Case Summary (G.R. No. 232395)
Background of the Case
The petitioner was charged with multiple counts of rape against a minor, AAA, by means of force and intimidation. Criminal Cases Nos. 3821 to 3826 were initiated against the petitioner based on these accusations. The petitioner filed a Motion to Quash on jurisdictional grounds, asserting his status as a member of the Higaonon-Sugbuanon Tribe and claiming that the cases should be resolved according to the customary laws of his tribe, as outlined in Republic Act No. 8371.
Procedural Developments
The trial court judge denied the Motion to Quash, stating it lacked merit. The court clarified that RA 8371 applies only to disputes concerning customary laws and civil cases but does not pertain to criminal prosecutions such as those for rape, which fall under the jurisdiction of regular courts. Undeterred, the petitioner filed a Petition for Mandamus, seeking to compel the court to recognize the jurisdictional claims of Indigenous Peoples and aimed to prevent the prosecution of cases against him.
Respondents' Positions
The respondents, including the judge, prosecutor, and police officers, contended that the petition for mandamus was procedurally flawed. They argued that mandamus is inappropriate because it is reserved for cases where there is a failure to perform a ministerial duty, which was not the case here. They asserted that the alleged jurisdictional privileges claimed by the petitioner under RA 8371 did not exempt him from facing prosecution under national penal laws.
Court’s Analysis of Jurisdiction
The Supreme Court emphasized the principle of the hierarchy of courts, explaining that direct recourse to the Supreme Court for a petition for mandamus is discouraged unless exceptional circumstances exist. The Court reiterated that such petitions should first be directed to the appropriate lower courts, in this instance, the Regional Trial Court, due to the shared original jurisdiction.
Determination of Legal Rights
The Court found that the petitioner did not demonstrate any clear legal right that was infringed upon by the prosecution of criminal charges against him. The petitioner's reliance on Sections 65 and 66 of RA 8371 was found to be inapplicable in this context, as the matters addressed were criminal in nature rather than civil disputes rooted in customary laws.
Evaluation of Ministerial Duties
The Court noted that the actions of the j
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Case Overview
- This case involves a Petition for Mandamus filed by Datu Malingin, a tribal chieftain of the Higaonon-A-Sugbuanon tribe, against several respondents including police officers and a regional trial court judge.
- The petitioner seeks to declare the Regional Trial Court of Abuyog, Leyte as lacking jurisdiction over disputes involving Indigenous Peoples (IPs) and to prevent the prosecution of cases involving him based on the premise of customary laws.
Antecedents of the Case
- Petitioner was accused by the respondent Prosecutor of raping a minor, referred to as AAA, on multiple occasions.
- Criminal cases were filed against him, prompting him to file a Motion to Quash based on a claim of lack of jurisdiction, citing provisions of Republic Act No. 8371, which pertains to the rights of Indigenous Peoples.
- The respondent Judge denied the Motion to Quash, arguing that RA 8371 does not extend to criminal cases involving violations of the Revised Penal Code (RPC).
Proceedings Before the Court
- Petitioner argues that a writ of mandamus is necessary to protect the rights of Indigenous Peoples and to address perceived grave abuses of discretion by the respon