Case Summary (G.R. No. 203605)

Background of the Case

• Lilian I. De Vera filed a complaint on July 28, 2009, against several Philippine National Police (PNP) officers, alleging multiple murders.
• The complaint involved PNP officers from the Highway Patrol Group (HPG) and the Special Action Force (SAF).
• Lilian accused the officers of conspiring to kill her husband, Alfonso "Jun" S. De Vera, and their daughter, Lia Allana.
• The incident occurred on December 5, 2008, when Lilian attempted to meet her family but learned they were involved in a police shootout.
• Upon arriving at the scene, she discovered that both Jun and Lia had died from gunshot wounds.

Witness Accounts and Initial Investigation

• Witnesses reported that Jun and Lia were in their vehicle when police officers, identified as SAF members, opened fire.
• Jun attempted to rescue Lia, who had been shot, but was subsequently shot himself by the police.
• Following a preliminary investigation, the Department of Justice (DOJ) found probable cause to indict the involved police officers for murder.

Regional Trial Court Proceedings

• On March 16, 2010, the DOJ filed charges against the officers in the Regional Trial Court (RTC) of Parañaque City.
• The petitioner HPG officers filed a motion to dismiss the charges, claiming a lack of probable cause and violation of their rights.
• On June 16, 2010, the RTC dismissed the case against the HPG officers, citing insufficient evidence linking them to the shooting.
• The RTC found that the HPG officers acted as a blocking force in a legitimate police operation.

Court of Appeals Review

• Lilian sought reconsideration of the RTC's dismissal, which was denied on September 24, 2010.
• The Office of the Solicitor General (OSG) filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC.
• On June 15, 2012, the CA granted the OSG's petition, stating that the RTC failed to properly evaluate witness statements.

Findings of the Court of Appeals

• The CA noted that witness affidavits indicated the involvement of the HPG officers in the shooting.
• The CA ordered the issuance of arrest warrants against the HPG officers, leading to their petition for review.

Issues Presented

• The case raised three primary issues regarding the CA's decision to grant the OSG's petition for certiorari, the counting of the prescriptive period for filing, and the finding of probable cause against the HPG officers.

Court's Rulings on Procedural Issues

• The Court ruled that the RTC acted within its authority to dismiss the case for lack of probable cause.
• The CA should have denied the OSG's petition for certiorari, as the RTC's dismissal was a final and appealable order.
• The Court emphasized that the OSG's petition was filed beyond the allowed 60-day period, rendering it untimely.

Examination of the Merits

• The Court reviewed the merits of the RTC's dismissal, noting that the evidence presented by the prosecution did not establish probable cause against the HPG officers.
• Witness testimonies indicated that the shooting was carried out by SAF officers, not HPG officers.
• The crime laboratory report confirmed that HPG officers...continue reading

Case Syllabus (G.R. No. 203605)

Case Background

• On July 28, 2009, Lilian I. De Vera filed a complaint with the Department of Justice (DOJ) against several Philippine National Police (PNP) officers, including petitioners P/C Insp. Lawrence B. Cajipe and others, charging them with multiple murders.
• The complaint alleged that the officers conspired with members of the PNP Special Action Force (SAF) to kill Lilian's husband, Alfonso "Jun" S. De Vera, and their 7-year-old daughter, Lia Allana.
• The tragic event occurred on December 5, 2008, when Lilian attempted to meet Jun and Lia but found them involved in a shootout at their subdivision.
• Witnesses reported that Jun and Lia were in their vehicle when police officers opened fire, resulting in both fatalities.

Incident Details

• Lilian called Jun to inform him of her arrival in Pasay City but, upon reaching the area, found that they were missing.
• After learning about a police shootout, she was informed by a neighbor, Hilario Indiana, to go to the hospital where Lia was taken.
• At the hospital, Lilian discovered that Lia had died from a gunshot wound, and Jun was found dead near a jeepney, also shot in the head.
• Witnesses claimed Jun was shot while trying to rescue Lia from the vehicle.

Legal Proceedings

• On December 28, 2009, the DOJ issued a resolution indicating probable cause for murder charges against the involved police officers.
• Subsequent to the DOJ findings, the Regional Trial Court (RTC) of Parañaque City received the information in Criminal Cases 10-0280 and 10-0281.
• The petitioner HPG officers filed an omnibus motion seeking a judicial determination of ...continue reading