- Case No.: G.R. No. 177600 and G.R. No.

178684
- Case Title: Mayor Anwar Berua Balindong, Lt. Col. Jalandoni Cota, Mayor Amer Oden Balindong, and Ali
Balindong vs. Court of Appeals, State Prosecutor Leah Armamento, Office of the Solicitor General, and
Zenaida Limbona / Zenaida M. Limbona vs. Hon. Judge Alexander S. Balut of the Regional Trial Court of
Quezon City, Branch 76
- Date: October 19, 2015

Summary of the Case:

This case involves two consolidated cases: G.R. No. 177600 and G.R. No. 178684. G.R. No. 177600 concerns
an appeal by Mayor Anwar Berua Balindong and others against a decision by the Court of Appeals (CA)
regarding a shooting incident in Malabang, Lanao del Sur in 1998. G.R. No. 178684 involves a petition by
Zenaida M. Limbona against Presiding Judge Alexander S. Balut for contempt of court due to his actions
regarding the criminal cases against Balindong, et al.

Antecedents:

The case originated from a shooting incident resulting in fatalities and injuries. After a preliminary investigation,
the prosecutor found probable cause to charge several individuals with Double Murder with Multiple Frustrated
Murder. However, after a series of motions and reconsiderations, the charges were downgraded and modified
several times. Despite final rulings by the Department of Justice (DOJ) and the Supreme Court affirming the
charges, the trial court judges continued to entertain motions to reconsider and redetermine probable cause.

Issues:

In G.R. No. 177600, Balindong, et al. question whether they are precluded from invoking certain procedural
rules after exhausting their executive remedies and appellate processes. In G.R. No. 178684, Limbona seeks
contempt charges against Judge Balut and Balindong, et al. for allegedly disobeying Supreme Court decisions
and obstructing justice.

Key Points:

1. Probable Cause Determination: The issuance of a warrant of arrest by the trial court implies a determination
of probable cause. It is unnecessary for the accused to seek a separate determination of probable cause.

2. Case History: The case involves a complex history of motions, appeals, and reconsiderations regarding the
charges stemming from a shooting incident.

3. Judicial Actions: Despite final rulings affirming the charges by higher courts, trial court judges continued to
entertain motions challenging probable cause and attempted to downgrade the charges.

4. Contempt Charges: Limbona seeks contempt charges against Judge Balut and Balindong, et al. for
allegedly disobeying Supreme Court decisions and obstructing the administration of justice.

5. Appellate Issues: Balindong, et al. raise questions regarding procedural rules and whether they are
precluded from invoking certain remedies after exhausting executive and appellate processes.

Doctrine Highlighted:
The doctrine of finality of judgment is emphasized, which dictates that once a judgment becomes final and
executory, it should no longer be disturbed. This doctrine promotes stability and certainty in legal proceedings,
preventing endless litigation and ensuring respect for judicial decisions.

Ruling and Decision:

1. G.R. No. 177600:

- The petition for review on certiorari is denied due to lack of merit.
- The Court affirmed the decision of the Court of Appeals, which annulled the DOJ Resolution and reinstated
previous resolutions.
- Balindong, et al. cannot seek further determination of probable cause independently of the executive
determination.
- Judge Balut did not disobey previous court decisions and acted prudently, thus the contempt charge
against him is dismissed.

2. G.R. No. 178684:

- The petition for contempt is dismissed.
- Judge Balut's actions were deemed prudent and did not disobey previous court decisions.
- The Regional Trial Court is directed to resume proceedings in the mentioned criminal cases.

Conclusion:

The case underscores the significance of adhering to final rulings, respecting the doctrine of finality of
judgment, and the consequences of disregarding legal directives. It highlights the need for procedural
compliance and the importance of maintaining the integrity of judicial processes.

In the context of the case provided, the amendment or substitution of the complaint or information could be
relevant in several ways:

1. Downgrading of Charges: Throughout the case's history, there were instances where the charges against
the accused were modified or downgraded. This could involve amending the complaint or information to reflect
lesser offenses or fewer counts of the original charges. The legality and procedural correctness of such
amendments or substitutions could be contested by the parties involved.

2. Probable Cause Determination: Any amendment or substitution of the complaint or information would likely
prompt a reevaluation of probable cause by the trial court. This reevaluation would influence the issuance of
warrants of arrest and further legal proceedings. The adherence to proper procedures in effecting such
amendments or substitutions would be crucial to ensure the validity of subsequent actions by the court.

3. Contempt Charges: In the case, Zenaida Limbona sought contempt charges against Judge Balut and other
parties for allegedly obstructing justice. If any amendments or substitutions to the complaint or information
were made in defiance of previous court rulings or without proper legal basis, it could be interpreted as a form
of obstruction of justice, potentially strengthening the contempt charges.

4. Appellate Review: The legality of any amendments or substitutions to the complaint or information could also
be subject to appellate review. Parties dissatisfied with such amendments may seek recourse through appeals
to higher courts, arguing procedural irregularities or violations of substantive rights.
Therefore, the amendment or substitution of the complaint or information is relevant to the case as it pertains
to the evolution of charges against the accused, the determination of probable cause, the allegations of
obstruction of justice, and the potential for appellate review of legal decisions related to these amendments.