Case Summary (G.R. No. 257685)
Allegations Against Respondents
The CHR filed a complaint against the respondents alleging various violations, including arbitrary detention, delay in the delivery of detained individuals, grave threats, grave coercion, and robbery/extortion under the Revised Penal Code, alongside violations of the Anti-Torture Act of 2009 and the 2013 Revised Philippine National Police (PNP) Operational Procedures. A visit by CHR personnel on April 27, 2017, revealed what was described as a "secret detention cell". The conditions of this cell were described as cramped, dark, and lacking basic sanitary provisions.
Findings by the CHR
During its investigation, CHR reported that there were detainees, among them three women and nine men, who had been unlawfully kept without access to a proper judicial process. Allegations were made regarding inadequate food provision, extortion demands from police officers, and physical abuse. Evidence presented included videos, photographs, and sworn statements from various witnesses.
Respondents' Defense
PSUPT Domingo contended that the detainees had been lawfully arrested during police operations and placed in a "holding room" for logistical reasons pending further inquest. He denied the CHR's allegations, asserting that the conditions were misunderstood and that the holding room had adequate facilities.
Ombudsman Ruling
On July 28, 2020, the Office of the Ombudsman dismissed the complainants' allegations for lack of probable cause, stating that the evidence presented by the CHR was not clear and convincing enough to support the claims. The Ombudsman found the defense provided by the respondents to be credible and asserted that the overcrowding in the detention facility was due to operational necessities rather than deliberate disregard for the detainees' rights.
CHR's Reconsideration and Subsequent Ruling
Following the dismissal, the CHR sought reconsideration of the Ombudsman’s ruling, which was denied on May 18, 2021. The Ombudsman maintained its prior findings, highlighting inconsistencies among the detainees’ testimonies and reiterating the absence of physical evidence supporting claims of maltreatment.
Legal Framework and Standards of Evidence
The heart of the dispute revolved around the standard of evidence. The CHR contended that the Ombudsman had applied an inappropriate standard, requiring "clear and convincing evidence" rather than the requisite "probable cause". The court noted that while the Ombudsman might have used varied phrasing, the essence of its ruling targeted the insufficiency of evidence to establish probable cause against the respondents.
Court's Disposition
The court ultimately denied CHR’s petition for certiorari, stressing that the Ombudsman possesses the discretion
...continue readingCase Syllabus (G.R. No. 257685)
Case Background and Parties Involved
- The case involves a Petition for Certiorari under Rule 65 against the Office of the Ombudsman’s dismissal of criminal and administrative complaints filed by the Commission on Human Rights (CHR).
- CHR filed complaints against respondents, including several police officers of Raxabago Police Station 1 in Tondo, Manila, led by PSUPT Robert C. Domingo.
- The complaints alleged violations under the Revised Penal Code (arbitrary detention, grave threats, robbery/extortion), Republic Act No. 9745 (Anti-Torture Act of 2009), and the 2013 Revised Philippine National Police Operational Procedures.
Facts and Allegations
- CHR visited Raxabago Police Station 1 on April 27, 2017, after receiving information about a secret detention cell.
- They discovered a cramped, fetid, windowless room measuring 1 by 5 meters, described as a "secret detention cell," with poor sanitary conditions including only one male urinal.
- There were 12 detainees (3 women, 9 men) allegedly arrested for violations of the Comprehensive Dangerous Drugs Act.
- Allegations included:
- Names not logged in the police logbooks.
- Unlawful arrests and lack of inquest proceedings.
- No provision of food.
- Extortion of money from detainees.
- Physical abuse including beatings and electric shocks with tasers.
- Fear of death expressed by detainees.
Evidence Submitted by CHR
- Video of confrontation at the police station (not submitted to the Court).
- Photos of the police station.
- Sworn statements from relatives of detainees.
- Affidavits of CHR attorneys.
Defense and Counter-Affidavit by Respondents
- PSUPT Domingo submitted a counter-affidavit denying allegations and presenting the "secret detention cell" as a "holding room" for detainees while documents were processed.
- He explained the holding room’s location, lighting, ventilation, and reasons for its use (separating from trial detainees, decongesting cells).
- PSUPT Domingo claimed detainees were lawfully arrested during valid police operations and underwent inquests before transfer or release.
- Other responding officers did not submit counter-affidavits.
Ombudsman’s Resolution
- The Office of the Ombudsman dismissed the complaint for lack of probable cause in the criminal and administrative aspects.
- The Ombudsman found the CHR failed to prove detainees were held beyond legal detention periods or subjected to abuse.
- Found the evidence of torture, extortion, and other alleged violations lacking independent, credible support.
- Noted overcrowding at the police station, acknowledging constrained circumstances.
- Detainees’ affidavits mostly contradicted CHR’s allegations except for