Case Digest (G.R. No. 247611) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In P/Supt. Hansel M. Marantan v. Atty. Jose Manuel Diokno and Monique Cu-Unjieng LaaO (G.R. No. 205956, February 12, 2014), petitioner P/Supt. Hansel M. Marantan was the respondent in G.R. No. 199462, a petition filed on December 6, 2011, seeking to annul the Ombudsman’s resolution downgrading charges from murder to homicide in three related criminal cases (Ortigas incident, November 7, 2005) before the RTC of Pasig City, where Marantan and co-accused were charged with homicide for the deaths of Anton Cu-Unjieng, Francis Xavier Manzano, and Brian Anthony Dulay. While that petition remained pending, the Atimonan incident occurred on January 6, 2013, in Quezon Province, resulting in thirteen fatalities under Marantan’s command. In response, respondent LaaO (mother of one of the Ortigas victims) and her counsel, Atty. Diokno, held a televised and radio-broadcast press conference, alleging police “rub-out” tactics, condemning the Court’s delay in G.R. No. 199462, and branding Marant Case Digest (G.R. No. 247611) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and related proceedings
- Petitioner: P/Supt. Hansel M. Marantan
- Respondents: Monique Cu-Unjieng LaaO (petitioner in G.R. No. 199462) and Atty. Jose Manuel Diokno (her counsel)
- Underlying incidents and petitions
- Ortigas incident (Nov. 7, 2005): Three civilians shot by police officers – led to Criminal Case Nos. 146413-PSG, 146414-PSG, 146415-PSG before RTC Pasig, Branch 265; petition filed Dec. 6, 2011 in the Supreme Court (G.R. No. 199462) to upgrade charges from homicide to murder.
- Atimonan incident (Jan. 6, 2013): Thirteen men killed in police-military operation commanded by Marantan; spawned negative publicity.
- Respondents’ press conference and statements
- Organized and televised/radio-cast press conference post-Atimonan incident, alleging court inaction and accusing Marantan of murder in the Ortigas incident.
- Broadcast on Jan. 29, 2013 via ABS-CBN’s TV Patrol, containing statements calling for intervention, criticizing Supreme Court delay, and branding Marantan guilty.
- Contempt petition and respondents’ defense
- Marantan’s petition: respondents violated the sub judice rule and are liable for indirect contempt under Sec. 3(d), Rule 71, for remarks tending to obstruct or degrade justice.
- Respondents’ Comment: statements were fair comment on matters of public interest, lacked malice or intent, and did not obstruct or degrade judicial proceedings.
Issues:
- Did respondents’ public statements violate the sub judice rule?
- If so, do such statements constitute indirect contempt under Section 3(d) of Rule 71?
- Was there a “clear and present danger” that respondents’ comments would impede or obstruct the administration of justice?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)