PEOPLE OF THE PHILIPPINE, petitioner, vs. HON. MA.

THERESA
L. DELA TORRE-YADAO
G.R. No. 162144-54, November 13, 2012

FACTS:
In 1995, the PNP Anti-Bank Robbery and Intelligence Task Group killed 11
suspected members of the Kuratong Baleleng Gang in Quezon City. The
cases were moved to the Regional Trial Court (RTC) of Quezon City by the
Sandiganbayan, but the Sandiganbayan chose to keep the jurisdiction and
try the Kuratong Baleleng murder cases. The case was contested by
respondent Lacson, but the Court affirmed its legality.

In 1999, the RTC temporarily dismissed the cases due to insufficient

evidence. In 2001, PNP Director Leandro R. Mendoza revived the cases by
asking the Department of Justice to examine their cases. Prosecutors
found enough evidence to hold Lacson and his co-accused responsible for
the murders, leading to distinct charges against them in Criminal Cases
01-101102 to 12.

In 2003, the parents of the two victims provided birth certificates as

evidence, and the prosecution modified legal documents to include this
information. However, Judge Ma. Theresa L. Yadao rejected the
prosecution's plea for the cases to be relocated to a family court,
dismissing the charges against the accused individuals due to
inconsistencies between the prosecution's witnesses' statements and
those provided during preliminary inquiries.

ISSUE:
Whether or not Judge Yadao gravely abused her discretion when she took
cognizance of Criminal Cases 01-101102 to 12 contrary to the
prosecution’s view that such cases fell under the jurisdiction of family
courts?

RULING:
NO, the allocation of exclusive original jurisdiction over criminal cases
concerning minors to family courts is inherently motivated by the intention
to safeguard their welfare and paramount interests. Hence, when the
imperative of such safeguarding remains unaltered, the Court has the
capacity to make exceptions to this principle. This has been evident in
numerous instances, where the Court has ruled that the Court of Appeals
possesses concurrent jurisdiction with family courts in entertaining
petitions for habeas corpus concerning minors.
In the present matter, the focal point is on the two juvenile victims whose
interests led to the public's desire for the transfer of the murder cases to a
family court. However, it is noteworthy, as the respondents aptly assert
that these two minor victims are no longer alive. Consequently, the core
argument gains traction that no living minor is involved in the murder
cases, obviating the necessity for the specialized attention and
safeguarding that a family court provides. In actuality, no minor would
assume the role of a litigant in those proceedings during the trial phase,
given that the legal representation of the minor victims has transitioned to
their legal guardians who have assumed the position of actual private
complainants.