Case Digest (G.R. No. 6344)
Facts:
In People v. Lacson (G.R. No. 149453, October 7, 2003), the People of the Philippines, represented by the Secretary of Justice, the Director General of the Philippine National Police, and the State Prosecutors, filed Murder Informations (Criminal Cases Nos. 01-101102 to 01-101112) in the Regional Trial Court (RTC) of Quezon City on June 6, 2001, charging respondent Panfilo M. Lacson and co-accused with the 1995 killings of 11 persons. The original cases (Criminal Cases Nos. Q-99-81679 to Q-99-81689) had been provisionally dismissed by Judge Wenceslao Agnir, Jr. on March 29, 1999 after Lacson moved for a judicial determination of probable cause and sought to withhold arrest warrants. Lacson challenged the refiling on double jeopardy and speedy-disposition grounds in the RTC and then in the Court of Appeals (CA), which granted his petition based on Section 8, Rule 117 of the 2000 Revised Rules of Criminal Procedure (RRCP). The People appealed under Rule 45 to the Supreme Court enCase Digest (G.R. No. 6344)
Facts:
- Parties and Case Background
- Petitioners: People of the Philippines, Secretary of Justice, Director General of the Philippine National Police, Chief State Prosecutor Jovencito Zuao, State Prosecutors Peter L. Ong and Ruben A. Zacarias, 2nd Assistant City Prosecutor Conrado M. Jamolin, and City Prosecutor Claro Arellano of Quezon City.
- Respondent: Panfilo M. Lacson, former PNP officer and senator, charged with multiple murder.
- Procedural History in the Supreme Court
- Motions filed by respondent after April 29, 2003 Resolution:
- Omnibus Motion (reconsideration of April 29 Resolution; request for recusation of five sitting Justices).
- Motion for Reconsideration.
- Supplement to Motion for Reconsideration.
- Motion to Set for Oral Arguments.
- Prior recusation attempts by respondent:
- May 24, 2002 urgent motion to recuse Justices Corona and Austria-Martinez (denied).
- March 18, 2003 motion to recuse Justice Callejo, Sr. (denied by resolution of March 25, 2003).
- April 1, 2003 Court Resolution denied further recusation and motions for reconsideration of earlier orders.
- Underlying Criminal Proceedings
- February 19, 2002 oral arguments En Banc; case submitted for decision May 28, 2002.
- Criminal Cases Q-99-81679 to Q-99-81689 provisionally dismissed by RTC Judge Agnir, Jr. on March 29, 1999.
- RRCP Section 8 (2000) provides one-year and two-year time-bars for revival of provisionally dismissed cases.
- Informations in Criminal Cases 01-101102 to 01-101112 filed June 6, 2001 before RTC Quezon City—respondent claims these were beyond the two-year bar.
Issues:
- Should respondent’s Omnibus Motion and Motion to Set for Oral Arguments be granted?
- Should Section 8, Rule 117 of the RRCP be applied prospectively only or also retroactively?
- Did respondent comply with the express-consent and notice requirements of Section 8, Rule 117?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)