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People of The Philippines vs. Angelo o Montilla Sps. Rodolfo Palmes and Esmaelita Palmes vs. Ca and Angelo O. Montilla

This document summarizes a Supreme Court case regarding a double murder charge against Angelo Montilla and Doris Lapuz. The case was initially filed in RTC Cotabato City but was later transferred and dismissed by RTC Davao City for lack of probable cause. However, RTC Cotabato City reinstated the case without making its own determination. The Court of Appeals and Supreme Court both ruled that RTC Davao City properly dismissed the case as the doctrine of judicial stability did not apply given the lawful transfer, and Lapuz's right to a determination of probable cause was violated. The appeal was dismissed regarding the deceased Montilla and the CA ruling upholding dismissal was affirmed for Lapuz.

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321 views2 pages

People of The Philippines vs. Angelo o Montilla Sps. Rodolfo Palmes and Esmaelita Palmes vs. Ca and Angelo O. Montilla

This document summarizes a Supreme Court case regarding a double murder charge against Angelo Montilla and Doris Lapuz. The case was initially filed in RTC Cotabato City but was later transferred and dismissed by RTC Davao City for lack of probable cause. However, RTC Cotabato City reinstated the case without making its own determination. The Court of Appeals and Supreme Court both ruled that RTC Davao City properly dismissed the case as the doctrine of judicial stability did not apply given the lawful transfer, and Lapuz's right to a determination of probable cause was violated. The appeal was dismissed regarding the deceased Montilla and the CA ruling upholding dismissal was affirmed for Lapuz.

Uploaded by

mubarak.gutoc
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© © All Rights Reserved
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PEOPLE OF THE PHILIPPINES VS. ANGELO O MONTILLA GR NO.

241911, SPS. RODOLFO PALMES AND ESMAELITA PALMES VS. CA


AND ANGELO O. MONTILLA GR NO. 242375. FEBRUARY 8, 2023

Facts:
 Criminal case for double murder filed against Angelo
O. Montilla and Doris P. Lapuz
 Case initially filed before RTC of Cotabato City,
Branch 15
 Montilla and Lapuz included as additional accused in
the case
 RTC-Cotabato City, Branch 15 issued Second Amended
Information including Montilla and Lapuz
 Provincial Prosecutor filed motions to recall and
dismiss Second Amended Information
 Case transferred to RTC-Davao City, Branch 16
 Case dismissed for lack of probable cause based on
evidence presented during preliminary investigation
 Prosecution filed motion for reconsideration, granted
by RTC-Davao City, Branch 15, reinstating criminal
proceedings
 Montilla and Lapuz appealed reinstatement of case to
Court of Appeals (CA)
 CA granted their petition and reinstated dismissal of
case
 CA ruled that doctrine of judicial stability was
misapplied
 People of the Philippines and Spouses Palmes
challenged CA ruling before Supreme Court

Issue:
 Whether the CA erred in reinstating the dismissal of
the case against Montilla and Lapuz

Ruling:
 Appeal dismissed as to Montilla, who passed away
during the case
 Death of accused extinguishes criminal and civil
liabilities
 CA ruling upheld as to Lapuz
 Doctrine of judicial stability does not apply when
another court with concurrent jurisdiction acquires
jurisdiction pursuant to a sanctioned change of venue
 RTC-Davao City, Branch 16 had complete authority to
dismiss the case against Lapuz based on lack of
probable cause
 Lapuz's right to a judicial determination of probable
cause was violated when RTC-Davao City, Branch 15
reversed finding of probable cause without making a
personal determination
 Dismissal of case against Lapuz justified as there was
no factual circumstance to raise a well-engendered
belief that Lapuz was probably guilty of the crime

Ratio:
 Doctrine of judicial stability or non-interference in
regular orders or judgments of a co-equal court is a
basic procedural precept
 Doctrine does not apply when another court with
concurrent jurisdiction acquires jurisdiction pursuant
to a sanctioned change of venue
 RTC-Davao City, Branch 16 had complete authority to
dismiss the case against Lapuz based on lack of
probable cause
 Lapuz's right to a judicial determination of probable
cause was violated when RTC-Davao City, Branch 15
reversed finding of probable cause without making a
personal determination
 Dismissal of case against Lapuz justified as there was
no factual circumstance to raise a well-engendered
belief that Lapuz was probably guilty of the crime

Conclusion:
 Supreme Court affirmed CA ruling and dismissed
criminal case against Lapuz.

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