evaluation of evidentiary matters.

The Court is not a trier of facts,

II. JURISDICTION and cannot accept the petition for certiorari for that reason.

ANTONIO F. TRILLANES IV v. EVANGELINE C.

CASTILLO-MARIGOMEN
GR No. 223451 | 14 March 2018
Subtopic: B. Doctrines of hierarchy of courts and continuity
The Hierarchy of Courts should have been observed, because direct
of jurisdiction filing with the SC is only allowed when there are genuine issues of
constitutionality that must be addressed at the most immediate
DOCTRINE: The Supreme Court is not a trier of facts, because time.
findings of facts rest on the trial courts, but the SC is allowed to
review the same when there are genuine issues of The SC has the power to issue writs of certiorari, prohibition, and
constitutionality that must be addressed with immediate time. mandamus but the same is not exclusive because it shares the
jurisdiction over petitions for these extraordinary writs with the
FACTS: Court of Appeals and the Regional Trial Courts.
 Sen. Trillanes filed Proposed SR No. 826 directing the
Senate's Committee on Accountability of Public Officials Jurisprudence has established the sufficient standards and
and Investigations to investigate, in aid of legislation, guidelines by which the trial and appellate courts can address and
the alleged P1.601 Billion overpricing of the new 11- resolve the issue of parliamentary immunity raised by petitioner.
storey Makati City Hall II Parking Building.
 Petitioner alleged that at the Senate Blue Ribbon The Court is, thus, unconvinced that petitioner has presented an
hearing, former Makati Vice Mayor Mercado (Mercado) "exceptionally compelling reason" to justify his direct application
testified on how he helped former VP Binay acquire and for a writ of certiorari with this Court. Petitioner's statements in
expand what is now a 350-hectare Hacienda Binay in media interviews are not covered by the parliamentary speech or
Batangas who later on claimed absolute ownership over debate privileges.
it.
 The Petitioner admitted that based on his office's
review of the documents, Morigomen appears to be a In the case of Jimenez, it is evident that petitioner's remarks fall
"front" or "nominee" or is acting as a "dummy" of the outside the privilege of speech or debate under Section 11, Article
actual and beneficial owner of the estate, VP Binay. VI of the 1987 Constitution. The statements were clearly not part
 Morigomen filed a complaint for damages against Sen. of any speech delivered in the Senate or any of its committees.
Trillanes for his alleged defamatory statements on the They were also not spoken in the course of any debate in said fora.
media. It cannot likewise be successfully contended that they were made
 In petitioner Trillanes’ Answer with Motion to Dismiss, in the official discharge or performance of petitioner's duties as a
he raised that private respondent failed to state and Senator, as the remarks were not part of or integral to the
substantiate his cause of action since petitioner's legislative process.
statement that private respondent was acting as a
"front," "nominee" or "dummy" of VP Binay for his
Hacienda Binay is a statement of fact;.
 Trillanes also averred that his statements were part of
an ongoing public debate on a matter of public concern
which is protected by his constitutionally guaranteed
rights to free speech and freedom of expression and of
the press; and that his statements, having been made in
the course of the performance of his duties as a Senator,
are covered by his parliamentary immunity under
Article VI, Section 11 of the 1987 Constitution.
 Petitioner’s motion for reconsideration was denied by
the RTC.
 Petitioner filed the petition for Certiorari to the SC,
assailing public respondent's May 19, 2015 and
December 16, 2015 Orders on the ground of grave
abuse of discretion amounting to lack or excess of
jurisdiction.

ISSUE: Whether or not the hierarchy of court’s was violated by the

Petitioner when it directly filed the petition for certiorari to the SC.

RULING: Yes. Even granting that the petition for certiorari might
be directly filed with the SC, its dismissal is proper because its
resolution would inevitably require the consideration and