Case Digest (G.R. No. 242552) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 111771-77, decided on November 9, 1993, Antonio L. Sanchez, Mayor of Calauan, Laguna, filed a petition for certiorari and prohibition against Judge Harriet O. Demetriou of the Regional Trial Court (RTC), Branch 70, Pasig, Franklin Drilon as Secretary of Justice, and the six members of the State Prosecutor’s Office, namely Jovencito R. Zuno, Leonardo C. Guiyab, Jr., Carlos L. de Leon, Ramoncito C. Mison, Reynaldo J. Lugtu and Rodrigo P. Lorenzo. The petition assailed the denial of his motion to quash seven informations charging him and six co-accused with the rape-slay of Mary Eileen Sarmenta and the killing of Allan Gomez. On August 9 and 13, 1993, preliminary investigations were conducted by the Department of Justice panel, during which Sanchez was represented by counsel and expressly waived his right to submit counter-affidavits. On August 13 he was “invited” to Camp Vicente Lim, positively identified by state witnesses, placed under “arrest status,” and later take Case Digest (G.R. No. 242552) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioner: Mayor Antonio L. Sanchez of Calauan, Laguna, accused of raping and killing Mary Eileen Sarmenta and killing Allan Gomez.
- Respondents: RTC Judge Harriet O. Demetriou, Sec. Franklin Drilon, and six DOJ state prosecutors.
- Investigation and Arrest
- July 28, 1993 – Presidential Anti-Crime Commission requests charges; Aug. 9 – DOJ Panel conducts preliminary investigation (counsel waives counter-affidavits).
- Aug. 12–13 – PNP issues “invitation” to Camp Vicente Lim; Sanchez taken into custody, identified by two witnesses, placed on “arrest status,” inquest held at DOJ, warrant issued for R.A. 6713 offense, detained at Camp Crame.
- Informations and Procedural History
- Aug. 16 – Seven informations filed in RTC Calamba for rape with homicide; Aug. 26 warrant of arrest issued; venue transferred to Pasig.
- Sept. 10 – Informations amended to add Allan Gomez killing; same day Sanchez files motion to quash; Sept. 13 – motion denied; petition for certiorari filed before the Supreme Court.
Issues:
- Validity of Preliminary Investigation
- Whether waiver of counter-affidavits by petitioner’s counsel was valid.
- Whether only the Ombudsman may investigate a public officer.
- Jurisdiction over Arrest and Person
- Legality of the warrantless arrest via military “invitation.”
- Effect of subsequent warrants on the court’s jurisdiction over Sanchez.
- Sufficiency and Propriety of Informations
- Alleged duplication: charging seven homicides from two deaths.
- Alleged discrimination: omitting Alqueza and Lavadia as co-accused.
- Whether Sandiganbayan, not regular courts, has jurisdiction over public officers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)