Subject: Law on Legal Processes

Topic: Criminal Procedure

digest this case with format of 4 sentences for facts 1 sentences for issue and 3
sentences for ruling in a paragraph form for each where the issue start with whether
or not and the ruling start whether the answer is yes or no

Beltran vs. People (G.R. No. 137567; June 20, 2000)

Case Digest: G.R. No. 137567 (June 20, 2000)
Facts:

Meynardo L. Beltran and Charmaine E. Felix were married on June 16, 1973, and
they had four children. After 24 years of marriage, Beltran filed a petition for nullity of
marriage on February 7, 1997, claiming psychological incapacity under Article 36 of
the Family Code. In response, Charmaine filed a criminal complaint for concubinage
against Beltran and his paramour, leading to Criminal Case No. 236176 in the
Metropolitan Trial Court of Makati City. Beltran sought to defer the criminal
proceedings, arguing that the civil case posed a prejudicial question, but the trial
court denied his motions.
Issue:
Whether or not the pendency of the civil case for nullity of marriage should suspend
the criminal case for concubinage to avoid conflicting judicial outcomes.
Ruling:
No, the Supreme Court ruled that the civil case for nullity does not present a
prejudicial question to the concubinage case, as the resolution of the civil matter does
not determine the guilt or innocence in the criminal case. The Court stated that until a
court formally declares the marriage void, the presumption remains that it exists, and
cohabiting with another woman before such a declaration subjects one to prosecution
for concubinage. Consequently, the petition was dismissed for lack of merit, affirming
the decisions of the lower courts.

People v. Camenforte (G.R. No. 220916, 14 June 2021)

Facts
Conflicts arose when the Granda spouses sold their land to different individuals by
deeds executed on December 7, 1985. Over a decade after the Granda spouses sold
this property, her grandson Rafael argued that the documents used in those
transactions weren't authentic. Criminal cases against various people were initiated
but only those against Camenforte and Silvina moved forward. Meanwhile, the lawsuit
aimed at reversing the sales was declared as final and binding. Eventually, all the
remaining criminal cases were dismissed by the RTC. The court’s decision was upheld
at the CA level following a challenge by the Solicitor General.
Issue
Whether the principle of res judicata applies to bar the prosecution in the pending
criminal cases.
2. Whether a prejudicial question exists due to the final and executory decision of the
civil case, thereby preventing the continued prosecution of the criminal cases.
Ruling
The Court dismissed the appeal and affirmed the decision of the appellate court but
noted some alterations. Although cases related to the same acts couldn't be relitigated,
an essential fact had been definitively settled. The outcome of the civil case determined
that the signature was valid, therefore the criminal cases could no longer proceed.
Consequently it was justifiable to dismiss the criminal charges against Camenforte
and Lastrilla.
Shu vs. Dee (G.R. No. 182573, April 23, 2014)
Case Digest: Ray Shu vs. Jaime Dee et al.
Facts:

Ray Shu, the President of 3A Apparel Corporation, accused employees of Metrobank of

falsifying mortgage deeds, which resulted in the foreclosure of properties securing a
loan. Following an investigation by the NBI, the City Prosecutor of Makati found no
probable cause and dismissed Shu's complaint based on a Questioned Documents
Report that indicated discrepancies in the signatures. Shu appealed this dismissal to
the Secretary of Justice, who reversed the decision, finding probable cause for
falsification. The respondents then appealed to the Court of Appeals (CA), claiming a
denial of due process during the investigations, leading the CA to side with them and
void the Secretary of Justice’s resolution.

Issue:

Whether or not there was a denial of due process in the proceedings at the NBI and
the Secretary of Justice.

Ruling:

No, the Supreme Court ruled that there was no denial of due process at either the NBI
or the Secretary of Justice levels, as the opportunity to be heard was maintained
throughout the process. Yes, the Court found that the CA's conclusion of due process
violations was unsupported, particularly since the respondents had avenues for
redress, including motions for reconsideration. Additionally, the Court clarified that
the Secretary of Justice did not commit grave abuse of discretion and affirmed her
right to review the City Prosecutor's findings, emphasizing that the determination of
probable cause requires only a prima facie showing of guilt rather than absolute
certainty.
Honasan II vs. DOJ Panel (G.R. No. 159747, April 13, 2004)
Case Digest: Honasan vs. Panel of Investigating Prosecutors of the DOJ et al.
Facts:

On August 4, 2003, Eduardo Matillano, Director of the CIDG-PNP, filed an

affidavit-complaint against Senator Gregorio Honasan II, accusing him of committing a
coup d'état related to events on June 4 and July 27, 2003. The June 4 meeting
involved Honasan and military personnel discussing the National Recovery Program
(NRP) and strategies to implement it, including the use of violence, culminating in a
blood compact. Following this, on July 27, military rebels publicly declared a coup
attempt, citing Honasan's NRP, leading to the DOJ's investigation despite Honasan's
jurisdictional challenges.

Issue:

Whether or not the DOJ Panel has jurisdiction to conduct the preliminary
investigation over the charge of coup d'état against Honasan.

Ruling:

Yes, the Supreme Court ruled that the DOJ Panel had the authority to investigate the
charges under the Administrative Code of the Philippines and Presidential Decree No.
1275, establishing concurrent jurisdiction with the Ombudsman. The Court found
that the Ombudsman did not possess exclusive authority over such cases, allowing
DOJ prosecutors to conduct preliminary investigations. Additionally, the Court
determined that there was no grave abuse of discretion by the DOJ Panel in its
procedural handling, including the decision to continue the investigation while
addressing jurisdictional issues.
Luz vs. People (G.R. No. 197788, February 29, 2012)
Case Digest: Rodel Luz y Ong vs. People of the Philippines
Facts:

Rodel Luz y Ong was apprehended on March 10, 2003, for riding a motorcycle without
a helmet, violating a municipal ordinance in Naga City. During the stop, police officer
PO2 Emmanuel L. Alteza invited Luz y Ong to the police sub-station for a citation,
where he noticed Luz y Ong's nervous behavior and asked him to empty his jacket
pocket, revealing a metal container with four plastic sachets, two of which tested
positive for shabu (methamphetamine). Luz y Ong was arraigned and found guilty of
illegal possession of dangerous drugs, a decision later upheld by the Court of Appeals.

Issue:

Whether or not the search and seizure of the shabu were invalid.

Ruling:

Yes, the Supreme Court ruled that the search and seizure were invalid, reversing the
Court of Appeals' decision and acquitting Luz y Ong. The Court determined that there
was no valid arrest stemming from the traffic violation, rendering the subsequent
warrantless search illegal. It emphasized that a lawful arrest is a prerequisite for any
valid warrantless search, thereby dissecting the legal framework surrounding such
arrests and searches in the context of traffic violations.
Rolito Go vs. CA (G.R. No. 101837, February 11, 1992)
Case Digest: Rolito Go v. Court of Appeals, et al.
Facts:

The case involves Rolito Go, who fatally shot Eldon Maguan during a traffic altercation
on July 2, 1991, in San Juan, Metro Manila. After voluntarily presenting himself at
the police station on July 8, 1991, he was identified as the shooter by an eyewitness,
and following Maguan's death on July 9, a murder complaint was filed against Go.
Despite filing a motion for preliminary investigation after his arrest, the trial court
initially granted bail but later recalled it, leading to a series of legal proceedings
culminating in Go's contention that his warrantless arrest was unlawful and his right
to a preliminary investigation had been violated.

Issue:

Whether or not Go’s warrantless arrest was lawful.

Ruling:

No, the Supreme Court declared Go’s warrantless arrest invalid, stating it did not meet
the necessary requirements under Rule 113 of the Rules of Court. The Court also held
that Go did not waive his right to a preliminary investigation by merely posting bail
and participating in trial proceedings. Emphasizing the importance of the right to a
preliminary investigation as part of due process, the Supreme Court ordered that it be
conducted before any further trial proceedings could take place.
People vs. Andan (G.R. No. 116437; March 06, 1997)
Here’s a digest of the case "The People of the Philippines vs. Pablito Andan y
Hernandez" following your requested format:

Facts
On February 19, 1994, Pablito Andan y Hernandez, alias "Bobby," was accused of
raping and murdering a 20-year-old woman, AAA. The crime occurred when AAA was
lured into his home under the pretext of checking on a relative's health, where he then
assaulted her. After the act, he attempted to conceal his crime by inflicting fatal
injuries on her body with a concrete block and abandoning her in a vacant lot. The
subsequent investigation revealed bloodstains in his backyard and led to his
confession, which he later recanted, claiming coercion by police.

Issue
Whether or not the confession obtained from the appellant was admissible in court
given the claims of coercion.

Ruling
The answer is yes, the confession was deemed admissible despite the appellant's
claims of coercion. The court found that the confession was made voluntarily in the
presence of witnesses, including the mayor, and was corroborated by physical
evidence linking him to the crime. Consequently, the trial court convicted him of rape
with homicide, sentencing him to death and ordering him to pay damages to the
victim's heirs.
People vs. Malngan (G.R. No. 170470; September 26, 2006)
Here’s a digest of the case "People of the Philippines vs. Edna Malngan y Mayo" in the
requested format:

Facts
Edna Malngan y Mayo was accused of setting fire to her employer's house, resulting in
the deaths of six individuals, including the employer and his family, on January 2,
2001. Witnesses saw Edna leaving the scene in a suspicious manner shortly before the
fire was discovered. After her apprehension by the Barangay Chairman, a lighter was
found in her possession, and she allegedly confessed to the act, citing unpaid wages
and mistreatment. Despite pleading "Not Guilty," the Regional Trial Court found her
guilty of "Arson with Multiple Homicide" and sentenced her to death, a ruling later
modified by the Court of Appeals.

Issues
Whether or not the circumstantial evidence was sufficient for a conviction beyond a
reasonable doubt, and the legality of the confessions obtained without counsel.

Ruling
The answer is yes, the circumstantial evidence established an unbroken chain of guilt
against Edna. The Supreme Court ruled that while the uncounselled confession to the
Barangay Chairman was inadmissible, the confession made outside of custodial
context was admissible. Ultimately, Edna was found guilty of simple arson, leading to
a modification of her sentence to reclusion perpetua and adjustments to the civil
damages awarded.
People vs. Judge Ayson (G.R. No. 85215; July 07, 1989)
Here’s a digest of the case "The People of the Philippines vs. Hon. Judge Ruben Ayson
and Felipe Ramos" in the requested format:

Facts
Felipe Ramos, a ticket freight clerk for Philippine Airlines (PAL), was involved in
irregularities related to ticket sales. Prior to an internal investigation, he submitted a
note expressing his willingness to settle the charges. During the investigation, he
made statements that implicated him in misusing ticket sales proceeds. These
statements were later used to file charges of estafa against him. Upon arraignment,
Ramos pleaded not guilty, and his statements were presented as evidence. The defense
objected, arguing that Ramos was not informed of his rights during the investigation,
leading the trial court to rule the statements inadmissible. The prosecution's motion
for reconsideration was denied, prompting them to seek relief from the Supreme
Court.

Issues
Do constitutional rights during custodial interrogation apply to administrative
investigations by private employers?
Are Ramos's statements during the PAL investigation admissible in a criminal trial?
How should the right against self-incrimination be applied in this context?
Court’s Decision
The Supreme Court granted the petition, ruling that Ramos's statements were
admissible. The Court distinguished between two sets of rights: the right against
self-incrimination, which applies in legal proceedings, and specific rights during
custodial interrogation. It found that Ramos was not under custodial interrogation
during the PAL investigation, rendering the protections irrelevant. The Court
emphasized the voluntary nature of his statements and upheld his criminal liability
admission.
Rosete vs. Lim (G.R. No. 136051; June 08, 2006)
Here’s a concise digest of the case "G.R. No. 136051 Alfredo P. Rosete vs. Juliano Lim":

Facts
Petitioners Alfredo P. Rosete, Oscar P. Mapalo, and Chito P. Rosete challenged the
Court of Appeals' decision allowing the taking of their depositions in a civil case filed
by Juliano and Lilia Lim. The petitioners argued that their depositions would violate
their right against self-incrimination, as they were also defendants in related criminal
cases.

Issues
Does the right against self-incrimination apply to depositions in civil cases when the
deponents are also facing criminal charges?
Was it correct for the trial court to allow depositions without leave of court?
Court's Decision
The Supreme Court dismissed the petition, ruling that:The right against
self-incrimination does not exempt petitioners from giving depositions in a civil case.
They can only refuse to answer specific incriminating questions. The depositions could
be taken without leave of court since the petitioners had already served their answers,
even if filed ex abudanti cautela. The Court clarified that the civil nature of the case
did not provide grounds for refusing to testify.
People vs. Pagal (G.R. No. 241257; September 29, 2020)
Facts
Brendo P. Pagal was indicted for the murder of Selma Pagal, pleading guilty during his
arraignment on August 20, 2009. The trial court proceeded to determine his culpability,
but the prosecution failed to present any witnesses despite multiple subpoenas.
Consequently, the RTC convicted Pagal based solely on his guilty plea and sentenced him
to reclusion perpetua. Pagal appealed, arguing that his conviction was improper due to the
lack of evidence.

Procedural History
The Court of Appeals recognized a procedural flaw regarding Pagal's plea of guilt to a
capital offense and remanded the case to the RTC for further proceedings. Pagal then
elevated the matter to the Supreme Court for review.

Issues
Did the trial court err in convicting Pagal based solely on his plea of guilt without evidence
from the prosecution?
What are the legal consequences of a conviction based solely on an improvident plea of
guilt to a capital offense?
What are the procedural steps required when an accused pleads guilty to a capital
offense?
How does the right to a speedy trial apply in this context?
Court's Decision
The Supreme Court set aside the CA's remand order, finding that Pagal's plea of guilt was
improvidently made without proper inquiry into its voluntariness and consequences. The
prosecution had ample opportunity to present evidence but failed to do so. Therefore, the
Court ruled that the lack of evidence, combined with the improper plea, necessitated
Pagal's acquittal based on the presumption of innocence and the right to a speedy
disposition of cases.
Aguilar vs Judge Modesto-San Pedro (November 17, 2010)
Case Digest
Facts:

In August 2004, Jason Ivler was involved in a vehicular accident with the spouses
Evangeline and Nestor Ponce, leading to two separate criminal cases against him in the
Metropolitan Trial Court (MeTC) of Pasig City. Criminal Case No. 82367 charged Ivler with
Reckless Imprudence Resulting in Slight Physical Injuries to Evangeline, to which he
pleaded guilty and received public censure. The second case, Criminal Case No. 82366,
charged him with Reckless Imprudence Resulting in Homicide and Damage to Property
due to the death of Nestor Ponce. Ivler filed a motion to quash the second case, claiming
double jeopardy, which the MeTC rejected, stating there was no identity of offenses.

Issue:

Whether or not Ivler forfeited his standing to seek relief in S.C.A. No. 2803 by not
appearing at the arraignment in Criminal Case No. 82366.

Ruling:

The answer is no; the Court ruled that Ivler did not lose the right to maintain his petition
in S.C.A. No. 2803 due to his non-appearance at the arraignment. The Court distinguished
between the appeal for judgment of conviction and pre-arraignment motions, asserting
that such non-appearance does not automatically divest a defendant of standing.
Furthermore, the Court found in favor of Ivler regarding double jeopardy, emphasizing
that quasi-offenses are singular regardless of outcomes, thereby barring further
prosecution based on the same act of recklessness.