G.R. No. 226494 - People vs. Sisracon y Rupisan

A complaint for libel was filed against petitioners—Ramon K. Ilusorio, Ma. Lourdes C. Cristobal, Romeo G. Rodriguez, Eduardo C. Rojas, Cesar B. Crisol, Violeta J. Josef, Erlinda K. Ilusorio, Shereen K. Ilusorio, and Cecilia A. BisuAa—stemming from an alleged libelous book entitled “On the Edge of Heaven.”
The libelous book, authored by Erlinda K. Ilusorio and circulated by officers of various foundations (PI-EKI Foundation, Senior Partners Foundation, Inc., and Multinational Investment Bancorporation), became the subject of the criminal action.
An Information dated December 18, 2008, was filed, which initiated the criminal case docketed as Criminal Case No. 09-270043.
Subsequent pleadings and motions revealed various developments, including:

The defendants’ motion for determination of probable cause (with prayer to defer the issuance of a warrant of arrest) filed in August 2009.
Findings by the DOJ Investigating Panel and resolutions by the DOJ Secretary that initially dismissed the charge for lack of probable cause, which were later interspersed with reversals and further motions on reconsideration.

The case was initially raffled to the Manila RTC Branch 6 and later reassigned to Branch 52 after Judge Jansen R. Rodriguez’s involvement and subsequent inhibition.
On January 28, 2010, Judge Rodriguez issued an Order denying the defendants’ motion by finding probable cause for the issuance of a warrant of arrest based on the libelous excerpts.
A series of motions followed:

Motion for Reconsideration (MR) which was denied on October 27, 2008, and again after further review on June 5, 2012, by Acting Presiding Judge Ruben Reynaldo G. Roxas.
A Motion to Quash filed by the defendants on several grounds including lack of jurisdiction, authority, and insufficiency of the information, which was denied on April 3, 2013.

The petitioners originally assailed the RTC Order denying their motion (Order dated April 3, 2013) through a petition for certiorari.
They sought a Temporary Restraining Order (TRO) or a writ of preliminary injunction (WPI) enjoining the continuation of the criminal action and other legal and equitable reliefs.
Despite the petition’s general prayer for relief, it did not specifically mention the declaration of nullity of the RTC Order—a defect attributed to mere inadvertence or excusable negligence.

The petition for certiorari was initially filed before the CA, resulting in Resolution dated July 17, 2013, which dismissed the petition for certiorari on the ground that it was merely seeking injunctive relief without a principal action for nullification.
An amended petition was later filed but was again denied on November 21, 2013, on the basis that:

The petition was incipiently defective in form and substance.
The attempt to cure the defect beyond the non-extendible 60-day period could not be allowed.
The allegations did not sufficiently substantiate a grave abuse of discretion warranting the extraordinary remedy of certiorari.

The Supreme Court ultimately granted the petition for review on certiorari.
The Court found that the omission of a specific prayer to declare the RTC Order void was a formal defect resulting from inadvertence, which did not preclude granting of relief.
It determined that the general prayer for “other legal and equitable reliefs” was broad enough to encompass the nullity of the challenged RTC Order.
The erroneous dismissal by the CA was therefore reversed and set aside, and the case was remanded for resolution on the merits with reasonable dispatch.

Whether the failure of the petitioners to include a specific prayer for the declaration of nullity of the RTC Order constitutes a fatal defect in their petition for certiorari.

The issue of whether a mere omission in the prayer, due to excusable negligence, should bar relief was examined.
The interpretation of a general prayer for “other legal and equitable reliefs” as sufficiently broad to cover the specific relief of nullifying the RTC Order.

Whether the RTC and CA orders, which denied motions for reconsideration and quash based on technical and jurisdictional arguments, amount to grave abuse of discretion or jurisdictional error.

The abuse was alleged particularly in the context of statements ruling out further motions related to the case.
The consolidation of errors regarding both procedural deficiencies and substantive determination of probable cause.

The proper role of the court in considering a petition’s merit when faced with technical defects versus the necessity to dispose of cases on the merit to prevent injustice.

The Court’s approach to prioritizing the merits of the case over technical formalities.
The broader judicial policy favoring dispute resolution on substantive grounds rather than on procedural technicalities.