Facts:

The case involves Jovito R. Salonga as 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 events leading to this case began in 1980 when a series of bombings occurred in Metro Manila, causing injuries and fatalities. One significant incident involved Victor Burns Lovely, Jr., an American citizen, who was injured by a bomb explosion in his YMCA room on September 6, 1980. Following this, Lovely was detained by military authorities, and during his detention, he implicated Salonga in a supposed conspiracy related to the bombings.

Lovely claimed that he had visited Salonga's residence on multiple occasions, suggesting that Salonga was involved in a subversive plot against the government. This led to the issuance of arrest, search, and seizure orders against Salonga and others. Salonga was arrested while hospitalized f...

Facts:

Background of the Case
The case involves petitioner Jovito R. Salonga, who was accused of subversion in connection with a series of bombings in Metro Manila in 1980. Salonga, a prominent member of the democratic opposition, was arrested without being informed of specific charges and detained under questionable circumstances.

Key Events Leading to the Charges

1. Bombings in Metro Manila: A series of bombings occurred in August, September, and October 1980, including incidents at Rustan’s Supermarket, three major hotels, and the Philippine International Convention Center.
2. Victor Lovely’s Involvement: Victor Burns Lovely Jr., a Philippine-born American citizen, was injured in a bomb explosion at the YMCA in Manila. He was detained and later implicated in the bombings, claiming to have received materials for the bombings from individuals connected to the political opposition.
3. Linking Salonga to the Bombings: Lovely testified that he visited Salonga’s residence to receive bomb-making materials, though his testimony was inconsistent and lacked corroboration.
4. Salonga’s Arrest and Detention: Salonga was arrested in his hospital room while receiving treatment for bronchial asthma. He was detained without charges and later released under house arrest for humanitarian reasons.

Procedural Developments

• Salonga was included in a preliminary investigation for subversion, but the charges were based on Lovely’s unreliable testimony and group photos taken at a birthday party.
• The prosecution failed to present credible evidence linking Salonga to the bombings or any subversive activities.
• The case was later dropped by the prosecution on January 18, 1985, rendering the petition moot.

Issue:

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Ruling:

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Ratio:

1. Insufficient Evidence: The prosecution relied solely on the inconsistent and uncorroborated testimony of Victor Lovely, which was insufficient to link Salonga to any subversive activities. The group photos and alleged political discussions did not constitute proof of conspiracy or involvement in the bombings.
2. Freedom of Thought and Expression: The Court highlighted that Salonga’s alleged statements about the likelihood of a violent struggle in the Philippines, assuming they were made, were protected under the constitutional guarantee of freedom of thought and expression.
3. Procedural Safeguards: The Court reaffirmed the importance of preliminary investigations as a protection against malicious and oppressive prosecutions. It stressed that the judiciary must ensure that constitutional rights are upheld, even in the absence of a prima facie case.
4. Mootness Doctrine: While the case became moot due to the dismissal of charges, the Court used the opportunity to reiterate guiding principles on the protection of constitutional rights and the standards for establishing probable cause in criminal prosecutions.