Case Digest (G.R. No. 172070-72)
Facts:
In Vicente P. Ladlad et al. v. Emmanuel Y. Velasco et al. (G.R. Nos. 172070–72, 172074–76) and Crispin B. Beltran v. People of the Philippines (G.R. No. 175013), the Supreme Court consolidated petitions challenging the Department of Justice’s (DOJ) inquest and preliminary investigation into allegations of Rebellion under Articles 134 and 135 of the Revised Penal Code. In G.R. No. 175013, Representative Crispin B. Beltran was arrested without a warrant on 25 February 2006 after Proclamation No. 1017 declared a State of Emergency. He underwent an inquest for Inciting to Sedition, was released by the Metropolitan Trial Court of Quezon City, then subjected to a second inquest for Rebellion on 27 February 2006 by a DOJ panel. The panel found probable cause and filed an Information in Makati RTC Branch 137, later raffled to Branch 146 then Branch 150, which issued orders on 31 May 2006 and 29 August 2006 sustaining probable cause. In G.R. Nos. 172070–72 and 172074–76, petitioners Ladl...
Case Digest (G.R. No. 172070-72)
Facts:
- Parties and Charges
- Petitioners
- Crispin B. Beltran (G.R. No. 175013) – Member of the House of Representatives
- Liza L. Maza, Joel G. Virador, Saturnino C. Ocampo, Teodoro A. Casião, Rafael V. Mariano (G.R. Nos. 172074–76) – Party-list Representatives
- Vicente P. Ladlad, Nathanael S. Santiago, Randall B. Echanis, Rey Claro C. Casambre (G.R. Nos. 172070–72) – Private individuals
- Respondents
- Department of Justice prosecutors and Justice Secretary
- Philippine National Police officials and panel of prosecutors
- Criminal Proceedings
- Beltran Petition (G.R. No. 175013)
- Arrest without warrant on 25 February 2006 under Proclamation No. 1017
- First inquest for Inciting to Sedition; second inquest for Rebellion on 27 February 2006
- Resolution of probable cause; Information filed in RTC Makati, Criminal Case No. 06-452
- Motions for judicial determination of probable cause; recusal of Branch 137 and Branch 146 judges; denial by Branch 150
- Maza and Ladlad Petitions (G.R. Nos. 172070–72; 172074–76)
- DOJ subpoenas issued 6 March 2006; preliminary investigation conducted 13 March 2006
- Presentation of masked “eyewitness” Jaime Fuentes; distribution of his affidavit to media
- Denial of motions for inhibition and dismissal on 22 March and 4 April 2006
- Resolution of probable cause dated 21 April 2006; Information filed as Criminal Case No. 06-944 (consolidated with No. 06-452)
Issues:
- Beltran Petition (G.R. No. 175013)
- Was the inquest proceeding against Beltran for Rebellion valid?
- Was there probable cause to indict Beltran for Rebellion?
- Maza and Ladlad Petitions (G.R. Nos. 172070–72; 172074–76)
- Should the DOJ prosecutors be enjoined from continuing the prosecution of Criminal Case No. 06-944?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)