SEN. ANTONIO “SONNY” F. TRILLANES IV, PETITIONER, VS. HON. SALVADOR C. MEDIALDEA IN HIS CAPACITY AS EXECUTIVE SECRETARY, ET AL., RESPONDENTS. [G.R. No. 256660] PEOPLE OF THE PHILIPPINES, PETITIONER, VS. SEN. ANTONIO F. TRILLANES IV, RESPONDENT. [G.R. No. 256078] PEOPLE OF THE PHILIPPINES, PETITIONER, VS. SEN. ANTONIO F. TRILLANES IV, RESPONDENT.
FACTS
Former Senator Antonio F. Trillanes IV, a former Navy officer, led the Oakwood Mutiny in 2003 and was charged with Coup d’etat. During the pendency of that case, he and his group staged the Manila Peninsula Incident in 2007, leading to a charge of Rebellion. In 2010, President Benigno S. Aquino III issued Proclamation No. 75, granting amnesty to participants of these incidents. Congress concurred via Concurrent Resolution No. 4. Trillanes applied for amnesty under this proclamation. He filled out the official application form, admitted his guilt for the acts involved, and his application was processed and granted by the DND Ad Hoc Amnesty Committee. Consequently, the Coup d’etat and Rebellion cases against him were dismissed by the respective trial courts in 2011. In 2018, President Rodrigo R. Duterte issued Proclamation No. 572, declaring Proclamation No. 75 void ab initio for Trillanes, alleging his application was defective due to a lack of formal admission of guilt and failure to comply with application requirements. The government sought to have the dismissed cases revived and for arrest warrants to be issued against Trillanes.
ISSUE
The primary issue is whether Proclamation No. 572, which declared Trillanes’s amnesty void ab initio and sought the revival of the criminal cases against him, is valid and constitutional.
RULING
The Supreme Court declared Proclamation No. 572 void and unconstitutional. The Court ruled that President Duterte’s proclamation unlawfully encroached upon judicial powers, as the dismissal of the criminal cases against Trillanes by the trial courts were final and executory judgments. The President cannot unilaterally revoke an amnesty previously granted by a predecessor and concurred in by Congress. The Court found that Trillanes had substantially complied with the amnesty application requirements, including the admission of guilt. The amnesty granted to Trillanes in 2011 extinguished his criminal liability, and the doctrine of res judicata bars the revival of the dismissed cases. The Court upheld the supremacy of the rule of law and the Constitution, affirming that no one, not even the President, is above the law.
