Title
Supreme Court
Trillanes vs. Medialdea
Case
G.R. No. 241494
Decision Date
Apr 3, 2024
The Supreme Court held that Proclamation No. 572 revoking Trillanes' amnesty is void, affirming the principles of due process and equal protection under the law.

Case Digest (G.R. No. L-25712)
Expanded Legal Reasoning Model

Facts:

  • Background and Incidents
    • Antonio F. Trillanes IV, a former Navy Lieutenant Senior Grade and member of the Armed Forces of the Philippines (AFP), led the Oakwood Mutiny on July 27, 2003, where a group of armed soldiers seized the Oakwood Premier Apartments in Makati City.
    • Trillanes and co-conspirators were charged with Coup d’etat under Article 134-A of the Revised Penal Code (RPC) (Coup d’etat Case).
    • In 2007, while the Coup d’etat Case was pending, Trillanes and his group took over the Manila Peninsula Hotel (Manila Peninsula Incident), calling for the ouster of President Gloria Macapagal-Arroyo.
    • Following the Incident, Trillanes and others were charged with Rebellion (Rebellion Case).
  • Amnesty Proclamation No. 75
    • On November 24, 2010, President Aquino issued Proclamation No. 75 granting amnesty to AFP and Philippine National Police (PNP) personnel and their supporters connected to the Oakwood Mutiny, Marines Stand-Off, and Manila Peninsula Incident.
    • The proclamation required applicants to personally file applications and admit guilt in writing.
    • An ad hoc DND Amnesty Committee was created to receive and process the applications, including oppositions; its decisions were appealable to the Office of the President.
    • Trillanes applied for and was granted amnesty on January 21, 2011, as evidenced by a Certificate of Amnesty signed by Secretary Gazmin. Subsequently, the cases against him were dismissed.
  • Revocation Proclamation No. 572 and Subsequent Legal Proceedings
    • On August 31, 2018, President Duterte issued Proclamation No. 572, which declared Trillanes’ amnesty void ab initio, citing that he did not file an application and did not admit guilt as required.
    • DOJ filed motions for issuance of warrants of arrest and hold departure orders in the pending rebellion and coup d’etat cases.
    • Branch 148 RTC denied the DOJ motion in the coup d’etat case, finding Trillanes had complied with amnesty requirements and that Proclamation No. 572, although valid, could not revoke the amnesty.
    • Branch 150 RTC granted the DOJ motion and ordered the reopening of the rebellion case, declaring the dismissal void ab initio based on non-compliance with amnesty requirements.
    • The Court of Appeals (CA) upheld Branch 148’s denial of the motion but reversed Branch 150’s grant of the motion, affirming the finality of the dismissal and procedural due process violations.
  • Petitions before the Supreme Court
    • Trillanes filed a Petition for Certiorari challenging the validity of Proclamation No. 572.
    • The DOJ filed Petitions for Review contesting the CA decisions on the motions in the coup d’etat and rebellion cases.
    • The Supreme Court consolidated the cases to resolve the numerous constitutional and procedural issues raised.

Issues:

  • In G.R. No. 241494 (Trillanes’ Petition)
    • Whether Trillanes committed forum shopping by filing the petition in the Supreme Court while similar issues were pending before RTCs.
    • Whether defects in the notarization of the Verification and Certification Against Forum Shopping warranted dismissal.
    • Whether filing directly with the Supreme Court violated the doctrine of hierarchy of courts.
    • Whether Proclamation No. 75 was an unconstitutional delegation of the presidential power to grant amnesty to the DND and its Committee.
    • Whether Proclamation No. 572 is unconstitutional, particularly on grounds of due process, equal protection, double jeopardy, political question doctrine, bills of attainder, ex post facto laws, and unlawful warrantless arrest.
  • In G.R. No. 256660 (DOJ Petition on Coup d’etat Case)
    • Whether the CA erred in ruling that Branch 148 did not commit grave abuse of discretion in denying DOJ’s Omnibus Motion to issue a warrant of arrest and hold departure order against Trillanes.
  • In G.R. No. 256078 (DOJ Petition on Rebellion Case)
    • Whether the CA erred in ruling that Branch 150 acted with grave abuse of discretion in reopening the Rebellion Case and granting the Omnibus Motion without adequate hearing.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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