Case Digest (G.R. No. 114427) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the Petition for Prohibition and Mandamus, petitioner Panfilo M. Lacson, joined by intervenors Romeo M. Acop and Francisco G. Zubia, Jr., assails the constitutionality of Sections 4 and 7 of Republic Act No. 8249—an amendment to the Sandiganbayan’s organic law—and disputes the Sandiganbayan’s jurisdiction over Criminal Cases Nos. 23047–23057 (multiple murder) against them. On May 18, 1995, elements of the PNP’s Anti-Bank Robbery and Intelligence Task Group (ABRITG), co-headed by Lacson, Acop, and Zubia, shot and killed eleven alleged Kuratong Baleleng members along Commonwealth Avenue, Quezon City. A Blancaflor investigative panel under the Ombudsman initially exonerated the officers; a subsequent review board recommended murder indictments against 26 persons, including Lacson and intervenors. On November 2, 1995, the Ombudsman filed eleven murder informations in the Sandiganbayan’s Second Division, accusing Lacson as principal and Acop and Zubia as accessories. The accused m Case Digest (G.R. No. 114427) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- May 18, 1995 Commonwealth Avenue Incident
- Eleven suspected Kuratong Baleleng members were killed by the PNP’s Anti-Bank Robbery and Intelligence Task Group (ABRITG) under Chief Supt. Jewel Canson, with units led by Panfilo Lacson, Romeo Acop, Francisco Zubia Jr., and others.
- A media exposé alleged a summary execution, prompting Ombudsman Desierto to form the Blancaflor panel, which initially cleared the officers; a subsequent review board led by Villa recommended multiple murder indictments.
- Criminal Informations and Pre-enactment Proceedings
- On November 2, 1995, Ombudsman filed 11 murder informations before the Sandiganbayan’s Second Division charging Lacson as principal and Acop/Zubia as accessories; after reinvestigation, amended informations (March 1, 1996) named all three only as accessories.
- Accused filed motions questioning Sandiganbayan jurisdiction under R.A. 7975 (which limited SB jurisdiction to cases where a principal accused held SG 27 or PNP Chief Supt. rank); by Resolution dated May 8, 1996, SB ordered transfer to the Quezon City RTC.
- Legislative Amendments and Sandiganbayan’s Final Resolution
- While SB motions were pending, Congress consolidated House Bills 2299 & 1094 and Senate Bill 844 into R.A. 8249 (approved February 5, 1997; effectivity February 25, 1997), deleting “principal” from Section 4 and adding Section 7 applying it to pending cases.
- On March 5, 1997, SB denied reconsideration of its May 8, 1996 Resolution but issued an Addendum (3–2 vote) applying R.A. 8249 to retain jurisdiction over the murder cases involving three PNP Chief Superintendents.
- Lacson (with Acop and Zubia) filed a petition for prohibition and mandamus before the Supreme Court challenging SB’s addendum and the constitutionality of Sections 4 and 7 of R.A. 8249.
Issues:
- Whether Sections 4 and 7 of R.A. 8249 violate the Constitution (due process, equal protection, ex post facto, one-title-one-subject).
- Whether R.A. 8249 or R.A. 7975 governs the jurisdiction of the Sandiganbayan over Criminal Cases Nos. 23047–23057.
- Whether the amended murder informations sufficiently allege that the crime was committed “in relation to their office,” a jurisdictional requirement under Section 4 of R.A. 8249.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)