Primary Holding

The Supreme Court upheld the time-honored practice of non-interference in preliminary investigations conducted by prosecutory bodies absent grave abuse of discretion, affirming that Sundays, holidays, and election days are excluded in computing the periods prescribed in Article 125 of the Revised Penal Code.

Facts

• 1. On May 13, 2001 (Sunday, day before elections), at 8:30 PM, petitioners were arrested without warrant for alleged illegal possession of firearms and ammunition.
• 2. Soria was arrested for alleged possession of a .38 caliber revolver and violation of Article 261(f) of the Omnibus Election Code.
• 3. Bista was arrested for alleged possession of a submachine pistol UZI (9mm) and a .22 caliber revolver with ammunition.
• 4. Both were detained at Santa, Ilocos Sur Police Station, where Bista was found to have a standing warrant for violation of BP 6.
• 5. On May 14, 2001 (Election Day), at 4:30 PM, they were brought to Provincial Prosecutor Viloria's residence where the arresting officers' Joint-Affidavit was sworn.
• 6. At 6:30 PM of May 14, Soria was released (after 22 hours of detention) while Bista remained detained.
• 7. On May 15, 2001, Bista posted bail for the BP 6 case but remained detained for the firearms case until June 8, 2001 (26 days total).

Arguments of the Petitioners

• 1. The computation of the period under Article 125 should not exclude Sundays, holidays, and election days as the law makes no such exception.
• 2. The filing of information did not justify Bista's continued detention, as he was detained for 26 days before release.

Arguments of the Respondents

• 1. Sundays, holidays, and election days should be excluded from the computation period based on jurisprudence (Medina v. Orozco and Sayo v. Chief of Police of Manila).
• 2. The duty of arresting officers ended upon filing of information with proper judicial authorities.

Issues

• 1. Whether Sundays, holidays, and election days should be excluded in computing the period under Article 125.
• 2. Whether the filing of information justifies continued detention beyond the periods in Article 125.

Ruling

• 1. The Supreme Court dismissed the petition and affirmed the Ombudsman's resolution
• 2. The exclusion of Sundays, holidays, and election days from the computation period is proper, following established jurisprudence.
• 3. The duty of arresting officers ends upon filing of information with proper judicial authorities.
• 4. No grave abuse of discretion was committed by the Ombudsman in dismissing the complaint.

Doctrines

• 1. Non-interference with Ombudsman's investigatory powers - Courts will not interfere with the Ombudsman's investigatory and prosecutory powers absent grave abuse of discretion.
• 2. Exclusion of non-working days - Sundays, holidays, and election days are excluded in computing periods under Article 125 due to practical impossibility of filing charges on such days.
• 3. Termination of police duty - The duty of arresting officers ends upon filing of information with proper judicial authorities.

Precedents Cited

• 1. Medina v. Orozco (1966) - Established that Sundays and holidays are excluded from Article 125 computation.
• 2. Sayo v. Chief of Police of Manila (1948) - Considered practical difficulties in filing charges when computing detention periods.
• 3. Agbay v. Deputy Ombudsman for Military (1999) - Held that filing of complaint with court satisfies Article 125's intent.
• 4. People v. Acosta - Supported that police duty ends upon filing of information.

Statutory and Constitutional Provisions

• 1. Article 125, Revised Penal Code - Delay in delivery of detained persons
• 2. Article 261(f), Omnibus Election Code
• 3. COMELEC Resolution No. 3328
• 4. Batas Pambansa Blg. 6