Case Digest (G.R. No. L-2128) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. L-2128, decided August 27, 1948 under the 1935 Philippine Constitution, petitioners Melencio Sayo and Joaquín Mostero were arrested in the City of Manila without a warrant by the Chief of Police and the Officer in Charge of the Municipal Jail. They were detained for more than six hours without being “delivered” to a judicial authority as prescribed by Article 125 of the Revised Penal Code. Believing that the City Fiscal of Manila should qualify as a “judicial authority” to receive arrestees under that provision, petitioners sought relief by filing a motion for reconsideration of this Court’s earlier ruling to the contrary. No decision by any lower court is involved, as the controversy was raised directly before the Supreme Court in its exercise of original jurisdiction over motions for reconsideration of its own decisions. The Court, upon full hearing of the motion, reaffirmed its prior interpretation that only a competent court or judge is a “judicial authority” und Case Digest (G.R. No. L-2128) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioners Melencio Sayo and Joaquin Mostero filed a motion for reconsideration of this Court’s prior resolution.
- The prior resolution had held that, under Article 125 of the Revised Penal Code, the phrase “judicial authority” means a competent court or judge, and does not include the City Fiscal of Manila.
- Statutory and Jurisprudential Background
- Article 125, Revised Penal Code (RPC): Officers making warrantless arrests must deliver the arrested person to the “judicial authority” within six hours of arrest.
- Provisional Law for application of the Spanish Penal Code (Royal Decree Sept. 4, 1884), as construed in United States v. Fortaleza (12 Phil. 472), remains in force unless expressly repealed or amended by subsequent legislation.
- Rules 27 & 28 of the Provisional Law and Section 37 of Act No. 133 (Charter of Manila) largely survived as Section 6, Rule 109 of the Rules of Court and Section 2463 of the Revised Administrative Code (RAC), defining grounds for warrantless arrest.
- Provisional Law Articles 30 & 31 mandated delivery to a judge within 24 hours (extendible to 3 days) and issuance of a warrant of commitment or release with grounds (auto motivado). These provisions were modified by Section 17, Rule 109 and by Article 125 RPC but preliminary‐investigation rules (Article 31, Provisional Law; Section 2, Act No. 194) were held still in force outside Manila.
Issues:
- What is the proper interpretation of the phrase “judicial authority” in Article 125 of the Revised Penal Code?
- Does the City Fiscal of Manila qualify as a “judicial authority” under that provision?
- What are the procedural consequences for offenders arrested without warrant in Manila versus in the provinces if the City Fiscal is excluded from the term “judicial authority”?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)