Title
Supreme Court
Madarang vs. Court of Appeals
Case
G.R. No. 143044
Decision Date
Jul 14, 2005
A car ownership dispute led to replevin and criminal cases; SC ruled replevin case's non-finality doesn't bar criminal prosecution, affirming CA's dismissal.

Case Digest (G.R. No. 172035)
Expanded Legal Reasoning Model

Facts:

  • Initiation of Litigation and Alleged Facts
    • On February 11, 1994, private respondent Janice Young-Chua and her husband, Eduardo Chan-Chua, filed a complaint for replevin and damages against petitioners William Madarang and Evans Kho in the RTC of Quezon City, Branch 84, Civil Case No. Q-94-19266.
    • The complaint alleged that:
      • Janice Young-Chua was the owner of a 1990 dark gray Kia Pride car, as evidenced by Certificate of Registration No. 08605800 dated May 31, 1991.
      • On January 29, 1994, petitioners, by force and intimidation, took possession of the subject car based on a purported falsified Deed of Sale dated December 3, 1993, allegedly executed by private respondent in favor of petitioner Madarang.
  • Criminal Proceedings and Consolidated Charges
    • On May 12, 1994, following the complaint, petitioner Madarang was charged with Falsification of Public Document in the Metropolitan Trial Court (MeTC) of Quezon City, Criminal Case No. 94-24930 (Branch 32).
    • On the same day, petitioners were charged with Grave Coercion in Criminal Case No. 94-24931, also in Branch 32, with the two cases consolidated and jointly tried.
    • Subsequent filings and motions within the MeTC included:
      • A Motion to Suspend Criminal Proceedings by petitioner Madarang on August 8, 1996, based on the claim of a prejudicial issue arising out of the replevin suit.
      • The MeTC’s denial on October 1, 1996, holding that the civil replevin decision would not determine the criminal charge of falsification.
  • Civil Litigation Developments in the RTC
    • On March 7, 1997, RTC, Branch 84 dismissed the replevin complaint after finding:
      • The Deed of Sale was genuine.
      • The private respondent had voluntarily surrendered the car to the petitioners.
    • A timely appeal was filed by the private respondent with the Court of Appeals (CA) in CA-G.R. CV No. 57597.
  • Criminal Case Motions and Procedural Posturing
    • On June 13, 1997, petitioner Madarang filed a Motion to Dismiss the falsification charge, arguing that the RTC decision in the replevin case absolved him criminally.
    • The MeTC initially granted the Motion to Dismiss on January 22, 1998, but later, on February 27, 1998, the prosecution filed a Motion for Reconsideration.
    • On July 27, 1998, the MeTC recalled the dismissal.
    • Petitioners filed a Second Omnibus Motion to Quash the criminal cases (Nos. 94-24930 and 94-24931), contending that:
      • The factual determinations by RTC, Branch 84 (regarding the genuineness of the signature and voluntary surrender) should bind the criminal proceedings.
      • The RTC’s findings constituted res judicata on the disputed issues.
    • The prosecution, in its opposition, argued that:
      • The Motion to Quash was untimely under Section 1, Rule 117 of the Rules of Court since it was filed post-arraignment.
      • The civil replevin suit was distinct and independent of the criminal proceedings.
  • Review and Certiorari Proceedings
    • On March 26, 1999, the MeTC denied the petitioners’ motion to quash, basing the decision on:
      • The RTC decision not being final and executory due to its pending appeal before the CA.
      • Petitioners’ waiver of the right to move to quash according to Section 1, Rule 117.
    • Petitioners pursued relief by filing a petition for certiorari before RTC, Branch 77, in Civil Case No. Q-99-37324.
      • RTC, Branch 77 dismissed the petition on October 8, 1999, citing:
        • The inability to invoke res judicata with a non-final decision.
ii. The proper timing for a motion to quash was before arraignment.
  • A motion for reconsideration was filed by petitioners but denied on February 29, 2000.
  • On April 18, 2000, the petitioners filed a petition for certiorari before the CA, which was dismissed on the ground that:
    • The writ of certiorari is not a proper remedy for challenging the denial of a motion to quash.
    • The People of the Philippines was not impleaded, which is necessary given their role in the criminal proceedings.
  • Grounds Raised by Petitioners and Respondents’ Arguments
    • Petitioners argued that:
      • The factual findings of RTC, Branch 84 in its March 7, 1997 decision – establishing the genuineness of the signature on the Deed of Sale and the voluntary surrender of the car – should bar the criminal prosecutions for falsification and grave coercion.
      • The MeTC Judge abused her discretion by not adopting these factual findings.
    • The Solicitor General contended that:
      • The decision in the replevin suit did not foreclose or suspend criminal prosecution because the civil decision was not final, executable, and lacked essential identity of parties.
    • Private respondent maintained that:
      • The RTC decision’s lack of finality and its separation from criminal jurisdiction meant it could not bind the criminal proceedings.
      • The MeTC acted within its jurisdiction by denying the motion to quash in accordance with established law and jurisprudence.
    • Petitioners also later contended that the CA committed reversible error in dismissing their petition for certiorari, anchoring their argument on alleged grave abuse of discretion by the MeTC and an improper course of judicial proceedings.

Issues:

  • Whether the factual findings of RTC, Branch 84 in the replevin case – determining the genuineness of the signature on the Deed of Sale and the voluntary surrender of the car – can be invoked as res judicata to bar criminal prosecution for falsification of public document and grave coercion.
    • Consideration of whether the civil decision qualifies as final and executory.
    • Determination of whether the issues of falsification and coercion were adequately litigated in the replevin suit.
  • Whether the proper procedural remedies were observed:
    • The timeliness and appropriateness of the petitioners’ motions to quash, given the requirement under Section 1, Rule 117 of the Rules of Court.
    • The impact of the failure to implead the People of the Philippines in the RTC and CA petitions for certiorari on the validity of the relief sought.
  • Whether the petition for certiorari is the proper remedy to challenge the interlocutory denial of a motion to quash an information and whether the CA erred in dismissing the petition.
    • Analysis of the appropriate remedy for adverse interlocutory orders.
    • Whether special circumstances existed to justify the immediate filing of a petition for certiorari instead of awaiting the final judgment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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