G.R. No. 179817; June 27, 2008
ANTONIO F. TRILLANES IV, petitioner, vs. HON. OSCAR PIMENTEL, SR., IN HIS CAPACITY AS PRESIDING JUDGE, REGIONAL TRIAL COURT- BRANCH 148, MAKATI CITY; GEN. HERMOGENES ESPERON, VICE ADM. ROGELIO I. CALUNSAG, MGEN. BENJAMIN DOLORFINO, AND LT. COL. LUCIARDO OBEÑA, respondents.

FACTS

Petitioner Antonio F. Trillanes IV, a former naval officer, was charged with coup d’etat for his involvement in the 2003 “Oakwood Incident” and was detained pending trial. In 2007, while in detention, he was elected as a Senator of the Philippines. Before the commencement of his Senate term, he filed an Omnibus Motion with the Regional Trial Court (RTC) seeking, among other requests, permission to attend Senate sessions and official functions, to set up a working area in his detention cell, and to receive staff and media for the purpose of discharging his legislative duties. The RTC denied all his requests. Petitioner moved for reconsideration, waiving some requests and narrowing them down to three: attending Senate sessions, giving media interviews, and receiving media at his place of confinement. The RTC denied his motion for reconsideration.

ISSUE

Whether the trial court committed grave abuse of discretion in denying petitioner’s requests to attend Senate sessions and perform other legislative functions, despite his status as an elected Senator.

RULING

The Supreme Court DENIED the petition. The Court held that election to a legislative office does not automatically override the requirements of procedural due process or suspend the operation of criminal laws. A detained individual, even if elected, is not entitled to a blanket grant of freedom to attend legislative sessions. The right to public office is not a justification for evading lawful imprisonment. The Court emphasized that confinement is the necessary consequence of a valid finding of probable cause for a non-bailable offense, and the privilege of discharging legislative duties must yield to the primacy of lawful custody and the orderly administration of justice. The ruling in People v. Jalosjos was cited as controlling, where the Court declared that a detained Congressman’s duty to attend sessions is not a constitutional imperative that trumps judicial authority. The trial court did not gravely abuse its discretion, as its orders were aimed at preventing any opportunity for escape and ensuring the proper conduct of the criminal proceedings. The Court noted that petitioner’s change of custodial venue from a military brig to a police custodial center during the pendency of the case rendered some issues moot, but the core legal principle remained applicable.