Facts:

This case involves Jose S. Baltazar as the petitioner against multiple respondents including Domingo B. Pantig, Ruben Pantig, and several others, concerning a property dispute over a fishpond located in Sasmuan, Pampanga. On previous litigation, specifically the case of Pantig vs. Baltazar, the Supreme Court ruled that the respondents were the rightful owners of the fishpond measuring 139,126 hectares. After the decision, the respondents took possession of the fishpond, initiated cleaning, surveyed the area, and constructed dikes to separate their property from Baltazar's. Alleging theft of fish and other marine products from his property, Baltazar filed a complaint for qualified theft against the respondents with the Municipal Trial Court (MTC) of Sasmuan. The MTC found probable cause and forwarded the case to the Office of the Provincial Prosecutor, which subsequently filed an Information for qualified theft with the Regional Trial Court (RTC), Branch 49, Guagua, Pampanga,

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Facts:

Background of the Dispute

• The case is an offshoot of a long-standing property dispute involving a 139,126-hectare fishpond located in Sasmuan, Pampanga.
• In Pantig vs. Baltazar, this Court declared respondents as the rightful owners of the fishpond, which set the stage for ensuing conflicts.
• After the case ruling in Pantig vs. Baltazar, the respondents proceeded to clean the fishpond, conduct a resurvey, and rebuild the dikes separating their fishpond from the petitioner’s property.

Allegations and Initiation of Criminal Proceedings

• Petitioner Jose S. Baltazar alleged that respondents had stolen fish and other marine products from his property.
• Based on the allegation, petitioner filed a complaint for qualified theft with the Municipal Trial Court (MTC) of Sasmuan, Pampanga.
• The MTC, after a preliminary investigation, found probable cause against all the accused (respondents) and forwarded the records to the Office of the Provincial Prosecutor.

Preliminary and Subsequent Criminal Actions

• On December 7, 1999, the Provincial Prosecutor filed an Information for qualified theft against respondents with the Regional Trial Court (RTC), Branch 49, Guagua, Pampanga (Criminal Case No. G-4877).
• Subsequent to the filing, respondents moved for a reinvestigation of the case. This led the RTC to issue a Resolution on December 14, 1999 ordering such reinvestigation.
• On January 10, 2000, the Office of the Provincial Prosecutor recommended the dismissal of the complaint, explaining that the prior land registration case (decided in favor of the respondents) should conclusively resolve the issue of ownership and possession.

Administrative Remedies and Petitioner’s Response

• Acting on the dismissal recommendation, the RTC issued an Order on January 25, 2000 dismissing the Information.
• Instead of filing a motion for reconsideration within the RTC, petitioner filed a motion with the Office of the Provincial Prosecutor on February 9, 2000, praying for the Information’s reinstatement or re-filing.
• The Provincial Prosecutor denied petitioner’s motion on March 6, 2000, emphasizing the reinvestigation was court-ordered and that petitioner’s remedy was to file a motion for reconsideration with the RTC, or alternatively, elevate the matter directly to a higher court.

Petition for Certiorari and Subsequent Proceedings

• Petitioner, after filing a motion for reconsideration which was denied on March 31, 2000, resorted to filing a petition for certiorari on April 4, 2000 with the RTC (Special Civil Case No. G-313), alleging grave abuse of discretion and denial of due process by the Provincial Prosecutor.
• Respondents contested the petition on several grounds, including non-exhaustion of administrative remedies, failure to appeal to the Secretary of Justice, and questions regarding petitioner’s legal capacity to sue.
• On October 20, 2000, the RTC dismissed the petition for certiorari on the ground that petitioner failed to exhaust all administrative remedies.

Appeal to the Court of Appeals and Elevation to the Supreme Court

• Petitioner then appealed to the Court of Appeals (CA), contesting the RTC’s dismissal and arguing that the proper remedy for his grievances was available within the judicial system.
• In a Decision dated March 23, 2001, the CA affirmed the RTC’s dismissal, holding that petitioner’s remedy was to appeal the Provincial Prosecutor’s resolutions, not to file a petition for certiorari.
• Petitioner subsequently filed the instant petition for review on certiorari with the Supreme Court, raising multiple arguments including alleged irregularities in the CA resolution and a denial of his due process rights.

Issue:

Whether petitioner failed to exhaust all available administrative remedies before resorting to the petition for certiorari.

• The central contention being whether the proper remedy was to file a motion for reconsideration with the RTC instead of seeking certiorari.

Whether the jurisdiction of the court was correctly invoked in dismissing the Information based on the Provincial Prosecutor’s resolutions.

• The issue extends to whether the petitioner’s alternative remedy of appealing to the Secretary of Justice was misdirected.

Whether the petitioner’s due process rights were violated in the handling of his administrative motions.

• Petitioner argued that the lack of proper due process in addressing his claims contributed to the erroneous dismissal of his petition.

Whether the Court of Appeals erred in upholding the RTC’s basis for dismissal involving the non-exhaustion of administrative remedies.

• This issue examines if the procedural remedy prescribed by law was wrongly applied by the CA in affirming the RTC’s dismissal.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)