G.R. No. 188372 - Beams Philippine Export Corp. vs. Castillo

Petitioner: Beams Philippine Export Corporation.
Respondents: Marianita Castillo and Nida Quirante.
The respondents were charged with 16 counts of estafa, with allegations that they conspired, confederated, and assisted one another in issuing, encashing, and misappropriating the proceeds of some of the petitioner’s checks.

The criminal cases were raffled to the Regional Trial Court (RTC) of Cebu City, Branch 7, and docketed as Criminal Cases Nos. CBU-56537 to CBU-56552.
On August 30, 2007, the RTC rendered a decision dismissing the estafa cases on the ground that the acts complained of did not constitute the crime of estafa.
A Motion for Reconsideration was filed on September 7, 2007 but was denied by the RTC in an Order dated September 28, 2007.

Aggrieved by the RTC’s dismissal, the petitioner filed a petition for certiorari with the Court of Appeals (CA) to assail the RTC decision dismissing the estafa cases.
On November 28, 2007, the CA issued a resolution dismissing the petitioner’s petition for certiorari for being defective because it was not filed by the Office of the Solicitor General (OSG).
The CA noted additional defects, including issues with the Verification/Certification for Non-Forum Shopping and a violation of Section 1, Rule 65 of the Rules of Civil Procedure due to the failure to attach the relevant pleadings and documents.
A Motion for Reconsideration was subsequently filed by the petitioner, which the CA denied in a Resolution dated May 28, 2009.

The petitioner’s certiorari challenged the criminal aspect of the RTC’s decision, seeking to reverse the dismissal of the estafa cases.
The petition’s "Discussion" focused on:

Asserting that the evidence established beyond reasonable doubt the commission of estafa, warranting a judgment of conviction.
Arguing that the RTC gravely abused its discretion by arbitrarily dismissing the cases, allegedly injecting unfounded facts not raised by the respondents’ defenses.
Claiming that the RTC ignored relevant laws and abused its discretion by issuing orders directing the filing of new Informations.

Notably, the petitioner did not address any issue regarding the civil liability of the respondents, clearly concentrating on the criminal dismissal.

Whether the Court of Appeals erred in dismissing the petitioner’s certiorari petition on the basis that the petitioner, a private entity, lacked the legal standing to challenge the dismissal of a criminal case.
Whether the petition was defective due to the failure of being filed by the Office of the Solicitor General (OSG), which is the proper representative of the People of the Philippines in criminal cases.

Whether defects such as the issues with the Verification/Certification for Non-Forum Shopping and the non-attachment of pertinent pleadings and documents justified the dismissal of the petition.