Facts:
On March 8, 1996, Vicente Bauzon and Elizer Tuliao were found dead in Purok Nibulan, Ramon, Isabela, with respondent Virgilio Tuliao being the latter’s father. Initially, SPO1 Wilfredo Leaño and others were charged with the murder in the RTC Santiago City, convicted, but later acquitted by the Supreme Court on reasonable doubt.
During the pendency of the appeal, SPO2 Maderal, previously at large, was arrested and executed a sworn confession implicating petitioners Miranda, Ocon, and Dalmacio, among others, as culprits. Based on this, criminal complaints for murder were filed against petitioners, and in June 2001, a trial judge issued warrants for their arrest. Petitioners sought to quash the warrants and requested reinvestigation, asserting the court did not acquire jurisdiction over their persons.
In August 2001, a new presiding judge, Anastacio Anghad, reversed the previous orders, quashed the warrants for Miranda’s arrest, and later applied the same order to Ocon and Dalmacio. After a failed motion for reconsideration and inhibition filed by State Prosecutor Reyes and respondent Tuliao, they sought relief in the Supreme Court, which was later referred to the Court of Appeals (CA).
Subsequently, Tuliao filed for certiorari, mandamus, and prohibition with the Supreme Court. The CA issued a temporary restraining order against Judge Anghad’s orders. However, Judge Anghad dismissed the murder informations against petitioners, prompting Tuliao to seek contempt charges. The Supreme Court referred the contempt charges to the CA.
The Court of Appeals decided that Judge Anghad acted with grave abuse of discretion, reinstated the criminal charges, and ordered the issuance of warrants of arrest against the petitioners and Maderal.
Issues:
1. Whether the Court of Appeals erred in reversing Judge Anghad’s Orders quashing the warrants of arrest.
2. Whether the CA correctly directed the reinstatement of the criminal cases and the re-issuing of warrants of arrest.
3. Whether there was error in reinstating the criminal cases on the argument that the order of dismissal had become final and executory.
Court’s Decision:
The Supreme Court denied the petition, affirming the CA’s decision, with the modification to transfer the criminal cases to the RTC of Manila. The Court stated that seeking an affirmative relief constitutes voluntary appearance and that jurisdiction over the person of the accused is not required for the adjudication of motions to quash the warrant of arrest. Furthermore, it ruled that the pendency of a petition for review of the prosecutor’s resolution or the political climate were not grounds to quash an arrest warrant. Also, the Supreme Court clarified that the dismissal of a criminal case on a decision of the Court in a different case with different accused showed that Judge Anghad abused his discretion. Additionally, it found that nullifying proceedings includes reinstating orders set aside by the nullified proceeding and that there is no double jeopardy in the reinstatement of a criminal case dismissed before arraignment.
Doctrine:
An accused can invoke the jurisdiction of the court, without necessarily being in custody of the law, by seeking affirmative relief. However, applying for bail requires the accused to be in custody. Custody of the law is distinct from jurisdiction over the person of the accused.
Class Notes:
– Jurisdiction over the person of the accused is deemed waived when the accused files any pleading seeking affirmative relief except when challenging jurisdiction over his person or quashing a warrant of arrest.
– Jurisdiction over the person of the accused is not a requirement for adjudicating a motion to quash a warrant of arrest.
– A criminal case can be reinstated even if previously dismissed if the dismissal is prior to arraignment and the case was dismissed upon the accused’s motion.
Historical Background:
The case arises in the context of the tumultuous political climate of the Philippines in the 1990s, highlighting issues of jurisdiction, grave abuse of discretion by judges, and the proper procedures for testing the legality of a warrant of arrest. It also illustrates the dynamic interactions between law enforcement agencies, the prosecutorial service, the judiciary, and the rights of the accused.
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