Case Digest (G.R. No. 194469) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Hubert Jeffrey P. Webb v. NBI Director Magtanggol B. Gatdula et al. (G.R. No. 194469, September 18, 2019), petitioner Webb filed a Petition for Indirect Contempt under Rule 71 of the Rules of Court against ten officers of the National Bureau of Investigation (NBI)—Directors Magtanggol B. Gatdula, Carlos S. Caabay, Nestor M. Mantaring; Medico-Legal officers Dr. Renato C. Bautista and Dr. Prospero Cabanayan; Atty. Floresto P. Arizala, Jr.; Atty. Reynaldo O. Esmeralda; Atty. Arturo Figueras; Atty. Pedro Rivera; and Agent John Herra. The petition arose from the rape-homicide trial of the Vizconde massacre (People v. Webb), wherein Webb sought DNA analysis of the semen specimen collected from the victim’s cadaver to establish his innocence. After the trial court denied his motion, this Court’s April 20, 2010 Resolution—relying on the 1987 Constitution’s guarantee of due process—ordered the NBI to facilitate submission of the slides to the UP Natural Science and Research Institute Case Digest (G.R. No. 194469) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Hubert Jeffrey P. Webb; Respondents: ten (10) NBI officers (current and former Directors, Medico‐Legal officers, attorneys, and an agent).
- Origin in the Vizconde Massacre (1991): Webb charged with rape with homicide; sought DNA testing of semen found on victim.
- SC DNA Order and NBI’s Compliance
- April 20, 2010 Resolution: SC granted Webb’s petition to submit semen specimen for DNA analysis and ordered NBI to assist and report compliance within 15 days.
- NBI Compliance (April 27, 2010; July 16, 2010): Claimed specimen no longer in custody—allegedly submitted by Dr. Cabanayan in 1996—but trial court records and Dr. Bautista’s 1997 certification contradicted this.
- Petition for Indirect Contempt
- Allegations: NBI officers impeded justice and disobeyed SC order by losing or misrepresenting custody of the specimen; made false reports; exhibited negligence in safekeeping.
- Additional misconduct claims: Coaching of star witness Jessica Alfaro for inconsistent affidavits and coached in-court identification; suppression of alibi and fingerprint evidence.
- Procedural History
- December 14, 2010: In Lejano v. People, Webb and co-accused acquitted—respondents argue mootness of contempt petition.
- Respondents’ Comments: Assert no bad faith, lack of custody at order time, presumption of regularity, and absence of deliberate misconduct; some respondents claim they assumed office after loss.
Issues:
- Whether the contempt action is barred by the SC’s decision in Lejano (res judicata).
- Whether respondents are guilty of indirect contempt by:
- Disobedience or resistance to a lawful order of the Court.
- Improper conduct tending to impede, obstruct, or degrade the administration of justice.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)