Case Digest (G.R. No. 72670) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 228 Phil. 42 (1986), petitioners Saturnina Galman and Reynaldo Galman, mother and son of the slain Rolando Galman, together with twenty-nine prominent citizens—including retired Supreme Court Justices, university presidents and bar leaders—filed a petition for certiorari with preliminary injunction and prohibition on November 11, 1985 against the Sandiganbayan, First Division, and the Tanodbayan. The petition challenged the handling of Criminal Cases Nos. 10010 and 10011, which arose from the August 21, 1983 assassination of former Senator Benigno “Ninoy” Aquino, Jr. A Fact-Finding Board had earlier concluded that Aquino’s killing was the result of a military conspiracy, not a communist plot, and recommended the prosecution of twenty-six military and civilian respondents. In January 1985, the Tanodbayan filed murder charges in the Sandiganbayan, but petitioners alleged serious irregularities—suppression of vital evidence, harassment of prosecution witnesses, and bias on the p Case Digest (G.R. No. 72670) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Aquino Assassination
- On August 21, 1983, former Senator Benigno “Ninoy” Aquino, Jr. was fatally shot at Manila International Airport under military escort.
- The military’s initial version blamed a lone communist-hired gunman, Rolando Galman, who was immediately killed by soldiers.
- Agrava Board Investigation and Reports
- President Marcos appointed the Fact-Finding Board (Agrava Board) on October 22, 1983.
- After 125 hearing days and 194 witnesses, the Board issued:
- A four–member majority report finding a military conspiracy and recommending indictment of all 26 military respondents.
- A minority report by the chairman narrowing culpability to six military conspirators.
- Marcos publicly rejected the Board’s findings, insisted on the original military version, and referred the minority report for prosecution in the Sandiganbayan.
- Tanodbayan/Sandiganbayan Proceedings and Commission Inquiry
- In January 1985, the Tanodbayan filed Informations in the Sandiganbayan charging 26 military and civilian respondents.
- Petitioners (Galman family, retired Justices, academics) sought certiorari/prohibition alleging serious irregularities:
- Executive interference (“moro-moro”) via a secret Malacañang conference ordering a pre-scripted acquittal.
- Suppression and harassment of prosecution evidence and witnesses.
- Bias of Sandiganbayan justices and partiality of prosecutors.
- A Supreme Court–appointed three-member Commission (Vasquez, German, Caguioa) held hearings (June 16–July 16, 1986), found credible proof of Presidential pressure on both court and prosecutors, and recommended a mistrial.
Issues:
- Did executive interference and collusion vitiate the Sandiganbayan trial and strip it of due process and jurisdiction?
- Were vital prosecution evidence and witnesses suppressed or harassed, undermining a fair opportunity to prosecute?
- Is the resulting acquittal judgment null and void ab initio, and does double jeopardy bar a retrial?
- Are petitioners entitled to injunctive relief and a declaration of mistrial?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)