G.R. No. 121422 - Cruz y Digma vs. People

On June 19, 1990, police officers arrested petitioner Noel Cruz y Digma without a warrant while he was waiting outside the Manila Pavilion Hotel along U.N. Ave., Manila.
The arrest was made on the ground of illegal possession of a firearm—a .38 caliber Colt revolver bearing Serial Number 376420, along with six live rounds of ammunition.

On June 25, 1990, Assistant Prosecutor Tranquil P. Salvador, Jr. filed an information with the Regional Trial Court (RTC), Manila, charging petitioner with violation of Presidential Decree No. 1866 (illegal possession of firearm and ammunition).
The accusatory portion of the information specifically stated that on or about June 19, 1990, petitioner was in wrongful possession of the specified firearm and ammunition without the necessary license or permit.
Prior to the arraignment, petitioner’s parents filed a petition for habeas corpus on his behalf with the RTC in Quezon City.
At arraignment in the Manila RTC, petitioner pleaded not guilty to the charges.

On January 18, 1993, during trial proceedings, the RTC admitted into evidence the gun and ammunition seized from petitioner over his objections and after the prosecution formally offered its evidence.
After the prosecution rested its case, petitioner filed a demurrer to evidence.
On December 20, 1993, the RTC denied petitioner’s demurrer to evidence and ordered him to present his evidence.
Petitioner subsequently filed a motion for reconsideration, which was denied on July 8, 1994.

On October 27, 1994, petitioner filed a petition for certiorari with the Court of Appeals (CA) seeking the annulment of three interlocutory orders issued by the RTC:

Petitioner argued that these orders were issued capriciously, arbitrarily, and with grave abuse of discretion, resulting in extreme prejudice to him.
On November 7, 1994, the CA gave due course to the petition and ordered the RTC to temporarily halt further proceedings in Criminal Case No. 90-85059.
On August 8, 1995, the CA rendered a decision denying the petition on the ground that the orders in question were interlocutory in nature and not reviewable by certiorari.

His arrest was illegal due to the warrantless nature of the apprehension, and consequently, the evidence (gun and ammunition) was fruits of an illegal search and arrest, rendering them inadmissible.
The prosecution’s evidence was insufficient to sustain a conviction, citing inconsistencies in witness testimonies.

He asserted that once the interlocutory orders had become immutable (subject to no further amendment by the RTC), immediate review was necessary to prevent extreme prejudice.
Petitioner also sought a temporary restraining order (TRO) to stop further trial proceedings pending review, as well as a writ of preliminary injunction and the reversal of the CA’s resolution.

Whether the RTC’s orders—specifically, the order admitting the prosecution’s evidence, the denial of the demurrer to evidence, and the denial of the motion for reconsideration—being interlocutory in nature, are reviewable by certiorari.
Whether the petitioner’s claim that his warrantless arrest and the subsequent search violated his rights, thereby affecting the admissibility of the seized evidence, constitutes a basis for immediate review.
Whether the alleged insufficiency and inconsistencies in the prosecution’s evidence warrant the issuance of certiorari to correct errors made by the trial court in handling evidentiary and procedural matters.