Title
Trillanes IV vs. Pimentel, Sr.
Case
G.R. No. 179817
Decision Date
Jun 27, 2008
Detained Senator Trillanes sought privileges to perform Senate duties; SC upheld trial court's denial, ruling detention restricts liberty, election confers no special rights, and condonation doesn’t apply to criminal cases.

Case Digest (G.R. No. 116487)
Expanded Legal Reasoning Model

Facts:

  • Oakwood Incident and Criminal Charges
    • On July 27, 2003, over 300 armed soldiers led by junior AFP officers stormed Oakwood Premier Apartments in Makati City, publicly demanding the resignation of the President and key officials. President Gloria Macapagal-Arroyo issued Proclamation No. 427 and General Order No. 4 declaring a state of rebellion; the mutineers surrendered later that evening.
    • Antonio F. Trillanes IV was charged with coup d’état under Article 134-A, Revised Penal Code, in RTC Makati (Crim. Case No. 03-2784 “People v. Maestrecampo, et al.”) and detained at the Marine Brig, Fort Bonifacio, since June 13, 2006.
  • Election to the Senate and Omnibus Motion
    • In May 2007, while in detention, Trillanes won a six-year Senate seat, term to begin June 30, 2007.
    • On June 22, 2007, he filed an “Omnibus Motion for Leave of Court to be Allowed to Attend Senate Sessions and Related Requests,” seeking among others:
      • Permission to attend Senate sessions, committee meetings, hearings, caucuses and official functions.
      • Authority to set up a working area in detention with computer, telephone, and internet.
      • Right to receive staff, resource persons, and media interviews at his place of detention.
      • Leave to attend the Senate’s organizational meeting on July 23, 2007.
  • RTC Proceedings and Petition for Certiorari
    • By Order of July 25, 2007, the trial court denied all requests. Trillanes waived some requests in his reconsideration but the RTC again denied relief on September 18, 2007.
    • He filed a petition for certiorari, prohibition, and mandamus before the Supreme Court to set aside the RTC orders and compel respondents (Judge Pimentel, AFP and later PNP custodial officers) to allow him full exercise of his senatorial functions.

Issues:

  • Did the RTC err in denying Trillanes’s motion to attend Senate sessions and perform related duties while in detention?
  • Does the presumption of innocence entitle a detainee charged with a non-bailable offense punishable by reclusion perpetua to full civil and political rights, including freedom of movement?
  • Does election to the Senate operate as condonation of the pending criminal charge and justify performance of legislative functions?
  • Did the denial of Trillanes’s omnibus requests violate equal protection by treating him less favorably than other detainees granted temporary leaves?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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