ASG Law

Tag: Clarificatory Hearing

  • Due Process in Preliminary Investigations: Safeguarding Rights in Philippine Criminal Procedure

    Understanding Due Process in Preliminary Investigations: Ensuring Fair Criminal Proceedings

    TLDR: This case clarifies that a clarificatory hearing is not mandatory in preliminary investigations in the Philippines, and prosecutors have the discretion to obtain additional evidence like autopsy reports. The key takeaway is that due process in this stage primarily means providing an opportunity to be heard, not a full-blown trial. This ensures efficient case progression while protecting fundamental rights.

    G.R. NO. 147932, January 25, 2006

    INTRODUCTION

    Imagine being accused of a crime based on preliminary findings, with your life hanging in the balance. In the Philippine legal system, the preliminary investigation serves as a crucial filter, ensuring that only cases with probable cause proceed to trial. This case, *De Ocampo v. Secretary of Justice*, delves into the critical aspect of due process during this preliminary stage, specifically examining the necessity of clarificatory hearings and the prosecutor’s role in evidence gathering. At its heart is the question: How much process is ‘due’ before a person is formally charged in court?

    Laila G. De Ocampo, a teacher, faced homicide and child abuse charges after allegedly causing the death of a student. The Department of Justice (DOJ) upheld the prosecutor’s finding of probable cause, prompting De Ocampo to question the fairness of the preliminary investigation, arguing she was denied due process. This Supreme Court decision provides valuable insights into the scope of due process rights during preliminary investigations in the Philippines, particularly regarding clarificatory hearings and evidence collection.

    LEGAL CONTEXT: DUE PROCESS AND PRELIMINARY INVESTIGATIONS IN THE PHILIPPINES

    The cornerstone of Philippine criminal procedure is the constitutional right to due process. This fundamental right, enshrined in Section 1, Article III of the 1987 Constitution, guarantees that no person shall be deprived of life, liberty, or property without due process of law. In the context of criminal proceedings, due process encompasses fairness throughout the different stages, beginning with the preliminary investigation.

    A preliminary investigation, as defined in Section 1, Rule 112 of the Rules of Court, is an inquiry to determine if there is sufficient ground to believe that a crime has been committed and that the accused is probably guilty. It is not a trial, but rather an inquisitorial proceeding. The purpose is to filter out baseless complaints and spare innocent individuals from the ordeal of a public trial. Crucially, the level of evidence required at this stage is not proof beyond reasonable doubt, but probable cause.

    Rule 112 outlines the procedural steps for preliminary investigations. Section 3(e) of Rule 112, which is central to this case, addresses clarificatory hearings:

    “(e) If the investigating officer believes that there are matters to be clarified, he may set a hearing to propound clarificatory questions to the parties or their witnesses, during which the parties shall be afforded an opportunity to be present but without the right to examine or cross-examine. xxx”

    The use of “may” in this provision is crucial. Legal interpretation, supported by Philippine jurisprudence, dictates that “may” is generally permissive, indicating that clarificatory hearings are discretionary, not mandatory, for the investigating officer. This discretion is further emphasized by established case law, which underscores that preliminary investigation is not a venue for exhaustive evidence presentation but a determination of probable cause.

    CASE BREAKDOWN: DE OCAMPO V. SECRETARY OF JUSTICE

    The case began with a complaint filed by Magdalena Dacarra and Erlinda Orayan against Laila G. De Ocampo, a teacher, for homicide and violation of Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act). The accusations stemmed from an incident where De Ocampo allegedly banged the heads of two students, Ronald Dacarra and Lorendo Orayan, resulting in Ronald’s death.

    Here’s a chronological breakdown of the case’s procedural journey:

    1. Initial Complaint and Inquest: Magdalena Dacarra reported the incident to the police. During inquest proceedings, the inquest prosecutor initially found insufficient evidence for homicide and recommended further investigation.
    2. Preliminary Investigation: The case was assigned for preliminary investigation. Erlinda Orayan alleged De Ocampo offered her money to withdraw the complaint. Witnesses, including another student, Jennilyn Quirong, came forward.
    3. Counter-Affidavit and Autopsy Report: De Ocampo submitted a counter-affidavit. The investigating prosecutor obtained an autopsy report revealing the cause of death as “Intracranial hemorrhage secondary to traumatic injury of the head.”
    4. Prosecutor’s Resolution: The investigating prosecutor found probable cause for homicide in relation to RA 7610 and violation of RA 7610, recommending charges against De Ocampo.
    5. Petition for Review to DOJ: De Ocampo appealed to the DOJ Secretary, alleging denial of due process due to the lack of a clarificatory hearing and the unilateral procurement of the autopsy report. She also argued the inquest prosecutor’s initial findings should prevail.
    6. DOJ Resolution: The DOJ Secretary denied the petition, affirming the prosecutor’s finding of probable cause. The DOJ Secretary emphasized the discretionary nature of clarificatory hearings and the prosecutor’s prerogative to gather evidence.
    7. Motion for Reconsideration and Petition for Certiorari to Supreme Court: De Ocampo’s motion for reconsideration was denied by the DOJ. She then filed a petition for certiorari with the Supreme Court, arguing grave abuse of discretion.

    The Supreme Court, in its decision penned by Justice Carpio, addressed two key issues raised by De Ocampo:

    1. Denial of Due Process: De Ocampo argued she was denied due process because the investigating prosecutor did not conduct a clarificatory hearing and unilaterally obtained the autopsy report.
    2. Probable Cause: De Ocampo challenged the finding of probable cause, arguing the head-banging incident was not the proximate cause of death.

    On the issue of due process, the Supreme Court firmly stated:

    “A clarificatory hearing is not indispensable during preliminary investigation. Rather than being mandatory, a clarificatory hearing is optional on the part of the investigating officer as evidenced by the use of the term ‘may’ in Section 3(e) of Rule 112.”

    The Court further clarified that due process at this stage is simply the opportunity to be heard, which De Ocampo was afforded by submitting her counter-affidavit. Regarding the autopsy report, the Court found no procedural violation, stating, “Neither is there a law requiring the investigating prosecutor to notify the parties before securing a copy of the autopsy report.”

    On the issue of probable cause, the Supreme Court upheld the DOJ Secretary’s finding. The Court reasoned that the intervening events (consultation with a quack doctor and hospital confinement) did not break the causal link between the head-banging incident and Ronald’s death. These were deemed evidentiary matters for trial, not for preliminary investigation. The Court reiterated that probable cause requires only probability, not absolute certainty.

    Ultimately, the Supreme Court denied De Ocampo’s petition, affirming the DOJ Resolutions and underscoring the discretionary nature of clarificatory hearings and the evidence-gathering powers of prosecutors during preliminary investigations.

    PRACTICAL IMPLICATIONS: WHAT THIS CASE MEANS FOR YOU

    The *De Ocampo* case provides crucial practical takeaways for individuals and legal practitioners involved in Philippine criminal procedure, particularly concerning preliminary investigations:

    Discretion in Clarificatory Hearings: This ruling reinforces that respondents in preliminary investigations cannot demand clarificatory hearings as a matter of right. Investigating officers have the discretion to determine if such hearings are necessary. Respondents should focus on submitting comprehensive counter-affidavits and evidence to present their defense effectively.

    Prosecutorial Discretion in Evidence Gathering: Prosecutors are not limited to the evidence presented by complainants. They can proactively gather additional evidence, like autopsy reports, to establish probable cause. This underscores the inquisitorial nature of preliminary investigations and the prosecutor’s role in ensuring a thorough inquiry.

    Focus on Probable Cause: Preliminary investigations are not mini-trials. The focus is solely on determining probable cause. Respondents should address the issue of probable cause directly in their submissions, understanding that evidentiary nuances and defenses are better suited for the trial proper.

    Importance of Counter-Affidavits: Since clarificatory hearings are not guaranteed, the counter-affidavit becomes a critical opportunity for respondents to present their side of the story and challenge the complainant’s allegations. A well-prepared counter-affidavit, supported by evidence, is crucial in effectively navigating the preliminary investigation stage.

    KEY LESSONS FROM DE OCAMPO V. SECRETARY OF JUSTICE:

    • Due Process in Preliminary Investigation is Primarily the Opportunity to be Heard: It does not equate to a full trial or demand specific procedures beyond the basic right to present a defense.
    • Clarificatory Hearings are Discretionary: Do not assume or demand a clarificatory hearing. Focus on robust written submissions.
    • Prosecutors Can Gather Evidence Independently: Be aware that prosecutors can and will seek evidence beyond what complainants provide.
    • Probable Cause is the Standard: The preliminary investigation is not about proving guilt beyond a reasonable doubt, but establishing a probability of guilt.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: Is a preliminary investigation a trial?

    A: No, a preliminary investigation is not a trial. It is an inquiry to determine if there is probable cause to charge someone with a crime. Trials occur in court after a charge is formally filed.

    Q: Am I entitled to a clarificatory hearing during a preliminary investigation?

    A: Not necessarily. Clarificatory hearings are discretionary for the investigating officer. You have the right to submit a counter-affidavit and evidence, but a hearing is not guaranteed.

    Q: What is probable cause?

    A: Probable cause means there are sufficient facts and circumstances to lead a reasonable person to believe that a crime has been committed and the person being investigated likely committed it.

    Q: What happens if probable cause is found?

    A: If probable cause is found, the prosecutor will file charges in court, and the case will proceed to trial.

    Q: What should I do if I am asked to attend a preliminary investigation?

    A: Seek legal counsel immediately. A lawyer can guide you through the process, help you prepare your counter-affidavit, and protect your rights.

    Q: Can I appeal a prosecutor’s finding of probable cause?

    A: Yes, you can appeal to the Secretary of Justice and potentially to higher courts if your appeal is denied.

    Q: Is it possible to win a case at the preliminary investigation stage?

    A: Yes, if you can successfully demonstrate that there is no probable cause, the prosecutor may dismiss the complaint.

    Q: What is the role of an autopsy report in a homicide case?

    A: An autopsy report is crucial evidence in homicide cases as it determines the cause of death, which is essential in establishing probable cause and proving the crime.

    ASG Law specializes in Criminal Litigation and Procedure. Contact us or email hello@asglawpartners.com to schedule a consultation.

  • Limits to Ombudsman’s Discretion: When Clarificatory Hearings are Not Mandatory

    In Dr. Benita F. Osorio v. Hon. Aniano A. Desierto, et al., the Supreme Court affirmed that the Office of the Ombudsman has discretion in deciding whether to conduct a clarificatory hearing during a preliminary investigation. The Court held that if the Ombudsman believes sufficient evidence exists to establish probable cause, a clarificatory hearing is not mandatory. This ruling underscores the principle that preliminary investigations are not trials, and the Ombudsman’s judgment on the adequacy of evidence will generally be respected by the courts, absent a clear showing of grave abuse of discretion.

    From School Principal to Courtroom: Navigating the Ombudsman’s Probe

    This case arose from a complaint filed against Dr. Benita F. Osorio, the principal of Dr. Cecilio Putong National High School, alleging various acts of misconduct and malfeasance. Following an investigation, the Office of the Ombudsman-Visayas found probable cause to indict Dr. Osorio for five counts of Malversation of Public Funds and five counts of violations of Section 3(e) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act. The charges stemmed from allegations that Dr. Osorio misappropriated funds from the sale of old newspapers, engaged in irregularities in the purchase of school supplies, and collected excessive membership fees for the Boy and Girl Scouts of the Philippines. These allegations painted a picture of a school official potentially abusing her position for personal gain, which warranted further legal scrutiny.

    Dr. Osorio sought to challenge the Ombudsman’s findings, arguing that a clarificatory hearing was necessary to resolve conflicting issues and that there was insufficient evidence to establish probable cause. However, the Court of Appeals upheld the Ombudsman’s decision, leading Dr. Osorio to appeal to the Supreme Court. Central to this legal challenge was the interpretation of Rule 112 of the Rules of Criminal Procedure, particularly Section 3(e), which states that an investigating officer “may” set a hearing if there are facts and issues to be clarified. The question before the Supreme Court was whether the Ombudsman had abused its discretion by not conducting a clarificatory hearing and whether the evidence supported the finding of probable cause.

    The Supreme Court held that the decision to conduct a clarificatory hearing lies within the sound discretion of the investigating officer. The Court emphasized that the use of the word “may” in Rule 112 indicates that such a hearing is not mandatory.

    “(e) The investigating officer may set a hearing if there are facts and issues to be clarified from a party or a witness. The parties can be present at the hearing but without the right to examine or cross-examine. They may, however, submit to the investigating officer questions which may be asked to the party or witness concerned.”

    Building on this principle, the Court cited its earlier ruling in Webb v. De Leon, stating that if the evidence already on hand yields a probable cause, the investigator need not hold a clarificatory hearing. The Court further reiterated the established definition of probable cause, which is “such facts as are sufficient to engender a well-founded belief that a crime has been committed and that respondent is probably guilty thereof.” Therefore, the Court ruled that the Ombudsman did not gravely abuse its discretion in finding probable cause against Dr. Osorio without conducting a clarificatory hearing, as there was enough evidence to warrant the indictment. Furthermore, the consistent and general policy of the Court is not to interfere with the Office of the Ombudsman’s exercise of its investigatory and prosecutory powers.

    The Court also rejected Dr. Osorio’s argument that she could not be charged with malversation because receiving and accounting for school funds was not part of her official duties as principal. The Court emphasized that the absence or presence of elements of the crime are matters of evidence that are best determined during a full trial, not during the preliminary investigation.

    In conclusion, the Supreme Court affirmed the Court of Appeals’ decision, reinforcing the principle that the Ombudsman has broad discretion in conducting preliminary investigations. This decision clarifies that a clarificatory hearing is not a mandatory step and that the courts should respect the Ombudsman’s judgment unless there is a clear showing of grave abuse of discretion.

    FAQs

    What was the key issue in this case? The key issue was whether the Office of the Ombudsman committed grave abuse of discretion by not conducting a clarificatory hearing before finding probable cause to indict Dr. Osorio. The court needed to determine if clarificatory hearings are mandatory.
    What is the definition of probable cause? Probable cause refers to facts sufficient to create a well-founded belief that a crime has been committed and the respondent is likely guilty. It is a lower standard than proof beyond a reasonable doubt and only requires a reasonable ground for suspicion.
    What is a clarificatory hearing? A clarificatory hearing is a discretionary proceeding in a preliminary investigation where the investigating officer seeks to clarify facts from a party or witness. It is not a trial, and parties do not have the right to cross-examine witnesses.
    Can a school principal be charged with malversation even if handling funds is not their primary duty? Yes, the Court clarified that whether a school principal can be charged with malversation, even if handling funds is not their primary duty, is a matter to be resolved during trial. The preliminary investigation determines probability of the charge.
    What does Section 3(e) of Republic Act No. 3019 cover? Section 3(e) of Republic Act No. 3019 prohibits public officials from causing undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage, or preference in the discharge of their official functions. This case touched on accusations that Dr. Osorio violated this law through irregular purchases and fee collections.
    What was the basis for the malversation charges against Dr. Osorio? The malversation charges were primarily based on allegations that Dr. Osorio misappropriated funds from the sale of old newspapers. COA findings suggested these proceeds were not properly recorded and accounted for in the school’s books.
    Does the Court generally interfere with the Ombudsman’s decisions? The Court’s policy is generally not to interfere with the Ombudsman’s investigatory and prosecutory powers, respecting the independence and authority granted by the Constitution. Interference only occurs if there’s a clear case of abuse of discretion.
    What was the significance of the word “may” in Rule 112 regarding clarificatory hearings? The use of the word “may” in Rule 112 signifies that conducting a clarificatory hearing is discretionary, not mandatory. This grants the investigating officer the flexibility to decide whether such a hearing is necessary based on the available evidence.

    This ruling serves as a reminder of the broad discretion afforded to the Office of the Ombudsman in conducting preliminary investigations and reinforces the importance of presenting a strong defense during the trial proper, where evidentiary matters are fully scrutinized. The decision highlights the necessity of showing grave abuse of discretion to successfully challenge the Ombudsman’s findings.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Dr. Benita F. Osorio v. Hon. Aniano A. Desierto, G.R. No. 156652, October 13, 2005

  • Ensuring Due Process: The Vital Role of Clarificatory Hearings in Philippine Preliminary Investigations

    The Right to Clarification: Why Preliminary Investigations Must Include Clarificatory Hearings

    In Philippine criminal procedure, the preliminary investigation serves as a crucial filter, ensuring that only cases with probable cause proceed to trial. This case underscores the importance of due process within this phase, specifically highlighting the right of the accused to request clarificatory hearings to challenge evidence and ensure a fair evaluation before charges are filed in court. Ignoring this right can be a grave abuse of discretion, potentially leading to the dismissal of flawed cases and safeguarding individual liberties from unwarranted prosecution.

    G.R. No. 132977, November 29, 2000

    INTRODUCTION

    Imagine being accused of a crime you didn’t commit, based on evidence you believe is questionable. In the Philippines, the preliminary investigation is designed to protect citizens from baseless accusations. This case, Mayor Luis Mondia, Jr. v. Deputy Ombudsman, revolves around whether the Ombudsman can refuse to conduct clarificatory hearings during a preliminary investigation, especially when the accused presents compelling reasons, like conflicting witness statements, to question the evidence against them. At its core, this case asks: Is denying a request for clarificatory questions a violation of due process, and what recourse do the accused have?

    LEGAL CONTEXT: PRELIMINARY INVESTIGATIONS AND DUE PROCESS

    The Philippine legal system emphasizes due process, ensuring fairness and impartiality at every stage of legal proceedings, especially in criminal cases. A preliminary investigation is a critical part of this process. It is an inquiry or proceeding to determine whether there is sufficient ground to engender a well-founded belief that a crime cognizable by the Regional Trial Court has been committed and that the respondent is probably guilty thereof, and should be held for trial.

    Rule 112 of the Rules of Court, specifically Section 4, outlines the procedure for preliminary investigations. Furthermore, the Rules of Procedure of the Office of the Ombudsman, Administrative Order No. 7, supplements these rules, particularly Section 4(f), which states:

    “If, after the filing of the requisite affidavits and their supporting evidences, there are facts material to the case which the investigating officer may need to be clarified on, he may conduct a clarificatory hearing during which the parties shall be afforded the opportunity to be present but without the right to examine or cross-examine the witness being questioned.”

    This provision explicitly grants the investigating officer the discretion to conduct clarificatory hearings. However, jurisprudence, as highlighted in this case, suggests that this discretion is not absolute, especially when the accused raises valid points requiring clarification. The right to a preliminary investigation itself is not merely procedural; it is a substantive right, denial of which can be a violation of due process. This right ensures that individuals are not subjected to the ordeal of a public trial without a prior impartial determination of probable cause.

    CASE BREAKDOWN: MONDIA VS. OMBUDSMAN

    The case began with a criminal complaint filed by Corazon Odelmo against Mayor Luis Mondia, Jr., and several others, for the killing of her husband and father-in-law. The Ombudsman initiated a preliminary investigation, and subsequently, two Informations for Murder were filed against the petitioners in the Regional Trial Court (RTC) of Bago City.

    Here’s a breakdown of the key events:

    1. Initial Filing and Quashing: The RTC initially quashed the Informations due to procedural issues regarding the Ombudsman’s resolution.
    2. Supreme Court Intervention (G.R. Nos. 118813-14): The Ombudsman appealed to the Supreme Court, which GRANTED the petition, setting aside the RTC’s order. The Supreme Court directed the Ombudsman to complete the preliminary investigation by furnishing copies of the resolutions to the petitioners and resolving any subsequent incidents.
    3. Petitioners’ Motion for Clarification: Instead of immediately seeking reconsideration of the probable cause finding, the petitioners requested a clarificatory hearing, citing conflicting affidavits from the complainant, Corazon Odelmo.
    4. Ombudsman’s Refusal and Revocation: The Deputy Ombudsman initially directed the Provincial Prosecutor to reinvestigate and conduct clarificatory questions but then abruptly revoked this directive and denied the motion for clarificatory hearing.
    5. Petition for Certiorari and Mandamus (G.R. No. 132977): Aggrieved by the Ombudsman’s refusal, the petitioners filed a special civil action for certiorari and mandamus with the Supreme Court, arguing grave abuse of discretion.

    The Supreme Court, in its Resolution, emphasized the substantive nature of preliminary investigations and the importance of clarificatory hearings, especially when requested by the accused to address material questions. The Court stated:

    “The propounding of clarificatory questions is an important component of a preliminary investigation, moreso in this case where it was requested by the petitioners in order to shed light on the affidavits of desistance purportedly executed by the private complainant.”

    Further, the Court highlighted the Deputy Ombudsman’s grave abuse of discretion in revoking the directive for reinvestigation and denying the clarificatory hearing, especially considering the conflicting affidavits and the complainant’s later statements seemingly recanting her accusations. The Court underscored the right to due process, stating:

    “To deny the accused’s claim to a preliminary investigation would be to deprive him of the full measure of his right to due process.”

    Ultimately, the Supreme Court GRANTED the petition, annulling the Ombudsman’s orders and directing the Deputy Ombudsman to conduct a clarificatory hearing and complete the preliminary investigation.

    PRACTICAL IMPLICATIONS: PROTECTING YOUR RIGHT TO DUE PROCESS

    This case serves as a powerful reminder of the significance of due process rights during preliminary investigations. It clarifies that while the Ombudsman has discretion in conducting clarificatory hearings, this discretion is not unlimited and must be exercised judiciously, especially when there are legitimate questions regarding the evidence.

    For individuals facing criminal complaints, this ruling provides crucial leverage. It reinforces the right to actively participate in the preliminary investigation and to seek clarification on evidence presented against them. Conflicting testimonies, affidavits of desistance, or any material inconsistencies are valid grounds to request clarificatory hearings.

    Key Lessons from Mondia v. Ombudsman:

    • Substantive Right to Preliminary Investigation: A preliminary investigation is not a mere formality but a fundamental right ensuring protection against unwarranted prosecution.
    • Importance of Clarificatory Hearings: Accused individuals have the right to request clarificatory hearings to address inconsistencies or ambiguities in the evidence, especially conflicting witness statements.
    • Ombudsman’s Discretion is Not Absolute: While the Ombudsman has discretion, refusing clarificatory hearings without valid reason, particularly when requested to clarify crucial issues, can be deemed a grave abuse of discretion.
    • Due Process Prevails: Denying a request for clarificatory hearing when justified can be a violation of due process, potentially leading to legal remedies like certiorari and mandamus.

    FREQUENTLY ASKED QUESTIONS (FAQs)

    Q: What is a preliminary investigation?

    A preliminary investigation is a process conducted by prosecutors or the Ombudsman to determine if there is probable cause to charge a person with a crime in court. It’s a crucial step to prevent baseless criminal charges.

    Q: What is a clarificatory hearing?

    A clarificatory hearing is a proceeding during a preliminary investigation where the investigating officer asks questions to clarify certain facts or issues arising from the submitted affidavits and evidence. It allows for a deeper understanding of the case before deciding whether to file charges.

    Q: When can I request a clarificatory hearing?

    You can request a clarificatory hearing if there are material facts that need clarification after you and the complainant have submitted your affidavits and evidence. Conflicting statements, ambiguities, or new evidence are valid reasons to request one.

    Q: What happens if the Ombudsman refuses my request for a clarificatory hearing?

    If the Ombudsman refuses a valid request for a clarificatory hearing, especially when it leads to a potential denial of due process, you can file a Petition for Certiorari with the courts to challenge the Ombudsman’s decision, as demonstrated in the Mondia case.

    Q: Does an affidavit of desistance automatically lead to the dismissal of a case?

    No, an affidavit of desistance is not automatic grounds for dismissal. However, it is a significant factor that investigating officers, like the Ombudsman, must consider. Clarificatory hearings can help determine the voluntariness and credibility of such affidavits.

    Q: What is grave abuse of discretion in the context of the Ombudsman’s actions?

    Grave abuse of discretion means the Ombudsman acted in a capricious, whimsical, arbitrary, or despotic manner in the exercise of their judgment, such as when they act contrary to the Constitution, laws, or settled jurisprudence, like improperly denying a justified request for clarificatory hearing.

    Q: How can I ensure my rights are protected during a preliminary investigation?

    Seek legal counsel immediately if you are subject to a preliminary investigation. A lawyer can guide you through the process, help you prepare your defense, and ensure your rights to due process, including the right to request clarificatory hearings, are protected.

    ASG Law specializes in criminal defense and navigating complex legal procedures like preliminary investigations before the Ombudsman and other prosecutorial bodies. Contact us or email hello@asglawpartners.com to schedule a consultation.