Case Digest (G.R. No. 129670) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manolet O. Lavides v. Court of Appeals, petitioner Manolet O. Lavides was arrested without a warrant on April 3, 1997, following an entrapment operation after a complaint by the parents of 16-year-old Lorelie San Miguel. He was found in Room 308 of the Metropolitan Hotel in Quezon City in the company of the minor, wearing only a T-shirt and underwear. An information for child abuse under R.A. No. 7610 (Art. III, Sec. 5[b]) was filed in the Regional Trial Court (RTC), Quezon City, docketed as Criminal Case No. Q-97-70550. Petitioner moved for judicial determination of probable cause, release, and bail. On April 29, 1997, nine more informations were lodged against him—four complainants alleged that he had engaged in sexual intercourse in exchange for money—bringing the total to twelve consolidated cases (Criminal Case Nos. Q-97-70550 and Q-97-70866 to Q-97-70874). On May 16, 1997, the RTC found probable cause, granted bail at ₱80,000 per case (₱800,000 total), and imposed four Case Digest (G.R. No. 129670) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Arrest and Information
- On April 3, 1997, petitioner Manolet O. Lavides was arrested without a warrant through a police entrapment operation for alleged child abuse under R.A. No. 7610.
- He was found in Room 308 of the Metropolitan Hotel, Quezon City, with Lorelie San Miguel, a 16-year-old minor, wearing only a t-shirt and underwear.
- Based on the complainant’s sworn statement and officers’ affidavits, an information for violation of Art. III, §5(b) of R.A. No. 7610 was filed on April 7, 1997 in RTC, Quezon City (Crim. Case No. Q-97-70550).
- Subsequent Informations and Omnibus Motion
- On April 29, 1997, nine additional informations (Crim. Case Nos. Q-97-70866 to Q-97-70874) were filed, each alleging acts of sexual intercourse with minor complainants exploited in prostitution.
- Petitioner filed on April 10, 1997 an Omnibus Motion:
- For judicial determination of probable cause;
- For immediate release from unlawful warrantless arrest;
- For bail as a matter of right.
- RTC Bail Orders and Arraignment
- On May 16, 1997, the RTC granted bail at ₱80,000 per case (total ₱800,000) but imposed four conditions, including that approval of bail bonds be made only after arraignment.
- Petitioner moved to quash, suspend arraignment, and reduce bail, all of which were denied on May 23, 1997; he was arraigned, pleaded not guilty, and was released upon posting bail.
- Court of Appeals Proceedings
- Petitioner filed CA-G.R. SP No. 44316 (certiorari) challenging the RTC’s May 16 and May 23, 1997 orders.
- While the petition was pending, two more informations were filed, bringing total cases to 12, later consolidated.
- On June 30, 1997, the CA annulled two bail conditions (non-waiver of appearance and automatic forfeiture), deemed the arraignment-approval condition moot, and otherwise upheld the RTC orders.
Issues:
- Whether the RTC’s condition that “approval of the bail bonds shall be made only after arraignment” is valid.
- Whether the arraignment held pursuant to that condition is void.
- Whether a petition for certiorari in the CA was the proper remedy to challenge denial of the motion to quash.
- Whether each act of sexual intercourse with a minor under R.A. No. 7610 must be the subject of a separate information or whether one information suffices for multiple acts/victims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)