G.R. No. 187094 - Maza vs. Turla

Petitioners Liza L. Maza, Saturnino C. Ocampo, Teodoro A. Casiao, and Rafael V. Mariano—former House Representatives of various Party-List groups—were charged with murder and kidnapping with murder.
Respondents include Judge Evelyn A. Turla of RTC–Palayan City, the Provincial Prosecutor’s Office of Nueva Ecija (officer-in-charge Floro Florendo and panel investigators Lapus, Rafanan, Gutierrez), and Justice Secretary Raul M. Gonzalez.

December 14, 2006: Police Inspector Palomo forwarded affidavits accusing 19 persons, including petitioners, of conspiracy in the killing of AKBAYAN supporters.
February 2, 2007: Subpoenas issued for petitioners’ testimonies; petitioners moved to quash and expunge, alleging lack of jurisdiction and due process.
July 2007–April 2008: Panel of prosecutors denied motions, required counter-affidavits, and on April 11, 2008, found probable cause for two counts of murder and kidnapping with murder against 18 respondents, recommending the filing of Informations.

April 21–May 12, 2008: Petitioners filed motions for judicial determination of probable cause in Palayan cases (CC Nos. 1879-P, 1880-P); hearings held, memoranda submitted.
July 18, 2008: Judge Turla set aside the prosecutors’ Joint Resolution, remanded cases for a “complete preliminary investigation,” and refused to dismiss or issue warrants.
December 2, 2008: Motion for reconsideration (praying for outright dismissal) denied.

March 27, 2009: Petitioners filed a Rule 65 petition in the Supreme Court seeking to annul the July 18 and December 2 Orders of Judge Turla and dismiss the cases.
Grounds cited: grave abuse of discretion in remanding the cases, failure to dismiss for lack of probable cause, refusal to rule on principal-by-inducement, and ignoring admissibility rules (res inter alios acta).
Respondents’ Comment (May 29, 2009) raised hierarchy-of-courts, exclusive prosecutorial authority, sufficiency of probable cause, and proper stage for evidentiary issues.

Petitioners’ Reply (Sept. 24, 2009) defended direct SC invocation and named Secretary Gonzalez as nominal respondent per Rule 65.
SC admitted exceptions to hierarchy-of-courts doctrine and framed three issues:

Validity of direct petition to the Supreme Court.
Whether Judge Turla gravely abused discretion in remanding for a new preliminary investigation.
Whether evidentiary admissibility may be ruled upon during preliminary investigation.

Did petitioners violate the doctrine of hierarchy of courts by directly invoking the Supreme Court’s certiorari/prohibition jurisdiction?

Did Judge Turla gravely abuse her discretion and exceed her jurisdiction when she remanded the Palayan cases to the Provincial Prosecutor for a “complete preliminary investigation”?

Can the admissibility or inadmissibility of evidence be ruled upon during preliminary investigation under Rule 112 of the Rules of Court?