Title
Sanchez vs. Demetriou
Case
G.R. No. 111771-77
Decision Date
Nov 9, 1993
Mayor Antonio L. Sanchez contests the dismissal of his motion to quash rape with homicide charges, asserting violations of his rights to present evidence and improper jurisdiction stemming from an unlawful warrantless arrest.
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Case Digest (G.R. No. 111771-77)

Facts:

  • Antonio L. Sanchez, the Mayor of Calauan, Laguna, was accused of heinous crimes, including the rape and murder of Mary Eileen Sarmenta and the killing of Allan Gomez.
  • On July 28, 1993, the Presidential Anti-Crime Commission requested charges against several individuals, including Sanchez.
  • A preliminary investigation was conducted on August 9, 1993, with Sanchez represented by Atty. Marciano Brion, Jr.
  • Sanchez received an "invitation" from PNP Commander Rex Piad to appear for investigation on August 12, 1993, and complied on August 13, 1993.
  • During the investigation, two witnesses positively identified Sanchez, leading to his "arrest status."
  • A warrant for Sanchez's arrest was issued on August 13, 1993, by Judge Enrico A. Lanzanas.
  • On August 16, 1993, prosecutors filed seven informations against Sanchez and six others for the crimes.
  • Due to concerns about a fair trial in Laguna, the case was transferred to Pasig and assigned to Judge Harriet Demetriou.
  • Sanchez filed a motion to quash the informations, which was denied on September 13, 1993, prompting him to petition the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that Sanchez was not denied the right to present evidence during the preliminary investigation.
  • The Court held that the Department of Justice had concurrent jurisdiction to investigate the case alongside the Ombudsman.
  • The Court found that while Sanchez's initial arrest was illegal, the Regional Trial Court acquired jurisdiction through a subsequent valid warrant.
  • The Court ruled that the informations were valid as they charged separate offenses of rape with homicide.
  • The Court dismissed the claim of discrimination, statin...(Unlock)

Ratio:

  • The Supreme Court emphasized the right to a fair trial and the presumption of innocence, which Sanchez was entitled to despite public outcry.
  • The Court clarified that Sanchez's counsel waived the right to present counter-affidavits, undermining his claim of denial of due process.
  • Regarding jurisdiction, the Court noted that the Ombudsman and t...continue reading

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