G.R. No. 191064 - People vs. Araneta y Abella

On August 28, 1998, Senator Blas F. Ople filed Senate Resolution No. 157 directing the Committee on National Defense and Security to investigate alleged coup plotting by military officers and purported fund irregularities in the Armed Forces of the Philippines (AFP).
On the same date, Senator Vicente C. Sotto III filed Senate Resolution No. 160 directing an inquiry into the alleged mismanagement of the funds and investment portfolio of the AFP Retirement and Separation Benefits System (AFP-RSBS).
The Senate President referred these resolutions to the Senate Blue Ribbon Committee (Committee on Accountability of Public Officers and Investigations) and the Committee on National Defense and Security for investigation.

During the Senate Blue Ribbon Committee's public hearings, it emerged that AFP-RSBS purchased a parcel of land, Lot X, MR-1160-D in General Santos City, from respondent Atty. Nilo J. Flaviano at P10,500.00 per square meter.
However, the deed of sale recorded with the Register of Deeds showed a purchase price of only P3,000.00 per square meter, suggesting a possible anomaly.
The Senate Blue Ribbon Committee served a subpoena on Atty. Flaviano, commanding him to testify before the Committee. Respondent Flaviano refused to appear and instead filed a petition for prohibition and preliminary injunction with the Regional Trial Court (RTC) of General Santos City, Branch 23 (SP Civil Case No. 496).

On October 21, 1998, the RTC issued a Temporary Restraining Order (TRO) directing the Senate Blue Ribbon Committee to cease and desist from proceeding with the inquiry, particularly with matters affecting Lot X, MR-1160-D, and from issuing subpoenas to witnesses from Region XI, specifically General Santos City.
On November 5, 1998, the Committee filed a motion to dismiss the petition for prohibition and injunction, citing lack of jurisdiction and failure to state a valid cause of action. It also argued the TRO was invalid due to the rule against ex-parte issuance and its lack of enforceability beyond the trial court’s territorial jurisdiction.
On November 11, 1998, the RTC denied the Committee’s motion to dismiss and granted the writ of preliminary injunction, enjoining the Committee from enforcing subpoenas in Region XI in relation to the inquiry about the acquisition of Lot X.

The Senate Blue Ribbon Committee and Senator Aquilino Q. Pimentel, Jr. (Chairman) filed a petition for certiorari, prohibition, mandamus, and preliminary injunction (G.R. No. 136760) challenging the RTC’s resolution denying dismissal and granting injunction.
A related case arose when the RTC Judge Majaducon, motu proprio, charged Senator Pimentel and others with indirect contempt of court for comments and publications related to the Senate Blue Ribbon Committee’s petition and allegations of “gross ignorance of the rules and procedures” by the judge.
On April 15, 1999, RTC Branch 23 declared Senator Pimentel guilty of indirect contempt, prompting another petition for review (G.R. No. 138378).
On December 11, 2000, these two petitions were consolidated for decision.

Whether or not the RTC Judge Majaducon committed grave abuse of discretion by denying the motion to dismiss the petition for prohibition and issuing a writ of preliminary injunction against the Senate Blue Ribbon Committee.

Whether or not RTC Judge Majaducon erred in finding Senator Aquilino Q. Pimentel, Jr. guilty of indirect contempt of court for statements and publication related to the petition filed before the Supreme Court.