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    Webb vs. De Leon

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    danielleoracion

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    Webb vs. De Leon

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    danielleoracion
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    Webb vs. De Leon

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    danielleoracion

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    of 1

    10/26/24, 7:27 AM Webb vs.

    De Leon
    Title
    Webb vs. De Leon

    Case Decision Date


    G.R. No. 121234 Aug 23, 1995

    Three individuals charged with rape and homicide seek to nullify the warrants of arrest
    issued against them, arguing that there was no probable cause, but the Supreme Court
    rules that there was sufficient evidence to establish probable cause and upholds the
    validity of Republic Act No. 6981.

    Case Digest (G.R. No. 121234, 121245, 121297)


    Comprehensive

    Facts:
    The case involves three petitioners, Hubert J.P. Webb, Michael A. Gatchalian, and Antonio L.
    Lejano, who were charged with the crime of rape with homicide. The charges stem from
    the brutal killing of Carmela N. Vizconde, her mother Estrellita Nicolas-Vizconde, and her
    sister Anne Marie Jennifer on June 30, 1991, in their home at BF Homes, Parañaque, Metro
    Manila. The National Bureau of Investigation (NBI) filed a letter-complaint with the
    Department of Justice (DOJ) on June 19, 1994, leading to the formation of a panel of
    prosecutors to conduct a preliminary investigation. The NBI presented several pieces of
    evidence, including the sworn statement of their principal witness, Maria Jessica M. Alfaro,
    and other corroborative testimonies. The petitioners, in turn, presented alibis and
    documentary evidence to prove their innocence. Despite their efforts, the DOJ Panel found
    probable cause and filed an Information for rape with homicide against them. The case was
    raffled to different branches of the Regional Trial Court of Parañaque, where warrants of
    arrest were issued. The petitioners sought to annul these warrants, arguing that there was
    no probable cause and that their constitutional rights were violated during the preliminary
    investigation.

    Issue:
    1. Did the respondent judges gravely abuse their discretion by failing to conduct a
    preliminary examination before issuing warrants of arrest against the petitioners?
    2. Did the DOJ Panel gravely abuse its discretion in finding probable cause to charge the
    petitioners with rape with homicide?
    3. Were the petitioners denied their constitutional right to due process during the
    preliminary investigation?
    4. Did the DOJ Panel unlawfully intrude into judicial prerogative by not including Jessica
    Alfaro in the Information as an accused?

    Ruling:
    1. The Supreme Court ruled that the respondent judges did not gravely abuse their
    discretion in issuing the warrants of arrest without conducting a preliminary
    examination.
    2. The Court found that the DOJ Panel did not gravely abuse its discretion in finding
    probable cause to charge the petitioners with rape with homicide.
    3. The Court held that the petitioners were not denied their constitutional right to due
    process during the preliminary investigation.
    4. The Court ruled that the DOJ Panel did not unlawfully intrude into judicial prerogative
    by not including Jessica Alfaro in the Information as an accused.

    Ratio:
    1. The Court emphasized that the Constitution and the Rules of Court do not require
    judges to conduct a preliminary examination before issuing warrants of arrest. Judges
    are only required to personally determine the existence of probable cause based on the
    evidence presented by the prosecution. The respondent judges reviewed the DOJ
    Panel's report and supporting documents, which provided substantial evidence to
    establish probable cause.
    2. The Court noted that the purpose of a preliminary investigation is to determine
    whether there is sufficient ground to engender a well-founded belief that a crime has
    been committed and that the respondent is probably guilty thereof. The DOJ Panel's
    finding of probable cause was based on the sworn statements of witnesses and other
    corroborative evidence. The inconsistencies in Alfaro's statements were deemed
    insufficient to discredit her testimony, and the alibi presented by the petitioners was
    not strong enough to outweigh the evidence against them.
    3. The Court found that the petitioners were given ample opportunity to present their
    evidence and counter the charges during the preliminary investigation. The DOJ Panel
    allowed the petitioners to submit additional evidence and even entertained their
    motions for the production of documents. The filing of the Information in court was in
    accordance with DOJ Order No. 223, which allows the filing of an Information even if
    the accused can still seek a review of the prosecutor's recommendation.
    4. The Court upheld the validity of Republic Act No. 6981, which provides for the Witness
    Protection Program. The law allows the DOJ to determine who can qualify as a state
    witness and grants immunity from prosecution to those admitted into the program.
    The non-inclusion of Alfaro in the Information was in compliance with this law, and
    the Court found no constitutional infirmity in its provisions.

    https://jur.ph/jurisprudence/v/digest/webb-v-de-leon?q=Webb+v.+De+Leon 1/1

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