Case Summary (G.R. No. 170447)
Timeline of Events
The sequence of events commenced with the filing of a complaint for vote buying against Olivarez, which led to the issuance of a Joint Resolution by Assistant City Prosecutor Antonietta Pablo-Medina. The prosecution filed two Informations before the Regional Trial Court (RTC) on September 29, 2004, charging Olivarez with violations under the Omnibus Election Code. The arraignment was initially set for October 18, 2004, but subsequent motions by the respondent delayed the proceedings.
Legal Actions Taken by the Respondent
On October 7, 2004, Olivarez filed an appeal with the Commission on Elections (COMELEC) regarding the Joint Resolution, arguing it should pause the formal proceedings in the RTC. Following directions from COMELEC, the city prosecutor was instructed to suspend the implementation of the Joint Resolution until the appeal was resolved.
Initial Court Proceedings and Motions
In a response to the charges, Olivarez filed a Motion to Quash the two Informations, alleging duplicity of charges. Despite this, the prosecutor submitted Amended Informations on October 28, 2004, which refocused the charges. Judge Fortunito Madrona of the RTC issued an order on January 12, 2005, admitting the Amended Informations and denying Olivarez's Motion to Quash. This sparked further motions from Olivarez, including a motion for reconsideration.
Court of Appeals Involvement
After Olivarez failed to appear for his arraignment on March 9, 2005, Judge Madrona ordered his arrest and the confiscation of his cash bond. In response, Olivarez filed a Special Civil Action for Certiorari in the Court of Appeals, which ruled in favor of Olivarez on September 28, 2005, declaring that the COMELEC had the authority to investigate and prosecute election offenses and revoked the RTC's acceptance of the Amended Informations.
Supreme Court Review
The petitioners sought review from the Supreme Court, questioning the Court of Appeals' conclusions regarding the authority of the City Prosecutor to amend the Informations. The Supreme Court noted that the filing of Amended Informations occurred before COMELEC's revocation of prosecutorial authority and found that the public prosecutors acted within the bounds of their authority.
Jurisdiction and Arraignment Procedures
The Supreme Court clarified that a trial court acquires jurisdiction once an information is filed, affirming the continuity of prosecutorial authority until formally revoked. The arraignment could not indefinitely be postponed due to Olivarez’s appeal process, as procedural rules permitted only a set suspension period.
Final Ruling
Ultimately, the Supreme Court rev
...continue readingCase Syllabus (G.R. No. 170447)
Case Overview
- Petitioners Bienvenido Diao and Renato Comparativo challenge the Decision of the Court of Appeals dated 28 September 2005.
- The Court of Appeals nullified the Orders dated 12 January 2005, 9 March 2005, and 31 March 2005 issued by Judge Fortunito L. Madrona of the Regional Trial Court (RTC) of ParaAque City.
- The case involves allegations of vote buying against respondent Pablo Olivarez stemming from events on 10 May 2004.
Allegations of Vote Buying
- Petitioners filed a complaint against Olivarez based on findings of probable cause by Assistant City Prosecutor Antonietta Pablo-Medina.
- Two Informations were filed on 29 September 2004, charging Olivarez with violations of Section 261 of the Omnibus Election Code.
- The charges alleged that Olivarez, along with others, engaged in vote buying by distributing Uniwide gift certificates to influence voters.
Procedural History
- The initial arraignment for the respondent was set for 18 October 2004.
- On 7 October 2004, Olivarez appealed the Joint Resolution of the City Prosecutor to the Commission on Elections (COMELEC), stating the pendency of the appeal should halt the filing of the Informations.
- Following this, the COMELEC directed the city prosecutor to transmit records and suspend further implementation of the Joint Resolution.
Motion to Quash and Amended Informations
- On 11 October 2004, Olivarez filed a Motion to Quash the Infor