Title
Salonga vs. Pano
Case
G.R. No. 59524
Decision Date
Feb 18, 1985
The court rules that insufficient and uncredible evidence cannot sustain charges against a democratic opposition member, reinforcing the necessity of upholding constitutional rights in criminal proceedings.
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Case Digest (G.R. No. 59524)

Facts:

  • Jovito R. Salonga is the petitioner against several respondents, including Hon. Ernani Cruz Pano, Hon. Rodolfo Ortiz, City Fiscal Sergio Apostol of Quezon City, and military officials Col. Balbino Diego and Col. Roman Madella.
  • The case arose from a series of bombings in Metro Manila in 1980, resulting in injuries and fatalities.
  • Victor Burns Lovely, Jr., an American citizen, was injured in a bombing incident on September 6, 1980, while in his YMCA room.
  • Following the bombing, Lovely was detained by military authorities and implicated Salonga in a conspiracy related to the bombings.
  • Lovely claimed to have visited Salonga's residence multiple times, suggesting Salonga's involvement in a subversive plot against the government.
  • Arrest, search, and seizure orders were issued against Salonga and others.
  • Salonga was arrested on October 21, 1980, while hospitalized for bronchial asthma, without being informed of the charges.
  • He was later transferred to an army prison and placed under house arrest.
  • Despite the absence of formal charges, the City Fiscal filed a complaint against Salonga for violating the Anti-Subversion Act.
  • Salonga's motion to dismiss the charges was denied, leading him to seek relief from the Supreme Court, arguing that no prima facie case had been established.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Jovito R. Salonga, granting the petition.
  • The Court found that the evidence presented by the prosecution was insufficient to establish a prima facie case against Salonga.
  • The denial of the ...(Unlock)

Ratio:

  • The Court's decision was based on the principle of due process, highlighting the need for a prima facie case before criminal prosecution can occur.
  • The prosecution's evidence relied heavily on Victor Lovely's testimony, which was found to...continue reading

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