CRIMPRO CASE NO.

SEN. LEILA DE LIMA, petitioner

NATURE OF THE CASE: A Petition for Certiorari and Prohibition with Application for a Writ of
Preliminary Injunction, and Urgent Prayer for Temporary Restraining Order and Status Quo Ante Order
against the decision of the Regional Trial Court (RTC) of Muntinlupa City. (Dismissed)

DOCTRINE: Hierarchy of Courts

FACTS:

The Senate and the House of Representatives conducted several inquiries on the proliferation of
dangerous drugs syndicated at the New Bilibid Prison (NBP), inviting inmates who executed affidavits in
support of their testimonies. These legislative inquiries led to the filing of four (4) complaints against
Senator Leila De Lima and her co-accused with the Department of Justice (DOJ).

The DOJ Panel conducted a preliminary hearing wherein the petitioner filed an Omnibus Motion to
Immediately Endorse the Cases to the Office of the Ombudsman and for Inhibition of the Panel of
Prosecutors and the Secretary of Justice (“Omnibus Motion”). In the said motion, the petitioner argued
that the Office of the Ombudsman has the exclusive authority and jurisdiction to hear the four (4)
complaints against her. She also contended that the DOJ prosecutors should inhibit themselves and refer
the complaints to the Office of the Ombudsman.

Referring to the omnibus motion, the complainants filed a Joint Comment/Opposition. In turn, the
petitioner interposed the said reply and submitted a Manifestation with Motion to First Resolve Pending
Incident and to Defer Further Proceedings. During the hearing, the petitioner decided not to submit her
counter-affidavit citing the pendency of her two (2) motions. The DOJ, however, ruled that it will not
entertain belatedly filed counter-affidavits and declared all pending cases as submitted for resolution.

The petitioner then filed before the Court of Appeals a Petition for Prohibition and Certiorari assailing
the jurisdiction of the DOJ Panel over the complaints against her, but the DOJ proceeded with the conduct
of the preliminary investigation and recommended the filing of informations against her. There, three (3)
complaints were filed to the RTC of Muntinlupa City presided by the respondent judge, Juanita Guerrero.

In response, the petitioner filed Motion to Quash raising the following:

The respondent judge found probable cause and issued the warrants of arrest against Sen. De Lima and
her co-accused, which no recommendation for bail.
The Office of the Solicitor General (OSG), on behalf of the respondents, interposed its Comment to the
petition arguing that the petition filed by the petitioner should be dismissed as De Lima failed to show
that she has no other plain, speedy, and adequate remedy. Further, the OSG posited that the petitioner did
not observe the hierarchy of courts and violated the rule against forum shopping.The OSG also asserted
inter alia that the RTC has jurisdiction over the offense charged against the petitioner and that the
respondent judge observed the constitutional and procedural rules, and so did not commit grave abuse of
discretion in issuing warrant of arrest.

Then, petitioner repaired to Supreme Court via the present petition, praying for the following reliefs:
a. Granting a writ of certiorari annulling and setting aside the warrant of arrest as well as the case
filed against her
b. Granting a writ of prohibition enjoining and prohibiting respondent judge from conducting
further proceedings until and unless the Motion to Quash is resolved with finality;
c. Issuing an order granting the application for the issuance of temporary restraining order (TRO)
and a writ of preliminary injunction to the proceedings; and
d. Issuing a Status Quo Ante Order restoring the parties to the status prior to the issuance of the
Order and Warrant of Arrest, both dated February 23, 201 7, thereby recalling both processes and
restoring petitioner to her liberty and freedom.26

ISSUE:

Whether or not petitioner is excused from compliance with the doctrine on hierarchy of courts
considering that the petition should first be filed with the Court of Appeals. NO (Procedural)

RULING:

The petitioner disregarded the hierarchy of court.

The court emphasized that the rule on hierarchy of courts is an important component of the orderly
administration of justice and not imposed merely for whimsical and arbitrary reasons. However, there are
recognized exceptions to this rule and direct resort to this Court were allowed in some instance, which
laid down in a case of recent vintage, Aala v. Uy. Unfortunately, none of those exceptions were
sufficiently established in the present petition so as to convince the court to brush aside the rules on the
hierarchy of courts. The petitioner being a Senator of the republic does not also merit a special treatment
of her case.

The petitioner's argument that the rule on the hierarchy of court should be disregarded as her case
involves pure questions of law does not obtain. One of the grounds upon which petitioner anchors her
case is that the respondent judge erred and committed grave abuse of discretion in finding probable cause
to issue her arrest. By itself, this ground removes the case from the ambit of cases involving pure
questions of law. It is established that the issue of whether or not probable cause exists for the issuance of
warrants for the arrest of the accused is a question of fact, determinable as it is from a review of the
allegations in the Information, the Resolution of the Investigating Prosecutor, including other documents
and/ or evidence appended to the Information. This matter, therefore, should have first been brought
before the appellate court, which is in the better position to review and determine factual matters.

The Court cannot thus allow a precedent allowing public officers assailing the finding of probable cause
for the issuance of arrest warrants to be brought directly to Supreme Court, bypassing the appellate court,
without any compelling reason.
DISPOSITIVE PORTION:

WHEREFORE, the instant petition for prohibition and certiorari is DISMISSED for lack of merit. The
Regional Trial Court of Muntinlupa City, Branch 204 is ordered to proceed with dispatch with Criminal
Case N6.17-165.

SO ORDERED.
(You may also use the case below as reference for deep understanding of this doctrine)

In The Diocese of Bacolod v. Commission on Elections, the court explained the reason for the doctrine
thusly”

The Court must enjoin the observance of the policy on the hierarchy of courts, and now affirms
that the policy is not to be ignored without serious consequences. The strictness of the policy is
designed to shield the Court from having to deal with causes that are also well within the
competence of the lower courts, and thus leave time for the Court to deal with the more
fundamental and more essential tasks that the Constitution has assigned to it. The Court may act
on petitions for the extraordinary writs of certiorari, prohibition and mandamus only when
absolutely necessary or when serious and important reasons exist to justify an exception to the
policy.

xxxx

The doctrine that requires respect for the hierarchy of courts was created by this court to ensure
that every level of the judiciary performs its designated roles in an effective and efficient manner.
Trial courts do not only determine the facts from the evaluation of the evidence presented before
them. They are likewise competent to determine issues of law which may include the validity of
an ordinance, statute, or even an executive issuance in relation to the Constitution. To effectively
perform these functions, they are territorially organized into regions and then into branches. Their
writs generally reach within those territorial boundaries. Necessarily, they mostly perform the all-
important task of inferring the facts from the evidence as these are physically presented before
them. In many instances, the facts occur within their territorial jurisdiction, which properly
present the "actual case" that makes ripe a determination of the constitutionality of such action.
The consequences, of course, would be national in scope. There are, however, some cases where
resort to courts at their level would not be practical considering their decisions could still be
appealed before the higher courts, such as the Court of Appeals.

The Court of Appeals is primarily designed as an appellate court that reviews the determination
of facts and law made by the trial courts. It is collegiate in nature. This nature ensures more
standpoints in the review of the actions of the trial court. But the Court of Appeals also has
original jurisdiction over most special civil actions. Unlike the trial courts, its writs can have a
nationwide scope. It is competent to determine facts and, ideally, should act on constitutional
issues that may not necessarily be novel unless there are factual questions to determine.

This court, on the other hand, leads the judiciary by breaking new ground or further reiterating -
in the light of new circumstances or in the light of some confusion of bench or bar - existing
precedents. Rather than a court of first instance or as a repetition of the actions of the Court of
Appeals, this court promulgates these doctrinal devices in order that it truly performs that
role.50 (Emphasis supplied.)