Case Digest (G.R. No. 180665) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. Nos. 162318 and 162341, a group of 321 junior officers and enlisted personnel of the Armed Forces of the Philippines, led by the so-called Magdalo Group, staged the takeover of Oakwood Premier Apartments, Ayala Center, Makati City, on July 27, 2003. Respondents General Narciso Abaya, as AFP Chief of Staff, and Brig. Gen. Mariano Sarmiento, Jr., as Judge Advocate General, issued a commitment order under Article 70 of the Articles of War on August 2, 2003, placing petitioners in military custody and charging them with violations of Articles of War 63 (Disrespect to the President), 64 (Disrespect to a Superior Officer), 67 (Mutiny), 96 (Conduct Unbecoming an Officer and a Gentleman), and 97 (General Article). Meanwhile, the Department of Justice filed coup d’état charges before the Makati Regional Trial Court (RTC) against the same group under Article 134-A of the Revised Penal Code. By orders dated November 14 and 18, 2003, Branch 61 of the RTC admitted an Amended Infor Case Digest (G.R. No. 180665) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Two consolidated petitions before the Supreme Court:
- G.R. No. 162318 – Petition for prohibition by seven junior officers and enlisted men (1Lt. Navales, et al.).
- G.R. No. 162341 – Petition for habeas corpus by their co-accused (Capt. Reaso, et al.).
- Respondents are General Narciso Abaya (AFP Chief of Staff), Brig. Gen. Mariano Sarmiento, Jr. (Judge Advocate General), and other AFP officers.
- The Oakwood Incident (July 27, 2003)
- Around 300 junior officers and enlisted personnel of the AFP took over Oakwood Premier Apartments in Makati, citing grievances against graft, corruption, and alleged mismanagement in the military.
- They broadcast demands for the resignation of civilian and military officials, prompting a state of rebellion declaration by President Arroyo and subsequent negotiations.
- Parallel Charging Schemes
- Civil‐court route: Department of Justice filed an Information for coup d’état (Art. 134-A, RPC) against 321 soldiers before the RTC of Makati.
- Military‐court route: The 290 dropped from the coup d’état charge were instead charged before the General Court-Martial with violations of Articles of War (AW 63, 64, 67, 96, 97).
- The petitioners’ motions in the RTC (Branch 148) to deem all offenses “not service-connected” and thus within civilian jurisdiction were granted by an Order (February 11, 2004) declaring all charges absorbed by the coup-d’état, later attacked as beyond that court’s power.
Issues:
- Whether the RTC (Branch 148) acted within jurisdiction in declaring AMW offenses “not service-connected” and subsumed them by coup d’état.
- Whether the General Court-Martial retains jurisdiction to try the petitioners for specified Articles of War offenses under Republic Act No. 7055.
- Whether the petitioners’ continued detention pursuant to the Commitment Order (Art. 70, AW) and the scheduled court-martial proceedings violate their rights, thus entitling them to habeas corpus or prohibition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)