Criminal Procedure SLU Baguio
Criminal Procedure SLU Baguio
Criminal Procedure SLU Baguio
Rule 111
to
the
General
1. When
the
offended
party waives the civil
action.
2. When
the
offended
party reserves the right
to institute a separate
action.
3. When
the
offended
party institutes civil
action prior to the
institution of a criminal
action.
In the civil aspect of the
criminal action, the real parties
in interest are the offended
party and the accused. As a
consequence, both the offended
party and the accused may file
an appeal in relation to the civil
aspect of the case. While the
law and rules prohibit double
recovery, there is no violation
of the right of an accused
against double jeopardy if the
offended party files an appeal
to seek an increase in the
1
these
actions
need
not
be
reserved, and the institution of a
prior civil action or waiver of the
civil liability does not extinguish
the right to file an independent
civil action.
What
are
the
different
independent civil actions?
The
following
are
the
different independent civil actions:
1. Civil actions arising from
Art. 32 of the Civil Code Violation of Political and
Civil Liberties.
2. Civil actions arising from
Art. 33 of the Civil Code Defamation,
Fraud
(including estafa as fraud
is used in its generic
sense)
and
Physical
Injuries (still in generic
senseincludes
all
offenses
resulting
to
physical injuries)
3. Civil actions arising from
Art. 34 of the Civil Code
Failure to render aid by a
Peace
Officer,
Mayor,
municipality
4. Civil Actions arising from
Art. 2176 of the Civil
Code Quasi-delicts
Waiver of Civil Liability
What is needed to make a valid
waiver?
A waiver of the civil liability
arising from the offense charged
needs a positive action and must
also be personal.
It shall be suspended in
whatever stage it may be found
until judgment on merits to await
final judgment to be rendered in
the criminal action.
Upon
a
motion
for
consolidation, there shall be a joint
trial for the civil and criminal
action for a joint judgment. The
civil action shall be consolidated in
the same criminal action. It may
happen that the civil action is in a
different
court.
Upon
consolidation, the civil action shall
be transferred to where the
criminal action is.
Is a consolidation of the prior
instituted civil action and the
criminal action mandatory?
No. It is not a ministerial
duty of the court trying the
criminal action to grant application
for consolidation of an earlier
instituted civil action.
Is the earlier instituted civil
action deemed abandoned for
failure to consolidate it with
the criminal action?
Yes if the civil action is one
to recover civil liability arising
from a criminal action committed
by government officials in relation
to their office. For all other cases,
there is no abandonment of the
civil action by reason of failure to
consolidate it with the criminal
action.
*Effect of failure to consolidate an
earlier instituted civil action for
crimes
committed
by
public
officials in relation to their
office = Abandonment of the Civil
Action
Prejudicial Question
What is a prejudicial question?
(Rule 111 Sec. 5)
A prejudicial question is an
issue involved in a civil case which
is similar or intimately related to
the issue raised in the criminal
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RULE 112
Preliminary Investigation
Nature of preliminary
investigation
It is not a judicial function
but an executive one. It is
generally inquisitorial.
While it is an executive
function, it is considered a judicial
inquiry, a judicial proceeding, as it
involves opportunity to be heard
for both parties, the production
and weighing of evidence and
decision
thereon
and
the
prosecutor, in the discharge of this
function, acts as a quasi-judicial
officer. (Arula v. Espino, 28 SCRA
226 (1990) As such, he must
exhibit the cold neutrality of an
6
preliminary
preliminary
c).
Prepare
brief
memorandum of the
reasons for the action
taken; and
d). Forward to city or
provl pros. for action.
If recommendation for
release is approved but the
evidence warrants conduct
of PI, release order shall be
served by officer having
custody and shall direct the
officer
to
serve
upon
detainee the subpoena or
notice of PI.
Who may conduct PI and
determine probable cause:
1. Provincial or city prosecutors
and their assistants;
2. National and Regional State
Prosecutors;
3. Other officers as maybe
authorized by law.
Judges of the 1st level courts
are no longer allowed to
conduct PI (Sibulo v. ToledoMupas, A.M. No. MTJ-071686, June 12, 2008)
4. COMELEC-legal
officers
have concurrent (by virtue of
RA 9369) powers with other
prosecuting arms of the govt
re: election offenses under
the Omnibus Election Code;
(Art.
IX,
Sec.
20,
Constitution)
5. Ombudsman-on its own or on
complaint by any person, any
act or omission of any public
officer or employee, office or
agency, when such act or
omission appears to be
illegal, unjust, improper or
inefficient. It has primary
jurisdiction
over
cases
cognizable
by
the
Sandiganbayan.
6. PCGG with the assistance of
the Sol Gen and other govt
agencies may investigate, file
and
prosecute
cases
investigated by it. (EO No.
14, May 7, 1986)
to
his
accused of his
rights as follows.
expanded
Miranda
be
given
in
the
Cash deposit
Property Bond
Corporate Surety
Recognizance
be
Accused
must
personally enter his plea.
Without a valid plea, any
subsequent proceedings are
void. Nonetheless, an invalid
plea will bar the application
of Double Jeopardy.
b) Promulgation Some authors
insist that the presence of
the accused is important in
promulgation. The absence
of
the
accused
during
promulgation
will
not
invalidate the proceedings.
However, it will cause him to
lose his remedies against a
judgment of conviction such
12
as reconsideration, appeal,
and new trial.
When is appearance by the
accused required by the Court?
Appearance by the accused is
required by the court in the following.
a) In-court Identification In a
criminal action, the identity
of the accused just like the
crime itself must be proven
beyond reasonable doubt.
b) Trial in absencia trial in
absencia
may
proceed
provided the accused was
given due notice for the date
of trial.
*Therefore, if a question is asked
calling for the instances when the
accuseds
presence
is
essential,
enumerate arraignment and entry of
plea, in-court identification, trial in
absencia. (promulgation may be
included)
Application
for
Determination of
Evidence of Guilt
Bail
and
Strength of
Procedure:
1. Accused applies for bail.
2. The
court
notifies
the
prosecution.
3. Bail hearing - The prosecution
presents evidence in opposition
to bail.
4. The court makes a resolution
whether the evidence of guilt is
strong or not. If the evidence of
guilt is strong, the application is
denied.
Otherwise,
the
application is granted.
What is the remedy when the
application for bail is denied?
The remedy is to file a petition
for certiorari under Rule 65 on the
ground that the court committed a
grave
abuse
of
its
discretion
amounting to excess or lack of
jurisdiction in denying the application
for bail.
What is the quantum of proof for
bail application?
Significance
of
Perfecting an Appeal.
The moment the records
of
the
case
have
been
transmitted to the appellate
court, the court loses its
jurisdiction over the case. Once
that happens, the trial court has
no authority to rule upon the
bail application of the accused.
5. Where
the
judgment
of
conviction changes the nature
of the offense from non-bailable
to bailable, the bail may only be
filed with the appellate court.
Is bail a bar to objections on
illegal arrest or lack of or irregular
of preliminary investigation? (Rule
114, Sec. 26)
No, bail is not a bar to
objections on the validity of an arrest,
warrant of arrest, or lack of or irregular
preliminary investigation. This is a
deviation from the old rule where
posting bail cures all defects in the
arrest,
warrant
of
arrest,
and
preliminary investigation. However, all
of those must be assailed before the
accused enters his plea, otherwise
their defects are deemed waived.
Other instances where Bail is
Available
Deportation Proceedings.
For
aliens
undergoing
deportation
proceedings,
bail
is
discretionary upon the Commissioner
of Immigrations.
Extradition Proceedings.
An extradite must apply for bail.
He must prove that he is not a flight
risk by clear and convincing evidence.
The Extradition Court decides whether
or not to grant the bail.
Note: No bail is allowed for cases
pending in Military Tribunals.
Forfeiture of Bond (Rule 114, Sec.
21)
by
Application
of
Upon
application
of
the
bondsman with due notice to the
prosecution, bail may be cancelled by
motion or petition upon surrender of
the accused or proof of his death.
Automatic Cancellation:
Cancelation of Bail is automatic
upon the following:
1. Acquittal of the accused
2. Dismissal of the case
3. Execution of the judgment of
conviction
15
during
the
preliminary
investigation as their direct
testimonies;
e) the court shall examine the
witnesses on their direct
testimonies or affidavits to
ascertain if the evidence of
guilt is strong;
through
the
courts
equipment or device and the
acknowledgment
of
the
recipient; or
c) reports of phone calls made
by the court.
of
electronic
transmitted
Against
Double
17
invoke
19
of
is
1. The
complaint
or
information
furnished and read to the accused
in an open court in a language or
dialect known by him.
*This may not be waived.
Any
defect may be a ground to impugn the
validity of arraignment.
2. The accused personally enters
his plea.
*The presence of the accused
during arraignment is required by the
Rules of Court.
Case: The accused was charged with
20 counts of estafa. Upon his
arraignment, the first information was
read in its entirety, and the accused
was asked whether he pleads guilty or
not to the charge. The accused
pleaded not guilty. To save time, as
the other informations were all
substantially
the
same,
the
accused
was
simply
asked
whether he pleads guilty or not to
the
charge
of
estafa
while
referring to the 19 other criminal
case docket numbers.
The
contents of the subsequent 19
criminal informations were never
read to the accused. In all of the
charges, the accused pleaded not
guilty.
Is the arraignment and
plea valid?
Suggested
Answer
which
is
in
conformity with the rules: (There is no
Supreme Court Decision on this matter
yet, but this is a prevailing practice to
save the time of Courts.) The
arraignment and plea as to the
first charge is valid while that of
the succeeding 19 charges for
estafa are void. Arraignment shall
be
made
by
furnishing
the
accused with a copy of the
complaint or information, reading
the same the language and dialect
known to him, and asking whether
he pleads guilty or not. Strict
compliance with the Rules on
Arraignment is needed since this
is the stage where the accused is
formally informed of the nature
20
21
22
amendment
of
or information is
the
not
Suspension of Arraignment
May arraignment be suspended? (Rule
116 Sec. 11)
Yes,
arraignment
may
be
suspended on the following grounds.
a. The accused appears to be
suffering from an unsound
mental
condition
which
effectively renders him unable
to fully understand the charge
against him and to plead
intelligently thereto.
b. Existence
of
a
prejudicial
question
c. Pendency of a petition for
review of the resolution of the
prosecutor either at the DOJ of
the Office of the President. The
period of suspension shall not
exceed sixty (60 days) counted
from the filing of the petition
with the reviewing office.
Bill of Particular (Rule 116 Sec. 9)
If the complaint or information
is vague, the accused may move/file a
motion for bill of particulars to enable
himself to properly plead and prepare
for trial.
When may a bill of particular be
filed?
A Bill of particular is filed before
arraignment.
What is the ground for filing a bill
of particular?
A bill of particular is filed when
the complaint or information is vague,
23
24
By
way
of
Jurisprudence:
An
information
is
sufficient
if
its
averments, if hypothetically admitted,
whether the facts alleged would
establish the essential elements of the
offense as defined by law without
considering matters aliunde.
Note: This is very similar to the test to
determine the sufficiency of a petition
or complaint in a civil action.
Only the ultimate, and not
evidentiary facts are considered.
Ultimate facts are those that allege
the cause of action or elements of a
crime. Evidentiary facts are those that
support the allegations of the ultimate
facts.
Eg.
In
a
petition
for
declaration of nullity of marriage
for
absence
of
essential
requisites, the following will be the
ultimate facts:
a) The parties were married.
b) At the time the parties were
married, either or both of
them do not possess all the
essential
elements
for
marriage
ie
consent,
contracting capacity such as
legal age, former marriage
that has not been nullified or
annulled, etc.
If applicable, the following
are added:
c) Allegations as to having
children and their custody;
d) Allegations as to acquisition
of property;
The evidentiary facts will be the
following:
a) How the parties met;
b) Making allegations as to
psychological incapacity;
c) Describing their life and
feelings before and after the
marriage;
Simply said:
Sufficiency of Criminal Information: A
criminal information is complete, if by
just looking at it, a judgment of
conviction may be had. / It can sustain
a judgment of conviction.
Sufficiency of a Complaint/Petition in a
Civil Action/ Special Proceeding: A
25
dismissal
Number of Years
before
provisional
dismissal
becomes final
1 year
1 year
2 years
Form
Who Files
When
to
File
Grounds
for Filing
Effect
Motion
to
Quash
Should be in
writing
Filed by the
Accused
Before
Entering Plea
Exclusiveonly
those
found in Rule
117, Sec. 3
Bars
Continuation
of
Proceedings
Provisional
Dismissal
May be in
any form
Either filed
by
the
accused,
prosecution
, or both.
Anytime
Any ground
will do
Shortens
the period
of
Prescription
30
JAR
in
criminal
is it daytime during
10am, the court may
simply take judicial notice
of it.
W: Im a student at UP.
P: Is UP a market?
*Again, instead of adducing
evidence that UP is school or
university, the court may
simply take judicial notice of
it.
the
Doctrine of Processual
Presumption/ Presumed Identity
Approach
May courts take judicial notice of
foreign laws?
No. Foreign laws are never the
subject of judicial notice. They must
be properly alleged in a pleading and
duly proved. In case a foreign law is
not alleged or it is not duly proven, it
is presumed to be identical with the
local law.
How are foreign
(Rule 132 Sec. 24)
laws
proven?
Mediation
Conciliation
Mini trial
Early Neutral Evaluation
Arbitration
f) Proceedings
before
the
Philippine Mediation Center
g) Any combination of the
foregoing
Proceedings before the Philippine
Mediation Center (PMC) / Court
Annexed Mediation (CAM)
Purpose:
Possibility of
Amicable
Settlement
or
submission
to
the
alternative
modes
of
dispute
resolution
Impositio
n of
Sanctions
for
Failure to
Appear
during
Pre-trial:
The
nonappeara
nce of the
plaintiff
warrants
the
dismissal of
his
action.
The
nonappeara
nce by the
defendant
warrants
the
presentation
of evidence
by
the
plaintiff, exparte.
(It is the
party who is
sanctioned)
Necessity
of Pretrial Brief
The parties
are required
to file and
Before
pre-trial
and
trial,
criminal cases that may be the subject
of mediation are brought before the
PMC for CAM.
The
settlement.
purpose
of
CAM
is
Estafa
Violation of BP 22
Theft
Malicious Mischief
Slander or Libel
Quasi-offenses except those
that
result
to
physical
injuries or death
When
held:
33
The Court
moto
proprio or
upon an exparte
motion by
the plaintiff
After
all
pleadings
have been
served and
filed.
Criminal
Case
The court
moto
proprio
After
arraignme
nt
and
within
thirty (30)
days from
the
date
the
court
acquires
jurisdiction
over
the
person of
the
accused.
Plea
bargaining,
stipulation
of
facts,
marking of
evidence,
waiver of
objections
to
admissibilit
y
of
evidence,
modificatio
n of the
order
of
trial, other
matters
that
will
promote a
fair
and
expeditiou
s trial
If
the
counsel for
the
accused or
the
prosecutor
does
not
appear
during pretrial
conference
and does
not
offer
an
acceptable
excuse for
his lack of
cooperatio
n,
the
court may
impose
proper
sanctions
or
penalties.
(It is the
accuseds
counsel or
prosecutor
who
is
sanctioned
)
Pre-trial
briefs are
not
serve their
respective
pre-trial
briefs.
Record
During
Pre-trial.
There is no
such
rule
requiring
that
admissions
or
agreements
be in writing
and signed
by
the
parties
otherwise
they cannot
be
used
against
them.
mandated
by
the
rules. The
rules
are
silent as to
its
necessity.
There
is
strict
requireme
nt that all
agreement
s
and
admissions
made
by
the
accused be
in writing
and signed
by him and
his
counsel,
otherwise,
they
cannot be
used
against
him.
34
b)
c)
d)
35
e)
3) Delay
resulting
from
extraordinary
remedies
against interlocutory orders.
4) Delay resulting from pre-trial
proceedings; provided that
the delay does not exceed
thirty (30) days.
5) Delay resulting from orders
of inhibition, or proceedings
relating to change of venue
of cases or transfer from
other courts.
6) Delay
resulting
from
a
finding of the existence of a
prejudicial question; and
7) Delay
reasonably
attributable to any period,
not to exceed thirty (30)
days, during which any
proceeding concerning the
accused is actually under
advisement.
Any period of delay resulting
from
the
absence
or
unavailability of an essential
witness.
For
purposes
of
this
subparagraph,
an
essential
witness shall be considered
absent when his whereabouts
are
unknown
or
whish
whereabouts
cannot
be
determined by due diligence. He
shall be considered unavailable
whenever his whereabouts are
known but his presence for trial
cannot be obtained by due
diligence.
Any period of delay resulting
from the mental incompetence
or physical inability of the
accused to stand trial.
If the information is dismissed
upon motion of the prosecution
and thereafter a charge is filed
against the accused for the
same offense, any period of
delay from the date the charge
was dismissed to the date the
time
limitation
would
commence to run as to the
subsequent charge had there
been no previous charge.
A reasonable period of delay
when the accused is joined for
trial with a co-accused over
whom the court has not
acquired jurisdiction, or, as to
whom the time for trial has not
run and no motion for separate
trial has been granted.
proceed
in
the
Reverse Order of Trial.
Trial in Absentia
What are the requisites of a valid
trial in absentia?
The following are the requisites
of a valid trial in absentia.
a. The
accused
has
been
validly arraigned.
b. The accused has been duly
notified of the trial or
hearings.
c. The absence of the accused
or his failure to appear is
unjustified.
Discharge of an Accused as
a State Witness (Rule 119 Sec. 17,
18 and 19)
Q: There are several accused
jointly tried for an offense arising
from
a
single
complaint
or
information.
The
prosecution
cannot
locate
witnesses
and
cannot obtain pieces of evidence
to secure a conviction. What
remedy
may
the
prosecution
resort to if it wants to come up
37
with
evidence
conviction?
to
secure
Becoming
State
charging
the
Necessity
of
the
Witness
being an
Accused:
Offense
Charged:
39
The offense
charged
must be a
Necessity
of
the
witness
receiving
threats:
the
Witness
Protectio
n
Program
(WPP)
Necessity
of
being
charged
in court:
Discharge
of
an
Accused
to
be
State
Witness
Applies to
all offenses
whether
Authority
granting
the
immunity:
Witness
being
a
law
enforcer:
Benefits
Received:
grave
felony
punishable
by the RPC
or special
laws.
Any
witness,
whether a
plain
witness or
the
accused
himself
may
be
qualified
under the
WPP.
The
witness
need
not
be charged
in court in
order
to
qualify
in
WPP.
The
witness
and
his
relatives by
affinity or
consanguin
ity
within
the second
degree
is
being
threatened
with bodily
harm,
in
order
for
the witness
to
qualify
under WPP.
The
immunity is
granted by
the DOJ.
In order to
qualify
under the
WPP,
the
witness
must
not
be
a
member of
a
law
enforceme
nt agency.
The
witness
receives
light, less
grave,
or
grave.
The
witness is
one
or
more
accused
testifying
against his
coaccused.
The
witness is
necessarily
charged in
court.
No
such
requiremen
t exists.
The
immunity is
granted by
the courts.
No
such
requiremen
t exists.
The
accused
who
has
certain
benefits
such
as
relocation
and
change of
identity.
been
discharged
as a state
witness
receives no
such
benefits.
Demurrer to Evidence.
40
b)
the
the
the
by
of
45
principal,
accomplice,
or
accessory;
4) The penalty imposed upon the
accused;
5) The civil liability or damages
caused by his wrongful act or
omission to be recovered from
the accused by the offended
party, if there is any, unless the
enforcement of the civil liability
by a separate civil action has
been reserved or waived.
Contents
of
a
Judgment
Acquittal (Rule 119 Sec. 2)
of
or
necessarily
includes
From
this
Supreme
Court
decision, it may be inferred that other
crimes that bring about unjustified
insults
necessary
include
unjust
vexation as well. Eg. Murder, etc.
Attempted
Rape
Necessarily
Includes Light Coercion or Unjust
Vexation (Renato Baleros Jr. V.
People, GR No. 138033, January
30, 2007)
Facts: A, a lady is sleeping at
her dormitory room located at the
third floor. B, a man, climbed up to her
window, stealthily opened it, and was
about to place a handkerchief laden
with knockout gas on As face.
Fortunately, before A could inhale any
of the fumes, she noticed Bs
presence. B hastily went on top of A
and tried his best to make A inhale the
fumes. B failed. A was later charged
for attempted rape. The information
alleged that B committed preparatory
acts for rape. The trial court arrived at
a judgment of conviction. When the
case reached the Supreme Court
though, the judgment of conviction for
attempted rape was overturned.
46
47
the
who
and
who
be
made
during
48
49
Look
into
succeeding case.
the
A)
May
the
accused
still
B) Is there a need to
promulgate a decision by the appellate
court in the trial court before the said
decision becomes valid?
Ruling: A) No, the accuseds right
to appeal has already prescribed.
The judgment has long become
final. In fact, there has already
been an entry of judgment.
B) No, a repromulgation of
either the affirmed or modified
judgment of conviction by the trial
court is not necessary. Under
Administrative Circular No. 16-93,
issued on September 9, 1993, The
procedure for the promulgation of
judgments in the trial courts in
criminal cases, differs from that
prescribed for the Supreme Court
and the Court of Appeals where
promulgation is effected by filing
the signed copy of the judgment
with the Clerk of Court who
causes true copies thereof to be
served upon the parties. The
procedural consequence of this
distinction was reiterated in Jesus
Alvarado, etc. Vs. The Director of
Prisons, to wit: By sections 8 and
9 of Rule 53 (now Sections 10 and
11 of Rule 51) in relation to
section 17 of Rule 120 (now
Section 17 of Rule 124), a
judgment is entered 15 days after
its promulgation, and 10 days
thereafter,
the
records
are
remanded to the court below
50
is
A
judgment
of
conviction
becomes final upon the following
instances.
a) After the lapse of the period for
perfecting an appeal without an
appeal having been perfected.
b) When the sentence has been
partially or totally satisfied/
Total or partial service of
sentence.
c) When the accused has waived
in writing his right to appeal
d) When the accused has applied
for a probation.
Note: Even though the Rules of Court
mention that a judgment of conviction
becomes final after the lapse of the
period for perfecting an appeal, it is
understood that in such instance, no
appeal was ever perfected.
Application for probation must
be filed within the same period for
perfecting an appeal.
Probation and appeal are two
exclusive and incompatible remedies.
Jurisprudence dictates that they are
mutually exclusive remedies. Applying
for probation excludes the right to
appeal. The former is a waiver of the
latter. In applying for probation, the
accused is deemed to have accepted
the correctness of the judgment of
conviction against him. To apply for
probation, the judgment needs to
become final. In the opposite side,
appealing the case excludes one from
applying for probation. Resorting to
appeal is a waiver of the privilege to
apply for probation. In appeal,
judgment is stayed and does not
become final. The accused does not
accept
the
correctness
of
the
judgment and throws the whole case
for review.
But appealing the penalty alone
and not the conviction for a crime,
may entitle one for Probation.
(Colinares v. People, GR No.
182748, December 13, 2011)
Case: A was convicted of Frustrated
Homicide. He was meted the penalty
of from 2 years and 4 months of
prision correccional, as minimum, to 6
years and 1 day of prision mayor, as
maximum. During the trial, A insisted
that he is liable for Attempted
Homicide,
and
not
Frustrated
Judgment
(Rule
(Rule
120,
reclusion
perpetua,
but
after
application of the Indeterminate
Sentence Law, the penalty imposed is
Reclusion Temporal, the accused is not
entitled to automatic suspension of
sentence.
Grounds
:
Anytime
before
judgment of
conviction
becomes
final.
Limited only
to
those
mentioned
in Rule 121,
Sec. 2
from
Reopening of
Trial
Anytime
before
finality
of
judgment of
conviction.
To
avoid
miscarriage
of justice.
*Note: This
is a
very
broad
ground.
It
will warrant
resorting to
Reopening of
Trial in case
the grounds
for
appeal,
new trial, or
reconsiderati
on are not
available.
there
has
been a deprivation of a constitutional
right resulting in the restraint of a
person;
54
55
for
Perfection
of
the
A duly perfected
stays the judgment
Effect of appeal
several accused.
appeal
by any
of
Note:
Personal
circumstances
57
his
to
Wrong
Mode
of
judgment.
The
judgment
simply
becomes final as if no appeal has ever
been filed or perfected. Once more, it
is only for exceptional and compelling
reasons in the interest of substantial
justice or to avoid miscarriage of
justice that the court may relax the
rules on technicality of appeals.
Modes
of
Appeal
Sandiganbayan Cases
in
59
60
Supreme
Court
Circulars.
(The
simplified diagrams showing the
modes of appeal in criminal cases are
shown in the preceding topics.)
63
warrant.
supra)
(Santos
v.
Pryce
Gases,
66
Preliminary attachment
Preliminary injunction
Receivership
Replevin
Support Pendent elite
67
68