G.R. No. 202303 - Villasenor vs. Ombudsman

Petition for habeas corpus filed on July 29, 1965, by Aquilino del Rosario, Sr. and Aquilino del Rosario, Jr., father and son.
Aquilino del Rosario, Jr. was confined since July 11, 1965, in the municipal jail of Aringay, La Union based on a warrant of arrest issued by the municipal court of the same municipality.

The arrest warrant was issued on the basis of a criminal complaint for murder, which had been filed by Juanita Olidar, the widow of the alleged victim.
Petitioners contended that this complaint was void because, under the applicable Rules of Court provision, the complaint must be filed by the “offended party” and argued that the widow, being merely an heir, did not qualify as such.

The Court of First Instance of La Union, presided over by the Hon. Jose P. Flores, ruled that the complaint was void for not having been signed by the offended party.
The lower court held that the term “offended party” refers strictly to the person actually injured, thereby excluding the surviving spouse and other forced heirs.
As a result, the subsequent warrant of arrest was deemed void, and Aquilino del Rosario, Jr.’s detention was characterized as arbitrary and unlawful.
Despite this void complaint, a procedural resolution was reached wherein even after the filing of the petition, Aquilino del Rosario, Jr. had not been released because he had already surrendered to the police.

A motion to intervene, along with an opposition to the petition, was filed on July 31, 1965, by the widow, Juanita Olidar.
In her opposition, the widow maintained her right to file the criminal complaint and prayed that the petition for habeas corpus be denied.

The decision on the habeas corpus proceeding was rendered on October 29, 1965, sustaining the petitioners’ right to the writ, based on the technical defect in the complaint regarding the identity of the offended party.
The lower court’s reasoning emphasized that a valid criminal complaint should be filed either by the actual injured party or by a government official empowered to enforce the law.

Whether a widow, by virtue of losing her consortium, material support, and suffering profound emotional injury, can be considered an “offended party” under the applicable Rules of Court provision.
Whether the definition of “offended party” should be interpreted strictly as the person who personally suffered injury, or more broadly to include the surviving spouse.

The impact of the complaint’s signature on the validity of the arrest warrant and overall criminal prosecution.
Whether the technical defect in the signing of the complaint invalidates the subsequent arrest and detention of Aquilino del Rosario, Jr.

The potential consequences of excluding a widow from the status of an offended party, particularly when the accused is associated with law enforcement.
How such exclusion might result in delays in prosecuting crimes and compromise the effective enforcement of the law.