Title
Trillanes vs. Medialdea
Case
G.R. No. 241494
Decision Date
Apr 3, 2024
The Supreme Court held that Proclamation No. 572 revoking Trillanes' amnesty is void, affirming the principles of due process and equal protection under the law.

Case Summary (G.R. No. 221586)

Core facts: Oakwood Mutiny and Manila Peninsula Incident

Trillanes led the July 27, 2003 Oakwood incident (charged with coup d’état under Article 134-A RPC) and, during the ongoing trial, participated in the November 29, 2007 Manila Peninsula incident (subsequently charged with rebellion). Criminal cases were pending in Makati RTC Branches 148 (coup d’état) and 150 (rebellion).

Proclamation No. 75 (2010) and congressional concurrence

President Benigno S. Aquino III issued Proclamation No. 75 granting amnesty to active/former AFP and PNP personnel and their supporters for acts in connection with Oakwood, the Marines stand‑off, and Manila Peninsula, subject to exclusions (e.g., rape, torture) and procedural conditions. Congress adopted Concurrent Resolution No. 4, concurring with Proclamation No. 75 and recommending implementation requirements (including admission of guilt).

DND Ad Hoc Amnesty Committee and implementing rules

Pursuant to Proclamation No. 75, the DND created an Ad Hoc Amnesty Committee and promulgated Committee Rules of Procedure (DO No. 320 / DND-AC Circular No. 1). The rules provided the application form, filing period (90 days after publication), posting and opposition procedures, deliberation and recommendation process, requirement of express admission of involvement/guilt for specified incidents, and appeal of DND determinations to the Office of the President (decision immediately executory even if appealed).

Amnesty grant, certificates, and RTC dismissals (2011)

Trillanes received a Certificate of Amnesty signed by DND Secretary Gazmin dated January 21, 2011. On that basis, Branch 150 (rebellion) and Branch 148 (coup d’état) granted motions to dismiss the respective cases in September 2011; those dismissal orders became final and executory because the People did not appeal or move for reconsideration.

Proclamation No. 572 (2018) — revocation of Trillanes’ amnesty

On August 31, 2018, President Duterte issued Proclamation No. 572 declaring Trillanes’ amnesty void ab initio on the ground he allegedly failed to comply with minimum requirements (no official application form on file; did not admit guilt). The Proclamation directed the DOJ and Court Martial to pursue criminal and administrative cases against Trillanes and ordered AFP/PNP to “employ all lawful means” to apprehend him.

Immediate procedural consequences: DOJ motions and attempted arrest

Following Proclamation No. 572, the DOJ filed ex parte omnibus motions in Branches 148 and 150 for hold‑departure orders and warrants of arrest. Trillanes also filed an original action before the Supreme Court (certiorari/prohibition/injunction) seeking to invalidate Proclamation No. 572 and to enjoin enforcement. Trillanes alleged attempts by PNP/CIDG/AFP officers to arrest him at the Senate.

RTC Branch 148 (coup d’état): evidentiary hearing and denial of DOJ motion

Branch 148 conducted an evidentiary hearing and concluded that Trillanes had filed the prescribed amnesty application and admitted guilt; it denied the DOJ’s motion to issue warrant/HDO. Branch 148 also addressed the validity of Proclamation No. 572 (finding it valid in principle) but held Trillanes nonetheless satisfied Proclamation No. 75 requirements; its orders were subsequently affirmed by the CA on the evidentiary/fact findings.

RTC Branch 150 (rebellion): summary hearing and grant of DOJ motion

Branch 150 conducted only a summary hearing (affidavits and documentary submissions), credited DND certification that no copy of Trillanes’ application was in DND records, concluded Trillanes had not applied nor admitted guilt, declared the 2011 dismissal void ab initio, and granted the DOJ’s Omnibus Motion (issuance of warrant/HDO). Branch 150’s orders were later reversed by the CA for grave abuse of discretion for reopening a final judgment via the omnibus motion and for denying Trillanes adequate opportunity to present evidence.

Court of Appeals: divergent holdings on the two RTC rulings

The CA in the coup d’état appeal sustained Branch 148’s denial of the DOJ motion and agreed that Trillanes had complied with Proclamation No. 75; it nonetheless held Proclamation No. 572 valid as an executive act but not effective against Trillanes on the evidence. In the rebellion appeal, the CA granted relief to Trillanes, holding Branch 150 committed grave abuse in reopening a final and executory dismissal through a mere motion without proper procedure or adequate hearing.

Issues presented to the Supreme Court (consolidated)

Key issues: procedural (forum shopping, notarial defects, hierarchy of courts), substantive (whether Proclamation No. 75 unconstitutionally delegated presidential amnesty powers to DND/Committee; whether Proclamation No. 572 is constitutional), and whether Branch 148/150 acted with grave abuse in denying/granting DOJ motions respectively.

Procedural determinations by the Supreme Court

The Court rejected forum‑shopping and hierarchy‑of‑courts objections: Trillanes’ original action was permitted under recognized exceptions because the core questions were legal, of first impression, and concerned limits on executive power and fundamental rights; the Court found no deliberate multiplicity of suits. Minor notarial defects were insufficient to dismiss the Petition; presumption of regular performance of notarial duties prevailed absent clear and convincing proof to the contrary.

Justiciability and political‑question doctrine

The Supreme Court held the validity of Proclamation No. 572 is justiciable (not a non‑justiciable political question) because the 1987 Constitution expanded judicial review (Article VIII, Section 1) and the issues raised involve interpretation of constitutional limits and potential grave abuse of discretion by the Executive affecting Bill of Rights guarantees.

Substantive ruling — Proclamation No. 75 and delegation

The Court upheld Proclamation No. 75 and found there was no undue delegation of the presidential amnesty power. Proclamation No. 75 itself effected the grant; the DND Committee and Secretary merely processed applications and implemented administrative procedures. The Secretary of National Defense acted as the President’s qualified political agent; the Committee’s role was administrative and recommendatory, not the exercise of independent clemency power.

Substantive ruling — presidential revocation and congressional concurrence

The Court ruled that, while the Constitution expressly requires presidential grant of amnesty to be concurred in by Congress, it implicitly requires that revocation of an amnesty likewise cannot be unilaterally effected by the President without similar legislative concurrence. Allowing unilateral revocation by a later President would render the congressional concurrence at grant time nugatory and undermine finality and reliance interests.

Constitutional defects in Proclamation No. 572 — summary

The Court held Proclamation No. 572 void for grave abuse of discretion because it (a) violated procedural due process by disregarding the procedural reglementation that made DND’s amnesty decision final and immutable absent appeal, (b) retroactively stripped Trillanes of a vested legal protection (amnesty) in violation of the ex post facto prohibition, (c) violated double jeopardy by attempting to revive dismissed criminal cases whose dismissal was based on amnesty, and (d) violated equal protection by singling out Trillanes among hundreds of grantees whose application forms were also missing, without reasonable justification.

Narrow rulings on other constitutional claims

The Court found Proclamation No. 572 did not itself authorize or justify warrantless arrest because its language directed the AFP/PNP to “employ all lawful means,” which must be interpreted to require lawful procedures (i.e., arrest pursuant to valid warrant). The Court also concluded Proclamation No. 572 was not a bill of attainder because it did not itself impose punishment without judicial trial; rather, it sought to remove an asserted impediment to prosecution. Nonetheless, other constitutional infirmities rendered the Proclamation void.

Evidentiary and best‑evidence rule findings

The Supreme Court agreed with Branch 148 and the CA that the Best Evidence (Original Document) Rule did not bar admissibility of secondary evidence on the issue whether Trillanes filed an application. The central factual issue was existence/submission of the application form and admission of guilt, not disputed terms of a writing; the Certificate of Amnesty, Committee Resolution listing applicants, Secretariat testimony, and eyewit

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