Presumption of Innocence

People v. Dramayo, 42 SCRA 59 (1971)

Facts:
• The case involves the murder of Estelito Nogaliza, which occurred on the
morning of January 9, 1964, in Barrio Magsaysay, Sapao, Surigao del Norte.
• The accused, Pableo Dramayo and Paterno Ecubin, along with the deceased,
approached the chief of police to provide witness statements about a robbery
that had taken place in the deceased's house five days prior.
• The accused were prime suspects in the robbery, as they had been implicated by
confessing individuals.
• Later that day, the accused invited several others for a drinking session and
conspired to kill the deceased to prevent him from testifying about the robbery.
• Ecubin struck the deceased with a piece of wood, and Dramayo repeatedly
stabbed him with a short pointed bolo.
• The accused concealed their involvement in the murder, and Dramayo even
visited the deceased's widow to report the discovery of the cadaver.
• The lower court convicted Dramayo and Ecubin of murder and sentenced them
to reclusion perpetua.
• Three other accused were acquitted due to insufficient evidence, and two were
utilized as state witnesses.
Issues:
• The primary issue is whether the evidence presented by the prosecution is
sufficient to prove the guilt of the appellants, Pableo Dramayo and Paterno
Ecubin, beyond a reasonable doubt.
Ruling: The court ruled in favor of the prosecution, upholding the conviction of the
appellants for murder and modifying the indemnification to the heirs of Estelito Nogaliza
to be P12,000.00.
Key Points:
• The court emphasized the presumption of innocence and the constitutional
requirement that the prosecution must prove guilt beyond a reasonable doubt.
• The court stated that only if the evidence demonstrates moral certainty of guilt
should a conviction be upheld.
• The defense of alibi presented by the appellants was not persuasive and did not
cast reasonable doubt on their guilt.
• The court found that the credible and competent evidence established the moral
certainty of the appellants' guilt, leading to their conviction.
 • The court rejected the argument that the other acquitted co-accused should have
led to the appellants' acquittal as well, as the evidence against them was strong
and the conspiracy was evident.
• The court also rejected the argument that the lower court overlooked or
improperly considered material facts, as the testimony supported the manner in
which the deceased was killed and the motive behind the murder.
In summary, the court affirmed the conviction of the appellants, Pableo Dramayo and
Paterno Ecubin, for the murder of Estelito Nogaliza based on the evidence presented,
and emphasized the need for moral certainty in establishing guilt beyond a reasonable
doubt.

People v. Mingoa, 92 Phil. 857 (1953)

Facts:
• The defendant, Aquino Mingoa, was an officer-in-charge of the office of the
municipal treasurer of Despujols, Romblon.
• He was found short in his accounts by an amount of P3,938 upon examination of
his books and accounts on September 1, 1949.
• When demanded to produce the missing fund, he was unable to do so.
• Mingoa explained that he had mistakenly put the money in a large envelope, left
it on his seat, and it disappeared.
• Mingoa did not testify in court and presented no evidence in his favor.
• He was convicted of malversation of public funds in the Court of First Instance of
Romblon.
Issues:
• The main issue is whether Mingoa's conviction for malversation is justified based
on the evidence presented.
• Whether the legal presumption used in Mingoa's case, as provided in Article 217
of the Revised Penal Code, violates the constitutional right of the accused to be
presumed innocent until proven guilty.
Ruling:
• The court found that Mingoa's conviction was justified. His explanation of the
missing funds was deemed unbelievable, and his inability to produce the fund
gave rise to a presumption of guilt.
• The court rejected Mingoa's argument that he was convicted on mere
presumptions. The trial court did not believe his explanation and found it a cover
for actual misappropriation. The presumption of guilt based on the failure to
produce the missing funds was authorized by Article 217 of the Revised Penal
Code.
 • The court held that the legal provision did not violate the constitutional right of the
accused to be presumed innocent until proven guilty. This issue was not raised in
the lower court, and the court could not consider it for the first time on appeal.
• The court cited the view that there is no constitutional objection to laws providing
that the presumption of innocence may be overcome by contrary presumptions
based on the experience of human conduct. The presumption in Mingoa's case
was deemed reasonable and had a rational connection between the fact proved
(failure to produce funds) and the ultimate fact presumed (malversation).
• The statute in Mingoa's case created a prima facie presumption, giving the
accused an opportunity to present evidence to rebut it.
In summary, the court upheld Mingoa's conviction for malversation of public funds
based on the evidence presented and the legal presumption provided in Article 217 of
the Revised Penal Code. The court also rejected the argument that this legal provision
violated the constitutional right of the accused to be presumed innocent until proven
guilty.

Are corporate entities protected by the right?

Feeder Int'1 Line vs. CA, GR 94262 May 31, 1991
Facts:
• The case involves the petition to reverse a decision by the Court of Appeals,
which affirmed the decision of the Court of Tax Appeals regarding the forfeiture
of the vessel M/T "ULU WAI" and its cargo.
• M/T "ULU WAI" was a foreign vessel of Honduran registry, owned and operated
by Feeder International Shipping Lines of Singapore.
• The vessel carried 1,100 metric tons of gas oil and 1,000 metric tons of fuel oil
consigned to Far East Synergy Corporation of Zamboanga, Philippines.
• The vessel anchored at Guiuanon Island in Iloilo on May 14, 1986, without
notifying the Iloilo customs authorities.
• Customs authorities dispatched a team to investigate after learning of the
vessel's presence from a civilian informer.
 • The vessel did not have the required ship and shipping documents on board,
except for a clearance from the port authorities of Singapore clearing the vessel
for "Zamboanga."
• A Warrant of Seizure and Detention was issued, and forfeiture proceedings were
initiated.
• The vessel and its cargo were found guilty of violating sections of the Tariff and
Customs Code, and ordered to be forfeited.
Issues:
• Whether the Court of Appeals erred in finding that there was an illegal
importation or an attempt thereof that justifies the forfeiture of the vessel and its
cargo.
• Whether the petitioner was deprived of property without due process of law.
• Whether the sworn statements of certain individuals were taken without the
assistance of counsel, in violation of their constitutional rights.
Ruling:
• The Court upheld the findings of the Court of Appeals, which affirmed the
decisions of the Court of Tax Appeals. It concluded that substantial evidence
supported the assertion that there was an intent to unload the cargo in the
Philippines, justifying the forfeiture of the vessel and its cargo. The proceedings
were not criminal but rather civil and administrative in nature, and the proof
required was substantial evidence, not proof beyond reasonable doubt.
• The Court pointed out that a corporate entity like the petitioner had no personality
to invoke the right to be presumed innocent, as this right is available only to
individuals who are accused in criminal cases. Hence, the due process argument
was not applicable to the petitioner.
• The Court found that the testimonies of Deposa and Torres being given without
the assistance of counsel did not amount to a violation of their constitutional
rights. The need for the assistance of counsel is not considered indispensable in
non-criminal proceedings unless required by the Constitution or a specific law.
In conclusion, the Court denied the petition, affirming the judgment of the Court of
Appeals.

Right to Counsel
People v. Holgado, 85 Phil.752 (1950)
Facts:
 • Appellant Frisco Holgado was charged with slight illegal detention in the court of
First Instance of Romblon. The information stated that he had kidnapped and
detained one Artemia Fabreag, depriving her of her personal liberty.
• On May 8, 1948, during the trial, the court arraigned the accused. When asked
for his plea, Holgado pleaded guilty but qualified his plea by stating that he was
instructed by a certain Mr. Ocampo.
• The provincial fiscal was ordered to investigate Mr. Ocampo. The fiscal reported
that Ocampo had nothing to do with the case and found no evidence against him.
• Two days later, on May 10, 1948, the trial court rendered a judgment, finding the
accused guilty of the capital offense of "kidnapping and serious illegal detention."
Holgado was sentenced to ten years and one day of prision mayor to twenty
years.
• The trial court failed to inform the accused of his right to have an attorney, did not
ask him if he desired the aid of an attorney, and did not assign an attorney de
oficio to defend him. Holgado was unaided by counsel during the trial.
Issues:
• Whether the trial court's judgment was erroneous and based on a qualified plea
that required further investigation.
• Whether the trial court failed to follow the procedures outlined in Rule 112,
Section 3 of the Rules of Court, specifically in informing the accused of his right
to have an attorney and providing an attorney de oficio.
Ruling:
• The Court found that the judgment of the trial court was erroneous and based on
a qualified plea that warranted further investigation. The trial court found the
accused guilty of a capital offense without absolute evidence to clarify the facts of
the case.
• The Court emphasized that the trial court had not complied with its duties under
Rule 112, Section 3 of the Rules of Court. It had failed to inform the accused of
his right to have an attorney, ask him if he desired legal aid, assign an attorney
de oficio, or grant a reasonable time to procure an attorney. The question asked
by the court implied that Holgado should plead guilty if he had no attorney, which
was a violation of his right to a fair hearing under the due process clause.
The judgment of the trial court was reversed, and the case was remanded for a new
arraignment and trial after the accused was properly informed of his right to have and
be assisted by counsel.

Delgado v. CA, 145 SCRA 357 (1986)

Facts:
 • Emma R. Delgado, the petitioner, along with other individuals, was charged with
estafa through falsification of public and/or official documents, involving deceiving
an individual named Erlinda Rueda about arranging her travel to the United
States.
• During the trial, Emma Delgado was represented by her counsel de parte, Atty.
Lamberto G. Yco. On a particular trial date, Atty. Yco failed to appear and
requested a postponement due to alleged illness, but no medical certificate was
submitted. The trial court considered this motion dilatory and proceeded with the
trial, ultimately rendering a judgment of conviction.
• The judgment convicted Emma Delgado and others of estafa through falsification
of documents, sentencing them to an indeterminate penalty, a fine, and
indemnification to the offended party.
• Only Emma Delgado and one other individual, Celia Capistrano, appealed to the
Court of Appeals, raising the issue of whether the judgment should be
maintained based on the evidence and the law.
• The Court of Appeals affirmed the judgment for Emma Delgado and reversed it
for Celia Capistrano.
• An entry of final judgment was issued, and the records were remanded for
execution of the judgment.
• Emma Delgado filed an urgent motion to set aside the entry of judgment and
requested to personally receive a copy of the decision, claiming she was not
informed of it by her counsel on record. This motion was denied by the Court of
Appeals.
• A subsequent order from the Court of First Instance of Manila directed Emma
Delgado's arrest and the confiscation of her bond for failure to appear for the
execution of the judgment.
Issues:
• Whether Emma Delgado was deprived of her right to be represented by
competent counsel.
• Whether Emma Delgado is entitled to a new trial.
Ruling:
• The court ruled that Emma Delgado was indeed deprived of her right to be
represented by competent counsel. Her "lawyer," Atty. Lamberto G. Yco, was not
a member of the Philippine Bar. An accused person is entitled to be represented
by a member of the bar in a criminal case, and the absence of competent legal
representation could lead to inadequate defense and a denial of due process.
• Consequently, the judgment was set aside, and the case was remanded to the
trial court for a new trial, recognizing Emma Delgado's right to be represented by
a qualified attorney and ensuring a fair process.
People v. Baluyot, 75 SCRA 148 (1977) -- Improvident plea of guilt
Facts:
• The case involves the automatic review of a decision rendered on October 7,
1970, by the Circuit Criminal Court of the Fifth Judicial District in Malolos
Bulacan, presided over by Judge Abelardo M. Dayrit.
• The defendants, Miguel Baluyot y Dulay, Pablo Pinca y Narca, and Antonio
Balinjari y Naval (also known as Tony Baluyot), were convicted of the crime of
robbery with homicide.
• The accused were charged with robbing a taxi driver and causing his death on
August 6, 1970.
• The accused initially pleaded not guilty during their arraignment, but on October
7, 1970, they changed their plea to guilty without any explanation from the court
regarding the consequences.
Issues:
• Whether the trial court properly handled the accused's change of plea from not
guilty to guilty.
• Whether the trial court adequately explained the nature of the charges and the
aggravating circumstances to the accused.
• Whether the trial court conducted a reasonable examination to ensure that the
accused fully understood the implications of their plea of guilty.
Ruling:
The Supreme Court found that the trial court did not properly handle the accused's
change of plea. It failed to ensure that the accused fully understood the nature of the
charges, the meaning of the aggravating circumstances, and the consequences of their
plea of guilty. The trial court also did not inquire about the sudden change of plea. As a
result, the Supreme Court set aside the trial court's decision and remanded the case for
further proceedings, emphasizing the importance of complying with established
procedures in capital cases, where a plea of guilty is entered. The trial court's decision
was vacated, and the case was sent back for a fair and reasonable examination of the
accused's guilt and culpability, as well as a proper explanation of the charges and
consequences.

Libuit v. People, G.R. No.154363, September 13, 2005

Facts:
 • Joel P. Libuit filed a petition for review on certiorari to reverse the Court of
Appeals' Decision, which affirmed his conviction by the Regional Trial Court of
Lipa City, Branch 85, for estafa under Article 315 1(b) of the Revised Penal
Code.
• The Amended Information against the petitioner alleges that he unlawfully
misappropriated a car entrusted to him for repair, valued at P60,000. The
petitioner pleaded not guilty during arraignment.
Issues:
• Was there sufficient evidence to sustain the petitioner's conviction for estafa?
• Was the petitioner deprived of his constitutional right to counsel?
Ruling:
• The Court found that the evidence presented clearly established the elements of
estafa under Article 315 1(b), including the fact that the car was entrusted to the
petitioner's motor shop, which was under his responsibility, and the demand
made by the offended party for the return of the car. The Court affirmed the
conviction, stating that the petitioner's arguments merely rehashed those raised
in previous proceedings.
• The Court ruled that the trial court was not obligated to appoint a counsel de
oficio for the petitioner after his chosen counsel withdrew. The duty to appoint
counsel de oficio exists primarily at the time of arraignment. The petitioner had
already been represented by his counsel of choice during arraignment and the
subsequent trial. The trial court had granted postponements to the petitioner to
secure new counsel, but his new lawyer failed to appear without reason, leading
to the striking of his direct testimony. The Court found that the trial court's actions
were not tainted by grave abuse of discretion.
In summary, the Court denied the petition and affirmed the lower courts' decisions,
finding the petitioner guilty of estafa under Article 315 1(b) of the Revised Penal Code.

To be informed of the nature and cause of the charge, and to be heard

People v. Dy, G.R. 115236, January 29,2002

Facts:
That on or about the 12th day of January, 1994, in the City of Baguio, Philippines, and
within the jurisdiction of this Honorable Court, the above-named accused, actuated by
lust with lewd design and with deliberate intent to satisfy their lascivious desire,
conspiring, confederating and mutually aiding one another, did then and there willfully,
unlawfully and feloniously kiss her, fondle her breast, undress her and insert their fingers
into her vagina, who was then unconscious by reason of the drugs employed on her by
the accused, all against her will and without her consent, thereby inflicting upon the latter
moral shock, fright, humiliation, dishonor and besmirched reputation on the part of the
complainant and her family.
The two cases were tried jointly. Accused-appellants refused to be arraigned and enter a
plea; hence, a plea of "not guilty" was entered on their behalf.
Issues:
Was there a valid arraignment when the accused were not furnished a copy of the
complaint or information and the contents of the complaint or information was not
read in a dialect or language known to the accused?

Ruling:
Yes. The accused themselves refused to be informed of the nature and cause of the
accusation against them. The defense cannot hold hostage the court by their refusal to
the reading of the complaint or information. Indeed, the defense may waive their right to
enter a plea and let the court enter a plea of “guilty” in there behalf.
Accused-appellants were substantially informed of the nature and cause of the accusation
against them when their counsel received a copy of the Prosecutor’s resolution
maintaining the charge for rape and acts of lasciviousness. The failure to read the
complaint or information in a language or dialect known to them was essentially a
procedural infirmity that was deemed waived when after the arraignment, the defense
never brought up the supposed invalidity or defect thereof. Rather, accused-appellants
and their counsel vigorously and fully participated in the trial of the case.

Villareal v. People, GR 151258, 01 February 2012

Facts:
Accused Dizon filed a Rule 45 Petition for Review on Certiorari, questioning the CA’s
Decision dated 10 January 2002 and Resolution dated 30 August 2002 in CA-G.R. No.
15520.21 Petitioner sets forth two main issues – first, that he was denied due process
when the CA sustained the trial court’s forfeiture of his right to present evidence; and,
second, that he was deprived of due process when the CA did not apply to him the same
"ratio decidendi that served as basis of acquittal of the other accused."22
As regards the first issue, the trial court made a ruling, which forfeited Dizon’s right to
present evidence during trial. The trial court expected Dizon to present evidence on an
earlier date since a co-accused, Antonio General, no longer presented separate evidence
during trial. According to Dizon, his right should not have been considered as waived
because he was justified in asking for a postponement. He argues that he did not ask for
a resetting of any of the hearing dates and in fact insisted that he was ready to present
evidence on the original pre-assigned schedule, and not on an earlier hearing date.
Issues:
Whether the forfeiture of petitioner Dizon’s right to present evidence constitutes denial of
due process?
Ruling:
The right of the accused to present evidence is guaranteed by no less than the
Constitution itself.42 Article III, Section 14(2) thereof, provides that "in all criminal
prosecutions, the accused … shall enjoy the right to be heard by himself and counsel…"
This constitutional right includes the right to present evidence in one’s defense, 43 as well
as the right to be present and defend oneself in person at every stage of the proceedings.
Clearly, the waiver of the right to present evidence in a criminal case involving a grave
penalty is not assumed and taken lightly. The presence of the accused and his counsel
is indispensable so that the court could personally conduct a searching inquiry into the
waive.
The trial court should not have deemed the failure of the petitioner to present evidence
on 25 August 1993 as a waiver of his right to present evidence. On the contrary, it should
have considered the excuse of counsel justified, especially since counsel for another
accused – General – had made a last-minute adoption of testimonial evidence that freed
up the succeeding trial dates; and since Dizon was not scheduled to testify until two weeks
later. At any rate, the trial court pre-assigned five hearing dates for the reception of
evidence. If it really wanted to impose its Order strictly, the most it could have done was
to forfeit one out of the five days set for Dizon’s testimonial evidence. Stripping the
accused of all his pre-assigned trial dates constitutes a patent denial of the constitutionally
guaranteed right to due process.

Ivler v. Judge Modesto San Pedro, GR 172716, 17 November 2010

Facts:
Following a vehicular collision in August 2004, petitioner Jason Ivler (petitioner) was
charged before the Metropolitan Trial Court of Pasig City, Branch 71 (MeTC), with two
separate offenses: (1) Reckless Imprudence Resulting in Slight Physical Injuries (Criminal
Case No. 82367) for injuries sustained by respondent Evangeline L. Ponce (respondent
Ponce); and (2) Reckless Imprudence Resulting in Homicide and Damage to Property
(Criminal Case No. 82366) for the death of respondent Ponce’s husband Nestor C. Ponce
and damage to the spouses Ponce’s vehicle. Petitioner posted bail for his temporary
release in both cases.
On 7 September 2004, petitioner pleaded guilty to the charge in Criminal Case No. 82367
and was meted out the penalty of public censure. Invoking this conviction, petitioner
moved to quash the Information in Criminal Case No. 82366 for placing him in jeopardy
of second punishment for the same offense of reckless imprudence.
The MeTC refused quashal, finding no identity of offenses in the two cases.3
After unsuccessfully seeking reconsideration, petitioner elevated the matter to the
Regional Trial Court of Pasig City, Branch 157 (RTC), in a petition for certiorari (S.C.A.
No. 2803). Meanwhile, petitioner sought from the MeTC the suspension of proceedings
in Criminal Case No. 82366, including the arraignment on 17 May 2005, invoking S.C.A.
No. 2803 as a prejudicial question. Without acting on petitioner’s motion, the MeTC
proceeded with the arraignment and, because of petitioner’s absence, cancelled his bail
and ordered his arrest.4 Seven days later, the MeTC issued a resolution denying
petitioner’s motion to suspend proceedings and postponing his arraignment until after his
arrest.
In an Order dated 2 February 2006, the RTC dismissed S.C.A. No. 2803, narrowly
grounding its ruling on petitioner’s forfeiture of standing to maintain S.C.A. No. 2803
arising from the MeTC’s order to arrest petitioner for his non-appearance at the
arraignment in Criminal Case No. 82366. Thus, without reaching the merits of S.C.A. No.
2803, the RTC effectively affirmed the MeTC. Petitioner sought reconsideration but this
proved unavailing.
Issue:
whether petitioner forfeited his standing to seek relief in S.C.A. 2803 when the MeTC
ordered his arrest following his non-appearance at the arraignment in Criminal Case No.
82366?

Ruling:
Dismissals of appeals grounded on the appellant’s escape from custody or violation of
the terms of his bail bond are governed by the second paragraph of Section 8, Rule
124,8 in relation to Section 1, Rule 125, of the Revised Rules on Criminal Procedure
authorizing this Court or the Court of Appeals to "also, upon motion of the appellee or
motu proprio, dismiss the appeal if the appellant escapes from prison or confinement,
jumps bail or flees to a foreign country during the pendency of the appeal." The "appeal"
contemplated in Section 8 of Rule 124 is a suit to review judgments of convictions.
The mischief in the RTC’s treatment of petitioner’s non-appearance at his arraignment in
Criminal Case No. 82366 as proof of his loss of standing becomes more evident when
one considers the Rules of Court’s treatment of a defendant who absents himself from
post-arraignment hearings. Under Section 21, Rule 11411 of the Revised Rules of Criminal
Procedure, the defendant’s absence merely renders his bondsman potentially liable on
its bond (subject to cancellation should the bondsman fail to produce the accused within
30 days); the defendant retains his standing and, should he fail to surrender, will be tried
in absentia and could be convicted or acquitted. Indeed, the 30-day period granted to the
bondsman to produce the accused underscores the fact that mere non-appearance does
not ipso facto convert the accused’s status to that of a fugitive without standing.
Further, the RTC’s observation that petitioner provided "no explanation why he failed to
attend the scheduled proceeding"12 at the MeTC is belied by the records. Days before the
arraignment, petitioner sought the suspension of the MeTC’s proceedings in Criminal
Case No. 82366 in light of his petition with the RTC in S.C.A. No. 2803. Following the
MeTC’s refusal to defer arraignment (the order for which was released days after the
MeTC ordered petitioner’s arrest), petitioner sought reconsideration. His motion remained
unresolved as of the filing of this petition.

To secure, confront witnesses, and be present during trial

U.S. v. Javier, 37 Phil. 449 (1918)
Facts:
• On the afternoon of October 22, 1915, Doroteo Natividad fastened his carabao in
his corral, valued at P150, in the barrio of Trapiche, Tanauan, Province of
Batangas.
• The next morning, Natividad discovered that the gate to the corral was open, and
the carabao had disappeared.
• Natividad reported the theft to the Constabulary.
• On November 20, 1915, a Constabulary patrol, led by Sergeant Presa (now
deceased), encountered accused Lazaro Javier, Apolinario Mendoza, and Placido
de Chavez leading the stolen carabao. When they saw the Constabulary, the
accused scattered.
• The following day, the Constabulary found the stolen carabao tied in front of the
house of Pedro Monterola in the barrio of Santa Clara, San Pablo. Natividad
identified the carabao as the one taken from his corral, and the Constabulary
confirmed that it was the same carabao seen in the possession of the accused.
Issues:
• The admissibility of Exhibit B, the sworn statement of Sergeant Presa (now
deceased), as evidence.
• Whether the accused are entitled to the protection of the Bill of Rights concerning
confrontation and cross-examination.
Ruling: The Supreme Court ruled as follows:
• Exhibit B, the sworn statement of Sergeant Presa, was improperly received in
evidence. It did not meet the requirements of confrontation and cross-examination
as mandated by the Bill of Rights.
• While the Bill of Rights protects the right to confrontation and cross-examination,
there are exceptions. In this case, the statement of Presa did not fall under any
 exception, and there was no opportunity for the defense to cross-examine the
witness. However, despite the improper admission of Exhibit B, the Court found
that the testimony of the carabao owner and the two Constabulary soldiers, which
was unrebutted by the accused, was sufficient to prove their guilt beyond a
reasonable doubt. As a result, the defendants and appellants were each sentenced
to four years, two months, and one day of presidio correccional, with the accessory
penalties provided by law, and were ordered to pay one-third part of the costs of
both instances. The stolen carabao was to be returned to Doroteo Natividad if it
had not already been done.

People v. de Luna, 174 SCRA 204 (1989)

Facts:
• Defendant-appellant Patrick de Luna was charged with Murder based on an
information that alleged he intentionally killed a person named Tricia, with
treachery and evident premeditation.
• During his arraignment on December 23, 1986, Patrick de Luna entered a plea of
guilty with the qualification that "hindi ko sinasadya" (I did not do it intentionally).
• At the arraignment, the defendant repeatedly emphasized that he did not commit
the crime intentionally, and he claimed he was drunk at the time of the incident.
• Despite the plea of guilty, the court conducted a hearing, accepted the plea, and
convicted Patrick de Luna of Murder, sentencing him to Reclusion Perpetua (life
imprisonment) and ordering him to indemnify the victim's heirs.
Issues:
• Whether the defendant-appellant's plea of guilty was valid, considering his
repeated qualification that he did not commit the crime intentionally.
• Whether the trial court should have required the prosecution to present evidence
to determine the proper penalty after a plea of guilty to a capital offense.
Ruling:
• The plea of guilty was not valid because of the repeated qualification that Patrick
de Luna did not commit the crime intentionally. The qualification raised questions
about his understanding of the charges against him, and it indicated that he may
not have fully comprehended the consequences of his plea. The plea was not
unconditional, and the court should have recognized this and inquired further.
• After a plea of guilty to a capital offense, the trial court is mandated to conduct a
searching inquiry into the voluntariness and full comprehension of the
consequences of the plea. Additionally, the court should require the prosecution to
present evidence to prove the guilt of the accused and the precise degree of
culpability. This procedure is mandatory, and even if the accused waives the
presentation of evidence, the court must still require the presentation of evidence
for a better determination of the case. The trial court should have followed this
 procedure, and therefore, the decision is set aside, and the case is remanded for
a new arraignment and further proceedings.

When presence of accused mandatory - Rule 116, Sec. 1, Rule 120, Sec. 6
Aquino v. Military Commission No. 63 SCRA 546 (1975)
Facts:
• Following the proclamation of martial law in the Philippines, petitioner Ninoy
Aquino was arrested on September 23, 1972, for his alleged involvement in a
conspiracy to seize political and state power.
• Ninoy Aquino challenged the legality of martial law and his arrest through a habeas
corpus petition, but the Supreme Court dismissed the petition on September 17,
1974, upholding the validity of martial law and the petitioner's detention.
• In a separate case, Ninoy Aquino faced charges before Military Commission No.
2, challenging its jurisdiction over allegations of illegal possession of firearms,
violation of the Anti-Subversion Act, and murder.
• A Special Committee was created to reinvestigate the charges, but it faced
challenges in functioning effectively.
• Various legal filings, including supplemental petitions and motions, were made,
leading to a hearing on April 14, 1975.
• During the military commission proceedings, Argel refused to participate,
questioning the fairness of the trial and discharging his defense counsel.
Issue: Whether Ninoy Aquino could waive his right to be present during the proceedings
before Military Commission No. 2, particularly during the perpetuation of testimony, given
the constitutional and legal considerations surrounding the accused's presence at trial.
Ruling: The Supreme Court considered the conflicting authorities on whether an accused
can waive the right to be present at trial. Citing People v. Avanceña and constitutional
provisions, the Court acknowledged that an accused in a felony trial has the right to be
present at every stage, and this right is indispensable and cannot be waived in capital
offenses. However, for non-capital offenses and when the accused is not in custody, the
Court allowed waiver for specific stages such as arraignment, guilty plea, and
pronouncement of judgment.
In the specific context of military commission proceedings, the Court held that the
petitioner, Ninoy Aquino, could waive his right to be present during the perpetuation of
testimony, as it was not against public policy and was consistent with the constitutional
provisions. The Court acknowledged the modern trend favoring the doctrine that a party
in a criminal case may waive rights, and since the Constitution allows trial in absentia, the
petitioner's right to be present during perpetuation proceedings could be waived.
The ruling, however, modified the respondent Military Commission No. 2's order, always
requiring Ninoy Aquino's presence, to only require his presence when he needed to be
identified. The Court emphasized that military tribunals, despite differences, were bound
by fundamental rules of law and principles of justice observed in civil judicature.
As a result, the Court's decision allowed for the waiver of the petitioner's presence during
specific stages of the military commission proceedings.

People v. Salas, 143 SCRA 163 (1986) Exception: Light offenses

Facts:
• Mario Abong was originally charged with homicide in the Court of First Instance of
Cebu.
• The case underwent a reinvestigation upon the motion of the prosecution, resulting
in the filing of an amended information with no recommended bail.
• During the trial, Mario Abong managed to deceive the city court of Cebu into
granting him bail based on the original information for homicide, and he was
released.
• Upon learning of the deception, the respondent judge cancelled the illegal bail
bond and ordered Abong's re-arrest.
• The prosecution moved to continue the trial in absentia in accordance with the
constitutional provision allowing it.
• The respondent judge denied the motion and suspended all proceedings until the
accused's return.
Issues:
• Whether the trial in absentia should be allowed, as per the constitutional provision
under Article IV, Section 19 of the 1973 Constitution.
• Whether Mario Abong's escape constitutes a waiver of the right to be present at
his trial and an unjustified failure to appear.
Ruling: The trial in absentia should be allowed. The escape of the accused, Mario Abong,
effectively operates as a waiver of his right to be present at his trial, as provided for in
Article IV, Section 19 of the 1973 Constitution. His escape and subsequent failure to
appear are legally unjustified. The trial judge should proceed with the trial in absentia as
long as Abong has not reappeared, until the case is terminated.
The respondent judge's refusal to conduct the trial in absentia was based on a too-literal
reading of the law. The intention of the law is to speed up the disposition of criminal cases
and not to allow the escape of a defendant to thwart the prosecution. Mario Abong should
bear the consequences of his escape, including a possible conviction. The trial judge is
also directed to investigate the lawyer who assisted Abong in securing bail on the basis
of the withdrawn information for homicide.
Trial in absentia (See Rule 115, Sec. 1 (c) Rules of Court)

People v. Court of Appeals, G.R. No.140285, September 27, 2006

Facts:
• The case involves a petition for review on certiorari, assailing a Court of Appeals
Resolution dated September 20, 1999, in a case entitled "Wilfred N. Chiok,
petitioner, v. Hon. Marietta Legazpi, People of the Philippines, and Rufina Chua,
respondents."
• Rufina Chua met Wilfred Chiok in 1989, who represented himself as a licensed
stockbroker. Chiok encouraged Chua to invest her money in stocks and acted as
her stockbroker.
• In 1995, Chua entrusted Chiok with an amount of P9,563,900.00 for the purpose
of buying stocks. Chiok delayed the investment, and when Chua demanded
payment, he admitted to spending the money. Two checks issued by Chiok
bounced.
• An estafa case was filed against Chiok, and he was arraigned, pleading not guilty.
• During the promulgation of judgment, Chiok and his counsel failed to appear, and
the trial court set the promulgation for a later date.
• The trial court eventually canceled Chiok's bail for non-appearance and issued a
warrant of arrest.
• Chiok filed an appeal and a separate petition for certiorari with the Court of Appeals
to prevent his arrest.
Issues: Whether the Court of Appeals erred when it issued a writ of preliminary injunction
enjoining the arrest of Chiok.
Ruling: The Court of Appeals erred when it issued a writ of preliminary injunction enjoining
the arrest of Chiok. The trial court had correctly canceled Chiok's bail due to his failure to
appear during the promulgation of judgment. Chiok's non-appearance violated the
conditions of his bail, and he effectively jumped bail. As a result, his arrest was proper,
as provided by the Revised Rules on Criminal Procedure. The Court of Appeals'
declaration that Chiok might flee or commit another crime was unsubstantiated and
lacked merit. The instant petition is granted, and the Court of Appeals' Resolution is
reversed. Chiok's arrest is authorized.

Against Self-incrimination
People v. Ayson, GR 85215, July 7, 1989
Facts:
• Felipe Ramos, a ticket freight clerk of Philippine Airlines (PAL), was involved in
irregularities in the sales of plane tickets.
 • PAL scheduled an investigation into the matter, as per their Code of Conduct and
Collective Bargaining Agreement.
• A day before the investigation, Ramos voluntarily provided a handwritten note
stating his willingness to settle the irregularities subject to certain conditions.
• During the investigation conducted by the PAL Branch Manager, Ramos was
informed of the findings of an audit team. He provided answers to questions
without compulsion.
• Ramos was later charged with estafa for allegedly misappropriating ticket
proceeds.
• The prosecution offered evidence in the form of Ramos's statement and
handwritten admission.
• The defendant's attorneys objected to these exhibits, arguing that they were
obtained without counsel present.
Issues:
• Whether Ramos's rights under Section 20, Article III of the Constitution were
violated during the investigation.
• Whether the evidence obtained during the investigation, including Ramos's
statement and handwritten admission, should be admissible in court.
Ruling: The court made several key rulings:
• The rights of an individual not to "be compelled to be a witness against himself"
and the rights of a person "under investigation for the commission of an offense"
are distinct rights. The former applies to anyone providing evidence in any
proceeding, while the latter pertains to individuals under custodial interrogation.
• The right against self-incrimination does not obligate the judge or the witness to
advise a witness of this right. It can be claimed when an incriminatory question is
actually asked, and it may be waived, expressly or impliedly.
• Rights during custodial interrogation apply to suspects under investigation by the
police after being taken into custody or deprived of their freedom of action.
• The defendant in a criminal case has the right to refuse to be a witness, may testify
in their own behalf, and can refuse to answer specific questions that may
incriminate them for a different and distinct offense.
• Ramos was not under custodial interrogation during the administrative
investigation, and his constitutional rights related to custodial investigations did not
apply.
• Admissions or statements made by an employee during an administrative
investigation for the purpose of explaining their side cannot be rejected because
"Miranda rights" were not accorded to them.
In conclusion, the court ruled that the evidence, including Ramos's statement and
handwritten admission, should be admissible in court, and the orders of the respondent
judge were annulled and set aside. The judge's confusion in equating distinct rights under
Section 20, Article IV of the 1973 Constitution led to a grave abuse of discretion.
Senate v. Ermita, GR 169777, Apr. 20, 2006
Senate vs. Ermita (2006) – LAW I.Q. (wordpress.com)

Speedy, Impartial, Public Trials

Conde v. Rivera, 45 Phil.650 (1924)
Facts:
• Aurelia Conde, a former municipal midwife in Lucena, Tayabas, was charged with
various crimes and misdemeanors, resulting in her being required to attend
multiple hearings.
• Her case was marked by numerous postponements, resulting in delays exceeding
one year since the filing of the first information against her.
• Conde has been seeking redress for these delays, as they violate her right to a
speedy trial.
Issues:
• Whether Aurelia Conde's right to a speedy trial has been violated due to multiple
and arbitrary postponements.
• Whether she is entitled to legal relief in the form of a proceeding in mandamus or
habeas corpus to compel the dismissal of the information or secure her freedom.
Ruling: The court ruled in favor of Aurelia Conde. It established the legal principle that
when a prosecuting officer secures postponements of a defendant's trial without good
cause, exceeding a reasonable period, and against the defendant's protest, the accused
is entitled to relief. The court granted the writ of mandamus, which compelled the
Provincial Fiscal of Tayabas to dismiss the pending charges against Conde. The court
also ordered the charges before the justice of the peace of Lucena, Tayabas, to be
dismissed. The costs were imposed on the respondent fiscal, and the Attorney-General
was urged to take administrative action to prevent similar incidents in the future.

Flores v. People 61 SCRA 331

Facts:
• The petitioners, Francisco Flores and Francisco Angel, were accused of robbery,
with the accusation filed on December 31, 1951.
• The decision finding them guilty of the crime was rendered on November 29, 1955,
and the notice of appeal was filed on December 8, 1955.
• Over the course of several years, there were significant delays and inaction by the
Court of Appeals in their case, including remanding the case for a rehearing,
amending a resolution, and a lack of progress in the lower court.
 • The accused invoked their constitutional right to a speedy trial due to the long
delays in their case, which covered almost a decade, from December 8, 1955, to
May 10, 1965.
• The Court of Appeals did not respond to their plea, and various motions were
denied.
Issues:
• Whether the accused's constitutional right to a speedy trial has been violated.
• Whether the procedural defect regarding the party respondent, the Court of
Appeals, affects the validity of the plea.
Ruling: The court ruled in favor of the petitioners, stating that their constitutional right to
a speedy trial was violated. The court emphasized that this right means a trial that is "free
from vexatious, capricious, and oppressive delays." The delay was inordinate and
unjustified, thus infringing on the accused's rights.
The court clarified that the technical procedural defect, regarding the party respondent,
does not diminish the significance of the constitutional right to a speedy trial. The court
concluded that the denial of the remedy sought would exalt form over substance and that
the reality of the situation should be taken into account.
As a result, the court granted the petition for certiorari, set aside the orders of the Court
of Appeals, and ordered the dismissal of the criminal case against the petitioners. Costs
were to be borne by the government.

In re Petition for Coverage of the Ampatuan Cases, AM No.10-5-5-SC/AM No.10-11- 1-

SC/AM No.10-11-7-SC,14 June 2011
Facts:
• On November 23, 2009, 57 people, including 32 journalists and media
practitioners, were killed while on their way to Shariff Aguak in Maguindanao. This
incident, known as the Maguindanao Massacre, was one of the worst election-
related violence cases and the most brutal killing of journalists in recent history.
• The Maguindanao Massacre led to charges for 57 counts of murder and an
additional charge of rebellion against 197 accused individuals.
• Various parties, including the National Union of Journalists of the Philippines
(NUJP), media companies, relatives of the victims, individual journalists, and
members of the academe, filed petitions before the Court. They sought permission
for live television and radio coverage of the trial, the use of recording devices inside
the courtroom to assist journalists, and the formulation of reasonable guidelines
for broadcast coverage and device use.
• President Benigno S. Aquino III expressed support for these petitions,
emphasizing the need for a fair and humane approach.
Issues:
 • Whether live television and radio coverage of the trial in the Maguindanao
Massacre cases should be allowed.
• Whether recording devices (e.g., still cameras, tape recorders) should be permitted
inside the courtroom.
• Whether guidelines should be formulated to govern the broadcast coverage and
the use of devices.
Ruling: The Court partially granted the requests for live broadcast by television and radio
of the trial court proceedings of the Maguindanao Massacre cases. However, this grant
was subject to specific guidelines outlined in the decision. The Court acknowledged the
need to balance the rights of the accused, the principles of due process, and the rights to
freedom of the press, information, and public access to courts. The guidelines were
intended to ensure a transparent, open, and public trial while also preserving the dignity
and solemnity of judicial proceedings.
The guidelines include provisions for the installation of cameras inside the courtroom, the
application and approval process for media entities wishing to broadcast the proceedings,
continuous and uninterrupted broadcasting, restrictions on commercial breaks, and the
prohibition of repeat airings of the audio-visual recording until after the finality of judgment.
Additionally, the original audio recording was to be deposited for preservation and
exhibition, and a special committee was to be created to study and recommend
appropriate arrangements and administrative matters related to live broadcast.

In summary, the ruling partially allowed live television and radio coverage of the trial in
the Maguindanao Massacre cases, subject to a set of specific guidelines to address the
concerns raised by the involved parties and to balance the competing rights and interests
involved.

• Speedy Trials: The case involved a significant delay between the commission of
the crime (Maguindanao Massacre in 2009) and the legal proceedings, which
began almost a year later. This delay was mentioned in the context of
accommodating all interested parties, given the large number of accused and
victims' families. Despite the delay, the court aimed to balance the right to a speedy
trial with the need to accommodate all parties. The guidelines for live broadcast
and the creation of a special committee were designed to streamline the trial
process and ensure that justice was served without unnecessary delays.
• Impartial Trials: The ruling recognized the importance of preserving the
impartiality of the trial process. While addressing the need for public access and
transparency, the court was concerned about the potential influence of media
coverage on judges, counsels, and witnesses. It emphasized that any prejudice
resulting from media coverage must be proven, and the accused had legal
remedies available to challenge any potential bias. The guidelines aimed to
minimize the influence of media coverage on the trial's impartiality, such as
 restrictions on commentary during broadcasts and measures to protect the rights
of the accused.
• Public Trials: The ruling acknowledged the impossibility of accommodating all
interested parties inside the courtroom, considering the large number of victims'
families and accused individuals. The court recognized that technology could
provide a solution to ensure that the trials remained public, as required by law. The
guidelines included provisions for broadcasting the proceedings, making them
accessible to the public through live television and radio coverage while protecting
the dignity and solemnity of the proceedings.
In summary, the court's ruling aimed to balance the principles of speedy, impartial, and
public trials by allowing live broadcasts of the trial proceedings, provided specific
guidelines were followed to ensure that these principles were upheld. This approach
sought to leverage technology to make the trial more accessible to the public while
preserving the integrity of the legal process.

Garcia v. Domingo, 52 SCRA 143 (1970)

Facts:
• This case involves a petition for certiorari and prohibition.
• The central issue pertains to the constitutional right to a public trial.
• The respondents are accused individuals, including policemen, who faced eight
criminal cases.
• The trial was conducted in the air-conditioned chambers of the city court judge for
the convenience of the parties, and 14 hearings took place without objections.
• Respondent Judge issued an order declaring that the right to a public trial was
violated due to the trial being held in chambers, resulting in the postponement of
the promulgation of the judgment.
• The accused and their counsel did not object to the mode of trial until the 14
hearings were completed.
• Respondent Judge based his order on the alleged abdication by an assistant fiscal
of control over the prosecution.
Issue: The main issue before the court is the interpretation of the constitutional right to a
public trial. Specifically, the court must determine whether conducting the trial inside the
chambers of the city court judge violates this guarantee.
Ruling: The court ruled in favor of the petitioner (city court judge) and granted the petition
for certiorari and prohibition.
• The Constitution explicitly guarantees the right to a public trial for an accused.
• The term "public trial" means that anyone interested in observing the proceedings
in the courtroom may do so, without restrictions based on their relationship to the
parties.
• The fact that the trial took place in the judge's chambers did not necessarily violate
the right to a public trial, as long as the public was not excluded.
 • The size of the room or other logistical considerations do not automatically
constitute a violation of the right to a public trial.
• The absence of objections from the accused and their counsel during the 14
hearings held in chambers, as well as their active participation in the proceedings,
suggests a waiver of their right to object to the trial format.
• The concern for the reality of a public trial is legitimate, but the nature of municipal
or city courts and the presence of the public usually make it more likely for the trial
to be truly public.
• The ruling nullified the order of respondent Judge, Felix Domingo, dated November
29, 1968, for being issued with grave abuse of discretion.
• The writ of prohibition was granted, directing the respondent Judge or any acting
in his place to refrain from further action in the criminal case other than its
dismissal.
• The preliminary writ of injunction against the actions of the respondent Judge was
made permanent.
The court's decision was in favor of upholding the concept of a public trial and dismissed
the objections raised based on the trial taking place in the judge's chambers.
Note: The case you provided appears to be an actual legal case, but it does not contain
the names of the parties involved. The case and its ruling were presented in a
"hypothetical" or anonymized manner.

Soriano v. Angeles, G.R. No. 109920.August 31,2000

In this case, the petition for certiorari seeks to annul the decision of the Regional Trial
Court, Branch 121, Caloocan City, which acquitted the private respondent, Ruel Garcia,
of direct assault. Let's break down the facts, issues, and ruling:
Facts:
• The incident took place on November 7, 1991. Private respondent Ruel Garcia and
his uncle, Pedro Garcia, were members of the Caloocan police.
• They entered the barangay hall of Barangay 56, Zone 5 in Caloocan City, looking
for petitioner Ceferino A. Soriano, the barangay captain.
• Private respondent allegedly assaulted petitioner by giving him fist blows on the
face while holding a gun and cursing him.
• Four barangay tanods were present but couldn't come to petitioner's aid because
they were held at bay by Pedro Garcia.
• Private respondent and his companions left after the incident, and petitioner was
treated for his injuries in the hospital.
Issues:
• Whether the decision acquitting private respondent was rendered by an impartial
tribunal.
 • Whether respondent judge showed bias and partiality in her conduct during the
trial.
• Whether the petition should be dismissed because it was filed without the
intervention of the Office of the Solicitor General (OSG).
Ruling: The ruling of the court was to dismiss the petition for certiorari, finding that it
lacked merit.
• The court stated that the mere suspicion of bias on the part of the judge is not
sufficient to prove bias and prejudice. There must be actual evidence to show that
the judge was partial. In this case, there was no evidence presented to prove that
the judge was biased for the defense. She had no prior personal acquaintance with
petitioner.
• The court explained that the judge's efforts to have the parties settle the case
amicably were not evidence of partiality for the private respondent. These efforts
could have been motivated by other reasons, such as clearing the court docket or
promoting peace in the community.
• While there was an error in the judge's exclusion of certain evidence, it did not
amount to bias or partiality. The judge still considered the testimonies of the
excluded witnesses in her decision.
• The court concluded that there was no grave abuse of discretion in the judge's
decision. The judge evaluated the evidence presented by both the prosecution and
the defense and based her decision on her appreciation of the credibility of the
witnesses. The court emphasized that a writ of certiorari cannot be used to correct
a lower tribunal's evaluation of the evidence and factual findings.
In summary, the court ruled in favor of the acquittal of the private respondent and
dismissed the petition for certiorari. The petition did not provide sufficient evidence of
bias, partiality, or grave abuse of discretion on the part of the judge.

Duterte v. Sandiganbayan, 289 SCRA 721 (1998)

Duterte v. Sandiganbayan | All Things Legal And Fun (wordpress.com)

Double Jeopardy
Melo v. People, 85 Phil.766 (1959)
Melo vs. People G.R. No. L-3580, March 22, 1950 85 Phil. 766 (1959) (adrianantazo.com)
People v. Judge Vergara, 221 SCRA 560 (1993)
People vs. Judge Vergara G.R. Nos. 101557-58. April 28, 1993. 221 SCRA 560 (1993)
(adrianantazo.com)
Tupaz v. Ulep, GR.No.127777, October 1,1999
Tupaz v. Ulep G.R. No. 127777, October 1, 1999 (adrianantazo.com)

Argel v. Judge Pascua, A.M. No. RTJ-94-1131, August 20,2001

Facts:
• This is an administrative complaint filed by Miguel Argel against Judge Herminia
M. Pascua, RTC-Br. 25, Vigan, Ilocos Sur.
• Complainant alleged that the respondent judge rendered a Decision dated August
19, 1993, in Crim. Case No. 2999-V, convicting him of murder even though he had
been previously acquitted by the same judge in her Decision dated July 22, 1993.
• The complainant contended that the judge's actions constituted gross ignorance
of the law and violated his constitutional right against double jeopardy.
Issues:
• Whether the respondent judge's actions constituted gross ignorance of the law.
• Whether the judge's actions violated the complainant's constitutional right against
double jeopardy.
Ruling: The court ruled that the respondent judge displayed gross ignorance of the law,
and her actions violated the complainant's constitutional right against double jeopardy.
• The respondent judge's actions in "revising" a final and immutable decision of
acquittal constituted gross ignorance of the law. A final decision, especially in a
criminal case, cannot be amended, recalled, or withdrawn unless it falls under
specific exceptions. The respondent judge's belief that she could revise her
decision was erroneous and constituted a fundamental misunderstanding of the
law.
• The court emphasized that once a judgment of acquittal in a criminal case is
promulgated, it becomes immediately final and immutable. The respondent judge's
attempt to revisit and revise her decision was a clear violation of the principle of
double jeopardy, which protects individuals from being tried twice for the same
offense.
In addition, the court also noted the respondent judge's negligence in the preparation of
her decision, highlighting the importance of judges taking their own notes during hearings
to avoid critical omissions.
As a result, the respondent judge was fined P20,000 for gross ignorance of the law. This
fine was to be deducted from her retirement benefits, as she had already compulsorily
retired by the time of the decision. The remaining retirement benefits were ordered to be
released to her.

Galman v Sandiganbayan,144 SCRA 43 (1986)

The Case Station: Galman vs. Sandiganbayan, 144 SCRA 43 (1986)

Facts: The case involves the assassination of former Senator Benigno "Ninoy" Aquino,
Jr. Upon landing at the Manila International Airport, Ninoy was killed by a gunman later
identified as Rolando Galman. Military investigators quickly claimed that Galman was a
communist-hired assassin and was subsequently shot by military escorts. Due to public
demand for the truth, a Fact Finding Board was created to investigate.
The majority and minority reports of the Fact Finding Board rejected the military version,
asserting that Ninoy's assassination resulted from a military conspiracy. President Marcos
insisted that Galman was the killer. Petitioners sought a Temporary Restraining Order
(TRO) to prevent the Sandiganbayan from rendering a decision. The Court initially issued
a TRO but later dismissed the petition.
The Sandiganbayan ultimately acquitted all the accused, prompting petitioners to file a
motion for reconsideration, alleging serious irregularities, mistrial, and a violation of
constitutional rights. Tanodbayan Manuel Herrera revealed that Marcos had ordered a
whitewash of the case.
Issues:
• Whether petitioner was deprived of his rights as an accused.
• Whether there was a violation of the double jeopardy clause.
Ruling: The Court granted petitioners' second motion for reconsideration, ordering a
retrial due to serious irregularities, mistrial, and a violation of constitutional rights. Deputy
Tanodbayan Herrera exposed that the Sandiganbayan Justices and Tanodbayan
prosecutors were ordered by Marcos to whitewash the case. The Court found a scripted
and predetermined handling of the case from Malacañang Palace, leading to a verdict of
total absolution.
There was no double jeopardy since the Sandiganbayan's resolution of acquittal was
deemed a void judgment issued without jurisdiction. A void judgment has no legal effect,
does not bind anyone, and does not result in double jeopardy. The cases were ordered
to be retried before an impartial court with an unbiased prosecutor, ensuring due process.
The Court criticized the misuse of government resources and authoritarian powers to
corrupt the judicial process, emphasizing that an impartial court is essential for due
process. The declaration of nullity of the proceedings required a new trial with proper
adherence to the principles of justice and fairness.

People v. Judge Santiago, 174 SCRA 143 (1989)

Facts: The case involves the acquittal of Dominador Ong for the violation of Presidential
Decree No. 115 (Trust Receipts Law) and Article 315(1)(b) of the Revised Penal Code.
Ong, as Treasurer of Sun Ray Metal, Inc., was charged with willfully defrauding
Metropolitan Bank and Trust Company by misappropriating goods received under trust
receipts.
Issues:
• Whether the private respondent was duly authorized to represent Sun Ray Metal,
Inc.
• Whether the restructuring agreement effectively novated the obligation under the
trust receipts.
• Whether the petition for certiorari places the private respondent in double jeopardy.
Ruling: The Regional Trial Court acquitted Ong, finding that he lacked authority to
represent Sun Ray Metal, Inc., and that the restructuring agreement novated the trust
receipts' obligation. The petitioner (Metropolitan Bank and Trust Company) sought
certiorari, alleging grave abuse of discretion.
The court ruled that the cases cited by the petitioner were not applicable to the situation.
The exception to the double jeopardy rule applies only when the trial court commits grave
abuse of discretion, violating due process, or conducting a sham trial. The court
emphasized that there was no denial of due process, and the trial court allowed
exhaustive presentation of evidence from both parties.
The court rejected the petitioner's argument that the private respondent's acquittal could
be challenged without violating double jeopardy, as the petition sought nullification of the
judgment. The court cited People v. Santiago, emphasizing that the private complainant's
role is limited to the civil aspect after an acquittal.
In conclusion, the petition was dismissed for lack of merit and legal personality on the part
of the petitioner to appeal the criminal aspect of the case. The court affirmed the trial
court's ruling on the acquittal of Dominador Ong.

People v. Relova, 148 SCRA 292 (1987)

In this petition for certiorari and mandamus, People of the Philippines seeks to set aside
the orders of Respondent Judge Hon. Relova quashing an information for theft filed
against Mr. Opulencia on the ground of double jeopardy and denying the petitioner’s
motion for reconsideration.. On Feb.1 1975, Batangas police together with personnel of
Batangas Electric Light System, equipped with a search warrant issued by a city judge of
Batangas to search and examine the premises of the Opulencia Carpena Ice Plant owned
by one Manuel Opulencia. They discovered electric wiring devices have been installed
without authority from the city government and architecturally concealed inside the walls
of the building. Said devices are designed purposely to lower or decrease the readings of
electric current consumption in the plant’s electric meter. The case was dismissed on the
ground of prescription for the complaint was filed nine months prior to discovery when it
should be 2months prior to discovery that the act being a light felony and prescribed the
right to file in court. On Nov 24, 1975, another case was filed against Mr. Opulencia by
the Assistant City Fiscal of Batangas for a violation of a Batangas Ordinance regarding
unauthorized electrical installations with resulting damage and prejudice to City of
Batangas in the amount of P41,062.16. Before arraignment, Opulencia filed a motion to
quash on the ground of double jeopardy. The Assistant fiscal’s claim is that it is not double
jeopardy because the first offense charged against the accused was unauthorized
installation of electrical devices without the approval and necessary authority from the
City Government which was punishable by an ordinance, where in the case was
dismissed, as opposed to the second offense which is theft of electricity which is
punishable by the Revised Penal Code making it a different crime charged against the
1st complaint against Mr.Opulencia.

Issue: Whether or Not the accused Mr. Opulencia can invoke double jeopardy as defense
to the second offense charged against him by the assistant fiscal of Batangas on the
ground of theft of electricity punishable by a statute against the Revised Penal Code.

Held: Yes, Mr. Opulencia can invoke double jeopardy as defense for the second offense
because as tediously explained in the case of Yap vs Lutero, the bill of rights give two
instances or kinds of double jeopardy. The first would be that “No person shall be twice
put in jeopardy of punishment for the same offense and the second sentence states that
“If an act is punishable by a law or an ordinance, the conviction or acquittal shall bar to
another prosecution for the same act”. In the case at bar, it was very evident that the
charges filed against Mr. Opulencia will fall on the 2nd kind or definition of double jeopardy
wherein it contemplates double jeopardy of punishment for the same act. It further
explains that even if the offenses charged are not the same, owing that the first charge
constitutes a violation of an ordinance and the second charge was a violation against the
revised penal code, the fact that the two charges sprung from one and the same act of
conviction or acquittal under either the law or the ordinance shall bar a prosecution under
the other thus making it against the logic of double jeopardy. The fact that Mr. Opulencia
was acquitted on the first offense should bar the 2nd complaint against him coming from
the same identity as that of the 1st offense charged against Mr.Opulencia.

Exclusionary Rule -Art. III, Sec. 3(2)

In Re Laureta, 148 SCRA 382 (1987)
In Re Laureta 148 SCRA 382 (1987) Digest.docx - Google Docs
Gutang v. People, GR 135406, July 11,2000
Fly high in blue skies!: Consti II case digest: DAVID GUTANG vs PEOPLE OF THE
PHILIPPINES
KMU v. Dir. Gen. of NEDA, 487 SCRA 62
CASE DIGEST: KILUSANG MAYO UNO vs. THE DIRECTOR-GENERAL, NEDA, G.R.
No. 167798, APRIL 19, 2006 (lawschoolbuddy.info)