of arrest.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)