**Facts:**
1. Arturo Francisco Luy and others filed a Joint Sworn Statement on March 8, 2013, alleging Benhur Luy had been detained against his will since December 19, 2012.
2. Benhur Luy was reportedly held by Janet Lim Napoles and her brother, Reynald Lim, to cover up alleged illegal transactions related to the Priority Development Assistance Fund (PDAF) scam.
3. Secretary of Justice Leila M. De Lima ordered an NBI investigation, resulting in the rescue of Benhur Luy on March 22, 2013, from Pacific Plaza Tower, Bonifacio Global City, leading to Lim’s arrest.
4. A formal recommendation to prosecute Napoles and Lim for serious illegal detention followed.
5. Napoles and Lim denied the detention, claiming it was voluntary for a spiritual retreat.
6. Initial finding by Assistant State Prosecutor Juan Pedro V. Navera recommended the dismissal of the complaint, believing Luy’s stay was voluntary.
7. On review, Senior Deputy State Prosecutor Theodore M. Villanueva overturned this finding, citing probable cause for illegal detention, highlighting the motive linked to the PDAF scam.
8. The Information for serious illegal detention was filed before the Regional Trial Court (RTC) of Makati.
9. RTC, led by Judge Elmo M. Alameda, issued an arrest warrant for Napoles.
10. Napoles sought certiorari before the Court of Appeals, claiming grave abuse of discretion, which was denied.
**Procedural Posture:**
– Napoles elevated the case to the Supreme Court via a Petition for Review on Certiorari, questioning the filing of information and arrest warrant issuance.
**Issues:**
1. Was there grave abuse of discretion by DOJ and Judge Alameda in filing the information and issuing the arrest warrant?
2. Did Napoles have an adequate remedy in the ordinary course of law to address her grievances regarding probable cause?
**Court’s Decision:**
– The Supreme Court denied the petition as moot due to the trial court’s conviction of Napoles for serious illegal detention.
– **On Filing Information:** The Court found no abuse in the prosecutor’s discretion, as the Review Resolution thoroughly justified the reversed probable cause finding.
– **On Warrant Issuance:** Judge Alameda’s issuance of the arrest warrant was not done in haste and complied with constitutional requirements, independently evaluating evidence before deciding on probable cause.
**Doctrine:**
– The determination of probable cause is an executive function concerning filing information, subject to judicial review only for grave abuse of discretion.
– The trial court has jurisdiction over a criminal case upon the filing of an information; any previous procedural issues become moot post-conviction.
– Judicial determination of probable cause, for issuing a warrant, requires personal evaluation by judges based on supporting evidence, independent of prosecutorial findings.
**Class Notes:**
– **Serious Illegal Detention Elements:** Private individual detains another without legal authority for more than three days.
– **Probable Cause in Filing Information:** Must establish a well-founded belief of crime and probable guilt, primarily an executive function.
– **Probable Cause in Warrant Issuance:** Judges must evaluate evidence personally before issuing warrants independently.
– **Legal Statute:** Article 267 of the Revised Penal Code for serious illegal detention.
**Historical Background:**
This case arose amid the highly publicized “pork barrel scam” in the Philippines, where government officials and private individuals were implicated in misusing public funds. Janet Lim Napoles became infamous as the alleged mastermind, heightening public scrutiny, leading to her prosecution and further reforms in handling government allocations.
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