Case Digest (G.R. No. 241494)
Facts:
This is Sen. Antonio "Sonny" F. Trillanes IV v. Hon. Salvador C. Medialdea, et al., G.R. No. 241494 (consolidated with G.R. Nos. 256660 and 256078), promulgated April 03, 2024, Supreme Court En Banc, Singh, J., writing for the Court. The consolidated litigation arose from the grant and later revocation of amnesty and competing proceedings in two Makati Regional Trial Court branches and the Court of Appeals.Sen. Antonio F. Trillanes IV (a former lieutenant senior grade of the AFP) led the Oakwood mutiny (July 27, 2003) and later the Manila Peninsula incident (Nov. 29, 2007). He was criminally charged: coup d’état (Branch 148, RTC Makati, Criminal Case No. 03-2784) and rebellion (Branch 150, RTC Makati, Criminal Case No. 07-3126). While proceedings were pending he won a Senate seat in 2007. In November 2010 President Benigno S. Aquino III issued Proclamation No. 75 (2010) granting amnesty to classes of AFP/PNP personnel and supporters who applied and met conditions; the DND ad hoc committee was authorized to process applications under implementing Committee Rules of Procedure. On January 21, 2011 the DND, via Secretary Gazmin, issued a Certificate of Amnesty for Trillanes; both RTC Branches later dismissed the respective cases against him in September 2011.
On August 31, 2018 President Rodrigo R. Duterte issued Proclamation No. 572 (2018) declaring Trillanes’s amnesty void ab initio on grounds that he did not file the required form or admit guilt; it ordered the DOJ, AFP and PNP to revive prosecutions and “employ all lawful means to apprehend” him. The DOJ filed very urgent omnibus motions for hold-departure orders and warrants in Branch 148 and Branch 150. Trillanes filed a Rule 65 certiorari/prohibition/injunction petition with the Supreme Court (docketed G.R. No. 241494) asking Proclamation No. 572 be declared void; he also sought injunctive relief (denied in an initial Resolution). Branch 148 conducted an evidentiary hearing and denied the DOJ’s omnibus motion, finding Trillanes had applied and admitted guilt; Branch 150 held a summary proceeding and granted the DOJ’s motion, concluding he had not applied and declaring its 2011 dismissal void ab initio.
The People sought review: the OSG filed a Rule 65 petition with the Court of Appeals from Branch 148’s order (CA denied relief and sustained Branch 148); the DOJ’s reopening of the Rebellion case was challenged by Trillanes...(Subscriber-Only)
Issues:
- Did petitioner Trillanes commit forum shopping by filing his certiorari petition directly with the Supreme Court while omnibus motions were pending in the trial courts?
- Are minor defects in the notarization of the Verification and Certification Against Forum Shopping fatal to Trillanes’s petition?
- Did Trillanes violate the doctrine of hierarchy of courts by invoking the Supreme Court’s original jurisdiction?
- Did Proclamation No. 75 (2010) unlawfully delegate the President’s power to grant amnesty to the DND and its ad hoc committee?
- Was Proclamation No. 572 (2018) a valid revocation of Trillanes’s amnesty?
- Did the Court of Appeals correctly hold that Branch 148 did not act with grave abuse of discretion in denying the DOJ’s Omnibus Motion in the coup d’état case?
- Did the Court of Appeals correctly hold that Branch 150 acted wi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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