People vs. Quitola, G.R. No.

200537, July 13, 2016

Issue: Was the extra-judicial confession given by accused-appellant inside his cell during the interview
conducted by a field reporter admissible in evidence, if it was given without counsel and while
surrounded by police officers?

Ruling: Yes. Extra-judicial confession given by accused-appellant during the interview conducted by the
field reporter is admissible in evidence. That the confession was given without the assistance of counsel
and was therefore involuntary is immaterial. It is consistently held that the Bill of Rights does not
concern itself with relations between private individuals. The prohibitions therein are primarily
addressed to the State and its agents; thus, accused-appellant's confession to field reporter Tacason is
not covered by Section 12(1) and (3) of Article III of the Constitution. Furthermore, accused-appellant
would have the Court believe that the confession was given under a tense and fearful atmosphere,
similar to that of a custodial investigation. In a previous case -with similar circumstances, the court
observed that the presence of the police officers did not exert any undue pressure or influence on the
accused, coercing him into giving his confession. The interview was not in the nature of a custodial
investigation as the response of the accused-appellant was made in answer to questions asked by the
reporter and not by the police. There is no showing that the field reporter colluded with the police
authorities to elicit inculpatory evidence against accused-appellant. Neither is there anything on record
which suggests that the reporter was instructed by the police to extract information from him.
Moreover, accused-appellant could have refused to be interviewed, but instead, he agreed. A review of
the taped interview would show that he answered the questions freely and spontaneously.

Arroyo vs. People, G.R. No. 220598, July 19, 2016

Issue: Where the information alleged conspiracy but did not specify who was the main plunderer or
mastermind, was the Sandiganbayan correct in declaring GMA as the mastermind?

Ruling: No. To be considered a part of the conspiracy, each of the accused must be shown to have
performed at least an overt act in pursuance or in furtherance of the conspiracy, for without being
shown to do so none of them will be liable as a co-conspirator, and each may only be held responsible
for the results of his own acts. Sandigabayan gravely abused its discretion amounting to lack or excess
of its jurisdiction. To start with, its conclusion that GMA had been the mastermind of plunder was plainly
conjectural and outrightly unfounded considering that the information did not aver at all that she had
been the mastermind; hence, the Sandigabayan thereby acted capriciously and arbitrarily. In the second
place, the treatment by the Sandiganbayan of her handwritten unqualified "OK" as an overt act of
plunder was absolutely unwarranted considering that such act was a common legal and valid practice of
signifying approval of a fund release by the President. Indeed, pursuant to People v. Lizada, an act or
conduct becomes an overt act of a crime only when it evinces a causal relation to the intended crime
because the act or conduct will not be an overt act of the crime if it does not have an immediate and
necessary relation to the offense.

Mamba vs. Bueno, G.R. No. 191416, Feb 7, 2017

Issue: Whether or not the CA erred in granting the petition for the issuance of a writ of amparo?

Ruling: No. There is substantial evidence in this case that would warrant the conclusion that the
respondent's right to security, as a guarantee of protection by the government, was violated.
Accordingly, the CA correctly issued the writ of amparo in favor of the respondent. The writ of amparo
also covers violations of the right to security. What is clear is that the respondent was able to prove by
substantial evidence that he was apprehended by the members of the Task Force, illegally detained, and
tortured. The members of the Task Force apprehended and detained the respondent to make him
admit to his complicity in the heist the night before sans the benefit of legal and judicial processes.
Verily, the totality of the evidence presented by the respondent meets the requisite evidentiary
threshold.

DBP vs COA, G.R. No. 216538, April 18, 2017

Issue: Were the petitioner’s constitutional right to the speedy disposition of cases violated due to the
inordinate delay by COA in issuing the Notice of Disallowance?

Ruling: No. The petitioners' contention about the violation of their constitutional right to the speedy
disposition of cases is unwarranted. The right requires that proceedings should be conducted according
to fixed rules, free from vexatious, capricious, and oppressive delays. The right is violated when
unjustified postponements of the proceedings are sought and obtained, or when a long period of time is
allowed without justifiable cause or motive to elapse without the parties having their case tried. Yet,
none of such circumstances was attendant in this case. The petitioners cite the COA's issuance of the
Notice of Disallowance only after 10 years from the implementation of DBP's Board Resolution No. 0246
to support their insistence on the violation of their right to the speedy disposition of the case. However,
the timing of the disallowance was material only to their contention on the COA being estopped from
issuing the disallowance instead of to their invocation of the right to speedy disposition of their cases.
The latter unquestionably pertained only to the conduct of proceedings actually commenced in the COA.

Arroyo vs. People, G.R. No. 220598, April 18, 2017

Issue: What are the three related protections that the constitutional prohibition against double jeopardy
provides to the accused?

Ruling: The Constitutional prohibition against double jeopardy provides to the accused three related
protections, specifically: protection against a second prosecution for the same offense after acquittal;
protection against a second prosecution for the same offense after conviction; and protection against
multiple punishments for the same offense.

Additional notes: The rationale for the three protections is expounded in United States v. Wilson:

The interests underlying these three protections are quite similar. When a defendant has been once
convicted and punished for a particular crime, principles of fairness and finality require that he not be
subjected to the possibility of further punishment by being again tried or sentenced for the same
offense.Ex pa rte Lange, 18 Wall 163 (1874); In re Nielsen, 131 U.S. 176 (1889). When a defendant has
been acquitted of an offense, the Clause guarantees that the State shall not be permitted to make
repeated attempts to convict him,"thereby subjecting him to embarrassment, expense and ordeal, and
compelling him to live in a continuing state of anxiety and insecurity, as well as enhancing the possibility
that, even though innocent, he may be found guilty."
Issue: Will the consideration and granting of the motion for reconsideration of the State amount to a
violation of the constitutional prohibition against double jeopardy?

Ruling: Yes. The consideration and granting of the motion for reconsideration of the State will amount to
the violation of the constitutional guarantee against double jeopardy. The Court's consequential
dismissal of Criminal Case No. SB-12- CRM-0174 as to the petitioners for insufficiency of
evidence amounted to their acquittal of the crime of plunder charged against them. In People v.
Sandiganbayan, the court explained the general rule that the grant of a demurrer to evidence operates
as an acquittal and is, thus, final and unappealable. The constitutional prohibition against placing a
person under double jeopardy for the same offense bars not only a new and independent prosecution
but also an appeal in the same action after jeopardy had attached. As such, every acquittal becomes
final immediately upon promulgation and cannot be recalled for correction or amendment. With the
acquittal being immediately final, granting the State's motion for reconsideration in this case would
violate the Constitutional prohibition against double jeopardy because it would effectively reopen the
prosecution and subject the petitioners to a second jeopardy despite their acquittal.