Case Digest (G.R. No. 177438) Core Legal Reasoning Model
Facts:
In Ramon Ruffy, et al. v. Chief of Staff, P.A., et al. (75 Phil. 875, G.R. No. L-533, August 20, 1946), petitioners Ramon Ruffy, Prudente M. Francisco, Andres Fortus, Jose L. Garcia, Dominador Adeva, and Victoriano Dinglasan sought prohibition to halt their trial before the General Court-Martial of the Philippine Army. After preliminary injunction was denied, the court-martial proceeded, acquitting Ruffy, dismissing Dinglasan, and convicting Francisco, Fortus, Garcia, and Adeva for the October 19, 1944 killing of Lieutenant Colonel Enrique L. Jurado—a crime allegedly committed after petitioners, initially Philippine Constabulary officers or civilians, joined Major Ruffy’s guerrilla Bolo Combat Team in Mindoro. That outfit had been recognized by General MacArthur’s Southwest Pacific command as part of the 6th Military District, and petitioners received commissions, orders, funds, and supplies accordingly. When prohibition failed, they moved to convert their petition into one for
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Case Digest (G.R. No. 177438) Expanded Legal Reasoning Model
Facts:
- Nature of the Petition
- Petitioners filed for prohibition against respondents (Chief of Staff, PA, and General Court-Martial) to halt trial.
- After denial of preliminary injunction, the General Court-Martial proceeded: acquitted Ramon Ruffy, dismissed Victoriano Dinglasan, convicted Jose L. Garcia, Prudente M. Francisco, Dominador Adeva, and Andres Fortus.
- The petition was converted into one for certiorari to review military court records, on the ground that petitioners were not subject to military law when the offense was committed and that Article 93 of War is unconstitutional.
- Petitioners’ Military and Guerrilla Service
- At outbreak of war (Dec. 8, 1941):
- Ramon Ruffy – Provincial Commander, Philippine Constabulary (PC), Mindoro.
- Prudente M. Francisco – Junior PC officer; Andres Fortus – PC corporal.
- Formation and recognition of guerrilla forces:
- Feb. 27, 1942 – Ruffy disbands PC unit in Mindoro, forms Bolo Combat Team. Francisco, Fortus, and civilian Jose L. Garcia join in late 1942; Adeva and Dinglasan join in 1943.
- Major Macario Peralta’s 6th Military District (Panay) makes contact with General MacArthur; on Feb. 13, 1943, SWPAC recognizes the 6th Military District.
- Jan. 2, 1943 – Peralta names Ruffy Acting Commander for Mindoro and Marinduque, CO of 3rd Battalion, 66th Infantry.
- Successive orders promote and assign Francisco, Fortus, Garcia, and Adeva as officers in the Bolo Area under orders of Lt. Col. Enrique Jurado, 6th MD Chief of Staff.
- Criminal Charge and Military Proceedings
- Oct. 19, 1944 – Lt. Col. Enrique Jurado is slain, allegedly by the petitioners, who then secede from the 6th Military District.
- Charge: murder in time of war, tried by General Court-Martial under Article 93, Articles of War.
- Petitioners’ contentions:
- Philippine Army laws (including Articles of War) were suspended during enemy occupation.
- They were civilians or guerrillas, not subject to military jurisdiction.
- Article 93 of War is unconstitutional for denying Supreme Court review in capital/life-imprisonment cases.
Issues:
- Jurisdictional Issue:
- Were petitioners subject to military law under the Articles of War when the alleged murder was committed?
- Constitutional Issue:
- Does Article 93 of War violate Article VIII, Section 2(4) of the 1935 Constitution by depriving the Supreme Court of original jurisdiction over cases imposing death or life imprisonment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)