Case Digest (G.R. No. 280455)
Facts:
Atty. Hazel L. Meking v. Jesus Crispin C. Remulla, G.R. No. 280455, November 11, 2025, the Supreme Court En Banc, Dimaampao, J., writing for the Court. Petitioner Atty. Hazel L. Meking sought to nullify Department Circular No. 015 (the 2024 Department of Justice National Prosecution Service Rules on Preliminary Investigations and Inquest Proceedings), promulgated by respondent Jesus Crispin C. Remulla in his capacity as Secretary of the Department of Justice (DOJ). The challenged circular, adopted July 16, 2024, revised the alleged quantum of evidence in preliminary investigations to require a showing of "prima facie evidence with reasonable certainty of conviction" and specified criteria (e.g., admissibility, credibility, preservability) for such a quantum.Atty. Meking contended that Department Circular No. 015 effectively changed the quantum of evidence in preliminary investigations from the long-established "probable cause" standard under Rule 112, Section 3(a) of the Rules of Criminal Procedure and thus usurped the Supreme Court's exclusive rule-making power under Article VIII, Section 5(5) of the 1987 Constitution. There is no record of intermediate judicial dispositions; the petition was brought directly to the Supreme Court as a Petition for Certiorari.
The Court recalled that it had earlier addressed the same subject in Re: Draft Department of Justice‑National Prosecution Service's Rules on Preliminary Investigations and Inquest Proceedings (A.M. No. 24‑02‑09‑SC; 955 Phil. 15 (2024)), where it recognized the DOJ's authority to promulgate rules governing preliminary investigations and inquests and traced the historical and jurisprudential distinction between prosecutorial (executive) and judicial functions. The Court also noted precedents such as Salta v. CA and People v. Navarro that treat preliminary investigation as an executive function and app...(Pro-only)
Issues:
- In promulgating Department Circular No. 015 (the 2024 DOJ‑NPS Rules), did the respondent undermine the Supreme Court’s exclusive rule‑making power under Article VIII, Section 5(5) of the 1987 Con...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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