G.R. No. 178607 - Jimenez vs. Sorongon

Dante La. Jimenez (petitioner) is the president and representative of Unlad Shipping & Management Corporation, a local manning agency.
Socrates Antzoulatos, Carmen Alamil, Marceli Gaza, and Markos Avgoustis (respondents) are listed incorporators of Tsakos Maritime Services, Inc. (TMSI), another local manning agency.

On August 19, 2003, petitioner filed a complaint-affidavit for syndicated and large scale illegal recruitment, alleging respondents falsely represented their stockholdings in TMSI’s articles of incorporation to secure a POEA recruitment license.
October 9, 2003: Antzoulatos and Gaza filed a counter-affidavit; Alamil and Avgoustis did not respond.
May 4, 2004: The 3rd Assistant City Prosecutor found probable cause and recommended filing of information; the City Prosecutor complied, docketing Criminal Case No. MC04-8514 before RTC Branch 212.
December 14, 2004: The City Prosecutor moved to withdraw the information; petitioner and some respondents opposed.
August 1, 2005: RTC Branch 212 denied withdrawal, found probable cause, and issued arrest warrants.
September 2, 2005: The RTC denied respondents’ omnibus motion for reconsideration.
September 26–30, 2005: Alamil filed a motion for judicial determination of probable cause and deferred enforcement of warrants; the RTC ruled it moot, affirming prior probable cause findings.
October 10, 2005: Alamil moved for reconsideration and for Judge Capco-Umali’s inhibition; petitioner opposed.
January 4, 2006: Judge Capco-Umali inhibited herself; the case was re-raffled to RTC Branch 214 (Judge Edwin Sorongon).

March 8, 2006: The RTC granted Alamil’s motion for reconsideration (treating it as a motion to dismiss for lack of probable cause), dismissed the case, and set aside warrants.
April–May 2006: Petitioner’s motion for reconsideration was denied; Alamil’s motion to expunge was granted.
May 19–August 7, 2006: Petitioner filed a notice of appeal; the RTC expunged the appeal for lack of Solicitor General’s conformity, ruling the petitioner had no right to appeal.

October 18, 2006: Petitioner filed a Rule 65 petition for certiorari in the CA, assailing the March 8, May 10, and August 7, 2006 RTC orders.
November 23, 2006: The CA dismissed the petition for lack of legal personality, holding only the Office of the Solicitor General (OSG) can represent the People in criminal proceedings before the CA.
June 28, 2007: The CA denied petitioner’s motion for reconsideration.

Whether the Court of Appeals erred in dismissing the petitioner’s Rule 65 petition for certiorari on the ground that the petitioner lacked legal personality to represent the People of the Philippines in criminal proceedings.
Whether respondent Alamil voluntarily submitted to the jurisdiction of the RTC by filing motions seeking relief.