Facts:

The case revolves around a petition for review on certiorari filed by Fidel M. BaAares II, Lilia C. Valeriano, Edgar M. BaAares, Emilia Gatchialian, and Fidel Besarino (petitioners) against several respondents, including Elizabeth Balising and others, as well as the Public Prosecutor of Rizal, Antipolo. The timeline of events began when the petitioners were charged in sixteen separate criminal cases for estafa, which were assigned to the Municipal Trial Court of Antipolo, Rizal, Branch II. Following their arraignment, where they pleaded not guilty, the petitioners filed a motion to dismiss the charges, arguing that the complaints were premature due to the parties' failure to undergo mandatory conciliation proceedings under the supervision of the Lupong Tagapamayapa of Barangay Dalig, Antipolo. The petitioners claimed that since they resided in the same barangay as the private respondents, and given that the monetary amounts involved did not exceed Two Hundred Pesos (P200.00)

...

Facts:

Background of the Case

• Petitioners Fidel M. BaAares II, Lilia C. Valeriano, Edgar M. BaAares, Emilia Gatchialian, and Fidel Besarino were charged in sixteen criminal cases for estafa filed by various private respondents.
• The cases were originally docketed at the Municipal Trial Court of Antipolo, Rizal, Branch II.

Plea and Initial Motion

• Upon arraignment, the petitioners entered a plea of not guilty.
• They filed a Motion to Dismiss the cases on the ground that the filing was premature due to the failure of the parties to undergo the mandatory conciliation proceedings before the Lupong Tagapamayapa (barangay conciliation body).
• Petitioners based their motion on the requirement under Section 412 in relation to Section 408 of the Local Government Code of 1991 and Section 18 of the 1991 Revised Rule on Summary Procedure, noting that the amounts involved did not exceed Two Hundred Pesos (P200.00) and that the parties resided in the same barangay.

Trial Court Proceedings and Orders

• The Municipal Trial Court, in an Order dated July 17, 1995, denied the Motion to Dismiss on the basis that petitioners had waived the non-referral ground by not timely invoking it.
• Petitioners subsequently filed a Motion for Reconsideration, contending that the rules did not stipulate that a failure to promptly raise the issue would amount to a waiver.
• On November 13, 1995, notwithstanding earlier submissions, the Municipal Trial Court issued an Order dismissing the sixteen criminal cases without prejudice pursuant to Section 18 of the 1991 Revised Rule on Summary Procedure.

Revival of the Cases

• On February 26, 1996, private respondents, through their counsel, filed a Motion to Revive the cases.
• A Certification from the Lupong Tagapamayapa, dated February 13, 1996, was attached which verified that the parties had appeared before the body without reaching an amicable settlement.
• Petitioners opposed the motion on the ground that the dismissal order had long become final and executory, thereby necessitating the filing of a new complaint rather than a mere motion to revive.

Regional Trial Court and Further Proceedings

• Petitioners assailed the Order dated March 18, 1996, granting the Motion to Revive before the Regional Trial Court of Antipolo, Rizal.
• They filed a petition for certiorari, injunction, and prohibition with the Regional Trial Court, asserting that the dismissal order should be considered final and that the court had lost jurisdiction to revive it.
• The Regional Trial Court, however, ruled against the petitioners, holding that since the dismissal was without prejudice, the case had not attained finality, and the revival was accordingly proper.
• A subsequent Motion for Reconsideration filed by the petitioners was denied by the Regional Trial Court.

Issues Raised by the Parties in Their Submissions

• Petitioners questioned whether an order dismissing a case without prejudice could attain finality if no appeal or motion for reconsideration was filed within the prescribed fifteen-day reglementary period.
• They further questioned whether the dismissed case could still be revived by motion after the order had become final and executory.
• Finally, petitioners argued that once the dismissal order became final, the originating court lost its jurisdiction to act on any subsequent motion for revival.

Issue:

• Whether an order dismissing a case or action without prejudice attains finality if no motion for reconsideration or appeal is filed within the reglementary fifteen-day period.
• Whether a case dismissed without prejudice may be revived by motion after the order of dismissal has become final and executory.
• Whether the court that originally acquired jurisdiction over the dismissed case retains or loses its jurisdiction to act on the motion to revive after the dismissal has become final.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)