Case Summary (G.R. No. 149453)
Procedural History
The case commenced with Criminal Cases Nos. Q-99-81679 to Q-99-81689 concerning the aforementioned incident being filed in the Regional Trial Court (RTC) of Quezon City. After a series of affidavits emerged from police officers alleging wrongful killings, the Ombudsman conducted an investigation. Initially, the Ombudsman recommended the dismissal of the charges for lack of probable cause, but this was later reversed, leading to murder charges being formally filed against Lacson and other police officers.
Dismissal of Criminal Charges
On March 29, 1999, the RTC dismissed the criminal cases based on a lack of probable cause, influenced by the recantation of the principal prosecution witnesses and the desistance of private complainants, indicating their non-interest in pursuing the charges further. The dismissal was established as provisional due to the absence of final trials.
New Charges Filed
On June 6, 2001, new murder charges were filed against Lacson and others, stemming from the same incident with the RTC of Quezon City. Notably, these charges were based on new affidavits from various witnesses. The respondent Lacson filed a petition against the prosecutors, challenging the validity of the proceedings due to claims that the cases had already been dismissed.
Temporary Restraining Order and Judicial Determinations
In the proceeding before Judge Herminia V. Pasamba, Lacson sought a temporary restraining order to prohibit further investigation. This request was denied as the dismissal of the previous charges was not deemed final and conclusive. Following the dismissal of the temporary restraining order, the new charges were evaluated, leading to the judicial determination regarding the revival of previously terminated cases.
Court of Appeals Decision
The Court of Appeals, in its decision dated August 24, 2001, characterized the previous dismissal as provisional, asserting that the resumption of criminal proceedings for murder against Lacson was impermissible under Section 8, Rule 117 of the Revised Rules of Criminal Procedure. The decision stipulated that the revival of charges was barred since the two-year period for reviving such dismissed cases had elapsed.
Legal Questions and Remand
The central legal inquiry involved whether the state could file new charges against Lacson after the two-year prescriptive period from the provisional dismissal. The Court acknowledged the lack of clarity surrounding the notice given to offen
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Case Overview
- The case involves a petition for review on certiorari filed by the People of the Philippines against Panfilo M. Lacson, seeking to reverse the Decision of the Court of Appeals dated August 24, 2001.
- The Court of Appeals had granted Lacson's Second Amended Petition for Prohibition, which challenged the Order issued by Judge Herminia Pasamba of the Regional Trial Court (RTC) of Manila that allowed the continuation of the re-investigation of multiple murder cases related to the Kuratong Baleleng gang.
Background of the Case
- On May 18, 1995, PNP Director-General Recaredo Sarmiento II announced the death of eleven members of the Kuratong Baleleng Gang in what was initially reported as a police shootout.
- Subsequent claims arose suggesting that the incident was a summary execution rather than a legitimate shootout, leading to various affidavits from police officers involved.
- Affidavits from police officers, including SPO2 Eduardo delos Reyes and SPO2 Corazon dela Cruz, detailed the alleged wrongful arrest and execution of the gang members.
Progression of Charges
- On June 1, 1995, murder charges were filed against 97 officers involved in the operation, which prompted a preliminary investigation led by the Ombudsman.
- A resolution by the Ombudsman initially recommended dismissal of the charges, but a subsequent review panel reversed this decision, resulting in charges against 26 officers, including Lacson.
- The charges were downgraded from principal to accessory against Lacson after procedural motions.
Jurisdictional Issues
- Lacson contested the jurisdi