Facts:

The case at hand is People of the Philippines vs. Court of Appeals (G.R. No. 51635), decided by the Supreme Court of the Philippines on December 14, 1982. The principal respondents were Melchor J. Javier and Victoria L. Javier, who stood accused of estafa, a crime defined under the Revised Penal Code. The events unfolded in Pasay City, Metro Manila, where on November 8, 1977, the accused were charged with receiving an erroneous bank remittance of U.S. $999,993.70 instead of the correct amount of U.S. $1,000.00. The excessive amount was transferred to them through a telex error by Manufacturers Hanover Bank in New York.

After initially pleading not guilty, the trial proceeded, culminating in the prosecution resting its case. On June 30, 1978, the defense filed a demurrer to evidence, seeking dismissal of the charges, claiming that the evidence merely established civil liability rather than criminal liability. The trial court denied this demurrer on July 27, 1978, ruling the pros

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Facts:

Parties and Background

• The case involves the People of the Philippines (petitioner) and respondents, the accused Melchor J. Javier, Jr. and Victoria L. Javier, who were charged with estafa.
• The criminal case originated from an erroneous bank remittance: instead of receiving US$1,000.00, the accused received US$1,000,000.00, of which US$999,993.70 was available for misappropriation.
• The erroneous remittance from Manufacturers Hanover Bank, New York, was facilitated by instructions from Mellon Bank, N.A. and involved a mistaken transfer directive.

Criminal Charges and Trial Court Proceedings

• On November 8, 1977, the accused were charged before the Circuit Criminal Court of the Seventh Judicial District with estafa, as set out in the information detailing the alleged misappropriation and conversion of funds.
• The information alleged that the accused, fully aware of the bank’s error, fraudulently misappropriated and converted nearly US$999,000.00 for their own benefit.
• The accused pleaded not guilty, and the People duly presented evidence in support of the charge.
• After the People rested its case, on June 30, 1978, the accused filed a demurrer to evidence along with a motion to dismiss the criminal charge, asserting that their liability was civil rather than criminal.

Denial of Demurrer and Subsequent Proceedings

• The trial court, on July 27, 1978, denied the demurrer to evidence and motion to dismiss, finding that the prosecution had established a prima facie case.
• The trial court reiterated its ruling on August 18, 1978, setting the trial for further reception of evidence on September 22, 1978.
• On September 8, 1978, the accused filed a petition for certiorari with the Court of Appeals challenging the interlocutory orders post the denial of their evidentiary demurrer.
• At the oral argument on July 10, 1979, the accused, represented by counsel, accepted the trial court’s ruling by waiving their right to present any further evidence and moved that the interlocutory order be treated as a “judgment of conviction” so that their petition could be considered an appeal on the merits.

Actions of the Court of Appeals and Error in Procedure

• The Court of Appeals issued a resolution on September 18, 1979, treating the petition fileable as an appeal by granting a period for submission of briefs, although this was premised on the notion that the trial court’s denial constituted a conviction.
• A subsequent, manifestly erroneous resolution on October 8, 1979, declared the case submitted for decision without any briefs having been filed, based on the mistaken assumption that the appellate process had been initiated.
• The petitioner (the People) filed its petition for certiorari, prohibition, and mandamus seeking the annulment of these resolutions, arguing that the Court of Appeals improperly converted an interlocutory order into an appeal, thus exceeding its jurisdiction.
• A temporary restraining order was eventually issued on October 15, 1979, enjoining the Court of Appeals from proceeding further with the case and enforcing the challenged resolutions.

Issue:

Jurisdiction and Nature of the Order

• Whether the trial court’s interlocutory order denying the demurrer to evidence could be considered a “judgment of conviction” over which the appellate court may exercise its review.
• Whether the accused’s waiver of their right to present evidence conferred upon the Court of Appeals the authority to treat the certiorari petition as an appeal.

Proper Use of Appellate versus Original Jurisdiction

• Whether, in light of the pending criminal proceedings, the appellate court could usurp the trial court’s exclusive and original jurisdiction by converting an interlocutory order into a final judgment.
• Whether the proper remedy for the accused’s challenge should have been an appeal after a final judgment has been rendered by the trial court rather than through a certiorari petition.

Procedural and Evidentiary Due Process

• Whether the accused’s decision to waive presenting further evidence and accept the interlocutory order effectively prejudiced their right to a fair trial.
• Whether the resolution of the Court of Appeals, in accepting the waiver as conclusive evidence of conviction, violated the principles of due process and the orderly procedure prescribed by the Rules of Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)