G.R. No. 191416. February 7, 2017.
MAYOR WILLIAM N. MAMBA, ET AL., Petitioners, vs. LEOMAR BUENO, Respondent.

FACTS

Respondent Leomar Bueno, then a minor, was invited for questioning on June 14, 2009, regarding a robbery at a canteen owned by the mother of petitioners Mayor William Mamba and Atty. Francisco Mamba, Jr. Members of the local Task Force Lingkod Bayan brought him to the Tuao police station. The petitioners’ version states that the investigation could not proceed due to the absence of police investigators, and the respondent’s custody was referred to the Task Force. They allege the Mayor and Atty. Mamba were not in Tuao at the time. The respondent was later transferred to PNP custody on June 18.
The respondent alleged a different, more severe account. He claimed that after being taken to the police station, he was fetched by Task Force members and brought to Mayor Mamba’s house, where he and another minor were detained. He testified that during this detention, which lasted until June 18, they were tortured, beaten, and questioned under threat to admit to the robbery. His mother, Maritess Bueno, was denied access to him and sought assistance from the PNP and the Commission on Human Rights. The respondent was eventually released to the local Social Welfare office.

ISSUE

The core issue is whether the respondent’s allegations and evidence were sufficient to establish his entitlement to the protective relief of the writ of amparo against the petitioners.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ grant of the writ of amparo. The legal logic centered on the distinct nature and purpose of an amparo petition, which is not a criminal proceeding to establish guilt but a summary remedy to address threats to a person’s life, liberty, and security. The Court emphasized that the standard of proof required is substantial evidence, which is more than a mere scintilla but less than proof beyond reasonable doubt.
Applying this standard, the Court found the respondent’s detailed and consistent narrative, corroborated by his mother’s actions in desperately seeking help from various authorities, constituted substantial evidence of his illegal detention and the threats to his liberty and security. The petitioners’ defense, primarily denial and alibi, failed to convincingly refute these specific allegations. The Court noted the unexplained transfer of custody from the police station to a private residence and the denial of access to the minor’s parent as indicative of a deprivation of liberty. Consequently, the respondent successfully discharged the burden of proving by substantial evidence that his right to security was violated, justifying the issuance of the writ for his protection. The amparo ruling is without prejudice to any separate criminal actions that may arise from the alleged acts.