Case Digest (G.R. No. 34428) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 251177 decided on September 8, 2020, petitioners Alfredo J. Non, Gloria Victoria C. Yap-Taruc, Josefina Patricia A. Magpale-Asirit, and Geronimo D. Sta. Ana—then Commissioners of the Energy Regulatory Commission (ERC)—filed a Petition for Certiorari under Rule 65, seeking a TRO and preliminary injunction. They assailed the Regional Trial Court of Pasig City, Branch 155’s Orders of September 10 and October 22, 2018 in Criminal Case No. R-PSG-18-01280-CR, which denied their Motion to Quash the Information charging them with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The criminal Information arose from an Ombudsman Resolution finding probable cause that petitioners, conspiring with then-ERC Chairman Jose Vicente B. Salazar, acted with bad faith or gross negligence in issuing ERC Resolution No. 1-2016—which postponed the Competitive Selection Process requirement—and thereby granted undue preference to MERALCO affiliates in ... Case Digest (G.R. No. 34428) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners
- Alfredo J. Non, Gloria Victoria C. Yap-Taruc, Josefina Patricia A. Magpale-Asirit and Geronimo D. Sta. Ana, former Commissioners of the Energy Regulatory Commission (ERC).
- Respondents
- Office of the Ombudsman
- Alyansa Para sa Bagong Pilipinas, Inc. (ABP)
- Hon. Maria Gracia A. Cadiz-Casaclang, Presiding Judge, Branch 155, Regional Trial Court (RTC), Pasig City
- Origination and Administrative Proceedings
- ERC Resolutions
- Resolution No. 13-2015 required Distribution Utilities (DUs) to conduct a Competitive Selection Process (CSP) for their Power Supply Agreements (PSAs).
- Resolution No. 1-2016 moved the effectivity of Resolution No. 13-2015 from November 2015 to April 2016.
- ABP Actions and Ombudsman Complaints
- On November 3, 2016, ABP filed a certiorari petition (G.R. No. 227670) assailing Resolution No. 1-2016 and the CSP Guidelines.
- On November 23, 2016, ABP filed a verified administrative and criminal complaint with the Ombudsman (docketed OMB-C-A-16-0438 and OMB-C-C-16-0497), alleging graft and corrupt practices and other offenses against the petitioners and ERC Chairman Salazar.
- The Ombudsman’s Resolution of September 29, 2017 found probable cause for violation of Section 3(e), Republic Act (R.A.) No. 3019, leading to Criminal Information before RTC Pasig City.
- Criminal Information and Lower Court Proceedings
- Information and Motion to Quash
- On July 12, 2018, petitioners filed a Motion to Quash Information (Criminal Case No. R-PSG-18-01280-CR) on the ground that under Section 2, R.A. No. 10660, the RTC had no jurisdiction and venue must lie outside the region where the officials held office.
- RTC Orders and Relief Sought
- RTC Branch 155, Pasig City denied the Motion to Quash on September 10, 2018, citing absence of Supreme Court-promulgated implementing rules and applying default venue rules (Section 15(a), Rule 110, Revised Rules on Criminal Procedure).
- The RTC denied the petitioners’ Motion for Reconsideration on October 22, 2018.
- Petitioners sought certiorari relief (G.R. Nos. 239168, 240288, consolidated, and ultimately G.R. No. 251177) praying for annulment of the RTC orders and suspension of proceedings.
Issues:
- Whether the RTC Branch 155, Pasig City gravely abused its discretion and lacked jurisdiction in denying the Motion to Quash Information under the jurisdictional and venue provisions of R.A. No. 10660, which mandate trial in a judicial region other than where the accused public official holds office.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)