Pages 38 601 Macapagal Arroyo vs. People 63
Pages 38 601 Macapagal Arroyo vs. People 63
Pages 38 601 Macapagal Arroyo vs. People 63
Facts:
On July 19, 2016, the Supreme Court grants the petitions for certiorari; ANNULS and
SETS ASIDE the resolutions issued in Criminal Case No. SB-12-CRM-0174 by the
Sandiganbayan on April 6, 2015 and September 10, 2015; GRANTS the petitioners' respective
demurrers to evidence; DISMISSES Criminal Case No. SB-12-CRM-0174 as to the petitioners
GLORIAMACAPAGAL-ARROYO and BENIGNOAGUAS for insufficiency of evidence;
ORDERS the immediate release from detention of said petitioners; and MAKES no
pronouncements on costs of suit.
On August 3, 2016, the State, through the Office of the Ombudsman, has moved for the
reconsideration of the decision, submitting that the Supreme Court’s giving due course to
certiorari action assailing an interlocutory order denying the demurrer to evidence violates Rule
119, Section 23 of the Rules of Court and committed grave errors which amount to a violation or
deprivation of the state’s fundamental right to due process of law.
Issue:
Whether or not the grant of petitions for certiorari assailing an interlocutory order denying
demurrer of evidence by the Supreme Court violates Rule 119, Section 23 of the Rules of Court,
which provides that an order denying the demurrer to evidence shall not be reviewable by
appeal or by certiorari before judgement.
Ruling:
No, the grant of petitions for certiorari by the Supreme Court is valid and constitutional.
Section 1 Article 8 of the 1987 Philippine Constitution provides that, “ The judicial
power shall be vested in one Supreme Court and in such lower courts as may be established by
law. Judicial power includes the duty of the courts of justice to settle actual controversies
involving rights which are legally demandable and enforceable, and to determine whether or not
there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the
part of any branch or instrumentality of the Government.” In addition, in the Court decided
cases, GR No. 220953, “In the exercise of judicial power is to correct grave abuse of discretion
amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the
Government cannot be thwarted by rules of procedure to the contrary or for the sake of the
convenience of one side. This is because the Court has the bounden constitutional duty to strike
down grave abuse of discretion whenever and wherever it is committed.
In this case, the Sandiganbayan as the trial court was guilty of grave abuse of discretion
when it capriciously denied the demurrers to evidence despite the absence of competent and
sufficient evidence to sustain the indictment for plunder, and despite the absence of the factual
bases to expect a guilty verdict. Thus, notwithstanding the interlocutory character and effect of
the denial of the demurrers to evidence, the petitioners as the accused could avail themselves
of the remedy of certiorari when the denial was tainted with grave abuse of discretion.