Arnie D.

Andaya JD-2 Module 2 Case Digest

People of the Philippines vs. Renante Mendez

G.R. No. 147671, November 21, 2002

Facts:
• Renante Mendez and Baby Cabagtong were accused of rape with homicide
involving a 13-year-old victim, Candy Dolim.
• The victim was found lifeless in a remote area after being missing for two days.
• Both Mendez and Cabagtong were arrested without a warrant based on
information provided by a witness, Aurea Cabagtong.

Issue:
Whether the warrantless arrests of Mendez and Cabagtong were valid.

Ruling:
The Supreme Court ruled that the warrantless arrests were not valid. For a warrantless
arrest to be lawful under Rule 113 of the Rules of Criminal Procedure, it must be based
on “probable cause,” which means an actual belief or reasonable grounds of suspicion.
In this case, the arresting officers did not know the crime personally, and the
information the witness provided was insufficient to establish probable cause.

Legal Principle:
A warrantless arrest requires probable cause based on personal knowledge of facts or
circumstances that would lead a reasonable person to believe that a crime has been
committed. Mere information from a third party does not satisfy this requirement.

***

People of the Philippines vs. Fidel Abrenica Cubcubin, Jr.

G.R. No. 136267, July 10, 2001

Facts:
• Fidel Abrenica Cubcubin, Jr. was charged with the murder of Henry Pecho
Piamonte, who was found dead on his tricycle with gunshot wounds.
• The police arrested Cubcubin without a warrant based on information that he
was seen with the victim shortly before the incident.

Issue:
Whether the warrantless arrest of Cubcubin was lawful.

Ruling:
The Supreme Court upheld the validity of the warrantless arrest. Under Section 5(b) of
Rule 113 of the Rules of Criminal Procedure, a warrantless arrest is lawful if an offense
has just been committed and the arresting officer has personal knowledge of facts
indicating that the person to be arrested has committed it. In this case, the police
officers had personal knowledge from witnesses that Cubcubin was the last person seen
with the victim, which provided sufficient grounds for the arrest.

Legal Principle:
A warrantless arrest is valid if the arresting officer has personal knowledge of facts or
circumstances indicating that the person to be arrested has just committed an offense.
This knowledge must be based on credible information and immediate circumstances.

***

People of the Philippines vs. Ruben Montilla y Gatdula

G.R. No. 123872, January 30, 1998

Facts:
• Ruben Montilla y Gatdula was charged with violating Section 4, Article II of the
Dangerous Drugs Act of 1972 (Republic Act No. 6425, as amended).
• He was apprehended by police officers near a waiting shed in Dasmariñas, Cavite,
while transporting 28 kilos of dried marijuana leaves.
• The arrest was based on information from an informer who had tipped off the
police about Montilla’s activities.
Issue:
Whether the warrantless arrest of Montilla was lawful.

Ruling:
The Supreme Court upheld the validity of the warrantless arrest. The Court ruled that
the arrest fell under Section 5(b) of Rule 113 of the Rules of Criminal Procedure, which
allows warrantless arrests when an offense has just been committed and the arresting
officer has personal knowledge of facts indicating that the person to be arrested has
committed it. In this case, the police officers had reliable information from an informer
and observed Montilla in possession of the marijuana.

Legal Principle:
A warrantless arrest is lawful if the arresting officer has personal knowledge of facts or
circumstances indicating that the person to be arrested has just committed an offense.
Reliable information from an informer can contribute to establishing probable cause.

***

People of the Philippines vs. Rogelio Mengote y Tejas

G.R. No. 87059, June 22, 1992

Facts:
• Rogelio Mengote y Tejas was arrested without a warrant by plainclothes
policemen from the Western Police District.
• The arrest was based on a tip from an informer about suspicious-looking
individuals at the corner of Juan Luna and North Bay Boulevard, Tondo, Manila.
• Upon arrival, the police observed Mengote and another individual acting
suspiciously.
• When approached, Mengote attempted to flee but was apprehended and found in
possession of a .38 caliber revolver.

Issue:
Whether the warrantless arrest of Mengote was lawful.

Ruling:
The Supreme Court ruled that the warrantless arrest was not lawful. The Court
emphasized that for a warrantless arrest to be valid under Rule 113, Section 5 of the
Rules of Court, the arresting officer must have personal knowledge of facts indicating
that the person to be arrested has committed, is committing, or is about to commit an
offense. In this case, the officers did not have such personal knowledge, and Mengote’s
behavior did not conclusively indicate that he had committed a crime.

Legal Principle:
A warrantless arrest requires personal knowledge of facts or circumstances indicating
that the person to be arrested has committed, is committing, or is about to commit an
offense. Mere suspicion or information from an informer is not sufficient to justify a
warrantless arrest.

***

Soria and Bista vs. Desierto

G.R. Nos. 153524-25, January 31, 2005

Facts:
• On the evening of May 13, 2001, Rodolfo Soria and Edimar Bista were arrested
without a warrant by Philippine National Police officers for alleged illegal
possession of firearms and ammunition.
• Soria was found with a .38 caliber revolver, while Bista had a sub-machine pistol
UZI and a .22 caliber revolver.
• They were detained at the Santa, Ilocos Sur, Police Station. It was later discovered
that Bista had an existing arrest warrant for a different offense.

Issue:
Whether the warrantless arrests of Soria and Bista were lawful.
Ruling:
The Supreme Court ruled that the warrantless arrests were lawful. The Court held that
the arrests fell under Section 5(a) of Rule 113 of the Rules of Criminal Procedure, which
allows warrantless arrests when the person to be arrested has committed, is actually
committing, or is attempting to commit an offense in the presence of the arresting officer.
The possession of firearms and ammunition without proper authority constituted a
continuing offense, justifying the warrantless arrests.

Legal Principle:
A warrantless arrest is lawful if the person to be arrested is caught in the act of
committing an offense. The presence of the arresting officer and the immediate
circumstances of the offense are crucial in determining the validity of the arrest.

***

Bryan Ta-ala y Constantino vs. People of the Philippines

G.R. No. 254800, June 20, 2022

Facts:
• On August 6, 2016, Bryan Ta-ala y Constantino and Wilford Palma y Zarceno
were arrested without a warrant by officers from the Criminal Investigation and
Detection Group (CIDG) in Negros Occidental.
• The arrest was based on intelligence from US Homeland Security and the Bureau
of Customs regarding a package containing firearms and accessories shipped
from the United States to Bacolod City.
• The suspects were apprehended while claiming the package.

Issue:
Whether the warrantless arrest of Ta-ala and Palma was lawful.

Ruling:
The Supreme Court upheld the validity of the warrantless arrest. The Court ruled that
the arrest fell under Section 5(a) of Rule 113 of the Rules of Criminal Procedure, which
allows warrantless arrests when the person to be arrested has committed, is actually
committing, or is attempting to commit an offense in the presence of the arresting officer.
The intelligence report and the circumstances of the arrest provided sufficient grounds
for the officers to act without a warrant.

Legal Principle:
A warrantless arrest is lawful if the person to be arrested is caught in the act of
committing an offense. Reliable intelligence and immediate circumstances can justify
such an arrest.

***

People of the Philippines vs. Jerry Sapla y Guerrero

G.R. No. 244045, June 16, 2020

Facts:
• Jerry Sapla y Guerrero, also known as Eric Salibad y Mallari, was arrested
without a warrant by police officers based on an unverified tip from an
anonymous informant.
• The police conducted a search of Sapla’s vehicle and found marijuana bricks.
• Sapla was charged with violating Section 5, Article II of the Comprehensive
Dangerous Drugs Act of 2002 (Republic Act No. 9165).

Issue:
Whether the warrantless arrest and search of Sapla were lawful.

Ruling:
The Supreme Court ruled that the warrantless arrest and search were invalid. The Court
emphasized that for a warrantless search of a moving vehicle to be lawful, there must
be probable cause that the vehicle contains items subject to seizure. In this case, the
unverified tip from an anonymous informant did not constitute probable cause.
Consequently, the evidence obtained from the unlawful search was inadmissible.
Legal Principle:
A warrantless search and arrest require probable cause based on credible information
and immediate circumstances. An unverified tip from an anonymous informant does
not meet the standard for probable cause, making any evidence obtained from such a
search inadmissible.

***

People of the Philippines vs. Ramon Solomon y Aguilar

G.R. No. 246579, February 19, 2020

Facts:
• Ramon Solomon y Aguilar was arrested without a warrant after robbing a grocery
store.
• The incident was captured on CCTV, and the police were informed by the grocery
attendant.
• The police viewed the CCTV footage, identified Solomon, and arrested him at his
residence.
• During the arrest, an unlicensed firearm was found in his possession.

Issue:
Whether the warrantless arrest of Solomon was lawful.

Ruling:
The Supreme Court upheld the validity of the warrantless arrest. The Court ruled that
the police officers had acquired personal knowledge of the crime through the CCTV
footage, which provided sufficient grounds for a hot pursuit arrest. The continuous and
unbroken pursuit from the time of the crime to the arrest justified the warrantless
arrest.

Legal Principle:
A warrantless arrest is lawful if the arresting officers have personal knowledge of facts
indicating that the person to be arrested has just committed an offense. Viewing CCTV
footage and acting on immediate information can establish the necessary personal
knowledge for a valid hot pursuit arrest.

***

Chester De Joya vs. Judge Placido C. Marquez

G.R. No. 162416, January 31, 2006

Facts:
• Chester De Joya was implicated in a case of syndicated estafa involving the State
Resources Development Management Corporation (SRDMC).
• The private complainant, Manuel Dy Awiten, alleged that he was induced to
invest over a hundred million pesos in SRDMC, but the checks issued to him
were dishonored.
• Based on the investigation by the National Bureau of Investigation (NBI) and the
resolution of the State Prosecutor, a warrant of arrest was issued against De Joya
and his co-accused.

Issue:
Whether the trial judge erred in finding the existence of probable cause for issuing the
warrant of arrest against De Joya.

Ruling:
The Supreme Court dismissed De Joya’s petition, affirming the validity of the warrant
of arrest. The Court held that the documents reviewed by the respondent judge provided
sufficient basis to establish probable cause. The Court emphasized that probable cause
for arrest pertains to facts and circumstances that would lead a reasonably discreet and
prudent person to believe that an offense has been committed by the person sought to
be arrested.

Legal Principle:
Probable cause for the issuance of a warrant of arrest requires a reasonable belief, based
on factual evidence, that a person has committed a crime. The judge must personally
evaluate the evidence presented by the prosecutor to determine if it justifies the issuance
of a warrant.

***

Estrada vs. Ombudsman

G.R. No. 212140-41, January 21, 2015

Facts:
• Senator Jinggoy Ejercito Estrada was implicated in the Priority Development
Assistance Fund (PDAF) scam and charged with plunder and violations of the
Anti-Graft and Corrupt Practices Act (RA 3019).
• The Office of the Ombudsman conducted a preliminary investigation and found
probable cause to indict Estrada.

Issue:
Whether the Office of the Ombudsman committed grave abuse of discretion in finding
probable cause to indict Estrada.

Ruling:
The Supreme Court dismissed Estrada’s petition, affirming the Ombudsman’s finding
of probable cause. The Court held that the Ombudsman did not commit grave abuse of
discretion and that Estrada was not denied due process.

Dissenting Opinion (Justice Brion):

Justice Brion distinguished between the probable cause determination by a fiscal
(prosecutor) and that by a judge. He emphasized that the fiscal’s determination of
probable cause is to file information in court, while the judge’s determination is for the
issuance of a warrant of arrest. Brion argued that the Ombudsman should have
provided Estrada with copies of the counter-affidavits of his co-respondents and other
documents to ensure a fair preliminary investigation.

Legal Principle:
The probable cause determination by a fiscal is distinct from that of a judge. The fiscal’s
role is to decide whether there is sufficient ground to file information, while the judge’s
role is to determine whether there is probable cause to issue a warrant of arrest.

***

People of the Philippines vs. Sandiganbayan (First Division)

G.R. Nos. 219824-25, February 12, 2019

Facts:
• The case involves several public officials, including Mario L. Relampagos, Marilou
D. Bare, Rosario S. Nuñez, and Lalaine N. Paule, who were charged with
violations of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt
Practices Act) and Article 217 of the Revised Penal Code (malversation of public
funds).
• The charges stemmed from their alleged involvement in the misuse of the Priority
Development Assistance Fund (PDAF) allocated to lawmakers.

Issue:
Whether the Sandiganbayan committed grave abuse of discretion in dismissing the
criminal cases for lack of probable cause.

Ruling:
The Supreme Court ruled that the Sandiganbayan did not commit grave abuse of
discretion. The Court emphasized the distinction between the probable cause
determination by a fiscal (prosecutor) and that by a judge. The fiscal’s determination of
probable cause is to file an information in court, while the judge’s determination is for
the issuance of a warrant of arrest. The Sandiganbayan, acting as a judge, found that
the evidence presented did not establish probable cause to issue a warrant of arrest.
Legal Principle:
The probable cause determination by a fiscal is distinct from that of a judge. The fiscal’s
role is to decide whether there is sufficient ground to file an information, while the
judge’s role is to determine whether there is probable cause to issue a warrant of arrest.

***

Jovencito R. Zuño vs. Judge Alejandrino C. Cabebe

A.M. No. OCA 03-1800-RTJ, November 26, 2004

Facts:
• Chief State Prosecutor Jovencito R. Zuño filed an administrative complaint
against Judge Alejandrino C. Cabebe of the Regional Trial Court, Branch 18,
Batac, Ilocos Norte.
• The complaint alleged that Judge Cabebe granted bail to several accused
individuals without a proper hearing and any application or motion for bail.
• The accused were charged with illegal possession of prohibited or regulated
drugs.

Issue:
Whether Judge Cabebe’s act of granting bail without a hearing and an application or
motion for bail was lawful.

Ruling:
The Supreme Court found Judge Cabebe guilty of gross ignorance of the law and
partiality. The Court emphasized that bail is a matter of right only in cases where the
offense charged is not punishable by reclusion perpetua or death. In cases where the
offense is punishable by reclusion perpetua, bail can only be granted after a hearing
where the prosecution is allowed to present evidence. Judge Cabebe’s act of granting
bail without a hearing and an application or motion for bail was deemed irregular and
unjust.

Legal Principle:
The nature of bail requires that it be granted only after a proper hearing, especially in
cases involving serious offenses. The prosecution must be allowed to present evidence,
and the court must determine whether the evidence of guilt is strong before granting
bail.

***

Romulo SJ Tolentino vs. Judge Policarpio S. Camano, Jr.

A.M. No. RTJ-00-1522, January 20, 2000

Facts:
• State Prosecutor Romulo SJ Tolentino filed an administrative complaint against
Judge Policarpio S. Camano, Jr. of the Regional Trial Court, Branch 58, Tigaon,
Camarines Sur.
• The complaint alleged that Judge Camano granted bail to Roderick Odiaman,
who was charged with violating Section 5(b) of the Child Abuse Act (R.A. No.
7610), without conducting a proper hearing.
• The prosecution failed to appear at several scheduled hearings, and Judge
Camano granted bail in the amount of PHP 50,00012.

Issue:
Whether Judge Camano’s act of granting bail without a proper hearing was lawful.

Ruling:
The Supreme Court found Judge Camano guilty of gross ignorance of the law and grave
abuse of discretion. The Court emphasized that bail is a matter of right only in cases
where the offense charged is not punishable by reclusion perpetua or death. In cases
where the offense is punishable by reclusion perpetua, bail can only be granted after a
hearing where the prosecution is given an opportunity to present evidence. Judge
Camano’s act of granting bail without a proper hearing was deemed irregular and
unjust.
Legal Principle:
Bail is a matter of right in cases where the offense charged is not punishable by reclusion
perpetua or death. In cases involving serious offenses, bail can only be granted after a
proper hearing where the prosecution is given an opportunity to present evidence.

***

Allen C. Padua and Emelita F. Pimentel vs. People of the Philippines

G.R. No. 220913, February 4, 2019

Facts:
• Allen C. Padua and Emelita F. Pimentel were charged with estafa under Article
315 of the Revised Penal Code.
• The charges stemmed from allegations that they falsely claimed to be in the
business of power plant construction, resulting in financial losses for the
complainant.
• Warrants of arrest were issued, and the accused sought to quash these warrants
and applied for bail.

Issue:
Whether the Court of Appeals erred in upholding the denial of bail, considering the
accused were charged with bailable offenses.

Ruling:
The Supreme Court granted the petition, reversing the Court of Appeals’ decision. The
Court clarified that while custody of the law is required before the court can act upon
bail applications, it is not a prerequisite for adjudicating other relief forms sought by
the accused. The Court emphasized that bail is a matter of right for offenses not
punishable by reclusion perpetua or life imprisonment, and the trial court should have
resolved the Motion to Quash and fixed the amount of bail.

Legal Principle:
Bail is a matter of right for offenses not punishable by reclusion perpetua or life
imprisonment. While custody of the law is required for bail applications, it is not
necessary for other forms of relief sought by the accused.

***

Juan Ponce Enrile vs. Sandiganbayan

G.R. No. 213847, August 18, 2015

Facts:
• Senator Juan Ponce Enrile was charged with plunder and violations of the Anti-
Graft and Corrupt Practices Act (RA 3019) in connection with the Priority
Development Assistance Fund (PDAF) scam.
• Enrile filed a bail petition, arguing that his advanced age and poor health
warranted his release on humanitarian grounds.
• The Sandiganbayan denied his petition, leading Enrile to elevate the matter to
the Supreme Court.

Issue:
Whether the Sandiganbayan committed grave abuse of discretion in denying Enrile’s
petition for bail.

Ruling:
The Supreme Court granted Enrile’s petition for bail. The Court held that while bail is
generally a matter of right for offenses not punishable by reclusion perpetua or death,
it can also be a matter of discretion in exceptional cases. The Court considered Enrile’s
advanced age and frail health as compelling reasons to grant bail on humanitarian
grounds. The Court emphasized that the primary purpose of bail is to ensure the
accused’s appearance at trial, and Enrile’s circumstances justified his temporary
release.

Legal Principle:
Bail can be a matter of discretion in exceptional cases, particularly when humanitarian
considerations such as advanced age and poor health are involved. The primary purpose
of bail is to ensure the accused’s appearance at trial, and courts may grant bail based
on the totality of circumstances.

***

Jose Antonio Leviste vs. Court of Appeals

G.R. No. 189122, March 17, 2010

Facts:
• Jose Antonio Leviste was charged with the murder of Rafael de las Alas.
• The Regional Trial Court (RTC) of Makati City convicted Leviste of the lesser crime
of homicide and sentenced him to an indeterminate penalty of six years and one
day of prision mayor as minimum to twelve years and one day of reclusion
temporal as maximum.
• Leviste sought bail pending appeal, citing his advanced age and medical
condition, but the Court of Appeals (CA) denied his application.

Issue:
Whether the denial of bail pending appeal by the CA was a grave abuse of discretion.

Ruling:
The Supreme Court dismissed Leviste’s petition and upheld the CA’s decision. The Court
emphasized that bail pending appeal is discretionary and should be exercised with grave
caution and only for strong reasons. The Court noted that the discretion to grant bail
pending appeal involves two stages: the determination of discretion and the exercise of
discretion. The absence of specific circumstances enumerated in Section 5, Rule 114 of
the Rules of Court does not automatically entitle the accused to bail; the court must
still assess the potential frivolity of the appeal and the gravity of the offense.

Legal Principle:
Bail pending appeal is a matter of judicial discretion and should be granted with grave
caution. The court must balance the interests of society and the rights of the accused,
considering the gravity of the offense and the potential frivolity of the appeal.

***

Efraim C. Genuino, Erwin F. Genuino, and Sheryl G. See vs. Hon. Leila M. De
Lima
G.R. Nos. 197930, 199034 & 199046, April 17, 2018

Facts:
• The consolidated petitions were filed by Efraim C. Genuino, Erwin F. Genuino,
Sheryl G. See, and former President Gloria Macapagal-Arroyo, challenging the
constitutionality of Department of Justice (DOJ) Circular No. 41, series of 2010.
• This Circular consolidated previous rules on the issuance of Hold Departure
Orders (HDOs), Watchlist Orders (WLOs), and Allow Departure Orders (ADOs).
• The petitioners argued that the Circular unduly restricted their constitutional
right to travel.
• The DOJ issued several WLOs and HDOs against the petitioners based on
Circular No. 41.

Issue:
Whether DOJ Circular No. 41 and the consequent orders issued pursuant to it violate
the constitutional right to travel.

Ruling:
The Supreme Court ruled that DOJ Circular No. 41 was unconstitutional. The Court
held that the DOJ does not have the legal authority to issue such Circulars and the
consequential WLOs, HDOs, and ADOs, as they infringe on the constitutional right to
travel without a statutory basis. The right to travel can only be impaired through
legislation expressly provided by law or in the interest of national security, public safety,
or public health.

Legal Principle:
The right to travel is a fundamental liberty protected under the Constitution (Article III,
Section 6). Any restriction on this right must have a statutory basis and be in the
interest of national security, public safety, or public health. Administrative issuances
like DOJ Circular No. 41 cannot legally impair constitutional rights without explicit
legislative authorization.

***

Joel P. Libuit vs. People of the Philippines

G.R. No. 154363, September 13, 2005

Facts:
• Joel P. Libuit was charged with estafa under Article 315(1)(b) of the Revised Penal
Code.
• The charge stemmed from an incident where Domingo del Mundo brought his car
to Libuit’s motor shop for repairs.
• Despite repeated demands, Libuit failed to return the car, leading to allegations
of misappropriation and conversion of the vehicle.

Issue:
Whether Libuit’s rights as an accused were violated during the trial.

Ruling:
The Supreme Court upheld Libuit’s conviction, affirming the decision of the Court of
Appeals. The Court found that Libuit’s rights as an accused were not violated. The trial
court had provided him with due process, including the right to be heard and to present
evidence. The evidence presented by the prosecution was sufficient to establish his guilt
beyond reasonable doubt.

Legal Principle:
The rights of the accused at trial include the right to due process, which encompasses
the right to be heard, to present evidence, and to cross-examine witnesses. A conviction
can be upheld if the trial court ensures these rights are respected and the evidence
supports the verdict.

***

People of the Philippines vs. Elizar Tomaquin

G.R. No. 133188, July 23, 2004

Facts:
• Elizar Tomaquin was charged with the murder of Jaquelyn Luchavez Tatoy.
• The prosecution’s evidence included Tomaquin’s extrajudicial confession, which
he made in the presence of a barangay captain who was also a lawyer.
• Tomaquin argued that his confession was inadmissible because he was not
provided with an independent counsel during custodial investigation.

Issue:
Whether the extrajudicial confession made by Tomaquin was admissible, considering
the presence of a barangay captain who was a lawyer during the custodial investigation.

Ruling:
The Supreme Court ruled that Tomaquin’s extrajudicial confession was inadmissible.
The Court held that a barangay captain, even if he is a lawyer, cannot be considered an
independent counsel within the purview of Section 12, Article III of the 1987
Constitution. The Court emphasized that the right to counsel during custodial
investigation is meant to protect the accused from coercive interrogation practices, and
the counsel provided must be truly independent and impartial.

Legal Principle:
The right to counsel during custodial investigation requires the presence of an
independent and impartial lawyer. A barangay captain, despite being a lawyer, does not
meet this requirement, and any confession made in his presence is inadmissible.

***
 People of the Philippines vs. John Mamarion
G.R. No. 137554, October 1, 2003

Facts:
• John Mamarion and several co-accused were charged with kidnapping for
ransom.
• The victim, Roberta Cokin, was kidnapped and held for ransom.
• Despite the ransom being paid, the victim was killed.
• Mamarion and his co-accused were arrested and charged with the crime.

Issue:
Whether the trial court should allow an accused to plead guilty to a lesser offense in
consideration of testifying as a prosecution witness.

Ruling:
The Supreme Court ruled that the accused, with the consent of the offended party and
the prosecutor, may be allowed by the trial court to plead guilty to a lesser offense. This
is permissible even if the lesser offense is not necessarily included in the crime charged,
provided that the plea is made before the prosecution rests its case. In this case, one of
the accused, Amado Gale, was allowed to plead guilty to the lesser offense of slight illegal
detention in exchange for his testimony against the other accused.

Legal Principle:
An accused may plead guilty to a lesser offense with the consent of the offended party
and the prosecutor. This plea can be made at arraignment or after withdrawing a plea
of not guilty, but it must be done before the prosecution rests its case.

***

People of the Philippines vs. Rufino Ernas y Villanueva

G.R. Nos. 137256-58, August 6, 2003

Facts:
• Rufino Ernas y Villanueva was charged with three counts of rape against his
daughters, Elsa and Celeste Ernas.
• He entered a plea of guilty to the charges.
• The trial court, without conducting a thorough inquiry into the voluntariness and
consequences of his plea, convicted him and sentenced him to death for each
count.

Issue:
Whether the trial court erred in accepting Ernas’ plea of guilty without conducting a
proper inquiry into its voluntariness and consequences.

Ruling:
The Supreme Court ruled that the trial court committed an error by not conducting a
searching inquiry into the voluntariness and full comprehension of the consequences of
Ernas’ plea of guilty. The Court emphasized that in capital offenses, it is imperative for
the trial court to ensure that the accused fully understands the nature and
consequences of their plea. The Court remanded the case to the trial court for further
proceedings.

Legal Principle:
In cases involving capital offenses, the trial court must conduct a thorough and
searching inquiry into the voluntariness and full comprehension of the consequences of
a plea of guilty. Failure to do so renders the plea improvident and necessitates further
judicial proceedings.

***

People of the Philippines vs. Brendo P. Pagal

G.R. No. 241257, September 29, 2020

Facts:
• Brendo P. Pagal was charged with the murder of Selma Pagal.
• During his arraignment, Pagal pleaded guilty to the crime.
 • The trial court accepted his plea without conducting a thorough inquiry into its
voluntariness and the consequences of the plea.
• The court then convicted Pagal based solely on his plea and sentenced him to
reclusion perpetua.

Issue:
Whether the trial court erred in convicting Pagal based solely on his plea of guilt without
a comprehensive inquiry into its voluntariness and the consequences.

Ruling:
The Supreme Court ruled that the trial court committed an error by not conducting a
thorough and searching inquiry into the voluntariness and full comprehension of the
consequences of Pagal’s plea of guilty. The Court emphasized that in capital offenses,
the trial court must ensure that the accused fully understands the nature and
consequences of their plea. The Court set aside the conviction and remanded the case
to the trial court for further proceedings.

Legal Principle:
In cases involving capital offenses, the trial court must conduct a thorough and
searching inquiry into the voluntariness and full comprehension of the consequences of
a plea of guilty. Failure to do so renders the plea improvident and necessitates further
judicial proceedings.

***

Melbarose R. Sasot and Allandale R. Sasot vs. People of the Philippines

G.R. No. 143193, June 29, 2005

Facts:
• Melbarose R. Sasot and Allandale R. Sasot were charged with unfair competition
under Article 189 of the Revised Penal Code.
• The charges stemmed from a complaint by NBA Properties, Inc., alleging that the
Sasots were engaged in the manufacture, printing, sale, and distribution of
counterfeit NBA garment products.
• The National Bureau of Investigation (NBI) conducted an investigation and
recommended the filing of charges.

Issue:
Whether the trial court erred in denying the motion to quash the information filed by
the Sasots.

Ruling:
The Supreme Court upheld the trial court’s decision to deny the motion to quash. The
Court found that the grounds cited by the Sasots, namely that the facts charged did not
constitute an offense and that the court had no jurisdiction over the offense or the
person of the accused, were without merit. The Court emphasized that the information
sufficiently alleged the elements of unfair competition and that the trial court had
jurisdiction over the case.

Legal Principle:
A motion to quash an information can be denied if the information sufficiently alleges
the elements of the offense charged and the court has jurisdiction over the case. The
grounds for a motion to quash must be clearly established and supported by evidence.

***

Gina Villa Gomez vs. People of the Philippines

G.R. No. 216824, November 10, 2020

Facts:
• Gina Villa Gomez was charged with corruption of public officials under Article
212 of the Revised Penal Code.
• The charge stemmed from an incident where she allegedly offered a bribe to police
officers in exchange for the release of her companion, who was arrested for a non-
bailable offense.
 • The trial court dismissed the case motu proprio, citing the lack of a signature
and approval from the City Prosecutor on the Information.

Issue:
Whether the trial court committed grave abuse of discretion in dismissing the criminal
case based on the alleged jurisdictional defect due to the absence of a signature and
approval from the City Prosecutor on the Information.

Ruling:
The Supreme Court ruled that the trial court committed grave abuse of discretion. The
Court emphasized that there is no provision in the Rules of Court requiring that the
authority or approval of the city or provincial prosecutor must appear on the face of the
Information. The Court of Appeals correctly found that the trial court erred in dismissing
the case on its motion without a motion filed by the accused.

Legal Principle:
An order sustaining a motion to quash is not a bar to another prosecution for the same
offense unless the motion was based on grounds such as extinguishment of criminal
liability or double jeopardy. If the motion to quash is sustained, the court may order
that another complaint or information be filed. If no new information is filed within the
specified time, the accused, if in custody, shall be discharged unless admitted to bail.

***

Artemio T. Torres, Jr. vs. Spouses Drs. Edgardo Aguinaldo & Nelia T. Torres-
Aguinaldo
G.R. No. 164268, June 28, 2005

Facts:
• Respondent-spouses Edgardo and Nelia Aguinaldo filed a complaint against
Artemio T. Torres, Jr. for falsification of public documents.
• They alleged that Torres transferred the titles of their properties to his name using
a forged Deed of Sale.
• Torres denied the allegations, claiming he legally acquired the properties through
a legitimate sale.
• The Office of the City Prosecutor (OCP) of Manila found probable cause and filed
an information against Torres.
• However, the Secretary of Justice later ordered the withdrawal of the information,
which the Metropolitan Trial Court (MTC) granted.

Issue:
Whether the Court of Appeals erred in reinstating the OCP’s resolution finding probable
cause against Torres after the MTC had already granted the motion to withdraw the
information.

Ruling:
The Supreme Court ruled in favor of Torres, granting the petition. The Court held that
the Court of Appeals erred in disregarding the evidence presented by both the
complainant and the accused during the preliminary investigation. The Secretary of
Justice did not abuse his discretion in examining all available evidence to determine the
lack of probable cause. The Court concluded that the Aguinaldos failed to establish a
direct link between Torres and the alleged forgery.

Legal Principle:
In determining probable cause during a preliminary investigation, it is imperative to
consider all evidence presented by both the complainant and the defense. The decisions
of the Secretary of Justice in reviewing findings of a public prosecutor are persuasive
but not binding on courts, which must independently assess the merits of the case.

***
 People of the Philippines vs. Castillo
G.R. No. 252403, December 7, 2021

Facts:
• Castillo was charged with illegal possession of dangerous drugs.
• During the trial, the prosecution failed to present its key witness despite several
continuances.
• Consequently, the defense moved for the provisional dismissal of the case, which
the trial court granted.
• The prosecution later filed a motion to revive the case, arguing that the dismissal
was not final and that they had new evidence.

Issue:
Whether the trial court erred in granting the prosecution’s motion to revive the case
after a provisional dismissal.

Ruling:
The Supreme Court ruled that the trial court did not err in granting the prosecution’s
motion to revive the case. The Court emphasized that a provisional dismissal is not a
final adjudication on the merits and can be revived under certain conditions. The
prosecution’s failure to present its key witness initially did not preclude the revival of
the case, especially when new evidence was available.

Legal Principle:
A provisional dismissal is not a final resolution and can be revived if new evidence
emerges or if the prosecution can justify the delay in presenting its case. The revival of
a provisionally dismissed case does not violate the accused’s right to a speedy trial,
provided the revival is justified and reasonable.

***