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SECRETARY LEILA M. DE LIMA v. MAGTANGGOL B. GATDULA

FACTS:

The case involves a petition for the issuance of a temporary restraining order and/or writ of preliminary injunction to stop the implementation of the Regional Trial Court's decision in a civil case. The petitioner, Magtanggol B. Gatdula, filed a petition for the issuance of a writ of amparo against respondents, Justice Secretary Leila M. De Lima, Director Nonnatus R. Rojas, and Deputy Director Reynaldo O. Esmeralda of the National Bureau of Investigation. Gatdula alleges that the respondents were framing him for a fake ambush incident by filing bogus charges of frustrated murder against him.

The judge did not immediately decide on the issuance of the writ of amparo, but rather ordered the respondents to file an answer and set the case for a hearing. Later on, the judge conducted a hearing on the main case and ordered the filing of memoranda. The RTC subsequently rendered a decision granting the writ of amparo and interim reliefs. The respondents then filed a motion for reconsideration, which was denied by the RTC. Consequently, the petitioners appealed the RTC decision to the Supreme Court.

The Supreme Court held that the decision granting the writ of amparo was not a final judgment or order. The Court ruled that a petition for review under Rule 45 was not yet the proper remedy. The Court explained the nature of the remedy of amparo and the procedure involved, which includes the filing of a petition, evaluation of the facts, issuance of the writ, filing of a return by the respondents, summary hearing, and the rendering of a judgment.

ISSUES:

  1. Whether the "Decision" dated 20 March 2012 granting the Writ of Amparo is a final judgment or order appealable under Rule 45.

RULING:

  1. The Supreme Court ruled that the "Decision" dated 20 March 2012 is not the judgment or final order contemplated under Section 19 of the Rule on the Writ of Amparo. It is considered an interlocutory order and not subject to appeal under Rule 45.

PRINCIPLES:

  • Nature of the Writ of Amparo: The Writ of Amparo is an extraordinary remedy designed to safeguard the right to life, liberty, and security.

  • Procedure in Amparo Cases: The requirement for a Return instead of an Answer, and the settings for summary hearings post-issuance of the writ.

  • Final Judgment vs. Interlocutory Orders: Interlocutory orders, which include interim reliefs, are not appealable under Rule 45, and only final judgments are.

  • Procedural Regularity: The importance of adhering to procedural rules for the swift and effective resolution of Amparo cases.

  • Liberal Construction of Rules: The Supreme Court may liberally construe procedural rules to ensure the just, speedy, and inexpensive disposition of actions.

Note: This partial digest focuses only on the issues, rulings, and principles from the case. Facts and other parts of the original document were omitted as instructed.