G.R. No. 255100 - Domingo vs. De Guzman III vs. People

On June 12, 2014, Ferdinand "Enzo" Salas Pastor, an award-winning racecar driver, was shot at the intersection of Visayas Avenue and Congressional Avenue while driving a yellow truck with Salazar as a passenger.
Enzo’s wife, Dalia Guerrero Pastor (Dalia), was present at home before the drive and called Enzo multiple times during the trip.
The gunman wore black clothes, a motorcycle mask, and helmet, with a distinguishing characteristic of a slightly drooping eye.
Enzo died from the shooting; Salazar survived.

On August 23, 2014, PO2 Angel was arrested in a buy-bust operation and subsequently made an extrajudicial confession admitting to the killing of Enzo.
PO2 Angel implicated Domingo V. De Guzman III (De Guzman) as the mastermind, and Dalia as a conspirator who was present during the planning.
Details of the plot included inducement through claims of Dalia being abused by Enzo, multiple meetings, a down payment for the killing, and Dio Guzman providing the motorcycle and gun.
An entrapment operation led to De Guzman’s arrest on August 26, 2014 with evidence seized, including firearms and cash.

Witness Alvin Nidua (a self-proclaimed gun-for-hire) testified that De Guzman and Dalia tried to engage his services to kill Enzo but he declined due to insufficient payment.
PO2 Angel retracted his confession, alleging coercion and that he was forced to sign without reading the document.
Defense argued the illegal arrest of PO2 Angel, thereby rendering his confession inadmissible.
Testimonies of various witnesses, including Paolo Salazar and legal counsel Atty. Cecilio Lumantao, supported the validity of the initial confession.

The Regional Trial Court (RTC) Branches 85 and 91 handled the cases, issuing orders for warrants of arrest and hold departure orders against Dalia and De Guzman.
The prosecution consolidated the criminal cases for parricide (against Dalia) and murder (against De Guzman and PO2 Angel).
The trial court denied bail applications for De Guzman and PO2 Angel, citing strong evidence of guilt.

De Guzman filed petitions contesting the denial of bail and probable cause findings.
Dalia petitioned for certiorari questioning the warrant of arrest and requested dismissal of charges.
The CA granted Dalia’s petition, dismissing the parricide case due to lack of probable cause and annulling warrants against her.
The CA dismissed De Guzman’s petitions, affirming probable cause and denial of bail; in particular, it found the evidence sufficient to support murder charges against De Guzman.

The SC consolidated the petitions for review on certiorari initiated by De Guzman, Tomas Pastor (Enzo’s father), and the People of the Philippines.
Issues raised involved reviewing the sufficiency of evidence underlying probable cause and bail denial for De Guzman, and the conflicting findings on probable cause against Dalia.

Whether the Court may review the factual findings on the sufficiency of evidence to establish probable cause against De Guzman and the denial of his bail application.

Whether the Court may review the conflicting factual findings on the existence of probable cause against Dalia within her indictment for parricide and consequent issuance of a warrant of arrest.