Title
Spouses Santiago vs. Tulfo
Case
G.R. No. 205039
Decision Date
Oct 21, 2015
A physical altercation at NAIA led to threats and a petition for a writ of amparo, dismissed as it lacked government involvement and fell outside the writ's scope.

Case Digest (G.R. No. 80391)
Expanded Legal Reasoning Model

Facts:

  • Incident at the Airport
    • On May 6, 2012, at approximately 11:40 AM, petitioners-spouses Rozelle Raymond Martin ("Raymart") and Claudine Margaret Santiago ("Claudine") arrived at Ninoy Aquino International Airport Terminal 3 (NAIA 3) on a Cebu Pacific flight from a vacation.
    • Upon waiting for their baggage, they were informed it was offloaded and transferred to a different flight.
    • Petitioners filed a complaint at the Cebu Pacific complaint desk. While doing so, they noticed a man taking photos of Claudine with his cellphone.
    • Raymart confronted the man, identified later as Ramon “Mon” Tulfo, who then allegedly punched and kicked Raymart, leading to a physical fight.
    • Claudine approached and was allegedly kicked and pushed against the counter by Mon Tulfo. Raymart rushed to defend her; a man named Edoardo Benjamin Atilano joined the brawl.
    • Airport security intervened promptly, stopping the fight and bringing the parties to the Airport Police Department for investigation.
  • Media Threats and Amparo Petition
    • Days after the incident, respondents Raffy Tulfo, Ben Tulfo, and Erwin Tulfo (Mon's brothers) made public statements on their TV program, including comments, expletives, and retaliation threats against the petitioners.
    • Disturbed by these threats, petitioners filed for the issuance of a writ of amparo on May 11, 2012 before RTC Quezon City, Branch 219, docketed as SP No. Q-12-71275.
  • Procedural Posture
    • On May 23, 2012, Erwin Tulfo filed a Motion to Deny Issuance of Protection Order and/or Dismiss the Petition Motu Proprio, which petitioners opposed as a prohibited pleading.
    • On May 24, 2012, Presiding Judge Bayani Vargas granted a Temporary Protection Order (TPO) in favor of petitioners and directed respondents to file their return/answer.
    • Respondents, through Ben Tulfo, contended that their statements carried no actual threat but were expressions of strong sentiments defending their brother.
    • Judge Vargas submitted the case for resolution on June 29, 2012 but retired on July 11, 2012.
    • Acting Presiding Judge Maria Filomena Singh took over the case.
  • RTC Resolution and Further Proceedings
    • On August 6, 2012, RTC, via Judge Singh, dismissed the writ of amparo petition and dissolved the TPO.
    • The court ruled that the writ of amparo under the present rules applies only to cases of extralegal killings and enforced disappearances or threats thereof, not the present facts.
    • Despite the objection to the May 23, 2012 Motion as a prohibited pleading, the court exercised its discretion to dismiss the case as outside the rule’s scope.
    • Petitioners moved for reconsideration, denied on January 7, 2013, prompting this petition for review on certiorari before the Supreme Court.

Issues:

  • Whether the RTC correctly dismissed the petitioners’ writ of amparo petition on grounds that the petition did not involve extrajudicial killings or enforced disappearances or threats thereof.
  • Whether the May 23, 2012 Motion to Dismiss was a prohibited pleading and if the RTC erred in considering it.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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