was denied by the Sandiganbayan.

He then !led a petition for certiorari, alleging grave abuse of discretion

on the part of the Sandiganbayan.

Issue:
QR Link
Title Whether the Sandiganbayan gravely abused its discretion in denying
Baya vs. Sandiganbayan, 2nd Division Baya's motion for judicial determination of probable cause.

Whether Baya's right to due process and speedy disposition of cases

Case Ponente Decision Date
was violated.
G.R. No. 204978-83 LEONEN, J Jul 6, 2020

Ruling:
The case involves two separate petitions for certiorari !led by Ignacio The Sandiganbayan denied Baya's motion for judicial determination of
C. Baya and Peter Bejarasco, Jr., challenging the denial of their
probable cause.
motions for judicial determination of probable cause and alleging
violations of their right to due process and speedy disposition of The court found that there was no violation of Baya's right to due
cases, but the Supreme Court ruled in both cases that there was no process and speedy disposition of cases.
grave abuse of discretion and no violation of their rights.
Ratio:

Failure to furnish a copy of the resolution recommending the !ling of

information against the respondent does not invalidate the
information already !led in court.
Case Digest
The right to speedy disposition of cases is a "exible concept and
Facts: depends on the peculiar circumstances of the case.
Ignacio C. Baya, a Board Member of the Sangguniang Panlalawigan of There was no inordinate delay in the resolution of the case.
Zamboanga Sibugay, was charged with malversation of public funds
Baya failed to !le a timely motion for reconsideration and had several
and violation of the Anti-Graft and Corrupt Practices Act.
remedies available to him inAsk
theAI
ordinary course of law.
The charges were based on his alleged request for reimbursement for
There was no violation of Baya's right to due process and speedy
funds given to !ctitious bene!ciaries in the "Aid to the Poor" program.
disposition of cases.
Baya !led a motion for judicial determination of probable cause, which
Facts:

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 Petitioner Peter Bejarasco, Jr. failed to !le a Petition for Review before Bejarasco never asserted his right to speedy disposition of cases
the Court of Appeals within the extended period prayed for. during the preliminary investigation.

His conviction for grave threats and grave oral defamation became There were no allegations of prejudice su#ered by Bejarasco.
!nal, and a warrant for his arrest was issued.
Issue:
Bejarasco argued that his counsel's negligence in failing to !le the
appeal deprived him of due process. Whether Bejarasco's right to speedy disposition of cases was violated.

Issue: Ruling:

Whether Bejarasco's counsel's negligence deprived him of due The court found that there was no violation of Bejarasco's right to
process. speedy disposition of cases.

The length of the preliminary investigation was deemed reasonable

Ruling: considering the complexity of the case and the number of persons
The Supreme Court rejected Bejarasco's argument. charged.

The court ruled that it is the client's duty to be in contact with his Bejarasco never asserted his right to speedy disposition of cases
lawyer and be informed of the progress and developments of his case. during the preliminary investigation.

Bejarasco took almost seven years to !le a petition before the court, There were no allegations of prejudice su#ered by Bejarasco.
and his failure to know or !nd out the real status of his appeal
rendered him undeserving of any sympathy from the court. Ratio:

The right to speedy disposition of cases protects citizens from

Ratio: vexatious, capricious, and oppressive delays in the conduct of any case
It is the client's duty to be in contact with his lawyer and be informed !led against them.
of the progress and developments of his case. Violation of this right can result in the dismissal of the case, with
Bejarasco's failure to know or !nd out the real status of his appeal prejudice.
rendered him undeserving of any sympathy from the court.
Factors to determine inordinate delay include the length of delay, the
reason for the delay, the respondent's assertion of the right, and
Facts:
prejudice to the respondent.
Bejarasco !led a petition for certiorari before the Supreme Court,
There was no violation of Bejarasco's right to speedy disposition of
arguing that his right to speedy disposition of cases was violated.
cases.
The preliminary investigation lasted six years and six months.

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 Facts: Graft and Corrupt Practices Act.

Bejarasco !led a motion for judicial determination of probable cause,

which was denied by the Sandiganbayan.

He argued that the Sandiganbayan gravely abused its discretion in

denying his motion.

Issue:

Whether the Sandiganbayan gravely abused its discretion in denying

Bejarasco's motion for judicial determination of probable cause.

Ruling:

The court ruled that the Sandiganbayan did not gravely abuse its
discretion in denying Bejarasco's motion.

The executive determination of probable cause during preliminary

investigation is within the exclusive domain of the prosecutor.

Absent grave abuse of discretion, this determination cannot be

interfered with by the courts.

Ratio:

The executive determination of probable cause during preliminary

investigation is within the exclusive domain of the prosecutor.

Absent grave abuse of discretion, this determination cannot be

interfered with by the courts.

Conclusion:

The Supreme Court dismissed Bejarasco's petition, !nding no violation

of his right to due process and right to speedy disposition of cases.

The court upheld the !nding of probable cause against Bejarasco for
malversation of public funds and violation of Section 3 (e) of the Anti-

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 Espeleta !led urgent motion for reinvestigation, claiming preliminary
investigation was conducted hastily

RTC arraigned both Espeleta and Canicon without resolving motion

for reinvestigation

QR Link Reinvestigation conducted by Assistant Provincial Prosecutor,

Title recommending dismissal of case against Espeleta and !ling of
Rural Bank of Mabitac, Laguna, Inc. vs. Canicon amended information

RTC granted motion and admitted amended information, dropping

Case Ponente Decision Date
Espeleta from list of accused
G.R. No. 196015 JARDELEZA, J Jun 27, 2018
Another judge issued resolution recalling and setting aside September
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17, 2003 Order, ruling reinvestigation conducted without judicial
A petition for review on certiorari is !led by a bank against two
imprimatur is nullity
accused individuals, leading to a legal battle over the dismissal of
charges and violation of double jeopardy rights. RTC reinstated September 17, 2003 Order, !nding public prosecutor
has sole discretion to decide whether to indict a person and reinstating
charge against Espeleta would violate her right against double
jeopardy

Case Digest
Issue:

Facts: 1. Whether petitioner has standing to !le petition without conformity of

O"ce of the Solicitor General (OSG)
Petition for review on certiorari !led by Rural Bank of Mabitac,
Laguna, Inc. (petitioner) against Melanie M. Canicon and Merlita L. 2. Whether present petition places Espeleta in double jeopardy
Espeleta (respondents) 3. Whether trial court committed grave abuse of discretion in issuing
Criminal complaint for estafa !led against Canicon, Espeleta, and October 23, 2007 Order
Aguilar
Ruling:
Case transferred to the Regional Trial Court (RTC) of San Pedro,
Supreme Court granted the petition and set aside decision of Court of
Laguna
Appeals (CA)
RTC issued warrant for arrest of all three accused, but only Canicon
Petitioner has standing to !le petition without conformity of OSG, as
and Espeleta were arrested

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 private complainant retains right to bring special civil action for
certiorari in own name in criminal proceedings before courts of law

Present petition does not place Espeleta in double jeopardy, as

previous dismissals of criminal case against her did not attach
jeopardy

Trial court committed grave abuse of discretion in issuing October 23,

2007 Order

Trial court failed to make independent determination or assessment of

merits of motion to amend information, which is required when
information is !led in court

Case remanded to trial court to resolve motion for leave to amend

information and to admit amended information, stating reason or
reasons for its resolution after due consideration of evidence of
parties.

[Link] 3/16/24, 3:40 AM

Page 3 of 3
 Court granted the petitioner's motion for an extension and noted the
compliance

Court ordered the respondents to !le a comment on the petition within

ten days from notice
QR Link Petitioner instructed to furnish a copy of the petition and its annexes,
Title which consisted of 493 pages, to the O"ce of the Solicitor General
Yokohama Tire Philippines, Inc. vs. Reyes
O"ce of the Solicitor General ordered to !le a comment within the
same period
Case Ponente Decision Date
G.R. No. 236686 N/A Oct 17, 2018 Court held in abeyance the proceedings before the Municipal Trial
Court of Clark!eld, Pampanga, Angeles City in Criminal Case No. 12-
5960
The Court grants an extension to Yokohama Tire Philippines, Inc. to Ask AI
comply with a resolution, while holding the proceedings in abeyance Criminal case involved an attempted theft charge under Article 308 of
to determine the admissibility of con!scated items in a criminal case, the Revised Penal Code
based on the issue of unreasonable searches and seizures.
Abeyance was due to the unresolved issue of the admissibility of
petitioner Yokohama Tire Philippines, Inc.'s Exhibits "L" to "Y"

Exhibits consisted of fourteen pieces of Hewlett Packard Printer Ink

Cartridges, allegedly con!scated from the respondents
Case Digest
Admissibility of the con!scated items would be determined based on
the resolution of the issue of unreasonable searches and seizures,
Facts:
which is a violation of the respondents' constitutional right
Yokohama Tire Philippines, Inc. is the petitioner

Sandra Reyes and Jocelyn Reyes are the respondents Issue:

Resolution issued by the Third Division of the Court on October 17, The main issue raised in the case is the admissibility of the con!scated
2018 items in a criminal case, speci!cally the fourteen pieces of Hewlett
Packard Printer Ink Cartridges
Petitioner sought an extension of ten days from June 19, 2018, to
comply with a resolution dated April 23, 2018 The issue is held in abeyance pending the resolution of the issue of
unreasonable searches and seizures
Resolution required the petitioner to submit a certi!ed true copy of the
!rst page of the assailed Decision dated July 10, 2017

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 Ruling:

The Court granted the petitioner's motion for an extension of ten days
to comply with the resolution requiring the submission of a certi!ed
true copy of the !rst page of the assailed Decision

The Court ordered the respondents to !le a comment on the petition

within ten days

The O"ce of the Solicitor General was ordered to !le a comment

within the same period

Regarding the criminal case, the Court held the proceedings in

abeyance until the !nal resolution of the issue of the admissibility of
the con!scated items

Ratio:

The Court's decision to grant the petitioner's motion for an extension is

based on the interest of justice

The Court recognizes the need for the petitioner to comply with the
resolution and notes the compliance

In holding the proceedings in abeyance, the Court acknowledges the

importance of resolving the issue of unreasonable searches and
seizures

The Court emphasizes that the admissibility of the con!scated items in

the criminal case is dependent on the resolution of this issue

This decision is in line with protecting the respondents' constitutional

right against unreasonable searches and seizures.

[Link] 3/16/24, 3:41 AM

Page 3 of 3
 physical and psychological su!ering and injury.

The trial court found Villarba guilty and ordered him to pay
compensatory damages, moral damages, and attorney's fees to Dordas.

Issue:
QR Link
Title Whether the amendment to the information was substantial and
Villarba vs. Court of Appeals whether Villarba's right to be informed of the nature and cause of the
accusation against him was violated.
Case Ponente Decision Date
Whether the information was su"cient and whether the prosecution
G.R. No. 227777 LEONEN, J Jun 15, 2020
su"ciently proved Villarba's guilt.

Omar Villarba is convicted for violating the Anti-Hazing Act after Ruling:
subjecting Wilson Dordas III to hazing, resulting in physical and
The amendment to the information was not substantial and did not
psychological su!ering, and the Supreme Court a"rms his
require a second arraignment. It did not change the crime charged or
conviction, ruling that the amendment to the information was not
a!ect Villarba's defense.
substantial and the evidence against him was su"cient.
The information was su"cient as it adequately apprised Villarba of the
o!ense charged. The lack of speci#c language regarding the acts as a
prerequisite for admission to the fraternity did not invalidate the
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information.
Case Digest
The prosecution su"ciently proved Villarba's guilt through the
Facts: credible testimony of Dordas, who provided a detailed and categorical
narration of the hazing incident. The lower courts' #ndings on witness
Omar Villarba was convicted for violating the Anti-Hazing Act after
credibility are entitled to great weight and respect.
subjecting Wilson Dordas III to hazing, resulting in physical and
psychological su!ering.
Ratio:
Villarba was a member of the Junior Order of Kalantiao, a fraternity
A formal amendment does not change the crime charged or a!ect the
based in the Central Philippine University in Iloilo City.
accused's defense. It adds nothing crucial for a conviction as to deprive
The original information charged Villarba and other members of the the accused of the opportunity to meet the new information. A second
fraternity with subjecting Dordas to hazing or initiation, resulting in arraignment is not necessary for a formal amendment.

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 The information need not reproduce the law verbatim in alleging the
acts or omissions that constitute the o!ense. As long as its language is
understood, the accused's constitutional right to be informed of the
nature and cause of the accusation against them stands unviolated.

The factual #ndings of the trial court, especially on witness credibility,

are binding unless substantial facts were overlooked,
misapprehended, or misinterpreted. The testimony of a single witness
may su"ce for conviction if it is deemed credible. Mere denial is
inherently a weak defense and cannot be accorded greater evidentiary
weight than the declaration of credible witnesses.

[Link] 3/16/24, 3:41 AM

Page 3 of 3
 arraignment.

Issue:

Whether the identi!cation made by the prosecution witnesses is

reliable and su"cient to establish the guilt of the accused beyond
QR Link
reasonable doubt.
Title
People vs. Nuñez
Ruling:

Case Ponente Decision Date The Court found that the identi!cation made by the prosecution
G.R. No. 209342 LEONEN, J Oct 4, 2017 witnesses was not reliable and failed to meet the threshold of proof
beyond reasonable doubt.

In the case of People v. Nuñez, the Court !nds the identi!cation made The Court reversed the decision of the Court of Appeals and acquitted
by the prosecution witnesses unreliable, leading to the acquittal of the accused. Ask AI
the accused due to reasonable doubt.
Ratio:

The Court pointed out several factors that raised doubts about the
reliability of the identi!cation made by the prosecution witnesses.

Case Digest Cruz initially admitted to not being able to remember the appearance
of the fourth robber, but later implicated Nuñez as the perpetrator.
Facts:
A signi!cant amount of time had passed since the incident, which
The case involves a robbery with homicide incident that occurred at a could a#ect the accuracy of the witnesses' recollection.
Caltex gasoline station on June 22, 2000.
The identi!cation of Nuñez was made after his arrest and in a context
Two witnesses, Ronalyn Cruz and Relen Perez, claimed to have that practically induced witnesses to identify him as the culprit.
witnessed the crime.
Inconsistencies were found in the testimonies of Cruz and Perez
Cruz initially admitted to not being able to remember the appearance regarding the participation of Nuñez in the crime.
of the fourth robber involved in the incident.
The Court emphasized that the conviction of an accused should be
During the trial, both Cruz and Perez identi!ed the accused, Crisente based on the certainty and accuracy of the identi!cation made at the
Pepaño Nuñez, as one of the perpetrators. initial opportunity.
Nuñez's identi!cation came after his arrest and was made during his

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 The identi!cation of Nuñez failed to withstand the totality of
circumstances test, as there were de!ciencies and doubts regarding
the witnesses' opportunity to observe the fourth robber and their
degree of attentiveness during the crime.

The Court considered the danger signals identi!ed in jurisprudence,

which were present in this case, further casting doubt on the reliability
of the identi!cation.

The Court concluded that it could not come to a conscientious

satisfaction of Nuñez's guilt and acquitted him for reasonable doubt.

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Page 3 of 3
 The information did not provide speci!c facts and circumstances
describing how treachery attended the killing.

Issue:

Whether the accused-appellant can be held guilty of murder if the

QR Link
information did not give him due notice of what he was being charged
Title
with.
People vs. Solar y Dumbrique

Ruling:
Case Ponente Decision Date
G.R. No. 225595 CAGUIOA, J Aug 6, 2019 The accused-appellant's conviction for murder is a"rmed.

The accused-appellant had waived his right to question the defects in

Accused-appellant found guilty of murder, but conviction the information.
downgraded to homicide due to lack of speci!c facts on treachery in
The accused-appellant is deemed to have understood the acts imputed
the information; court rules that accused-appellant waived his right
against him by the information.
to question defects in the information and establishes guidelines for
prosecutors to properly allege qualifying and aggravating
Ratio:
circumstances. Ask AI
The accused-appellant had the opportunity to clarify any unclear
matters during arraignment.

The right to be informed of the charges against the accused continues

until the accused is formally arraigned.
Case Digest
The procedure requiring speci!c details of the qualifying or
Facts: aggravating circumstance in the information shall apply only to
Accused-appellant Rolando Solar y Dumbrique was found guilty of pending and future criminal cases.

murder.
Additional Information:
The Court of Appeals (CA) a"rmed the conviction but downgraded the
The Court established guidelines for prosecutors to properly allege
o#ense to homicide.
qualifying and aggravating circumstances in the information to ensure
The information !led against the accused-appellant alleged conspiracy that the accused is su"ciently informed of the charges against him.
to attack and assault the victim, resulting in his death.

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[Link] 3/16/24, 3:42 AM
Page 3 of 3
 QR Link

Title
Palacios vs. People

Case Ponente Decision Date

G.R. No. 240676 PERLAS- Mar 18, 2019
BERNABE, J

In the case of Palacios v. People, the Supreme Court ruled in favor of

petitioner Jimmy Lim Palacios, stating that he was denied due
process when he was not given notice of the charges against him and
the opportunity to participate in the preliminary investigation,
ordering the suspension of the case pending completion of the
investigation.

Case Digest

Facts:

Petitioner Jimmy Lim Palacios !led a petition for review on certiorari

after the Court of Appeals upheld the denial of his motion for
preliminary investigation and to recall warrant of arrest.

The case originated from a complaint !led by the respondent, Ramirez,

against Palacios for violation of the Anti-Violence against Women and
Their Children Act of 2004.

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Page 1 of 3
:
 Ramirez alleged that Palacios abandoned her and their son and
refused to provide !nancial support.

The complaint was !led before the O"ce of the City Prosecutor in
Quezon City.

The investigating prosecutor found probable cause and !led an

Information before the Regional Trial Court (RTC), which issued a
warrant for Palacios' arrest.

Issue:

Whether the Court of Appeals erred in upholding the denial of

Palacios' motion for preliminary investigation and to recall warrant of
arrest.

Ruling:

The Supreme Court ruled in favor of Palacios.

The Court held that preliminary investigation is a crucial stage in

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criminal proceedings as it determines whether there is su"cient
ground to believe that a crime has been committed and the respondent
is probably guilty.

It is a constitutional right of the accused to be noti!ed and given an

opportunity to participate in the preliminary investigation.

Palacios claimed that he was not given notice of the proceedings and
was not able to participate due to Ramirez providing the wrong
address in her complaint.

The Court found that there was no proof that Palacios had been duly
noti!ed of the charges against him or served with a subpoena for the
preliminary investigation.

The burden of proving notice rests on the party asserting its existence,
and in this case, the respondent failed to provide such proof.

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Page 2 of 3
:
 Therefore, the Court concluded that Palacios was denied due process
and should be given the opportunity to submit counter-a"davits and
evidence in a preliminary investigation.

The Court ordered the suspension of the case pending the completion
of the preliminary investigation.

Ratio:

The Court emphasized the importance of preliminary investigation as

a substantive right of the accused.

The denial of Palacios' motion for reinvestigation based on procedural

grounds was unjust, as the right to preliminary investigation is not
merely formal or technical.

The Court highlighted the need for proper notice to the accused in
order to a#ord them the opportunity to participate in the proceedings
and present their side.

The certi!cation in the Information by the investigating prosecutor,

stating that the accused was informed of the complaint and evidence
against him, was deemed insu"cient in the absence of notice to the
accused.

The certi!cation is merely pro forma and does not enjoy the
presumption of regularity.

Therefore, the Court reversed the decision of the Court of Appeals and
ordered the conduct of a preliminary investigation, suspending the
case until its completion.

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: