Case Summary (G.R. No. 206354)
Background of the Incident
The Atimonan Encounter involved a shootout between personnel from the Philippine National Police (PNP) and armed individuals. Following the incident, then-President Benigno Simeon C. Aquino III ordered an investigation by the National Bureau of Investigation (NBI). Marantan expressed concerns over the impartiality of the DOJ following public statements made by Secretary De Lima, which he believed compromised his right to due process. Marantan sought to have the case referred to the Office of the Ombudsman instead of being investigated by the DOJ.
Preliminary Proceedings and Investigations
On March 11, 2013, the DOJ organized a panel of prosecutors to conduct a preliminary investigation into the incident. Subsequently, Marantan filed a motion requesting the DOJ to inhibit from the investigation due to alleged bias. Despite this, the panel proceeded with the investigation, which resulted in findings of probable cause against Marantan and others for multiple murder charges related to the incident.
Contentions of the Parties
Marantan contended that the DOJ exhibited bias through Secretary De Lima's public statements, effectively prejudging the case against him. He claimed that this impinged upon his constitutional rights to due process and equal protection under the law. The respondents argued that the petition should be dismissed due to Marantan’s failure to follow the proper hierarchy of courts and his lack of exhaustion of administrative remedies. They asserted that the preliminary investigation had already concluded, rendering Marantan’s petition moot.
Legal Principles Addressed
The central issues for determination included the applicability of judicial hierarchy and exhaustion of remedies, the alleged grave abuse of discretion by the DOJ and the Panel of Prosecutors, and whether the case became moot following the filing of the Information against Marantan. The Supreme Court emphasized that a petition for certiorari is permissible only under special circumstances that were not demonstrated by Marantan.
Findings of the Court
The Court found that the case did not warrant deviation from the established rules regarding judicial hierarchy and exhaustion of administrative remedies. Marantan's assertions of bias within the DOJ and the lack of an impartial tribunal were not substan
...continue readingCase Syllabus (G.R. No. 206354)
Case Background
- The case revolves around a petition for certiorari and prohibition filed by Police Superintendent Hansel M. Marantan against the Department of Justice (DOJ) and various members of its prosecution panel.
- The petition challenges the procedures and impartiality of a preliminary investigation concerning the Atimonan Encounter, which resulted in the deaths of 13 individuals during a shootout between police and armed men on January 6, 2013.
- Following the incident, then-President Benigno Simeon C. Aquino III ordered the National Bureau of Investigation (NBI) to investigate the matter.
Events Leading to the Petition
- On January 6, 2013, a violent confrontation occurred in Atimonan, Quezon, involving police forces and a convoy of armed men, leading to numerous fatalities.
- Secretary of Justice Leila De Lima made public statements naming Marantan during the investigation, which raised concerns regarding her impartiality.
- Marantan, alongside other soldiers, subsequently requested that any actions against those involved be forwarded to the Office of the Ombudsman, rather than the DOJ, for impartial handling.
Procedural Developments
- On March 6, 2013, Secretary De Lima reported to President Aquino that the NBI would file criminal charges against the police and armed forces personnel involved.
- The DOJ convened a Panel of Prosecutors on March 11, 2013, to conduct a preliminary investigation.
- Marantan filed a Lette