G.R. No. 241494 , April 3, 2024
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 “Sonny” F. Trillanes IV, a former military officer, was charged with coup d’etat for the 2003 Oakwood Mutiny and rebellion for the 2007 Manila Peninsula Hotel incident. In 2010, President Benigno S. Aquino III issued Proclamation No. 75, granting amnesty to participants of these incidents, requiring applicants to admit guilt. The Department of National Defense (DND) created a committee with rules (DND Amnesty Committee Circular No. 1) mandating an express admission of involvement and guilt. On January 21, 2011, the DND granted amnesty to Trillanes, issuing a Certificate of Amnesty. Based on this, the trial courts dismissed the criminal cases against him. In 2018, President Rodrigo R. Duterte issued Proclamation No. 572, revoking Trillanes’s amnesty grant, alleging he did not file an official application form and never admitted guilt. The Department of Justice subsequently filed motions for his arrest. Trillanes challenged the proclamation’s validity.

ISSUE

The primordial issue is the validity of Proclamation No. 572 and its subsequent effects on the coup d’etat and rebellion cases against Trillanes.

RULING

Proclamation No. 572 is declared VOID. The Separate Concurring Opinion concurs with the ponencia that the proclamation violated Trillanes’s constitutional rights. It specifically singled out Trillanes from the 277 other amnesty grantees under Proclamation No. 75 without reasonable classification or justification, violating his right to equal protection of the laws. The process was arbitrary, as Trillanes was not notified of any review of his amnesty application nor given an opportunity to explain, violating his right to due process. The opinion further states that rights already vested, such as the amnesty granted and the subsequent dismissal of his cases, cannot be arbitrarily withdrawn by a subsequent administration. The proclamation’s attempt to nullify a completed amnesty grant and revive already dismissed criminal cases is invalid.