Title
Himagan vs. People
Case
G.R. No. 113811
Decision Date
Oct 7, 1994
A PNP officer charged with murder challenged his indefinite preventive suspension under R.A. 6975, arguing for a 90-day limit. The Supreme Court ruled that suspension lasts until case termination, upholding the law's intent and rejecting equal protection claims.
A

Case Digest (G.R. No. 113811)

Facts:

  • Background of the dispute
    • Ishmael Himagan, petitioner, a policeman assigned with the medical company of the Philippine National Police Regional Headquarters at Camp Catitigan, Davao City.
    • People of the Philippines filed informations charging petitioner with murder and attempted murder for the killing of Benjamin Machitar, Jr. and the attempted murder of Bernabe Machitar; informations were filed with the Regional Trial Court, Branch 11, Davao City, on September 16, 1992.
    • The trial court issued an order suspending petitioner from office "until the case is terminated" pursuant to Section 47, R.A. 6975.
  • Trial-court proceedings and administrative steps
    • On October 11, 1993, petitioner filed a motion to lift the preventive suspension, invoking Sec. 42, P.D. 807 and reliance on Deloso v. Sandiganbayan and Layno v. Sandiganbayan.
    • The respondent ju...(Subscriber-Only)

Issues:

  • Primary legal questions presented
    • Whether Section 47, R.A. 6975 limits the duration of preventive suspension of a PNP member to ninety days.
    • Whether Sec. 42, P.D. 807 of the Civil Service Decree, which caps preventive suspension in administrative cases at ninety days, applies to a member of the PNP charged with a criminal offense.
    • Whether petitioner’s prolonged preventive suspension violates the constitutional guarantee of equal protection of the laws....(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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