Inocentes vs.

People
G.R. No. 205963-64 July 7, 2016
SECOND DIVISION

BRION, J.:

FACTS: Amando Inocentes, a Branch Manager of GSIS Tarlac Field Office, was charged with
violation of Section 3(e) of R.A No. 3019, as amended (Anti Graft and Corrupt Practices Act),
before the Sandiganbayan. On May 10, 2012, The Sandiganbayan issued a resolution finding
probable cause and ordered the issuance of a warrant of arrest against Inocentes. He
immediately posted Bail to avoid incarceration. Thereafter, Inocentes filed an Omnibus Motion
moving for redetermination of a judicial finding of probable cause. He argues that the quantum
of evidence required to establish probable cause for purposes of holding a person for trial
and/or for the issuance of a warrant of arrest was not met in this case.

ISSUE: Whether or not a redetermination of a judicial finding of probable cause would be

proper after accused’s voluntary surrender.

RULING: No. Redetermination of a judicial finding of probable cause is futile when the
accused voluntarily surrenders to the jurisdiction of the court.

The court, in citing the case of People vs. Castillo defined Judicial determination of probable
cause as one made by the judge to ascertain whether a warrant of arrest should be issued
against the accused. Further, The judge must satisfy himself that based on the evidence
submitted, there is necessity for placing the accused under custody in order not to frustrate the
ends of justice.

In this case, Innocentes availed the remedy after posting bail before the Sandiganbayan, and
such act is tantamount to voluntary surrender. Thus, it is no longer necessary to dwell on
whether there was grave abuse on the part of the Sandiganbayan in finding the existence of
probable cause to issue a warrant of arrest because the Sandiganbayan already gained
jurisdiction over Inocentes when he posted bail, and when he filed various motions to seek
affirmative reliefs.

Ryan Paul C. Rufino

II- Viada