G.R. No. 187094 - Maza vs. Turla

The case arises from the aborted coup d’état on August 28, 1987, which shook national security and led to a series of military investigations.
In the aftermath, numerous military personnel were implicated, leading to the filing of the case “People of the Philippines vs. LTC Gregorio Honasan, et al.” before General Court-Martial No. 9.
A total of seventy (70) petitioners, comprising officers and enlisted personnel, were charged with various offenses including Mutiny (AW 67), Conduct Unbecoming of an Officer and a Gentleman (AW 96), and, in connection with the Revised Penal Code, Murder (Article 248), and assorted felony counts.

Multiple investigation committees, instituted by the Philippine Army, General Headquarters, and the Philippine Constabulary, conducted fact-finding missions following the coup attempt.

These committees submitted reports that were consolidated and reviewed by a Board of Officers chaired by the AFP Inspector General.
The Chief of Staff, AFP, then approved the findings resulting in the issuance of charge sheets.

The first Charge Sheet, dated October 15, 1987, charged 44 officers with violations of AW 67 (Mutiny) and AW 96 (Conduct Unbecoming).
A subsequent Charge Sheet, dated December 1, 1987, charged an additional nine officers (with some overlap) and 67 enlisted personnel with AW 94 (Various Crimes) in relation to Murder (Article 248, RPC) and Robbery (Article 294, RPC).
Both Charge Sheets were subsequently forwarded to a Pre-trial Investigation (PTI) Panel.

Constituted on October 7, 1987, under Office Order No. 158, the panel was headed by Col. Francisco Paredes with two other officers as members.
The Panel was tasked with reviewing investigations, summoning the accused, and ensuring that the accused were informed of the charges against them.
The Panel issued its PTI Report on April 18, 1988, recommending trial for the charge of Mutiny and suggesting further disciplinary proceedings for some enlisted personnel.

Following the PTI Report, the Staff Judge Advocate (SJA) recommended the revision of charges to include Murder alongside Mutiny and other offenses.
On May 11, 1988, the amended Charge Sheets were referred to General Court-Martial No. 9 by order of Brig. Gen. Manuel B. Casaclang, AFP.
The accused were then scheduled for arraignment on June 17, 1988.
Petitioners filed motions to defer arraignment and hold proceedings in abeyance, claiming a denial of due process, but these motions were denied by the court.

Petitioners sought to nullify various investigative and charging documents including the Charge Sheets, PTI Report, amended charges, and related proceedings.
They requested the cessation of further court-martial proceedings and the ordering of a new investigation pursuant to AW 71.
Additionally, petitioners applied for a Writ of Preliminary Injunction or Temporary Restraining Order to halt the trial, contending that irreparable injury would ensue before their defense could be heard.

Petitioners argued that the constitution of the General Court-Martial occurred prematurely, even before all personnel were identified and investigated.
They asserted that the formation of the PTI Panel and the preparation of the Charge Sheets were irregular and prejudicial, denying them the opportunity to fully cross-examine witnesses and review evidence.

Petitioners contended that the Charge Sheets were invalid since they were signed by Capt. Al Perreras, who was not personally involved in the full investigation.
They argued that this non-compliance with the mandatory investigative requirements under AW 71 undermined the legitimacy of the charges.

The petitioners further stressed that there was no prima facie evidence strong enough to support the charges brought against them.
They maintained that the available evidence did not justify the continuation of criminal prosecution via the General Court-Martial process.

Whether the pre-trial and charge-sheet preparation procedures violated the petitioners’ due process rights.

Did the early constitution of the General Court-Martial and the PTI Panel, prior to the full identification and investigation of all involved personnel, prejudice the rights of the accused?
Was there any jurisdictional defect or grave abuse of discretion in the manner in which the investigative and pre-trial proceedings were conducted?

Whether the Charge Sheets, including their amendments and the involvement of Capt. Perreras as Accuser without direct personal investigation, were valid and in accordance with military law requirements.

Did Capt. Perreras’ reliance on the reports of various investigation committees suffice under Article 71 of the Articles of War?
Were any procedural irregularities in the formation of the Charge Sheets and PTI Report substantial enough to nullify the proceedings?

Whether there exists prima facie evidence to justify criminal prosecution under the charges of Mutiny, Murder, and other related offenses.

Does the pre-trial investigation establish a sufficient factual basis to warrant the trial of the petitioners?
Can the petitioners’ claim of insufficient evidence be sustained in light of the testimonies and documentary evidence on record?

Whether the issuance of a Temporary Restraining Order or Injunction to halt the court-martial proceedings is warranted, given the public interest and need for swift justice in cases involving national security and attempted coup.