Title
Supreme Court
De Lima vs. Guerrero
Case
G.R. No. 229781
Decision Date
Oct 10, 2017
Senator De Lima challenged DOJ and RTC actions in drug-related cases, alleging bias and procedural errors. Supreme Court denied her petition, upholding jurisdiction, probable cause, and procedural compliance.

Case Digest (G.R. No. 229781)
Expanded Legal Reasoning Model

Facts:

  • Legislative and Investigative Background
    • Senate and House inquiries on drug syndicates in New Bilibid Prison (NBP) triggered multiple complaints against petitioner Senator Leila M. De Lima and others.
    • The Department of Justice (DOJ) consolidated these cases and a DOJ Panel conducted a preliminary investigation in December 2016.
    • Petitioner filed various motions questioning DOJ’s jurisdiction and sought to inhibit the DOJ Panel; these motions were resolved against her.
    • Separate petitions assailing DOJ’s jurisdiction were filed with the Court of Appeals but were pending when DOJ filed Informations.
  • Filing of Informations and Trial Court Proceedings
    • On February 17, 2017, the DOJ Panel filed three Informations charging De Lima and co-accused with violations of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), docketed before RTC Muntinlupa Branch 204.
    • Charges alleged illegal drug trading from November 2012 to March 2013 involving extortion and receipt of illegal drug proceeds by De Lima, used to fund her senatorial bid.
    • Petitioner filed a Motion to Quash the Information for lack of jurisdiction, insufficient allegations, hearsay evidence, and multiplicity of offenses.
    • The RTC issued an order on February 23, 2017 finding probable cause and issued a Warrant of Arrest against De Lima without bail recommendation.
    • Petitioner was arrested on February 24, 2017 and committed to PNP Custodial Center.
  • Petition For Certiorari and Prohibition
    • On February 27, 2017, petitioner filed a petition before the Supreme Court assailing the RTC’s orders, warrant, and failure to resolve the Motion to Quash.
    • The plea included prayers to annul the RTC orders, enjoin further proceedings until resolution of the Motion to Quash, and restore her liberty.
    • The respondents argued procedural deficiencies, forum shopping, and supported the RTC’s jurisdiction and issuance of the warrant.
  • Notable Procedural Developments
    • Allegations arose that petitioner falsified jurats in her verification and certification against forum shopping; affidavits from the notary disputed this claim but revealed technical non-compliance.
    • Oral arguments were conducted on March 14, 21, and 28, 2017.

Issues:

  • Procedural Issues
    • Whether petitioner was excused from the doctrine on hierarchy of courts considering that the petition should have first been filed with the Court of Appeals.
    • Whether the pendency of the Motion to Quash renders the petition premature.
    • Whether petitioner violated the rule against forum shopping considering the pending Motion to Quash and petition in the Court of Appeals.
    • Whether the verification and certification against forum shopping filed with the Supreme Court were valid and sufficient.
  • Substantive Issues
    • Whether the RTC or the Sandiganbayan has jurisdiction over the offense charged under R.A. 9165 averred in the Information.
    • Whether the RTC judge gravely abused her discretion in finding probable cause to issue the warrant of arrest despite the pending Motion to Quash.
    • Whether petitioner is entitled to provisional reliefs such as Temporary Restraining Order or Status Quo Ante Order pending resolution of the petition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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