G.R. No. L-745 - Moya vs. Barton

Petitioner-appellant Goodland Company, Inc. is a corporation and the registered owner of a parcel of land in Pasong Tamo, Makati City, covered by Transfer Certificate of Title No. 114645, with an area of approximately 5,801 square meters.
The respondents are Abraham Co and Christine Chan, private individuals linked to Asia United Bank (AUB).
Goodland and Smartnet Philippines, Inc. are part of the Guy Group of Companies owned by Gilbert Guy's family.

In 2000, Goodland allowed its Makati property to be used, by accommodation, as security for Smartnet's loan with AUB.
Gilbert Guy, Vice President of Goodland, was allegedly made to sign a Real Estate Mortgage (REM) document in blank.
Mr. Rafael Galvez, Executive Officer of Goodland, handed over the original title to Mr. Guy with the understanding that it was a comfort document, to be completed only with the consent of both Goodland and Smartnet.

Approximately two years later, Goodland found that the REM signed in blank had been filled up and annotated at the back of the property title.
Goodland requested the National Bureau of Investigation (NBI) to investigate the fraud allegedly committed by Abraham Co and Christine Chan.
The NBI recommended filing charges of falsification of documents against Co, Chan, and the notary public Joel Pelicano.

The Makati Prosecutor’s Office filed Information against the respondents for falsification of public document (REM), alleging that Guy did not appear nor acknowledge the REM before the notary public, yet it was notarized and registered.
The case was docketed as Criminal Case No. 332313 in the Metropolitan Trial Court (MeTC), Branch 64, Makati City.
The prosecution presented witnesses including Goodland officials, the NBI agent, and the notary public.

Respondents filed a demurrer to evidence arguing insufficiency of evidence on elements involving participation and falsification.
The MeTC granted the demurrer, dismissing the case due to failure of prosecution to present sufficient and competent evidence to rebut presumption of innocence.

Goodland filed a motion for reconsideration and inhibition, both denied by MeTC.
Goodland filed a Rule 65 petition before the Regional Trial Court (RTC) challenging MeTC's orders.
The RTC upheld MeTC's decision, ruling lack of grave abuse of discretion.

Goodland appealed to the CA, which affirmed the RTC ruling and MeTC's dismissal of the case, ruling no grave abuse of discretion.

Goodland alleged grave abuse of discretion by the CA in affirming the demurrer to evidence and dismissal, ignoring material prosecution evidence.

Whether the dismissal of Criminal Case No. 332313 by the MeTC via granting of demurrer to evidence was proper.
Whether the RTC and CA committed grave abuse of discretion in affirming the dismissal of the case.
Whether Goodland's petition raises questions of law or fact beyond the scope of a Rule 45 petition.
Whether there was sufficient evidence to establish criminal liability of respondents for falsification of public document.