G.R. No. 47864 - Hiquiana vs. Veloso

In the justice of the peace court of Malita, Davao, four persons were accused of theft.
Acting Justice of the Peace Valerio P. Reyes rendered a decision on April 22, 1940, convicting two of the accused and acquitting the other two.

On the same day of the judgment, the two convicted accused filed a motion for a new trial.
The motion was submitted to Justice of the Peace Ismael L. Veloso, who had relieved Acting Justice of the Peace Reyes.

Without expressly setting aside the prior decision, Justice of the Peace Veloso granted the new trial.
In his order, he stated that a review of the case was necessary and announced an intention to conduct an ocular inspection of the place where the crime occurred.
A motion for reconsideration was filed by the offended party, which was denied, and the case was set for a new trial on June 22, 1940.

The offended party and the chief of police (acting as prosecutor) commenced certiorari proceedings before the Court of First Instance (CFI) of Davao.
They sought to annul the order of JP Veloso granting the new trial, asserting that such power was beyond a justice of the peace’s jurisdiction in a criminal case.
The CFI, under Judge Fernando Hernandez, granted the writ and ordered that the justice of the peace abstain from holding the new trial, effectively treating the case as if it had been appealed by the accused.

Dissatisfied with the CFI ruling, Justice of the Peace Veloso appealed to the Supreme Court.
The appeal raised the fundamental question regarding the authority of a justice of the peace to grant a new trial in criminal cases, despite the absence of an explicit statutory provision.

Does a justice of the peace have the inherent authority to grant a new trial in a criminal case?

Whether the act of granting a new trial—without expressly setting aside the predecessor’s judgment—amounted to a permissible review or an impermissible exercise of judicial power.
If the inherent power to correct errors (implied by Act No. 190 and existing in civil cases) extends to the realm of criminal proceedings within the jurisdiction of a justice of the peace.
The implications of granting a new trial solely for the purpose of discovering potential errors, and whether such a power could lead to undue delays or abuse of judicial procedure.