G.R. No. 161083 - People vs. Gabo

On May 14, 2001, around 12:15 a.m., a fire broke out at Sanyoware Plastic Products Manufacturing Corporation’s plant located at Km. 8, McArthur Highway, Lolomboy, Bocaue, Bulacan.
The plant comprised four single-storey buildings with concrete walls, steel trusses, and galvanized iron sheet roofing.
The affected building, known as Sanyoware 2 or Warehouse 2, was divided longitudinally by a tall concrete firewall with a steel gate.
Sanyoware occupied the western portion of the warehouse while New Unitedware Marketing Corporation (Unitedware) rented the eastern portion.

Investigations were conducted by the Philippine 3rd Regional Criminal Investigation and Detention Group (CIDG) and the Inter Agency Anti-Arson Task Force (IATF) of the Department of the Interior and Local Government.
Based on communications from the CIDG, IATF, and Bureau of Fire Protection (BFP), several individuals were accused of destructive arson. These included:

Witness testimonies were obtained from several Sanyoware employees and officers, including:

Richard Madrideo – Supervisor at Sanyoware, claimed that two separate sets of fire occurred concurrently but later alleged he was coerced.
Jaime Kalaw – Former head of Maintenance, testified that faulty wiring was an unlikely cause due to the operational status and condition of the warehouse.
Raymond Dy – A warehouse supervisor who described alleged product transfers between warehouses and noted varying conditions around the time of the fire.
Testimonies from other employees (Chit Chua, Jennifer Chua Reyes, Shanda Amistad) and firemen (SPO1 Valeriano Dizon, Inspector Allan Barredo) detailing observations at and around the time of the incident.

The investigation also included physical evidence and laboratory reports from the Bocaue Fire Station and the Bulacan Provincial Crime Laboratory, which indicated:

Respondents submitted a detailed Counter-Affidavit to refute the allegations, denying simultaneous fires, the use of incendiary materials, and claims of coercion or bribery in witness testimonies.

A preliminary investigation led the State Prosecutor to issue a Resolution recommending:

Filing of an Information for Destructive Arson against Wilson Ting, Edward Yao, Willy So Tan, and Carol Ortega.
Dismissing the case against Samson Ting for lack of sufficient evidence.
Remanding accessory charges involving three fire officers for further investigation.

An Information for Arson was filed under Criminal Case No. 300-47M, charging the accused with willful and malicious burning of the warehouses and associated stocks to conceal evidence of another violation of law.
Before arraignment and the issuance of arrest warrants, respondents filed a Motion to Conduct Hearing to Determine Probable Cause, which led to:

The Regional Trial Court (RTC) issuing an Order on February 27, 2002, dismissing the case for lack of probable cause.
A subsequent Motion for Reconsideration by the petitioner which was denied by the RTC on March 25, 2002.

The petitioner then sought relief by filing a petition for certiorari before the Court of Appeals (CA), which resulted in:

The CA’s Decision on July 24, 2003 affirming the RTC’s dismissal.
A Motion for Reconsideration by petitioner before the CA, also denied by the CA’s Resolution on October 3, 2003.

Finally, the petitioner raised a certiorari petition before the Supreme Court, challenging:

The use of the equipoise rule by the RTC.
The alleged grave abuse of discretion and lack or excess of jurisdiction in dismissing the case.

Whether the petition for certiorari under Rule 65 is proper given that an adequate appeal (petition for review under Rule 45) was available and subsequently allowed to lapse.
Whether certiorari can substitute for a lapsed appeal when a proper appeal remedy existed.

Whether the RTC’s application of the equipoise rule in dismissing the case was appropriate.
Whether the use of the equipoise rule was justified given that the evidence presented by the prosecution and the defendants’ counter-affidavits produced conflicting versions of the events.
Whether the RTC, in weighing the factual inconsistencies and physical evidence (particularly regarding the alleged simultaneous fire and faulty wiring), exercised its discretion without manifest error.

The role of physical evidence (such as laboratory findings and fire inspection reports) taken by the Bocaue Fire Station and verified by fire officials.
Whether such evidence should have been given more probative weight than the contradictory and allegedly coerced eyewitness testimonies.