Case Digest (G.R. No. 212774) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Erlinda K. Ilusorio v. Ma. Erlinda I. Bildner et al. (G.R. Nos. 173935–38, December 23, 2008), petitioner Erlinda K. Ilusorio, who claimed to be the bona fide chairperson and president of Lakeridge Development Corporation (LDC), accused respondents Ma. Erlinda I. Bildner, Lily F. Raqueao, Sylvia K. Ilusorio, Ma. Cristina A. Ilusorio, and Aurora I. Montemayor of perjury before the Metropolitan Trial Court (MeTC) of Pasig City. The allegations arose from four petitions filed on behalf of LDC, three in the Regional Trial Court (RTC) of Tagaytay City for new duplicate Transfer Certificates of Title Nos. 17010, 17011, and 17012, and one in the RTC of Makati City for a new duplicate Condominium Certificate of Title No. 21578. In each petition, respondents swore that the originals had been lost despite diligent search, when in fact petitioner maintained she still possessed them. Petitioner first lodged falsification and perjury charges with the Pasig City Prosecutor’s Office, which Case Digest (G.R. No. 212774) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- Petitioner Erlinda K. Ilusorio, as bona fide president and chair of Lakeridge Development Corporation (LDC), held the original duplicate certificates of title (CCT No. 21578 in Makati; TCT Nos. 17010, 17011, 17012 in Tagaytay) for LDC properties.
- Respondents Ma. Erlinda I. Bildner, Lily F. Raqueao, Sylvia K. Ilusorio, Ma. Cristina A. Ilusorio, and Aurora I. Montemayor, purporting to represent LDC, filed before the RTCs of Makati and Tagaytay petitions for issuance of new owner’s duplicate copies of the said titles, alleging that the originals were lost despite “earnest and diligent efforts” to locate them.
- Procedural history
- Petitioner opposed these petitions and respondents amended them to acknowledge petitioner’s possession of the originals and respondents’ lack of authority to hold them.
- Petitioner filed charges of falsification of public documents and perjury before the Pasig City Prosecutor’s Office; falsification was dismissed but perjury informations were filed in MeTC Pasig (Criminal Cases Nos. 121496–121499).
- MeTC Pasig granted respondents’ motions to quash the informations on the ground that the pleadings were “absolutely privileged” (citing Flordelis v. Himalalaon and People v. Aquino). RTC Branch 263 of Pasig City affirmed. Petitioner filed a Rule 45 petition for certiorari with the Supreme Court.
Issues:
- Whether Pasig City MeTC has jurisdiction (proper venue) over the perjury informations when the material false statements relate to petitions filed in Makati and Tagaytay.
- Whether statements in judicial pleadings are absolutely privileged such that they cannot form the basis for a criminal perjury prosecution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)