G.R. No. 213529 - Napoles vs. De Lima

Janet Lim Napoles is the petitioner challenging actions taken by key government officials and agencies, including Secretary Leila M. De Lima (Prosecutor General Claro Arellano, Senior Deputy State Prosecutor Theodore M. Villanueva, Judge Elmo M. Alameda of the RTC Makati, and agents of the National Bureau of Investigation).
The case involves allegations of serious illegal detention linked to anomalous transactions of the JLN Group of Companies and the so-called “pork barrel scam.”

A Joint Sworn Statement executed on March 8, 2013 by Arturo Luy, Gertrudes Luy, Arthur Luy, and Annabelle Luy claimed that Benhur Luy had been detained against his will since December 19, 2012.
It was alleged that Benhur Luy was being moved from place to place to conceal suspicious transactions linked to the Priority Development Assistance Fund and that Napoles, along with her brother Reynald Lim, masterminded the detention.

Responding to the Joint Sworn Statement, Secretary De Lima directed the NBI Special Task Force to investigate, leading to a “rescue operation” on March 22, 2013 at Pacific Plaza Tower, Bonifacio Global City, where Benhur Luy was released.
On March 23, 2013, a recommendation was addressed to Prosecutor General Arellano to file charges of serious illegal detention against Napoles and Lim.
Both Napoles and Lim, through their respective counter-affidavits, denied the charge and contended that Benhur Luy had voluntarily taken a three-month spiritual retreat at Bahay ni San Jose, Makati City.

Assistant State Prosecutor Juan Pedro V. Navera initially recommended dismissal of the complaint due to the indication of voluntariness in Benhur Luy’s stay, as supported by testimonies from a Monsignor and Chinese priests at the retreat.
However, the Review Resolution dated August 6, 2013 by Senior Deputy State Prosecutor Theodore M. Villanueva reversed this recommendation, emphasizing that the alleged diversion of funds provided a motive for the detention.
Consequently, an Information for serious illegal detention was filed before the Regional Trial Court of Makati, which included the element that Benhur Luy’s liberty was deprived for more than three days.

Judge Elmo M. Alameda, presiding over Branch 150 of the RTC Makati, issued a warrant for the arrest of Napoles and Lim based on the prosecutor’s finding, after personally evaluating the records.
Napoles filed a Petition for Certiorari before the Court of Appeals, alleging grave abuse of discretion in (a) the filing of the Information and (b) the issuance of the arrest warrant, arguing improper haste and undue influence.
The Court of Appeals, in its Decision and subsequent Resolution dated March 26, 2014 and July 8, 2014 respectively, dismissed Napoles’ petition for lack of grave abuse of discretion, noting the delegation of discretionary functions to the prosecutor and the inherent presumption of regularity in official acts.

On September 11, 2014, Napoles filed her Petition for Review on Certiorari with applications for temporary relief, even as the trial court had already acquired exclusive jurisdiction by filing an Information.
Eventually, during the pendency of the Petition, the RTC Makati found Napoles guilty beyond reasonable doubt of serious illegal detention, sentencing her to reclusion perpetua alongside civil indemnity and moral damages.
The Supreme Court resolved that the issues raised were moot and academic, given that the trial court’s full jurisdiction and final determination of guilt had been effected.

Whether there was grave abuse of discretion in the filing of an Information for serious illegal detention against Napoles during the preliminary investigation.
Whether the issuance of the arrest warrant by Judge Alameda—despite the initiative being taken the very day the records were received and pending Motions for Judicial Determination of Probable Cause—exemplified a grave abuse of discretion.
Whether the distinction between the executive function (determination of probable cause during preliminary investigation) and the judicial function (issuance of an arrest warrant) was properly observed.
Whether Napoles’ challenge, questioning the sufficiency of probable cause in both stages, is rendered moot given her subsequent criminal conviction.
Whether Napoles exhausted all available administrative remedies before resorting to petitions for certiorari and review.