Case Digest (G.R. No. 179817)
Facts:
Antonio F. Trillanes IV v. Hon. Oscar Pimentel, Sr., G.R. No. 179817, June 27, 2008, the Supreme Court En Banc, Carpio Morales, J., writing for the Court. Petitioner Antonio F. Trillanes IV was one of the junior officers who led the armed takeover of the Oakwood Premier Apartments on July 27, 2003; the incident prompted Proclamation No. 427 and General Order No. 4 declaring a state of rebellion and calling out the Armed Forces. He was charged with coup d’etat (Article 134‑A of the Revised Penal Code) in Criminal Case No. 03‑2784, People v. Capt. Milo D. Maestrecampo, et al., and remained in detention (from June 13, 2006 at the Marine Brig, Marine Barracks Manila, Fort Bonifacio, Taguig City).While detained, petitioner won election to the Senate (proclaimed June 15, 2007) and, on June 22, 2007, filed before the Regional Trial Court (RTC), Makati City, Branch 148, an “Omnibus Motion for Leave of Court to be Allowed to Attend Senate Sessions and Related Requests.” The Omnibus Motion sought, among others: (a) permission to attend Senate sessions and official functions; (b) to set up a working area at his place of detention with communications equipment; (c) to receive staff and resource persons at his place of detention; (d) to give interviews while at the Senate or elsewhere; (e) scheduled access for media interviews at the place of confinement; and (f) permission to attend the organizational meeting and election of Senate officers on July 23, 2007.
By Order dated July 25, 2007, the trial court denied all requests. Petitioner filed a motion for reconsideration, waived certain requests (thereby trimming them), but the trial court again denied relief by Order of September 18, 2007. Petitioner then filed a petition for certiorari, prohibition and mandamus with this Court to set aside the two RTC Orders and to enjoin respondents from preventing his Senate-related activities; he also sought restoration of the status quo ante with respect to meetings at the Marine Brig.
The trial‑court judge Hon. Oscar Pimentel, Sr. was impleaded as respondent, and several military officers — Gen. Hermogenes Esperon, Vice Adm. Rogelio I. Calunsag, MGen. Benjamin Dolorfino, and Lt. Col. Luciardo Obena — were made co-respondents. Petitioner later advised the Court that he had been transferred on November 30, 2007 to the custody of the Philippine National Police Custodial Center after the November 29, 2007 Manila Peninsula incident; this change prompte...(Pro-only)
Issues:
- Are the claims against the military officers-respondents still justiciable after petitioner’s transfer to PNP custody?
- Did the trial court commit grave abuse of discretion in denying petitioner’s Omnibus Motion to attend Senate sessions, receive staff/media, and set up a working area while in detention?
- Does petitioner’s election to the Senate or the presumption of innocence entitle him to the relief sought and distinguish his case from People v. Jalosjos?
- Were petitioner’s equal protection and condonation arguments sufficient to require permissive treatme...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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