G.R. No. 214163 - Lim vs. Lim

Ronald G. M. Lim (private complainant) filed before the City Prosecutor a complaint for grave threats against his brother Edwin M. Lim.
The City Prosecutor filed an Information on November 11, 2012 before the Municipal Trial Court in Cities (Branch 5, Iloilo City), charging Edwin with willfully and unlawfully threatening Ronald (“Pus-on ko ulo mo!”; “Patyon ta ikaw”), contrary to law.
On arraignment, Edwin pleaded not guilty. The case was referred to mediation, but no settlement was reached, and the case returned to court.

Pre-trial was initially set on August 12, 2013 but reset to September 5, 2013 due to the absence of Ronald and his counsel, then to October 17, 2013 upon defense motion, and finally to November 21, 2013 on mutual request.
At the November 21 pre-trial, the prosecution moved to submit its witnesses’ Judicial Affidavits belatedly (by 5:00 p.m. that day), explaining only that they had been completed but “for whatever reason” not filed earlier.
Despite defense opposition, the Municipal Trial Court in Cities granted the motion and imposed a ₱1,000 fine for late filing.

Edwin filed a petition for certiorari and prohibition on January 29, 2014 before the RTC (Branch 28, Iloilo City), arguing that the Municipal Trial Court committed grave abuse of discretion by allowing the belated Judicial Affidavits, in violation of the Judicial Affidavit Rule.
In its June 6, 2014 Decision, the RTC set aside the Municipal Trial Court’s November 21 and December 20 orders, expunged the Judicial Affidavits, and held the late submission unjustified.
The prosecution’s motion for reconsideration was denied by RTC Order on August 27, 2014.

On September 29, 2014, Ronald and the People of the Philippines filed a Petition for Review on Certiorari under Rule 45, assailing the RTC’s June 6 and August 27, 2014 rulings.
They contended (a) lack of jurisdiction by RTC due to improper service of summons on petitioners and the Office of the Solicitor General (OSG); (b) improper remedy by certiorari when appeal was available; (c) discretionary latitude of trial court in admitting tardy Judicial Affidavits; and (d) petitioner’s failure to attach pre-trial’s stenographic notes warranted dismissal.
The Supreme Court required comments and replies from both sides, raising issues of jurisdiction, proper remedy, and grave abuse of discretion.

Did the Regional Trial Court acquire jurisdiction over petitioners Ronald G. M. Lim and the People of the Philippines despite alleged improper service of process?
Was a petition for certiorari and prohibition the proper remedy to challenge the Municipal Trial Court’s interlocutory orders dated November 21 and December 20, 2013?
Did the Municipal Trial Court in Cities commit grave abuse of discretion in allowing the prosecution’s belated submission of Judicial Affidavits without a valid reason?