Case Digest (G.R. No. 175091)
Facts:
The case involves a petition for certiorari filed by Police Chief Inspector Fernando Billedo, Senior Police Officer 3 Rodrigo Domingo, Police Officer 3 Jorge Lopez, Ferdinand Cruz, and Mariano Cruz (collectively referred to as petitioners) against Wilhelmina Wagan, the Presiding Judge of the Regional Trial Court (RTC) of Branch III, Pasay City, and private respondents Alberto Mina, Nilo Jay Mina, and Ferdinand Caasi. The events leading to the case began on February 27, 2000, when the petitioners arrested the private respondents along an alley on Edang Street, Pasay City, for allegedly drinking liquor in a public place, which was a violation of City Ordinance No. 265. The private respondents contended that their arrest was unlawful and instigated by the accusations of Ferdinand Cruz and Mariano Cruz. Following their arrest, the private respondents were charged with violating the city ordinance in the Metropolitan Trial Court of Pasay City (MeTC), which was docketed as Criminal...
Case Digest (G.R. No. 175091)
Facts:
Arrest Incident:
On February 27, 2000, complainants Alberto Mina, Nilo Jay Mina, and Ferdinand Caasi were arrested by petitioners (police officers) for allegedly drinking liquor in a public place along an alley in Pasay City. The arrest was based on a report by Ferdinand Cruz and Mariano Cruz (the Cruzes). The complainants claimed the arrest was unlawful and induced by the Cruzes.Criminal Charges:
The complainants were charged with violating City Ordinance No. 265 (Drinking Liquor in Public Places) in Criminal Case No. 00-621 before the Metropolitan Trial Court (MeTC) of Pasay City.Civil Case for Damages:
On March 20, 2000, the complainants filed Civil Case No. 00-0089 against the petitioners for damages arising from the alleged unlawful arrest.Criminal Complaints Against Petitioners:
Complainants also filed criminal complaints against the petitioners for Unlawful Arrest and Violation of R.A. No. 7438 (Rights of Persons Under Custodial Investigation) before the City Prosecution Office (CPO) and the Office of the Ombudsman. Both offices dismissed the complaints for lack of probable cause, but the Ombudsman recommended filing charges for Violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) against some petitioners.Dismissal of Criminal Cases:
The CPO dismissed the criminal cases for lack of merit, noting that the Cruzes’ report had a semblance of truth, and the arrest was lawful. The complainants were later convicted by the MeTC for violating City Ordinance No. 265, which was affirmed by the RTC.Motion to Dismiss Civil Case:
During the trial of Civil Case No. 00-0089, petitioner Ferdinand Cruz filed a Motion to Dismiss, arguing that the Sandiganbayan, not the RTC, had jurisdiction over the civil case, and that the complainants were barred from filing a separate civil action under Section 4 of R.A. No. 8249 (Sandiganbayan Act).Denial of Motion to Dismiss:
The public respondent (Judge Wilhelmina Wagan) denied the Motion to Dismiss, ruling that the crime of unlawful arrest falls under the jurisdiction of the MeTC, not the Sandiganbayan. She also noted that no criminal case for unlawful arrest was filed, making Section 4 of R.A. No. 8249 inapplicable.Subsequent Motions and Denials:
Ferdinand Cruz filed a Motion for Reconsideration and a Second Motion for Reconsideration, both of which were denied by the public respondent.
Issue:
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Ruling:
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Ratio:
Jurisdiction of Civil Cases:
Civil actions for damages arising from alleged unlawful acts are distinct from criminal actions. The dismissal of criminal charges does not automatically extinguish the civil liability unless the court declares that the facts giving rise to the civil liability did not exist.Application of R.A. No. 8249:
Section 4 of R.A. No. 8249 applies only when a criminal action is filed before the Sandiganbayan or appropriate courts. Since no criminal action was filed in this case, the RTC properly exercised jurisdiction over the civil case.Preponderance of Evidence in Civil Cases:
Even if the criminal charges were dismissed, the complainants can still pursue the civil case by proving their claims through preponderance of evidence.Interlocutory Orders:
Orders denying motions to dismiss are interlocutory and not appealable. The proper remedy is to await the final judgment and raise the issue on appeal.