FACTS:

Petitioners Liza L. Maza, Saturnino C. Ocampo, Teodoro A. Casiño, and Rafael V. Mariano, former members of the House of Representatives, were accused of murder based on three letters from Police Senior Inspector Arnold M. Palomo. The case underwent a preliminary investigation conducted by an investigating prosecutor and a panel of prosecutors. The panel found probable cause for murder and recommended the filing of Informations against the suspects. Two Informations for murder were filed in Palayan City, Nueva Ecija, while an Information for kidnapping with murder was filed in Guimba, Nueva Ecija. Petitioners filed motions for judicial determination of probable cause with prayer to dismiss the case outright. The trial court dismissed the case in Guimba but issued an order on the Palayan cases stating that the proper procedure in the conduct of the preliminary investigation was not followed.

The petitioners filed a Motion for Reconsideration of the resolution of the preliminary investigation, arguing that they were denied the opportunity to file a motion for reconsideration before the filing of the Informations. Judge Turla set aside the Joint Resolution of the provincial prosecutor's office and ordered a complete preliminary investigation to be conducted. The petitioners filed a motion for the dismissal of the cases for lack of probable cause, but it was denied by Judge Turla. The petitioners then filed a Petition for Certiorari and Prohibition with the Supreme Court, seeking to annul the orders of Judge Turla and have the murder cases against them dismissed.

The petitioners argued that Judge Turla shirked her constitutional duty to determine probable cause and instead remanded the cases to the provincial prosecutor's office without sufficient evidence, constituting grave abuse of discretion. The petitioners contended that Judge Turla should have either issued arrest warrants or dismissed the case based on the evidence presented by the prosecution. They also claimed that the submission of prosecution documents did not establish their involvement in the deaths. The respondents, represented by the Office of the Solicitor General, argued that the judge's action of remanding the case to the prosecutor was in recognition of the prosecutor's exclusive authority to determine probable cause. They maintained that the prosecution had found probable cause and that this was merely binding on the suspects and did not equate to a pronouncement of guilt.

ISSUES:

1. Whether petitioners violated the principle of hierarchy of courts in bringing their petition directly before the Supreme Court.

2. Whether respondent Judge Turla gravely abused her discretion when she remanded the cases to the Provincial Prosecutor for the conduct of preliminary investigation.

3. Whether admissibility of evidence can be ruled upon in preliminary investigation.

4. Whether the Supreme Court has the power to take cognizance and assume jurisdiction over special civil actions for certiorari filed directly with it for exceptionally compelling reasons or if warranted by the nature of the issues clearly and specifically raised in the petition.

5. Whether the exceptions to the doctrine of hierarchy of courts apply in this case.

6. Whether the remand of the criminal cases to the Provincial Prosecutor for another preliminary investigation is proper.

7. Whether Judge Turla's remand of the case for another preliminary investigation was proper.

8. Whether the trial court judge has the authority to evaluate the sufficiency of evidence during a preliminary investigation.

9. Whether or not the admissibility or inadmissibility of evidence can be ruled upon in a preliminary investigation.

10. Whether or not the Regional Trial Court erred in ruling on the admissibility of evidence in the case.

RULING:

1. The petition is an exception to the principle of hierarchy of courts. While the general rule is for cases to be filed first before the lower courts and elevated through the appellate process, there are instances when direct invocation of the Supreme Court's original jurisdiction is allowed. In this case, the petition involves legal questions and the inclusion of Secretary Gonzalez as a nominal party-respondent is allowed under Rule 65, Section 5 of the Rules of Court.

2. Respondent Judge Turla did not gravely abuse her discretion when she remanded the cases to the Provincial Prosecutor for preliminary investigation. The determination of probable cause is an exclusive executive function of the prosecutorial arm of the government. Judge Turla's act of remanding the cases to the public prosecutors is confirmation of her observance of this principle.

3. The issue of admissibility or inadmissibility of evidence is properly addressed during the trial on the merits of the case and not during the early stage of preliminary investigation. The prosecutors' finding of probable cause merely engages the petitioners to stand trial and is not a final declaration of their guilt.

4. The Supreme Court has full discretionary power to take cognizance and assume jurisdiction over special civil actions for certiorari filed directly with it for exceptionally compelling reasons or if warranted by the nature of the issues clearly and specifically raised in the petition. The doctrine of hierarchy of courts is not an iron-clad rule and the Supreme Court can make exceptions for cases involving genuine issues of constitutionality, issues of transcendental importance, cases of first impression, issues better decided by the Supreme Court, exigency in certain situations, acts of a constitutional organ, lack of other sufficient remedies in the course of law, and questions dictated by public welfare and the advancement of public policy.

5. The presence of compelling circumstances warrants the exercise of the Supreme Court's jurisdiction in this case. The possibility of the arrest and incarceration of the petitioners, who were incumbent party-list representatives at the time of filing, would have affected their representation of their constituents in Congress. Although the circumstances have changed, the merits of the case still necessitate the exercise of the Supreme Court's jurisdiction.

6. The remand of the criminal cases to the Provincial Prosecutor for another preliminary investigation is improper. The documents submitted along with the Informations are sufficient for the judge to rule on the existence of probable cause. If the evidence is found inadequate, the judge may order the prosecutors to present additional evidence. Therefore, the judge's action in remanding the case to the prosecutors lacks legal basis.

7. No, Judge Turla's remand of the case for another preliminary investigation was not proper. The trial court judge, upon filing of the information, has the authority to determine the existence of probable cause and has the options to dismiss the case, issue a warrant of arrest, or order the prosecutor to present additional evidence. There is no provision allowing the judge to remand the case back to the panel of prosecutors for another preliminary investigation.

8. Yes, the trial court judge has the authority to evaluate the sufficiency of evidence during a preliminary investigation. The determination of probable cause for filing an information in court and that for issuance of an arrest warrant are different. The determination of probable cause during a preliminary investigation is an executive function of the prosecutor, while the determination of probable cause to issue an arrest warrant is a judicial function of the trial court judge. The judge must personally evaluate the prosecutor's report and supporting documents to determine the existence of probable cause.

9. No, the admissibility or inadmissibility of evidence cannot be ruled upon in a preliminary investigation. The purpose of a preliminary investigation is only to determine whether there is probable cause to hold the accused for trial, and it is not a trial on the merits. As such, it cannot be expected that all the evidence necessary to secure a conviction of the accused would have already been presented during the preliminary investigation.

10. Yes, the Regional Trial Court erred in ruling on the admissibility of evidence in the case. The Court set aside the orders of the RTC and remanded the case for further proceedings, emphasizing that the trial court should proceed with due and deliberate dispatch in accordance with the decision.

PRINCIPLES:

• Hierarchy of Courts: The principle of hierarchy of courts requires parties to file their cases first before the lower courts and to exhaust the available remedies before elevating the case to higher courts. However, there are exceptions to this rule, such as when the case involves legal questions or when direct invocation of the Supreme Court's original jurisdiction is allowed.

• Determination of Probable Cause: The determination of probable cause is an exclusive executive function of the prosecutorial arm of the government. It is not the duty of the judge to determine the existence of probable cause during preliminary investigation. The judge may remand the case to the public prosecutors for further investigation if there are doubts on the existence of probable cause.

• Admissibility of Evidence: The issue of admissibility or inadmissibility of evidence is properly addressed during the trial on the merits of the case and not during the early stage of preliminary investigation. The finding of probable cause by the prosecutors merely engages the accused to stand trial and does not amount to a final declaration of guilt.

• The Supreme Court has full discretionary power to take cognizance and assume jurisdiction over special civil actions for certiorari filed directly with it for exceptionally compelling reasons or if warranted by the nature of the issues clearly and specifically raised in the petition.

• The doctrine of hierarchy of courts is not an iron-clad rule and exceptions can be made for cases involving genuine issues of constitutionality, issues of transcendental importance, cases of first impression, issues better decided by the Supreme Court, exigency in certain situations, acts of a constitutional organ, lack of other sufficient remedies in the course of law, and questions dictated by public welfare and the advancement of public policy.

• The presence of compelling circumstances may warrant the exercise of the Supreme Court's jurisdiction even if the circumstances have changed.

• Remanding criminal cases for another preliminary investigation is improper if the documents submitted along with the Informations are sufficient for the judge to rule on the existence of probable cause. The judge may order the prosecutors to present additional evidence if necessary.

• The determination of probable cause during a preliminary investigation is an executive function of the prosecutor, while the determination of probable cause to issue an arrest warrant is a judicial function of the trial court judge.

• The trial court judge, upon filing of the information, has the authority to determine the existence of probable cause and has the options to dismiss the case, issue a warrant of arrest, or order the prosecutor to present additional evidence.

• The admissibility of evidence cannot be ruled upon in a preliminary investigation. 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.

• A preliminary investigation is merely preparatory to a trial and is not a trial on the merits.

• The admissibility or inadmissibility of evidence cannot be ruled upon in a preliminary investigation.

• The purpose of a preliminary investigation is to determine whether there is probable cause to hold the accused for trial.

• The trial court should proceed with due and deliberate dispatch in accordance with the decision of the higher court.