Case Digest (G.R. No. 97619) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 13, 2001, at around 8:30 p.m., petitioners Rodolfo Soria and Edimar Bista were arrested without warrant by members of the Philippine National Police stationed in Santa, Ilocos Sur, for alleged illegal possession of firearms and ammunition and, in Soria’s case, for violation of Article 261(f) of the Omnibus Election Code in relation to COMELEC Resolution No. 3328. Both were detained at the Santa Police Station, where it was discovered that Bista had a standing warrant of arrest for violation of Batas Pambansa Blg. 6 issued by the Municipal Trial Court (MTC) of Vigan. On May 14, 2001, at approximately 6:00 p.m., the arresting officers filed a Joint-Affidavit before Provincial Prosecutor Jessica Viloria in San Juan and later docketed it at the Provincial Prosecutor’s Office in Vigan. Soria was released at about 6:30 p.m. on May 14—22 hours after arrest—to undergo preliminary investigation, while Bista was brought to the MTC of Vigan on May 15, posted bail, and secured tempor Case Digest (G.R. No. 97619) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Arrest and initial detention
- On 13 May 2001 at about 8:30 PM, petitioners Rodolfo Soria and Edimar Bista were arrested without a warrant by PNP officers in Santa, Ilocos Sur for alleged illegal possession of firearms and ammunition.
- Soria was charged with illegal possession of a .38 cal. revolver (prisión correccional penalty) and violation of Article 261(f) of the Omnibus Election Code. Bista was charged with illegal possession of a sub-machine pistol UZI (9 mm) and a .22 cal. revolver.
- Detention, filing of charges, and release
- Immediately after arrest, both were detained at the Santa Police Station. Bista was identified as having a standing warrant of arrest under Batas Pambansa Blg. 6 (Criminal Case No. 12272, MTC Vigan).
- On 14 May 2001 at 4:30 PM, they were brought before Provincial Prosecutor Jessica Viloria, who took their joint affidavit; it was filed at the Vigan Provincial Prosecutor’s Office at about 6:00 PM. Soria was ordered released at 6:30 PM to undergo preliminary investigation (22 hours of detention). Bista remained detained.
- On 15 May 2001 at 2:00 PM, Bista was brought before the MTC of Vigan, posted bail, and secured an Order of Temporary Release for the BP 6 case. No release order was issued for the illegal-possession charges. At 4:30 PM, information was filed in the 4th Municipal Circuit Trial Court of Narvacan (Crim. Case No. 4413-S), and at 5:00 PM, additional informations were filed in the RTC Narvacan (Cases No. 2269-N and 2268-N).
- On 8 June 2001, Bista was released upon posting bail bonds in Crim. Cases No. 2268-N and 4413-S, after 26 days of detention.
- Ombudsman proceedings
- On 15 August 2001, petitioners filed a complaint-affidavit with the Office of the Ombudsman for Military Affairs for violation of Article 125 of the Revised Penal Code (delay in the delivery of detained persons).
- On 31 January 2002, the Ombudsman’s Joint Resolution dismissed the complaint for lack of merit. A motion for reconsideration was denied on 25 March 2002.
Issues:
- Whether Sundays, holidays, and election days are excluded in computing the 12-18-36-hour periods under Article 125, RPC.
- Whether petitioners’ detention violated Article 125: Soria’s 22-hour detention and Bista’s 26-day detention after information filing.
- Whether the filing of informations interrupts the detaining officers’ duty under Article 125 and terminates their liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)