Facts:
1. On November 3, 1995, PO3 Virgilio Dimatulac was shot dead in Masantol, Pampanga.
2. On November 5, 1995, a complaint for murder was filed against the YABUTs and others in the MCTC of Macabebe-Masantol, and warrants of arrest were issued after finding probable cause.
3. Evelino David, Justino Mandap, Juan Magat, and Francisco Yambao were arrested, but the YABUTs remained at large.
4. On December 1, 1995, the court confirmed the murder charge against the accused and ordered arrests without bail except for Yambao, who was granted bail after filing a counter-affidavit.
5. Assistant Provincial Prosecutor Alfonso-Flores conducted a reinvestigation and concluded on January 29, 1996, that the crime was homicide, not murder.
6. Petitioners appealed the downgrade to homicide to the DOJ on February 23, 1996, arguing the presence of qualifying circumstances.
7. Despite the appeal, an information for homicide was filed on February 28, 1996.
8. Arraignment was repeatedly deferred upon petitioners’ motions, but eventually proceeded; the YABUTs pleaded not guilty on May 20, 1996.
9. Secretary of Justice Teofisto Guingona eventually ruled treachery was present and ordered the Provincial Prosecutor to amend the charge to murder, but later reversed the directive, citing the accused’s arraignment.
10. Petitioners filed for Certiorari, Prohibition, and Mandamus with the Supreme Court.
Issues:
A. Whether the Provincial Prosecutor committed grave abuse of discretion in conducting reinvestigation and filing homicide charges.
B. Whether Judge Villon acted in excess by arraigning the accused and denying motions despite pending DOJ appeal.
C. Whether Secretary of Justice Guingona committed grave abuse in reconsidering the order to amend charges to murder post-arraignment.
Court’s Decision:
A. The Supreme Court found procedural irregularities and undue haste in the reinvestigation and downgrading of charges. The Prosecutor’s inappropriate actions — conducted while the YABUTs evaded arrest — facilitated filing homicide charges favoring the accused. Information should not have been filed amid pending appeals.
B. Judge Villon also committed grave abuse in holding the arraignment swiftly despite the merit of pending judgment from DOJ and the Court of Appeals. This deprived petitioners and the State of due process.
C. The SC ruled that the DOJ’s reversal of its decision following the arraignment exemplified grave abuse. The DOJ surrendered its control over the prosecution, failing to rectify injustices resulting from earlier actions.
Doctrine:
The legal doctrine emphasized prosecutorial discretion’s due moderation, the inviolability of due process, and the judicious prudence expected from the judiciary in criminal justice administration. Upholding the DOJ’s supervisory power ensures balanced administration of justice.
Class Notes:
– Key elements in this case include treachery as a qualifying circumstance for murder under Article 248 of the Revised Penal Code, prosecutorial discretion, supervisory authority of DOJ, due process, and double jeopardy.
– Rule 112 of the Rules of Court details procedure in preliminary investigation.
– DOJ Department Order No. 223 outlines appeals from prosecutorial resolutions and its exceptions.
Historical Background:
The case unfolded amid concerns about political connections influencing investigatory and prosecutorial conduct. This period saw tension between local government officials and justice enforcement, sparking discourse on the integrity of legal processes in politically sensitive criminal cases. The Dimatulac case emphasized the balance between legal rights and procedural fairness, reinforcing the foundations of impartial justice amid external pressures.
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