G.R. No. 100359 May 20, 1994
LT. COL. ONOFRE E. LACAMBRA, (Ret.), petitioner, vs. HON. EUGENIO E. RAMOS, Presiding Judge, Branch 39, RTC Lingayen, Pangasinan, HON. LAURENCIA N. ABELON, Asst. Provincial Prosecutor, Lingayen, Pangasinan, respondents.

FACTS

On August 26, 1989, Ramon Tamondong was killed inside the house of retired Lt. Col. Onofre E. Lacambra. The following day, two criminal complaints for murder and illegal possession of firearm (P.D. 1866) were filed against Lacambra with the Municipal Trial Court (MCTC) of Binalonan. Lacambra filed a counter-affidavit claiming he was attacked by seven armed men and that Tamondong was accidentally shot by his own companion during a struggle. The MCTC, after preliminary investigation, found strong evidence against Lacambra, issued a warrant of arrest recommending no bail, and later forwarded the case records to the Provincial Prosecutor. Lacambra was arrested on September 4, 1989. The Provincial Prosecutor filed Informations for illegal possession of firearm (Criminal Case No. L-4130) on September 6, 1989, and for murder (Criminal Case No. L-4132) on September 9, 1989, with the Regional Trial Court (RTC) Branch 39, Lingayen. Lacambra sought reinvestigation and filed petitions for review with the Department of Justice, which were denied. He also filed a petition for habeas corpus (G.R. No. 94600), which was dismissed by the Supreme Court. After multiple postponements due to changes in counsel and various motions, Lacambra was arraigned on May 23, 1991, where he refused to plead, and a plea of “not guilty” was entered for him. He then filed the present petition for certiorari and prohibition seeking to annul the criminal informations and his detention.

ISSUE

1. Whether the court acquired jurisdiction over the subject matter of the offense.
2. Whether the arraignment of the accused on May 23, 1991, constituted grave abuse of discretion.

RULING

The petition is devoid of merit.
1. The RTC acquired jurisdiction over the subject matter. The Supreme Court, in a prior en banc resolution (November 20, 1990) in the related habeas corpus case (G.R. No. 94600), had already upheld the court’s jurisdiction. The criminal complaints, supported by sworn statements, were filed with the MCTC, which conducted a preliminary investigation and found prima facie cases. Jurisdiction over the person was acquired through a valid warrant of arrest issued by the MCTC, and Lacambra has been under detention pursuant to valid court processes. The case records were properly transmitted to the Provincial Prosecutor, who then filed the Informations with the RTC.
2. The arraignment did not constitute grave abuse of discretion. The court appointed counsel de oficio for Lacambra after his counsel withdrew. When Lacambra refused to plead during arraignment, the court properly entered a plea of “not guilty” on his behalf, in accordance with procedural rules.
The Supreme Court denied the petition, noting the series of legal maneuvers that caused protracted delays. It ordered the RTC to conduct a continuous trial immediately and to render its decision within three months from the date the case is submitted for decision.