Marantan v. Department of Justice
REITERATIONFacts
The Antecedents: A shootout occurred in Atimonan, Quezon between police and armed forces personnel and 13 armed men. President Aquino ordered the National Bureau of Investigation (NBI) to investigate. Department of Justice (DOJ) Secretary De Lima made public pronouncements. Petitioner Marantan and others requested the investigation be referred to the Office of the Ombudsman. The NBI submitted a report to the President stating criminal charges would be filed. The DOJ convened a Panel of Prosecutors to conduct a preliminary investigation. Marantan filed a motion for inhibition, which was denied. Marantan and co-respondents were subpoenaed. Marantan filed a Petition for Certiorari and Prohibition, alleging lack of impartiality and independence in the DOJ's preliminary investigation. Procedural History: The DOJ Panel of Prosecutors issued an Omnibus Resolution finding probable cause to charge petitioner and others with multiple murder, citing conspiracy, evident premeditation, superior strength, treachery, and aid of armed men. An Information for multiple murder was filed before the Regional Trial Court. The respondents filed their Comment, attaching the Omnibus Resolution and Information. Petitioner filed a Reply and Memoranda. The Supreme Court considered the case moot and academic due to the filing of the Information and the trial court's acquisition of jurisdiction. The Petition: Petitioner sought a writ of certiorari and prohibition to restrain the DOJ from proceeding with the preliminary investigation, to annul DOJ Office Order No. 208, the subpoena, and the denial of his inhibition request, and to direct the DOJ to forward the case records to the Office of the Ombudsman. He argued that DOJ Secretary De Lima's public pronouncements showed prejudgment, violating his right to due process and an impartial tribunal. He also claimed exceptions to the rules on judicial hierarchy and exhaustion of administrative remedies.
Issue(s)
Whether the case constitutes an exception to the rule on judicial hierarchy. Whether the case constitutes an exception to the principle of exhaustion of administrative remedies. Whether the Department of Justice committed grave abuse of discretion in denying petitioner's request for inhibition. Whether the Panel of Prosecutors committed grave abuse of discretion during the preliminary investigation. Whether the case became moot when an Information was filed before the trial court against petitioner.
Ruling
The Supreme Court dismissed the Petition for Certiorari and Prohibition for being moot and academic, and for failure to show that respondents acted with grave abuse of discretion.
Ratio Decidendi
On the issue of judicial hierarchy: The Court held that direct invocation of its original jurisdiction is allowed only for special and important reasons, which were not sufficiently alleged or proven by the petitioner. Petitioner's claim of grave abuse of discretion by the DOJ did not, by itself, constitute an exception to the rule on judicial hierarchy, as such claims fall within the scope of a certiorari petition that could have been filed with the Court of Appeals. The Court found no compelling reason of public welfare, public policy, or the broader interest of justice that would justify bypassing the lower courts. On the issue of exhaustion of administrative remedies: The Court found that petitioner failed to exhaust all administrative remedies, specifically by not filing a motion for reconsideration of the denial of his inhibition request. His claims that such a motion would be useless or that the case was urgent due to the proximity of the preliminary investigation date were deemed speculative and insufficient to warrant an exception to the rule. The Court noted that he could have included his reasons for inhibition in the motion for reconsideration and that preliminary investigations are not meant to be punitive. On the issue of grave abuse of discretion in denying inhibition: The Court found no grave abuse of discretion in the DOJ's refusal to inhibit. Petitioner's reliance on Cojuangco, Jr. v. Presidential Commission on Good Government was misplaced, as the DOJ and NBI were not shown to be interested parties in the same manner as the Commission in that case. The Court distinguished the situation, stating that the NBI's prior investigation does not preclude the DOJ from conducting a preliminary investigation. The public pronouncements of DOJ Secretary De Lima were found to be evolving opinions based on the NBI's investigation and not indicative of bias or ulterior motive against the petitioner. The Court also noted petitioner's refusal to cooperate with the NBI investigation. On the issue of grave abuse of discretion by the Panel of Prosecutors: The Court agreed that while the DOJ Secretary's conduct could have been better, petitioner failed to prove bias or ulterior motives. The Court focused on whether petitioner was fundamentally deprived of an opportunity to be heard and whether the infirmities were fatal. The Panel's findings of probable cause were deemed well-reasoned and evidence-based, detailing irregularities in the checkpoint, the lack of forensic support for a shootout, and evidence suggesting close-range shootings and tampering. The Court found no proof that the Secretary exerted pressure on the Panel. On the issue of mootness: The Court reiterated that a petition questioning a preliminary investigation becomes moot once an information is filed before a trial court, which then acquires jurisdiction and completes its own determination of probable cause. In this case, an information for multiple murder had already been filed against the petitioner, rendering the resolution of whether the DOJ should have inhibited or forwarded the case to the Ombudsman of no practical use or value.
Main Doctrine
A petition for certiorari questioning the regularity of a preliminary investigation becomes moot and academic once an information is filed before a trial court, which then acquires jurisdiction over the case and completes its own determination of probable cause.