G.R. No. 212349 - Spouses Domasian vs. Demdam

Police Inspector Reynaldo Espina Valmoria (P/Insp. Valmoria) filed an Affidavit-Complaint against Orlando A. Fua, Jr. (petitioner), then Provincial Governor of Siquijor, before the Office of the Ombudsman.
The complaint arose from a buy-bust operation conducted around midnight on November 24, 2010, targeting James Alaya-ay Largo (@ "Aloy") for violation of the Comprehensive Dangerous Drugs Act (RA 9165).
After the buy-bust, a Search Warrant issued by the RTC, Larena, Siquijor was served upon Largo.

Petitioner arrived at Largo’s house during the search and questioned the legality of the operation, including the validity and grounds for the issuance of the search warrant, especially its nighttime execution.
Petitioner demanded to see the warrant and sought to be included as a witness to the search after learning only one barangay official was present.
Barangay officials Dioscuri Calunod and Susan Borongan refused to witness the search.
The police team led by P/Insp. Valmoria conducted the search with witnesses including Largo’s family, a DOJ representative, a media practitioner, and the barangay captain.
Despite petitioner’s questioning and presence, the search was completed, the inventory of seized items was taken, and petitioner voluntarily signed the inventory receipt.
Petitioner allegedly tried to prevent police from taking Largo into custody, even threatening P/Insp. Valmoria.

Ombudsman found probable cause for obstruction of justice under PD 1829, Section 1(e), and filed Information against petitioner.
Petitioner raised motions questioning jurisdiction, the nature of the offense, correctness of the warrant of arrest issuance, and whether proceedings should be deferred pending his Motion for Reconsideration before the Ombudsman.
Sandiganbayan denied petitioner’s Omnibus Motion and eventually issued a warrant of arrest after the Ombudsman denied the Motion for Reconsideration.
Petitioner refused to enter a plea; Sandiganbayan entered a plea of not guilty on his behalf.
During pre-trial, parties stipulated to key facts about the identities, positions held, composition of police team, conduct of the search, and petitioner’s actions.

Prosecution’s Witnesses: P/Insp. Valmoria and four police officers testified that petitioner questioned the legality of the operation, demanded the warrant, interfered during the search, and threatened the police to prevent Largo’s arrest. The search was verified to be conducted in an orderly manner except for delays caused by petitioner’s arrival.
Defense’s Witnesses: Petitioner testified that he exercised his right to question the legality of a nighttime search and only requested to act as a witness to the search. Witnesses Cresvie Alvaran Largo (Largo’s wife) and Armida Duran Saguion corroborated that petitioner’s conduct was civil and he did not obstruct the lawful activities of the police.

The Sandiganbayan found petitioner guilty beyond reasonable doubt for obstruction of justice under PD 1829 Section 1(e), sentenced him to a fine, subsidiary imprisonment in case of insolvency, and perpetual disqualification from public office.
It held that petitioner’s presence and conduct were intended to impede the service of the search warrant and that the “two-witness rule” excluded petitioner as a valid witness since Largo and his wife were present.
Petitioner’s Motion for Reconsideration was denied by the Sandiganbayan.

Petitioner contested factual findings that he argued were never admitted on record.
He asserted his right to question the nighttime execution of the warrant.
He contended he was legitimately admitted as a witness to the search.
He argued that the Sandiganbayan excluded material evidence favorable to him.
He claimed the Sandiganbayan had no jurisdiction because the Information did not allege damage to the government.

Whether the Sandiganbayan gravely erred in basing judgment on factual findings not admitted on record.
Whether petitioner’s questioning of the legality and nighttime execution of the search warrant was a legitimate exercise of his civic rights, and thus not obstruction of justice.
Whether petitioner was validly admitted as a witness to the execution of the search warrant.
Whether the inference that petitioner's actions obstructed justice was mistaken and unfair.
Whether the Sandiganbayan’s exclusion of petitioner’s material evidence constituted misapprehension of facts.
Whether the Sandiganbayan had jurisdiction to try the case given the absence of alleged damage to the government in the Information.