Case Digest (G.R. No. L-41958) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1988, Maximo V. Soliven, Antonio V. Roces, Frederick K. Agcaoili and Godofredo L. Manzanas, together with columnist Luis D. Beltran, filed petitions for certiorari and prohibition assailing three sets of actions: the filing of libel informations by the Manila City Fiscal; the review and affirmation of a prima facie finding by the Undersecretary and Secretary of Justice, and ultimately by President Corazon C. Aquino; and the issuance of arrest warrants by Hon. Ramon P. Makasiar, Presiding Judge of the Regional Trial Court of Manila, Branch 35, without personally examining the complainant or witnesses to determine probable cause. The petitioners argued that (1) the filing of informations while the Secretary of Justice and the President were still reviewing the prima facie case deprived them of due process, (2) the warrant issuance violated Article III, Section 2 of the 1987 Constitution, and (3) the President had no authority to initiate criminal proceedings by filing a complai Case Digest (G.R. No. L-41958) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioners
- Maximo Soliven, Antonio V. Roces, Frederick K. Agcaoili, Godofredo L. Manzanas – newspaper publisher, editorial board members, managing editor, business manager.
- Luis D. Beltran – newspaper columnist.
- Respondents
- Hon. Ramon P. Makasiar – Presiding Judge, RTC Manila, Branch 35.
- Undersecretary Silvestre Bello III, Secretary Sedfrey Ordoñez, Executive Secretary Catalino Macaraig – Department of Justice.
- Luis C. Victor, Jesus F. Guerrero – City Fiscal of Manila.
- President Corazon C. Aquino – complainant in the libel proceedings.
- Procedural History
- Filing of libel informations by City Fiscal against the petitioners while preliminary investigation findings were under review by DOJ and the President.
- Denial of motions for reconsideration:
- Undersecretary’s resolution finding prima facie case upheld by Secretary of Justice (March 30 and April 7, 1988).
- President, through the Executive Secretary, affirmed the Secretary’s resolution (May 2 and May 16, 1988).
- Petitioners filed consolidated petitions for certiorari and prohibition before the Supreme Court, challenging:
- Denial of due process in preliminary investigation.
- Issuance of arrest warrants without personal examination by the judge.
- President’s capacity to initiate criminal proceedings via complaint-affidavit.
Issues:
- Due Process in Preliminary Investigation
- Were petitioners denied due process by premature filing of informations before completion of administrative review?
- Did petitioners have to file counter-affidavits to preserve due process?
- Issuance of Arrest Warrants
- Does the Constitution require the issuing judge to personally examine the complainant and witnesses under oath to determine probable cause?
- Did Judge Makasiar commit grave abuse of discretion in issuing the warrants?
- Presidential Capacity to File Complaint-Affidavit
- May the President, under the Constitution, initiate criminal proceedings by filing a complaint-affidavit?
- Can an accused invoke presidential immunity to bar the prosecution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)