G.R. No. 226236 - De Leon vs. Luis

Background of Parties and Underlying Qualified Theft Case
Respondent Atty. Judith Z. Luis (Atty. Luis) served as counsel for Ernesto de los Santos (Ernesto) in a qualified theft case filed by petitioners Dr. Emily D. de Leon, Dr. Ma. Corazon Ramona Ll. de los Santos, Dean Atty. Joe-Santos B. Bisquera and Atty. Diosdado G. Madrid (petitioners).
A warrant of arrest was issued against Ernesto. On 13 February 2013 and 7 June 2013, Ernesto visited Atty. Luis’s law office in Pasig City to sign and verify pleadings. Atty. Luis did not notify authorities of his presence nor effect any citizen’s arrest.

Filing of Obstruction Complaint and MeTC Proceedings
Petitioners filed a complaint for obstruction of justice under Section 1(c) of P.D. No. 1829 against Atty. Luis (and her associate, Atty. Alfredo A. Salting, Jr.) for “harboring or concealing” Ernesto.
On 7 October 2013, the Pasig City Prosecutor approved the filing of an information against Atty. Luis before Branch 70 of the Metropolitan Trial Court (MeTC). Atty. Luis surrendered, posted cash bond, and filed an Omnibus Motion for Determination of Probable Cause, to Quash the Information, and to Defer Arraignment, all of which Judge Maria Gaerlan Mejorada denied on 4 June 2014.

Raffling, Motions, and Dismissal in MeTC
Judge Mejorada inhibited; the case was raffled to Branch 69 (Judge Pimentel) who also inhibited motu proprio; re-raffled to Branch 72 (Judge Marilou Runes-Tamang).
On 13 January 2015, Judge Runes-Tamang granted Atty. Luis’s motion for reconsideration, finding no proof of deliberate intent to help Ernesto evade prosecution, and dismissed the complaint for lack of probable cause.

Special Civil Action and RTC Proceedings
Petitioners moved for reconsideration and for inhibition of Judge Runes-Tamang; following another inhibition, the case went to Judge Eduardo Ramon Reyes, who on 15 May 2015 denied reconsideration and affirmed dismissal.
Petitioners filed a special civil action for certiorari under Rule 65 before Branch 265 of the RTC, Pasig City. The RTC denied the petition on 29 March 2016 and likewise denied reconsideration on 22 July 2016, prompting this Rule 45 petition for review on certiorari.

Whether the RTC correctly held that the MeTC did not commit grave abuse of discretion in dismissing the obstruction of justice complaint against Atty. Luis.
Whether Atty. Luis’s failure to arrest or report Ernesto’s presence, despite knowledge of an outstanding arrest warrant, constitutes “harboring or concealing” under Section 1(c) of P.D. No. 1829.