Case Digest (G.R. No. 92163)
Facts:
- On February 27, 1990, Juan Ponce Enrile was arrested by law enforcement officers led by Director Alfredo Lim of the NBI.
- The arrest was based on a warrant issued by Judge Jaime Salazar of the Regional Trial Court of Quezon City in Criminal Case No. 90-10941.
- Enrile was charged with rebellion, murder, and multiple frustrated murder related to a failed coup attempt from November 29 to December 10, 1990.
- Following his arrest, Enrile was detained overnight at the NBI headquarters without bail.
- The next day, he was transferred to Camp Tomas Karingal and placed under the custody of Brig. Gen. Edgardo Dula Torres.
- On February 28, 1990, Enrile filed a petition for habeas corpus, alleging violations of his constitutional rights.
- The Supreme Court issued a writ of habeas corpus returnable on March 5, 1990, and set a hearing for March 6, 1990.
- The Solicitor General argued that the case did not fall under the precedent set by People vs. Hernandez.
- The Court granted provisional liberty to Enrile and the Panlilio spouses, conditioned upon the posting of bail.
Issue:
- (Unlock)
Ruling:
- The Court ruled that the information filed against Enrile does charge an offense, specifically simple rebellion.
- The Court found that a preliminary investigation was conducted, thus Enrile was not denied due process.
- The Court held that the judge's actions in issuing the warrant were sufficient and did not violate constitutiona...(Unlock)
Ratio:
- The Supreme Court reaffirmed the doctrine from People vs. Hernandez, stating that rebellion cannot be complexed with other crimes.
- The Court clarified that the information against Enrile should be interpreted as charging simple rebellion, despite its phrasing.
- The essence of the Hernandez ruling is to protect the accused from harsher penalties associated with complex c...continue reading
Case Digest (G.R. No. 92163)
Facts:
On February 27, 1990, Juan Ponce Enrile, the Senate Minority Floor Leader, was arrested by law enforcement officers led by Director Alfredo Lim of the National Bureau of Investigation (NBI). This arrest was executed based on a warrant issued by Hon. Jaime Salazar, the Presiding Judge of the Regional Trial Court of Quezon City, Branch 103, in Criminal Case No. 90-10941. The warrant stemmed from an information filed earlier that day by a panel of prosecutors, including Senior State Prosecutor Aurelio C. Trampe, State Prosecutor Ferdinand R. Abesamis, and Assistant City Prosecutor Eulogio Mananquil Jr. The information charged Enrile, along with spouses Rebecco and Erlinda Panlilio and Gregorio Honasan, with rebellion, murder, and multiple frustrated murder, allegedly committed during a failed coup attempt from November 29 to December 10, 1990. Following his arrest, Enrile was detained overnight at the NBI headquarters without bail, as none was recommended in the information or fixed in the arrest warrant. The next day, he was transferred to Camp Tomas Karingal in Quezon City, where he was placed under the custody of Brig. Gen. Edgardo Dula Torres, Superintendent of the Northern Police District. On February 28, 1990, Enrile, through his counsel, filed a petition for habeas corpus, later supplemented on March 2, 1990. He alleged violations of his constitutional rights, including being held for a non-existent crime, lack of due process due to the absence of a preliminary investigation, denial of bail, and the issuance of a warrant without a personal determination of probable cause by the judge. The Supreme Court issued a writ of habeas corpus returnable on March 5, 1...