Case Digest (G.R. No. L-34022) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manuel Martinez y Festin v. Hon. Jesus P. Morfe and Fernando Bautista, Sr. v. Hon. Francisco Ma. Chanco, both decided on March 24, 1972, the petitioners were duly elected delegates to the 1971 Constitutional Convention and claimed immunity from arrest under Article VI, Section 15 of the 1935 Constitution as incorporated in Republic Act No. 6132. In L-34022, petitioner Manuel Martinez y Festin faced an information filed on June 10, 1971, in the Court of First Instance of Manila for falsification of a public document punishable by prision mayor. He moved to quash the information and arrest warrant, which were denied; he did not post bond, was arrested on September 6, 1971, and released on bail on September 11. In L-34046 and L-34047, petitioner Fernando Bautista, Sr. was charged with election offenses under the Revised Election Code after two criminal complaints by a defeated aspirant; his motion claiming immunity was denied, a warrant issued on August 23, 1971, quashed motions... Case Digest (G.R. No. L-34022) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioners and criminal proceedings
- Manuel Martinez y Festin (L-34022)
- Elected delegate to the 1971 Constitutional Convention.
- Charged June 10, 1971 with falsification of a public document for misstating his birth year in his certificate of candidacy.
- Filed special appearance and motions to quash (July 9 & 22, 1971); lower court denied motions (Aug 21, 1971) and suspended issuance of warrant pending resolution.
- Arrested September 6, 1971 by City Sheriff of Manila en route to a Convention session; arraigned September 9, 1971; released on bail September 11, 1971.
- Filed petition for certiorari and habeas corpus alleging constitutional immunity; habeas corpus aspect rendered moot by bail.
- Fernando Bautista, Sr. (L-34046 & L-34047)
- Elected delegate to the 1971 Constitutional Convention.
- Criminal complaints filed directly in the CFI of Baguio and Benguet for alleged violation of Sec. 51, Revised Penal Code (distribution of free food, drinks, cigarettes at public meetings).
- Invoked immunity under Art. VI, Sec. 15, Constitution, and Art. 145, RPC by motion August 14, 1971; respondent judge held motion in abeyance and scheduled hearing August 23, 1971.
- Warrant of arrest issued August 23, 1971; motion to quash denied September 11, 1971; petition for certiorari and prohibition filed September 15, 1971.
- Constitutional and statutory provisions invoked
- Art. VI, Sec. 15, Constitution: Senators and Representatives “privileged from arrest…except treason, felony, and breach of the peace” during sessions and travel thereto.
- Art. 145, Revised Penal Code: Penalizes official who arrests/searches a legislator in session except for crimes punishable by higher than prision mayor.
- Republic Act No. 6132 (1970): Extends congressional immunities to Constitutional Convention delegates.
- Government and Convention pleadings
- Solicitor General argued immunity covers only civil process; criminal prosecutions are not barred by Art. VI, Sec. 15.
- Detailed memoranda submitted by Office of the Solicitor General and by the Convention’s Committee on Legal Affairs analyzing constitutional history and purpose of immunity.
Issues:
- Whether delegates to the Constitutional Convention, as “members” entitled to parliamentary immunity, are immune from criminal arrest in all but treason, felony, and breach of the peace.
- Whether Art. 145, RPC’s expanded immunity provision remains operative after the 1935 Constitution.
- Whether the writ of certiorari lies to quash arrest warrants issued against the petitioners based on claimed legislative immunity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)