Facts:
Antonio F. Trillanes IV, then a Senator of the Republic of the Philippines, initiated public investigations by filing Proposed Senate Resolution No. 826 concerning alleged overpricing of Makati infrastructure and, during Senate Blue Ribbon Sub-Committee hearings in October 2014, publicly described private citizen
Antonio L. Tiu as a “front,” “nominee,” or “dummy” of former Vice President Jejomar Binay in connection with the so-called Hacienda Binay;
Antonio L. Tiu filed a Complaint for Damages in Civil Case No.
R-QZN-14-10666-CV on October 22, 2014 alleging that petitioner’s media statements from October 8 to 14, 2014 were defamatory, caused damage to his reputation and to the market value of publicly listed companies he chaired, and seeking moral and exemplary damages and attorney’s fees; petitioner answered and filed an Answer with Motion to Dismiss asserting, among others, that the statements were true or based on documents, protected by
parliamentary immunity under
Article VI, Section 11, 1987 Constitution, and by the constitutional rights to free speech and freedom of the press, and later moved, pursuant to
Section 6, Rule 16, to set his special and affirmative defenses for a preliminary hearing; public respondent
Hon. Evangeline C. Castillo-Marigomen, Presiding Judge of the Regional Trial Court, Quezon City, Branch 101, denied the motion to dismiss by Order dated May 19, 2015 and denied reconsideration by Order dated December 16, 2015 on the ground that the questions of parliamentary immunity and lack of cause of action raised factual issues requiring full trial, after which petitioner filed the present Petition for Certiorari under
Rule 65 assailing those orders for grave abuse of discretion.
Issues:
Whether the petition for certiorari was proper in the Supreme Court notwithstanding the doctrine on the hierarchy of courts and the availability of remedies in lower courts? Whether petitioner’s statements to the media are protected by
parliamentary immunity under
Article VI, Section 11, 1987 Constitution such that the RTC lacked jurisdiction? Whether the RTC erred in denying petitioner’s request to hold a preliminary hearing on his special and affirmative defenses under
Section 6, Rule 16, or in refusing to dismiss the Complaint for failure or lack of cause of action?
Ruling:
Ratio:
Doctrine: