PEOPLE OF THE PHILIPPINES vs. CLEMENTE BAUTISTA (G.R. No.

168641, April 27,2007)

FACT:
Clemente and Leonida Bautista faced a legal dispute with Felipe Goyena over minor physical injuries.
Goyena initially filed a complaint at the barangay office in Manila, but no resolution was reached. He
then pursued the case by filing against the Bautistas at the City Prosecutor's Office. Despite a
recommendation from Prosecutor Jessica Junsay-Ong, the approval of the Joint Resolution against the
Bautistas was not calendared.
Eventually, the case reached the Metropolitan Trial Court (MeTC) in June 2000. The Bautistas argued that
the case should be dismissed due to the expiration of the 60-day prescription period from the time the
offense was committed. However, both the MeTC and the Regional Trial Court (RTC) disagreed, stating
that the offense had not yet been prescribed.
The Bautistas appealed to the Court of Appeals (CA), arguing that the prescriptive period had indeed
elapsed. The CA acknowledged that the filing of the complaint with the City Prosecutor's Office
interrupted the prescriptive period, but ultimately ruled that the offense had still been prescribed by the
time the case was filed with the MeTC.

ISSUE:
Whether or not the respondents are absolved of criminal responsibility because the 60-day limitation
period had expired.

RULING/DECISION:
Yes. Despite the Office of the Prosecutor's delay in filing the case, such oversight should not unfairly
harm the State's interests or those of the victim. As established in People v. Olarte, it would be unjust to
deny the injured party the opportunity for justice due to delays beyond their control. The victim's
responsibility in initiating prosecution is limited to filing the necessary complaint. The Court refuses to be
complicit in depriving the offended party of their right to seek redress for a perceived wrong simply due
to a prosecutor's failure to act promptly.
The Court cannot condone the apparent lack of urgency displayed by prosecutors in fulfilling their duties.
Given the circumstances, the more appropriate action would be to pursue administrative disciplinary
measures against the responsible public officials.
Therefore, the Supreme Court overturns and cancels the previous rulings of both lower courts, and
Criminal Case No. 344030-CR, titled "People of the Philippines, Plaintiff, -versus- Clemente Bautista and
Leonida Bautista, Accused," is hereby dismissed. Each party will bear their costs.
BRILLANTE v. COURT OF APPEALS (G.R. Nos. 118757 & 121571, October 19, 2004)

FACT:
On January 7, 1988, Brillante, then a Councilor candidate in Makati, held a press conference at
the Makati Sports Club attended by around 50 journalists. During the conference, Brillante
accused Binay of orchestrating the assassination of Augusto Syjuco, another mayoral candidate
in Makati at the time, as well as engaging in acts of terrorism, intimidation, and harassment
against the Makati electorate. Brillante also distributed copies of an open letter to President
Aquino outlining his allegations against Binay. Subsequently, several journalists present at the
conference published news articles based on Brillante's statements. Following this, five libel
charges were filed against Brillante in the Regional Trial Court (RTC) of Makati.
The RTC found Brillante guilty of libel on four counts, sentencing him to an indeterminate
penalty of 4 months of arresto mayor as a minimum, to 2 years of prison mayor as a maximum,
and imposing a fine of P2000. He was also ordered to pay Dr. Nemesio Prudente, the alleged co-
conspirator of Binay in the assassination plot, a total of P1,000,000.00 in moral damages across
the four cases. The Court of Appeals upheld the decision.
Brillante refutes his liability for libel concerning the publication of his open letter implicating
Binay, Prudente, and associates in the alleged assassination plot and election-related offenses
during the January 7, 1988, press conference. He argues that his statements were privileged
communication made from a legal, moral, and social duty to safeguard the integrity of the
upcoming elections and prevent loss of life. Since his statements were privileged, malice cannot
be assumed. Brillante also asserts that since Binay, the subject of the alleged defamatory
remarks, is a public figure, his comments are constitutionally protected speech.

ISSUE:
Whether Brillante can be proven guilty of libel beyond a reasonable doubt and whether the
penalty imposed upon him is unduly harsh.

RULING/DECISION:
Yes, Brillante can be deemed guilty of libel as all the essential elements have been established:
the allegation of a discreditable act, publication of the charge, identification of the person
defamed, and the presence of malice. The Court determined that despite Brillante's claim of
privileged communication, this defense does not apply as his statements were not made in good
faith and without malice. While Brillante may have had a moral or social duty to make the
communication, his reliance on unconfirmed intelligence reports undermines the existence of
good faith. Additionally, the communication was not solely addressed to individuals who had the
power to provide the sought protection, as it was widely disseminated to the public through
publication in newspapers. Consequently, Brillante's conviction for libel was rightfully affirmed
by the Court of Appeals.
Regarding the awarded moral damages, they were deemed excessive given the circumstances
surrounding the defamatory statements. Therefore, the Court opted to reduce the number of
moral damages awarded.
Ebarle vs Sucaldito156 SCRA 803 G.R. No. L-33628, December 29, 1987

FACT:
This is a petition filed by Ebarle, the provincial Governor of Zamboanga del Sur and a candidate
for reelection in the 1971 local elections. He sought injunctive relief in two separate petitions to
halt further proceedings in Criminal Cases initiated in Pagadian City and the Fiscal’s office.
These cases alleged violations of certain provisions of the Anti-Graft and Corrupt Practices Act
(RA 3019) and various provisions of the Revised Penal Code, initiated by the Anti-Graft League
of the Philippines. On June 16, 1971, and October 8, 1971, the Supreme Court issued a
temporary restraining order (TRO) directing respondents to cease further proceedings. The Anti-
Graft League sought to have the TRO lifted and the case dismissed. Petitioner contends that the
prosecutions are politically motivated due to his candidacy for reelection as Governor of
Zamboanga del Sur, citing provisions of Executive Order 264 outlining the procedure for
charging government officials and employees with irregularities. Additionally, the petitioner
criticizes the failure of the respondents, the City Fiscal and the Anti-Graft League, to comply
with the provisions of Executive Order No. 264.

ISSUE:
Whether Executive Order No. 264 applies solely to administrative complaints and not criminal
charges.

RULING/DECISION:
Yes, the Order primarily addresses "COMMISSION OF IRREGULARITIES" without
mentioning criminal offenses or the term "crimes." If it were intended to apply to criminal
matters, it would have used more specific language. The Supreme Court is not tasked with
resolving complaints, as such matters fall under the jurisdiction of other agencies. Therefore, the
petitions are dismissed, and the temporary restraining orders are lifted and nullified. Petitioners
are directed to bear the costs.
 LAUDE V. GINEZ-JABALDE G.R. NO. 217456, NOVEMBER 24, 2015
FACT:
The case stems from the murder of Jennifer Laude on October 11, 2014, with her sister, Marilou
Laude, filing a murder complaint at the Prosecutor's Office of Olongapo City. Information was
subsequently filed before the RTC of Olongapo, leading to the arrest of the accused, Scott
Pemberton, on December 19, 2014, and his detention by the Armed Forces of the Philippines.
Marilou filed an Urgent Motion to Compel the Armed Forces of the Philippines to Surrender
Custody of the Accused to the Olongapo City Jail on the same day as Pemberton's surrender and
arraignment. However, this motion lacked the conformity of the public prosecutor and did not
observe the three-day notice rule for motions. Despite Pemberton's counsel being present at the
arraignment and being served with a copy of the motion on the spot, Judge Ginez-Jabalde denied
the motion and a subsequent Motion for Reconsideration.
This led to the filing of a Petition for Certiorari under Rule 65, alleging grave abuse on the part
of the respondent for supposedly disregarding the petitioner's human rights. The petitioner argues
that the three-day notice rule should not be absolute, as Pemberton's counsel was present and had
the opportunity to oppose the motion. Additionally, the petitioner questions the constitutionality
of the Visiting Forces Agreement (VFA), claiming it infringes on the court's procedural powers
by granting the United States custody over Pemberton.
The private respondents counter these arguments, emphasizing the importance of observing the
three-day notice rule to uphold due process and allow them the opportunity to refute the motion.
They also highlight the fatal defect of the motion, namely the lack of conformity from the public
prosecutor.

ISSUE:
 Whether the requirement to observe the three-day notice rule for motions was necessary.
 Whether the petitioner's rights were infringed upon.
 Whether the absence of conformity by the public prosecutor rendered the motion invalid.
 Whether the validity of the VFA could be challenged in this petition.
RULING/DECISION:
The failure to observe the three-day notice rule for motions deprived Pemberton of procedural
due process, thus rendering the motion invalid.
The interpretation of international obligations cannot justify disregarding domestic procedural
rules, as the accused's rights to due process must be respected.
The absence of conformity from the Public Prosecutor rendered the motion invalid, as the People
are the real party in interest in criminal cases.
The constitutionality of the VFA cannot be questioned in this case as it was not properly raised
and is not essential to resolving the issues at hand.

People vs Lucas, GR Nos. 108172-73, May 25, 1994 (233SCRA 537)

FACT:
Chanda Lucas, a 17-year-old girl, accused her biological father, Conrado Lucas, of rape and
attempted rape. She claimed that the abuse began when she was just 9 years old and continued
for several years. At the age of 17, her father attempted to rape her again but was interrupted by
her siblings. Conrado denied the charges, stating that they were fabricated because his children
did not like him.
The Supreme Court reviewed the case in 1994 and found Conrado guilty based on Chanda's
credible testimony. The court determined that it was a consummated rape since he had inserted
his penis into her vagina. However, since the information only charged him with attempted rape,
he could only be convicted of that offense.
The main issue in the 1995 case was determining the appropriate penalty for Conrado. Before
R.A. No. 7659, mitigating or aggravating circumstances did not affect the penalty for rape
because it was indivisible. However, with the new law in place, reclusion perpetua now has a
defined duration of 20 to 40 years.
Although there is no corresponding amendment to Article 76 of the same code regarding
divisible penalties for reclusion perpetua, Art 65 of the RPC was applied by dividing the penalty
into three equal portions to account for aggravating circumstances. Consequently, Conrado
received a sentence of 34 years, 4 months and one day of reclusion perpetua.
ISSUE:
Whether the Supreme Court in the 1994 case accurately segmented an "indivisible penalty" into
three parts to apply the aggravating circumstance.

FACT:
No, the Supreme Court acknowledged its error. Despite the provision in Section 17 of R.A. No.
7659 fixing the duration of reclusion perpetua, there was no clear legislative intent to change its
classification as an indivisible penalty. According to Article 63 of the RPC, indivisible penalties
must be applied without consideration for mitigating or aggravating circumstances. As such,
reclusion perpetua remains indivisible and is imposed in its entirety regardless of any attendant
circumstances. Therefore, the court revised its decision by removing the discussion on the
divisibility of penalties and imposed the penalty of reclusion perpetua.