Case Digest (G.R. No. 121234) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 19, 1994, the National Bureau of Investigation (NBI) filed with the Department of Justice a letter-complaint charging Hubert J. P. Webb, Michael A. Gatchalian, Antonio L. Lejano and six others with rape with homicide for the brutal killings of Carmela Vizconde, her mother Estrellita Nicolas-Vizconde and her sister Anne Marie Jennifer at their Paranaque home on June 30, 1991. A DOJ panel, headed by Assistant Chief State Prosecutor Jovencio Zuno, conducted the preliminary investigation during which the NBI presented the May 22, 1995 sworn statement of principal witness Maria Jessica M. Alfaro, as well as affidavits from former Webb household staff, a United Airlines passenger, and others detailing the crime scene. Petitioners countered with an alibi supported by several witnesses, documents showing Webb’s travel and residence in the United States from March 1991 to October 1992, and sought production of an FBI report and Alfaro’s earlier sworn statement (April 28, 1995) wh Case Digest (G.R. No. 121234) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Petitions
- Petitioners: Hubert J. P. Webb (G.R. No. 121234), Michael A. Gatchalian (G.R. No. 121245), Antonio L. Lejano (G.R. No. 121297), with Lauro Vizconde as intervenor.
- Respondents: RTC Judges Raul E. de Leon (Br. 258), Zosimo V. Escano (Br. 259), Amelita G. Tolentino (Br. 274); People of the Philippines; co-accused Zenon L. De Guia, Jovencito Zuno, Leonardo Guiyab Jr., Roberto Lao, Pablo Formaran; National Bureau of Investigation (NBI).
- Underlying Crime and Complaint
- June 30, 1991: rape with homicide of Carmela N. Vizconde (19 years), her mother Estrellita (51 years), and sister Jennifer (7 years) at their BF Homes, Paranaque residence.
- June 19, 1994: NBI filed letter-complaint with DOJ charging Webb, Gatchalian, Lejano, and six others with rape and homicide. DOJ formed panel of prosecutors (headed by A.C.S.P. Jovencio Zuno) for preliminary investigation.
- Evidence Presented by NBI/DOJ Panel
- Principal witness Maria Jessica M. Alfaro’s sworn statements (April 28 & May 22, 1995) claiming to have witnessed the crime from outside the house.
- Affidavits of former Webb household aides Nerissa E. Rosales and Mila S. Gaviola describing Webb’s presence and bloodstained clothing; Carlos J. Cristobal doubting Webb’s co-passenger status on March 9, 1991 UA Flight 808; girlfriend of co-accused Biong, Lolita Birrer, narrating Biong’s investigative role and alleged cover-up; other servant and security guard statements; autopsy reports showing multiple stab wounds; presence of spermatozoa in Carmela.
- Petitioners’ Defense Evidence
- Webb’s alibi: allegedly in U.S. from March 9, 1991 to October 26, 1992; corroborated by eight witnesses (Honesto Aragon et al.); documentary proof of U.S. driver’s license (June 14, 1991), purchase of bicycle and car, and letter from U.S. Embassy Legal Attaché.
- Motion for Production of Evidence granted: NBI produced photocopies of FBI certification on Webb’s U.S. stay, medico-legal report, Biong statements, fingerprints photos, NBI investigation records, list of suspects, and Alfaro affidavits. Original April 28, 1995 Alfaro affidavit lost by NBI; later obtained via subpoena in R.T.C. Makati Civil Case No. 951099. FBI report remained undisclosed.
- Resolution, Filing of Information, and Warrants
- August 8, 1995: DOJ panel issued 26-page Resolution finding probable cause for rape with homicide (accessory liability for Biong) and recommended filing of information.
- August 10, 1995: Information filed in RTC Paranaque as Crim. Case No. 95-404 (Br. 258). Judge Escano inhibited; case re-raffled to Br. 274 (Tolentino).
- Warrants of arrest issued by Judge de Leon (Br. 258) and reissued by Judge Tolentino (Br. 274). Petitioners surrendered and filed petitions for certiorari, prohibition, and mandamus before the Supreme Court seeking annulment of warrants, enjoining the criminal proceedings, dismissal of the case, or inclusion of Alfaro as accused.
Issues:
- Did the DOJ panel gravely abuse its discretion in finding probable cause despite alleged inconsistencies in Alfaro’s statements, weak corroboration, and denial of clarificatory hearing?
- Did respondent judges de Leon and Tolentino abuse discretion by issuing arrest warrants without personal examination of complainant and witnesses or issuance of an order of arrest?
- Were petitioners’ due process rights violated by hasty/malicious conduct of the preliminary investigation, prejudicial publicity, and exclusion of Alfaro from the information under R.A. 6981 (Witness Protection Act)?
- Did petitioners have a right to discovery—specifically production of Alfaro’s original affidavit (April 28, 1995) and FBI report—during the preliminary investigation to safeguard their defense?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)