Case Digest (G.R. No. 176033)
Facts:
In Felilibeth Aguinaldo and Benjamin Perez v. Reynaldo P. Ventus and Jojo B. Joson, decided March 11, 2015 under G.R. No. 176033, private respondents Ventus and Joson filed on December 2, 2002 before the Manila City Prosecutor’s Office a complaint-affidavit charging petitioners Aguinaldo and Perez with estafa under Article 315(2)(a) of the Revised Penal Code for allegedly misrepresenting ownership of two leased motor vehicles in exchange for ₱260,000. Perez denied any active role beyond an introduction; Aguinaldo failed to appear. On February 25, 2003, Assistant City Prosecutor Gonzaga recommended indictment. On July 16, 2003, an information was filed with the RTC of Manila. Petitioners filed various motions—including motions to recall warrants, for reconsideration and withdrawal of information, and to suspend arraignment—resulting in interlocutory orders deferring proceedings pending resolution of their petition for review before the Department of Justice (DOJ). In May 2005, aCase Digest (G.R. No. 176033)
Facts:
- Parties and Nature of the Petition
- Petitioners: Felilibeth Aguinaldo and Benjamin Perez.
- Respondents: Reynaldo P. Ventus and Jojo B. Joson (private complainants); Judge Felixberto T. Olalia (public respondent).
- Reliefs sought before the Court of Appeals (CA):
- Writ of Preliminary Injunction/Temporary Restraining Order against implementation of RTC orders dated May 16, 2005 and August 23, 2005.
- Writ of Certiorari annulling the same orders.
- Dismissal of the estafa case for premature filing and lack of cause of action.
- Underlying Transaction and Estafa Complaint
- March–April 2002: Petitioners allegedly induced private respondents to invest ₱260,000 with pledge of two motor vehicles misrepresented as owned by petitioners but actually owned by Levita De Castro.
- December 2, 2002: Private respondents filed Complaint-Affidavit for estafa under Art. 315(2)(a) of the Revised Penal Code with the Manila OCP.
- Preliminary Investigation Sequence:
- Jan. 15, 2003: Perez’s Counter-Affidavit.
- Jan. 22, 2003: Private respondents’ Reply-Affidavit.
- Jan. 29, 2003: Perez’s Rejoinder-Affidavit.
- Feb. 25, 2003: ACP Gonzaga recommended indictment; noted Aguinaldo’s non-appearance.
- Trial Court Proceedings and Interlocutory Orders
- July 16, 2003: Information filed in RTC Manila (Crim. Case No. 03-216182).
- July–August 2003:
- Perez arrested; bail reduced.
- Petitioners moved to recall/quash warrants and to withdraw Information; public respondent temporarily recalled warrant for Aguinaldo pending DOJ review.
- Proceedings deferred and case archived pending resolution of petition for review with DOJ.
- Feb. 27, 2004: Petitioners filed petition for review with DOJ.
- March–April 2004: RTC issued and later suspended orders setting arraignment pending DOJ action.
- Motion by Non-party and Subsequent RTC Orders
- June 23, 2004: Levita De Castro filed Motion to Reinstate Case and Issue Warrant of Arrest before RTC, claiming to be private complainant.
- Oct. 15, 2004: De Castro notified RTC of DOJ’s denial (in a different case) of her petition for review dated Sept. 6, 2004.
- May 16, 2005: RTC granted De Castro’s motion, reinstated case, and ordered arrest warrant against Aguinaldo.
- May 30, 2005: Petitioners moved for reconsideration and to quash warrant.
- Aug. 23, 2005: RTC denied reconsideration, quash motion, and set arraignment—citing 60-day limit under Rule 116, Sec. 11(c).
- CA Proceedings and Supreme Court Petition
- Aug. 11, 2006: CA dismissed Rule 65 petition for lack of merit.
- Dec. 4, 2006: CA denied motion for reconsideration.
- March 11, 2015: Supreme Court Decision affirming CA and directing remand for trial on merits.
Issues:
- Whether the RTC gravely abused its discretion in granting the Motion to Reinstate Case and Issue Warrant of Arrest filed by Levita De Castro, a non-party.
- Whether the 60-day suspension period for arraignment under Rule 116, Sec. 11(c) is directory and may be relaxed pending DOJ resolution.
- Whether petitioners were denied due process by premature filing of Information without completion of preliminary investigation and opportunity for motion for reconsideration of the DOJ resolution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)