**Facts:** In the early hours of July 27, 2003, a group of over three hundred junior officers and enlisted men from the elite units of the Armed Forces of the Philippines (AFP), notably the Philippine Army’s Scout Rangers and the Philippine Navy’s Special Warfare Group, seized the Oakwood Premier Apartments in Makati City. This group, known as the Magdalo Group, aired grievances against the administration and demanded the resignation of key government and military officials.
Following the incident, 321 soldiers were charged with coup d’état under the Revised Penal Code in the Regional Trial Court (RTC) of Makati, which included the petitioners referred to as Navalas et al. Subsequently, an Amended Information reduced the accused to 31, dismissing the charges against the 290 others, including the petitioners in this case. Concurrently, those not included in the Amended Information, including Navalas et al., faced charges under the Articles of War before a General Court-Martial.
Petitions for Habeas Corpus and for Prohibition were filed with the Supreme Court, challenging the jurisdiction of the military tribunal and the legality of the detention of the soldiers not included in the Amended Information. The petitioners argued, referencing Republic Act No. 7055, that the RTC’s finding that the offenses weren’t service-connected deprived the military tribunal of jurisdiction, and thus, their detention under military custody was unlawful.
**Issues:**
1. Whether the General Court-Martial holds jurisdiction to try the petitioners for violations of the Articles of War in connection with the Oakwood mutiny.
2. Whether the detention of petitioners under military custody is lawful.
**Court’s Decision:** The Supreme Court dismissed both petitions. It ruled that the General Court-Martial retains its jurisdiction over service-connected offenses as defined under Republic Act No. 7055 and the Articles of War, specifically Articles 63, 64, 67, 96, and 97. The Court found that the RTC, in declaring the military charges not service-connected, acted beyond its jurisdiction, making such proclamation void. Further, the Court held that the writs of prohibition and habeas corpus cannot be granted since the General Court-Martial lawfully exercises jurisdiction over the petitioners concerning the cited Articles of War and their detention was by a competent authority under a lawful commitment order.
**Doctrine:** The jurisdiction over service-connected offenses under the Articles of War, specifically Articles 54 to 70, Articles 72 to 92, and Articles 95 to 97, remains with the General Court-Martial, as clarified by Republic Act No. 7055.
**Class Notes:**
– *Jurisdiction of Military Tribunals:* The General Court-Martial holds jurisdiction over “service-connected offenses,” which include crimes as outlined under Articles 54 to 70, Articles 72 to 92, and Articles 95 to 97 of the Articles of War (Commonwealth Act No. 408, as amended).
– *Republic Act No. 7055:* This Act delineates the scope of military versus civil court jurisdiction over members of the Armed Forces of the Philippines, emphasizing that service-connected offenses are to be tried by court-martial.
– *Application of the Doctrine:* In determining whether a military or civil court has jurisdiction, the nature of the offense (i.e., service-connected or not) is crucial. Republic Act No. 7055 provides a clear delineation of offenses considered service-connected.
**Historical Background:** This case sheds light on the ongoing tension between military authority and civilian oversight within the Philippine legal system. The legal battle stems from the incident known as the Oakwood mutiny, which highlighted the grievances within the military and brought into question the jurisdictional boundaries between military and civilian courts in cases involving armed forces personnel. This scenario, set against the backdrop of post-Marcos Philippines, illustrates the challenges in balancing military discipline with ensuring the rights of military personnel are safeguarded within the civilian legal framework.
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