Case Digest (G.R. No. 213529)
Facts:
Janet Lim Napoles v. Hon. Secretary Leila De Lima, G.R. No. 213529, July 13, 2016, Supreme Court Second Division, Leonen, J., writing for the Court. Petitioner Janet Lim Napoles challenged prosecutorial and judicial acts after a complaint alleging serious illegal detention was investigated and brought to court.The controversy began with a Joint Sworn Statement executed on March 8, 2013 by Arturo Francisco Luy, Gertrudes Luy, Arthur Luy and Annabelle Luy alleging that their relative, Benhur Luy, had been detained against his will beginning December 19, 2012 and that the detention was connected to efforts to silence him about alleged anomalies involving the JLN Group of Companies and the Priority Development Assistance Fund. Acting on that Joint Sworn Statement, Secretary of Justice Leila M. De Lima directed the National Bureau of Investigation (NBI) to investigate; an NBI “rescue operation” on March 22, 2013 freed Benhur Luy from a condominium unit and led to the arrest of Reynald Lim.
Assistant State Prosecutor Juan Pedro V. Navera initially found no probable cause and recommended dismissal on June 10, 2013. Thereafter, Senior Deputy State Prosecutor Theodore M. Villanueva, upon review, reversed that recommendation in an August 6, 2013 Review Resolution and concluded there was probable cause to hold Napoles and Reynald Lim for trial; Prosecutor General Claro A. Arellano approved the Review Resolution and an Information for serious illegal detention was filed in the Regional Trial Court (RTC) of Makati. The Information alleged detention from December 19, 2012 to March 22, 2013 and was docketed with Branch 150, presided by Judge Elmo M. Alameda, who issued arrest warrants and ordered no bail.
Napoles filed a Petition for Certiorari with the Court of Appeals alleging grave abuse of discretion by the DOJ officials and by Judge Alameda; the Court of Appeals (Special Third Division) denied relief in its March 26, 2014 Decision and again denied reconsideration in its July 8, 2014 Resolution, finding no grave abuse in the filing of the information or in issuance of the warrant. Napoles then filed a Petition for Review on Certiorari with application for injunctive relief in the Supreme Court on September 11, 2014.
While the Petition to the Supreme Court was pending, the RTC, Branch 150, rendered an April 14, 2015 Decision convicting Napoles beyond reasonable doub...(Subscriber-Only)
Issues:
- Is Napoles’s Petition for Review on Certiorari moot and academic because an Information was filed and the RTC later convicted her?
- Was there grave abuse of discretion in the filing of the Information for serious illegal detention against Napoles?
- Was there grave abuse of discretion in the issuance of the arrest...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)