MAGSAYSAY, MAE CHLOE C.

60. MAZA v TURLA

PETITIONER: Liza Maza, Saturnino Ocampo, Teodoro Casino, and Rafael Mariano
RESPONDENTS: Hon. Evelyn Turla, Floro F. Florendo et al
DOCKET NO: 187094
DATE: February 15, 2017
PONENTE: Leonen, J:
TOPIC: General Provisions

FACTS:

 Petitioners are former members of the House of Representatives. Liza represented Gabriela Women’s
Party, while Saturnino and Teodoro represented Bayan Muna Party-List, while Rafael represented
Anakpawis Party-list.

 Inspector Palomo named 19 individuals, including Petitioners, who were allegedly responsible for the
death of Carlito Bayudang, Jimmy Peralta, and Danilo Felipe.

 On February 2, 2007, Investigating Prosecutor Antonio Ll. Lapus, Jr. issued a subpoena requiring
petitioners to testify at the hearings scheduled on February 16 and 23, 2007.

 The panel of prosecutors issued on April11,2008 a Joint Resolution, reviewed and approved by Officer-in-
charge Provincial Prosecutor Floro F. Florendo.

 On April 21, 2008, petitioners also filed a Motion for Judicial Determination of Probable Cause with Prayer
to Dismiss the Case Outright on the Palayan cases. The panel of prosecutors opposed the motion. And
Petitioners filed a reply on May 12, 2008.
 After the motion was heard by the RTC, both parties submitted their respective memoranda.

 Judge Turla held that the proper procedure for investigation was not followed.

ISSUE: THE PETITION SHOULD BE DISMISSED FOR VIOLATING THE HIERARCHY OF COURTS.

RULING: This petition is an exception to the principle of hierarchy of courts. The Court of Appeals is primarily
designed as an appellate court that reviews the determination of facts and law made by the trial courts. It is
collegiate in nature. This nature ensures more standpoints in the review of the actions of the trial court. But the
Court of Appeals also has original jurisdiction over most special civil actions. Unlike the trial courts, its writs can
have a nationwide scope. It is competent to determine facts and, ideally, should act on constitutional issues that
may not necessarily be novel unless there are factual questions to determine.

In this case, the presence of compelling circumstances warrants the exercise of this Court's jurisdiction. At the time
the petition was filed, petitioners were incumbent party-list representatives. The possibility of their arrest and
incarceration should the assailed Orders be affirmed, would affect their representation of their constituents in
Congress.

Although the circumstances mentioned are no longer present, the merits of this case necessitate this Court's
exercise of jurisdiction.
DISPOSITION: WHEREFORE, the Petition is PARTIALLY GRANTED. The assailed Orders dated July 18, 2008 and
December 2, 2008 of the Regional Trial Court, Palayan City, Branch 40 in Criminal Case Nos. 1879-P and 1880-P are
SET ASIDE.