G.R. No. 218232 - Revilla, Jr. vs. Sandiganbayan, 1st Division

On January 12, 2000, petitioners—Francisco C. Basa, Manuel H. OmeAa, Mark Philip L. Basa, and Renato H. Uy—were charged before the Metropolitan Trial Court (MeTC), Branch 65, Makati City.
They faced two distinct charges:

Swindling under paragraph 2, Article 316 of the Revised Penal Code (Criminal Case No. 279220).
Falsification of a public document under paragraph 4, Article 171 of the Revised Penal Code (Criminal Case No. 279221).

The accused, as corporate officers of One World Land and Properties Corporation, allegedly fraudulently mortgaged a property (covered by TCT No. 21163) to Pioneer Insurance and Surety Corporation for P60,000,000.00.
They made false representations that the property was free from encumbrances, despite known annotations indicating existing encumbrances.
The fraudulent act resulted in damage and prejudice to Pointer Construction International Corporation, represented by Ofelia P. Trinidad.

The petitioners were charged with causing the cancellation of Transfer Certificate of Title Nos. 210429 and 210430 and subsequently ordering the issuance of a new title (TCT No. 211643).
It was alleged that the new title misleadingly indicated that the property was unencumbered when, in reality, it bore annotations evidencing encumbrances.
This act of falsification of public documents was committed with wrongful intent, directly impacting the interests of Pointer Construction Company, Inc. and the public.

On February 23, 2000, petitioners filed a Joint Motion to Quash the charges, arguing that the facts in the Informations did not constitute an offense.
The Metropolitan Trial Court granted the motion on March 27, 2000, quashing the charges on the ground that the alleged facts failed to establish an offense.
Subsequently, the private complainant, with the Public Prosecutor’s support, filed a motion for reconsideration, which was denied on May 24, 2000.
The Regional Trial Court (RTC), Branch 65, Makati City, on appeal, set aside the MTC order, thereby directing the continuation of the criminal proceedings.

After the RTC reversed the quash order, petitioners filed their motion for reconsideration with the RTC, which was again denied on November 23, 2000.
Relying on Section 3(b), Rule 122 of the Revised Rules of Criminal Procedure and Rule 42 of the 1997 Rules of Civil Procedure, the petitioners sought to elevate the issue by filing a petition for review with the Court of Appeals.
On October 30, 2001, the Court of Appeals dismissed the petition on the basis that the remedy of appeal was improper as the RTC decision was interlocutory, not final.
A subsequent motion for reconsideration by the petitioners was denied in a Resolution dated February 27, 2002, leading to the present petition for review on certiorari.

Whether petitioners’ appeal by way of petition for review from the RTC’s decision is proper, given that the RTC order is interlocutory in nature.
Whether the petitioners erroneously assumed that the RTC Decision, which reversed the quash order, constituted a final order amenable to an immediate appeal.

Whether Section 3(b), Rule 122 of the Revised Rules of Criminal Procedure and Section 1, Rule 42 of the 1997 Rules of Civil Procedure, as amended, authorize an appeal from an interlocutory order.
Determining if the alleged elements and procedural posture of the case meet the requirements for a final judgment instead of an interlocutory order.