Primary Holding

The Supreme Court ruled in favor of the petitioners, granting the petition and permanently enjoining the trial court from proceeding with the cases. The Court held that criminal prosecution may be enjoined in cases of manifest bad faith, as demonstrated by the state officials' actions in this case.

Background

The case arose during a period of political unrest in the Philippines, marked by demonstrations and strikes against the government. Petitioners, including prominent filmmakers and activists, were arrested during a jeepney strike and subsequently charged with Illegal Assembly and Inciting to Sedition. The case highlights the tension between the government's authority to maintain order and the protection of individual rights and freedoms.

Facts

• 1. Petitioners were arrested and charged with Illegal Assembly following their participation in a jeepney strike. While in detention, they were subsequently charged with Inciting to Sedition without prior notice to their counsel. The second charge was based on the same actions that led to the Illegal Assembly charge. Petitioners argued that this constituted harassment and bad faith on the part of the state officials.

Arguments of the Petitioners

• 1. The charges of Inciting to Sedition were filed in bad faith and constituted harassment.
• 2. The second offense was illegal as it was based on the same act as the first offense.
• 3. The petitioners would be placed in double jeopardy.

Arguments of the Respondents

• 1. A Preventive Detention Action (PDA) justified the continued detention of the petitioners.
• 2. The charges of Inciting to Sedition were based on legitimate concerns about the petitioners' actions.

Issues

• 1. Whether or not the prosecution of the criminal cases for Inciting to Sedition may lawfully be enjoined.
• 2. Whether or not the second offense of inciting to sedition is illegal, being premised on the same act of attending and participating in the ACTO jeepney strike.
• 3. Whether or not the petitioners would be placed in double jeopardy.

Ruling

• 1. The Supreme Court ruled that the criminal prosecution of the petitioners for the second offense of inciting to sedition should be enjoined. The Court recognized that while there is a general rule against enjoining criminal prosecutions, exceptions exist, including cases of manifest bad faith and harassment by state officials.

Doctrines

• 1. Injunction against Criminal Prosecution: While generally prohibited, exceptions include cases of manifest bad faith, harassment, and the protection of constitutional rights.
• 2. Double Jeopardy: A person cannot be tried twice for the same offense.
• 3. Due Process: Individuals are entitled to fair treatment and legal protection.

Key Excerpts

• 1. "Constitutional rights must be upheld at all costs, for this gesture is the true sign of democracy. These may not be set aside to satisfy perceived illusory visions of national grandeur."
• 2. "Infinitely more important than conventional adherence to general rules of criminal procedure is respect for the citizen's right to be free not only from arbitrary arrest and punishment but also from unwarranted and vexatious prosecution."

Precedents Cited

• 1. Hernandez vs. Albano: Cited to support the doctrine that injunctions may be issued to protect constitutional rights.
• 2. Ilagan v. Enrile: Cited regarding the proper procedure for invoking Preventive Detention Actions.
• 3. Salonga vs. Pano: Cited to emphasize the importance of protecting citizens from unwarranted and vexatious prosecution.

Statutory and Constitutional Provisions

• 1. Article 142 of the Revised Penal Code (Inciting to Sedition)
• 2. Article 146 of the Revised Penal Code (Illegal Assembly)
• 3. Article 48 of the Revised Penal Code (Complex Crime)