Manangan v. Court of First Instance of Nueva Vizcaya, Branch 28
REITERATIONFacts
The Antecedents: Petitioner, claiming to be Filemon Manangan, was appointed Legal Officer I of the Bureau of Lands. A criminal case (Criminal Case No. 639) was filed against him for "Execution of Deeds by Intimidation" under Article 298 of the Revised Penal Code. An arrest warrant was issued. Petitioner filed a petition for Certiorari, Prohibition, and Mandamus with this Court, which was dismissed for non-payment of fees. Petitioner disappeared for about a year. A Second Amended Information identified the accused as Andres Culanag (alias Andres M. Culanag, Filemon Manangan, etc.). Petitioner later posted bail in Zamboanga del Sur. An alias warrant of arrest was issued by the respondent Court, which is the subject of the present petition. Petitioner filed various motions and petitions before the Court of Appeals and the respondent Court, including claims that the accused had died and that the Sandiganbayan had exclusive jurisdiction. These were consistently denied. Procedural History: The Court of Appeals dismissed petitioner's petitions, citing lack of legal and factual basis and res judicata. The respondent Court initially ordered the promulgation of judgment but later vacated it, stating the alias warrant remained in full force. The respondent Court refused to declare the case closed and terminated, noting the accused posted bail in 1979. The Intermediate Appellate Court dismissed a petition by the alleged heirs, holding the issue of grave abuse of discretion was res judicata. Petitioner filed an Omnibus Motion with Motion for New Trial, which was denied. A Motion to Quash was filed on grounds of lack of jurisdiction and double jeopardy. The Petition: The present Petition for Certiorari seeks to annul the proceedings in Criminal Case No. 639, including the alias warrant of arrest, alleging grave abuse of discretion for making it appear petitioner was tried and convicted when he was not, and for the irregular issuance of the alias warrant. Petitioner also claimed the Sandiganbayan had exclusive jurisdiction.
Issue(s)
Whether the respondent Court committed grave abuse of discretion in issuing the alias warrant of arrest, and whether the alias warrant of arrest is stale or functus officio. Whether the respondent Court committed grave abuse of discretion in not dismissing Criminal Case No. 639, and whether jeopardy had attached. Whether the Sandiganbayan has exclusive jurisdiction over Criminal Case No. 639. Whether petitioner is a fictitious person and guilty of contempt of court. Whether the petitions should be dismissed and the directive to proceed with the criminal case is proper.
Ruling
The Petition, Amended Petition, and Second Amended Petition are dismissed for utter lack of merit. Petitioner is adjudged in contempt of court, severely censured, and sentenced to suffer three (3) months imprisonment. Respondent Court is directed to retrieve Criminal Case No. 639 from its archives and proceed with its determination. All Courts are directed not to recognize any person representing himself as Filemon Manangan, Atty. Filemon Manangan, or Atty. Benjamin M. Facun. Petitioner's real name is declared to be Andres Culanag.
Ratio Decidendi
On the issuance of the alias warrant of arrest and its validity: The alias warrant of arrest is valid. Petitioner had evaded arrest. The respondent Court did not commit grave abuse of discretion in holding that the alias warrant was in full force and effect. The petitioner's resort to a petition for certiorari was premature. On the alleged grave abuse of discretion in not dismissing the criminal case and the attachment of jeopardy: While there may have been initial confusion on the part of the respondent Court, it was timely rectified. No jeopardy had attached, and therefore, no grave abuse of discretion could be attributed to the respondent Court. The various petitions filed by the petitioner seeking dismissal had been consistently denied. On the jurisdiction of the Sandiganbayan: The argument that the Sandiganbayan has exclusive jurisdiction is without merit. The petitioner was ineligible for the position. These findings negate the claim that the offense was committed in relation to his office. On petitioner being a fictitious person and guilty of contempt: The evidence overwhelmingly established that petitioner, claiming to be Filemon Manangan, is an impostor and is, in fact, Andres Culanag. He used the qualifications and bar admission of the real Filemon Manangan to secure his position. He had previously been found guilty of indirect contempt of court. His continued misrepresentation and fraudulent conduct impede the administration of justice. The contumacious acts were ongoing, thus, the action for contempt had not prescribed. On the dismissal of the petitions and the directive to proceed: The petitions were dismissed for utter lack of merit due to the petitioner's abuse of court processes and deceptive practices. The respondent Court was directed to retrieve the criminal case and proceed with its determination. All courts were ordered not to recognize any person representing himself as Filemon Manangan, Atty. Filemon Manangan, or Atty. Benjamin M. Facun, and the petitioner's real name was declared to be Andres Culanag.
Main Doctrine
A party who resorts to multiple, repetitive, and vexatious litigation, employing deceptive practices and misrepresentations to obstruct the administration of justice, may be held in contempt of court. Furthermore, an alias warrant of arrest remains valid until arrest is effected or the warrant is lifted, and its issuance is not rendered stale or functus officio by the mere passage of time or the filing of a property bond not accepted by the issuing court. Resort to higher courts is premature when a plain, speedy, and adequate remedy exists in the ordinary course of law, such as awaiting the resolution of a pending motion to quash.