G.R. No. 109975 - Republic vs. Dagdag

Petitioners: Godofredo Enrile and Dr. Frederick Enrile.
Respondents: Hon. Danilo A. Manalastas (RTC, Malolos, Bulacan), Hon. Eranio G. Cedillo, Sr. (MTC, Meycauayan, Bulacan), and the People of the Philippines.
Nature of Action: Petitioners sought to challenge adverse resolutions denying their motions to quash criminal complaints charging them with less serious physical injuries stemming from a mauling incident.

Date and Place: January 18, 2003, outside the petitioners’ residence in St. Francis Subdivision, Barangay Pandayan, Meycauayan, Bulacan.
Complainants:

Criminal Case No. 03-275 – Charged with frustrated homicide (victim: Rommel).
Criminal Case No. 03-276 – Charged with less serious physical injuries (victim: Josefina).
Criminal Case No. 03-277 – Charged with less serious physical injuries (victim: Perla).

The MTC found probable cause for the complaints in Criminal Cases Nos. 03-276 and 03-277.
Petitioners filed a motion for reconsideration before the MTC on August 19, 2003, arguing for dismissal due to insufficient evidence of a healing period of 10 days or longer and issues concerning the applicability of summary procedure.
On November 11, 2003, MTC denied the motion for reconsideration, holding that the grounds had already been decided and that the cases were governed by summary procedure rules.
Subsequent filings: Petitioners submitted a manifestation with a motion to quash and a motion for the deferment of arraignment.
On February 11, 2004, MTC denied the motion to quash, explaining that the issues raised were matters of defense to be fully determined at trial, and set the arraignment for March 15, 2004.
A further motion for reconsideration regarding the denial of the motion to quash was also denied on March 25, 2004.

Petitioners filed a special civil action for certiorari and prohibition challenging the February 11, 2004, MTC order (denial of motion to quash) and the March 25, 2004, order (denial of motion for reconsideration).
RTC Judge Manalastas dismissed the petition for certiorari on May 25, 2004, ruling that the issues were matters for trial and that dismissal at the preliminary stage was premature.
The RTC also denied the petitioners’ subsequent motion for reconsideration on July 9, 2004.

Petitioners then sought relief from the CA through a petition for certiorari and prohibition to nullify the RTC resolutions.
The CA dismissed their petition, finding that the remedy available was an appeal by notice of appeal—not a petition for certiorari—and also noted issues with the timeliness of their appeal filings.

Whether the trial courts (MTC and RTC) erred in denying the petitioners’ motion to quash the criminal complaints, given that the averments on the face of the complaint allegedly lacked an essential element of the crime of less serious physical injuries.
Whether the petitioners should have been allowed to challenge, on interlocutory grounds, the determination that the injuries sustained by the complainants were the result of acts committed by them.
Whether the petitioners erred in seeking certiorari and prohibition to challenge interlocutory orders instead of resorting to the proper appeal mechanism available under the Rules of Court.