G.R. No. 132607 - Cebu Shipyard and Engineering Works, Inc. vs. William Lines, Inc.

Manuel Monroy was killed on June 15, 1953 in Pasay City.
Several persons were implicated and accused in connection with the killing.
After a prolonged trial, the Court of First Instance of Pasay City found Oscar Castelo, Jose de Jesus, Hipolito Bonifacio, Bienvenido Mendoza, Francis Berdugo, among others, guilty of murder and sentenced them to death.
The convicted parties appealed their sentences, and even after a retrial (in which Oscar Castelo was reconvicted), the case remained under judicial scrutiny.

Pending the appeal, the late President Magsaysay ordered a reinvestigation of the original case.
Intelligence agents of the Philippine Constabulary and investigators from Malacanang conducted inquiries.
They obtained affidavits, confessions, and written statements implicating persons other than those previously convicted.

Counsel for Oscar Castelo and co-defendants submitted a request to respondent Fiscal Salva to reinvestigate the case based on the new evidence (affidavits, confessions, and statements).
Fiscal Salva consulted with the Solicitor General and held a conference with the Secretary of Justice.
The results of the reinvestigation by the Philippine Constabulary and Malacanang investigators were communicated to the counsel of the appellants.

Fiscal Salva resolved to conduct a reinvestigation by designating a committee comprised of himself (as chairman) and Assistant City Attorneys Herminio A. Avendanio and Ernesto A. Bernabe.
Timoteo Cruz, petitioner, was subpoenaed to appear at Fiscal Salva’s office for a criminal investigation scheduled initially for September 21, 1957.
Petitioner Cruz requested postponement due to a conflict (his counsel, Atty. Crispin Baizas, had a hearing in Naga City), leading to the investigation being rescheduled for September 24, 1957.

On the day of the preliminary investigation, Atty. Baizas questioned the jurisdiction of the committee (and Fiscal Salva in particular) to reinvestigate, given that the case (People vs. Oscar Castelo, et al.) was already pending appeal before the Supreme Court.
A petition for certiorari and prohibition was subsequently filed to restrain the continuation of the investigation.
The petition argued that the reinvestigation would interfere with the appellate process and encroach upon the administration of justice.

Unlike standard, unobtrusive investigations, the preliminary investigation was held in the session hall of the Municipal Court of Pasay City.
The location was chosen apparently to accommodate a large crowd, including members of the press.
Special privileges were granted to the press during the investigation, with Fiscal Salva inviting reporters to ask questions—practices that contributed to widespread media coverage and sensationalism.

The evidence under investigation, including affidavits and confessions, implicated petitioner Cruz as the alleged instigator and mastermind behind the killing of Manuel Monroy.
Although Fiscal Salva claimed that Cruz had requested to be present at the investigation for his protection and to rebut incriminating evidence, Cruz later denied making any such request.
Ultimately, the dispute centered on whether Cruz was obliged to testify in a reinvestigation of a case already decided (and under appeal) by lower courts.

Whether a prosecuting officer or fiscal has the authority to reinvestigate a case already pending appeal before the Supreme Court.
Whether conducting such a reinvestigation would interfere with the proper administration of justice and the appellate review of the original conviction.

Whether petitioner Cruz could be legally compelled to appear and testify at a preliminary investigation if he later objected to his presence.
Whether his right to refuse testimony was subordinated or inappropriately overridden by the fiscal’s actions.

Whether the manner in which the preliminary investigation was conducted (including hosting it in a public venue and involving the press) was proper and in conformity with judicial norms.
Whether Fiscal Salva’s actions in permitting and encouraging media participation amount to an abuse of prosecutorial discretion.

Whether the fiscal's duty to secure a conviction conflicts with his responsibility to protect the innocent by reevaluating potentially exculpatory evidence.
The extent to which the prosecutorial duty to reinvestigate new evidence is compatible with maintaining the integrity of ongoing appeals.