Case Digest (G.R. No. L-31260)
Facts:
- The case "People vs. Catolico" (G.R. No. L-31260) was decided by the Supreme Court of the Philippines on February 29, 1972.
- The petitioner was the People of the Philippines, while the respondents included Hon. Alfredo Catolico, the District Judge of the Court of First Instance of Cavite, Branch III, and accused individuals Renato Hortal and Felipe Cruz.
- A criminal information for robbery in band was filed against the respondents for an incident that occurred on June 17, 1969, in Carmona, Cavite.
- The information was filed on August 11, 1969, resulting in the detention of the accused due to their inability to post bail of P10,000.00 each.
- The trial was initially scheduled for October 13, 1969, but was postponed due to the absence of complainants and witnesses.
- On October 14, 1969, after the complainants failed to appear again, the Provincial Fiscal requested a provisional dismissal, which the court granted with the accused's consent.
- Shortly after the dismissal, the complainants and witnesses arrived, citing engine trouble for their delay.
- The Provincial Fiscal moved for reconsideration of the dismissal, but the trial judge denied the motion and ordered the release of the accused before the dismissal was signed.
- The Provincial Fiscal filed a petition for certiorari on November 27, 1969, claiming the trial judge acted with grave abuse of discretion.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the writ of certiorari and annulled the three orders of the respondent court dated October 14, 1969.
- The Court declared these orders devoid of legal effect.
- A permanent writ of preliminary mandatory injunction was issued, instructing the responde...(Unlock)
Ratio:
- The Supreme Court determined that the trial court's refusal to grant the timely motion for reconsideration constituted grave abuse of discretion, indicating an excess of jurisdiction.
- The Court emphasized that a trial court cannot arbitrarily deny a motion for reconsideration filed shortly after a dismissal, especially when complainants and witnesses arrived soon after the order was ...continue reading
Case Digest (G.R. No. L-31260)
Facts:
The case "People vs. Catolico" (G.R. No. L-31260) was adjudicated by the Supreme Court of the Philippines on February 29, 1972. The petitioner was the People of the Philippines, while the respondents included Hon. Alfredo Catolico, the District Judge of the Court of First Instance of Cavite, Branch III, along with two accused individuals, Renato Hortal and Felipe Cruz. The events leading to the case began with a criminal information filed against the respondents for robbery in band, which took place on June 17, 1969, in Carmona, Cavite. The information was formally filed on August 11, 1969, resulting in the detention of the accused due to their inability to post bail amounting to P10,000.00 each. The trial was initially scheduled for October 13, 1969, but was postponed due to the absence of the complainants and witnesses. On October 14, 1969, after the complainants failed to appear once more, the Provincial Fiscal requested a provisional dismissal of the case, which the court granted upon confirming the accused's consent. However, shortly after this dismissal order was dictated, the complainants and witnesses arrived, citing engine trouble as the reason for their delay. The Provincial Fiscal promptly moved for reconsideration of the dismissal, but the trial judge denied this motion and ordered the release of the accused before the dismissal or...