The Supreme Court (SC) stressed that the government must ensure clean and proper jail facilities, as it upheld the Office of the Ombudsman’s dismissal of charges against police officers over the alleged secret detention and mistreatment of detainees at a Manila police station.

In a decision penned by Associate Justice Jhonny J. Kho, Jr., the SC ruled that the Ombudsman did not commit grave abuse of discretion in finding no probable cause against the officers, citing a lack of credible, independent evidence to support the Commission on Human Rights’ (CHR) allegations. 

While dismissing the petition, the SC emphasized the State’s continuing responsibility to uphold humane conditions in all detention facilities.

“Custodial facilities are for the holding of arrested persons under custodial investigation;63 hence, it is a facility for people deprived of liberty for a limited period. Despite its temporariness, the people detained therein are also entitled to basic human rights. Necessarily, the PNP’s custodial facilities should be clean, adequately equipped, and sanitary, with decent provisions of quarters, food, water, and the like, consistent with the penal facilities envisioned in Republic Act No. 10575, Republic Act No. 6975, and the Nelson Mandela Rules. Thus, the Court calls the attention of the PNP to provide custodial facilities that are clean, adequately equipped, and sanitary. Persons deprived of liberty deserve no less,” the decision read.

FACTS AND ISSUE

The case stemmed from an April 2017 inspection by the CHR at Raxabago Police Station 1 in Tondo, Manila, where it discovered a concealed, cramped space inside the Drug Enforcement Unit office that it described as a “secret detention cell.” 

The CHR alleged that 12 individuals were being held there without proper arrest records, inquest proceedings, or adequate living conditions—claiming that some detainees were tortured and extorted by police personnel.

The CHR subsequently filed criminal and administrative complaints before the Ombudsman against several officers for alleged violations of the Revised Penal Code, the Anti-Torture Act (RA 9745), and the Revised Philippine National Police Operational Procedures. 

In 2020, the Ombudsman dismissed the complaints for lack of probable cause, citing insufficient and hearsay-based evidence. A motion for reconsideration was denied the following year.

In its petition before the SC, the CHR argued that the Ombudsman committed grave abuse of discretion by using a higher evidentiary threshold than probable cause. 

The central issue raised was whether the Ombudsman erred in dismissing the charges despite the allegations of inhumane treatment and unlawful detention.

RULING

The SC denied the petition and affirmed the Ombudsman’s dismissal of the criminal complaints, holding that it acted within its authority in determining that probable cause was lacking.

The SC found the CHR’s claims to be inadequately supported, relying largely on hearsay, a poorly lit video, and a recanted statement. It noted that 10 of the 12 detainees submitted sworn affidavits contradicting the allegations of abuse, and medical examinations revealed no signs of physical maltreatment. 

The High Court concluded that the Ombudsman properly exercised its mandate in evaluating the evidence and resolving the complaint.

While recognizing the systemic problems in custodial facilities, the SC clarified that structural deficiencies alone cannot justify criminal prosecution without legal and factual basis.

“Although the Court is not unmindful of the deplorable state of jail facilities in general and perennial jail congestion, as these were recognized in the En Banc case of Almonte v. People, it will be the height of injustice to blame the officers on the ground for the alleged unbearable detention facility, especially so that in this case, PSUPT Domingo’s defense was that they were forced to be resourceful due to budget constraints.” the SC wrote.

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