G.R. No. 224650 - People vs. Goyala Jr.

The case involves the People of the Philippines (petitioner) and Adolfo A. Goyala, Jr. (respondent).
The criminal case pertains to an allegation of statutory rape filed against the respondent.

A minor, identified as AAA, executed a sworn statement on June 17, 2013, with her mother’s assistance before Police Inspector Ernesto A. Mones of the Pasig City Police.
The affidavit accused the respondent of committing statutory rape, prompting the filing of a complaint by the minor.
Upon receipt, the Office of the City Prosecutor of Pasig City (OCP-Pasig City) docketed the complaint (IS No. XV-14-INV-13F-02337) and assigned Assistant City Prosecutor Pedro M. Oribe as the investigating prosecutor.

The respondent executed his Counter-Affidavit on July 30, 2013.
On August 16, 2013, he instituted a civil complaint for damages against the minor and her mother.
Relying on his civil case, the respondent subsequently filed a Petition for Suspension on the Ground of Prejudicial Question before the investigating prosecutor, followed by a supplemental Motion to Reiterate the petition.
The aforementioned motion was denied by a Resolution dated September 30, 2013.

On November 12, 2013, ACP Oribe issued a Resolution finding probable cause against the respondent and recommended the filing of an Information for Statutory Rape under the Revised Penal Code as amended by R.A. No. 8353.
On November 27, 2013, the Regional Trial Court (RTC), Pasig City, Branch 159, received and docketed the Information as Criminal Case No. 152682-PSG.
The respondent filed an Initial Urgent Ex-Parte Motion for Reconsideration and a Main Motion for Reconsideration with an accompanying Motion to Disqualify the investigating prosecutor.
On November 29, 2013, he also filed a Motion to Suspend Proceedings and to Hold in Abeyance the Issuance of a Warrant of Arrest.

On December 18, 2013, Pasig City Prosecutor Jacinto G. Ang issued a first indorsement forwarding the entire record to the Department of Justice (DOJ) for further proceedings while refraining from resolving the pending Motion for Reconsideration.
On January 24, 2014, the then Justice Secretary, Leila de Lima, issued Department Order No. 173, designating Senior Assistant City Prosecutor Josefa D. Laurente as Acting Prosecutor to resolve the preliminary investigation with finality.

On February 13, 2014, the RTC issued an Order denying the respondent’s Motion to Suspend Proceedings and Hold in Abeyance the Issuance of the Warrant of Arrest.

The RTC emphasized that the filing of a complaint or Information confers upon the court exclusive jurisdiction over the case.
It held that the determination of probable cause for the issuance of a Warrant of Arrest is within the court’s sound discretion.

A Warrant of Arrest was subsequently issued on February 21, 2014.
On March 3, 2014, the respondent filed an Omnibus Motion requesting, among other things, the recall of the Order for the issuance of the Warrant of Arrest, dismissal of the Information, or, alternatively, a suspension of such proceedings pending further review.
The RTC denied the Omnibus Motion in its Order dated March 26, 2014.

On September 16, 2015, the Court of Appeals (CA) reversed and set aside the RTC Orders of February 13, 2014, and March 26, 2014.
The CA ordered the RTC to:

Hold in abeyance further proceedings and remand the case to the prosecution for finalizing the preliminary investigation.
Revoke the implementation of the already issued Warrant of Arrest.
Resume proceedings only after the preliminary investigation had achieved finality and after proper indorsement.

The petitioner (through the Office of the Solicitor General) later filed a Motion for Reconsideration before the CA, which was denied in a Resolution dated May 5, 2016.

The respondent further argued that his comprehensive right to a full preliminary investigation was violated, as his Petition for Review (filed on October 5, 2015, with the DOJ) regarding the denial of his Motion for Reconsideration remained pending.
The petitioner contended that the RTC properly exercised its discretion and that the legal avenues provided to the respondent were not curtailed, emphasizing that issues related to due process were already addressed through available remedies.

Whether the criminal proceedings in Criminal Case No. 152682 should remain suspended despite the lapse of the 60-day period provided under Section 11(c), Rule 116 of the 2000 Revised Rules of Criminal Procedure.

The respondent argues that the preliminary investigation remains incomplete due to his pending Petition for Review before the DOJ.
The petitioner contends that the lapse of the 60-day period mandates the resumption of proceedings irrespective of the pending appeal.

Whether the respondent was deprived of his right to due process in the form of a complete preliminary investigation.

The respondent emphasizes that his right to file motions for reconsideration was effectively hindered.
The petitioner maintains that the legal processes afforded to the respondent were sufficient and that he availed himself of the remedies provided by law.

Whether the reliance on precedents such as Castro, Torralba, and Odilao is appropriate in the context of the present case.

The respondent relies on Castro and Torralba to assert that the preliminary investigation is incomplete if a motion for reconsideration remains pending.
The petitioner disputes this reliance, arguing that the circumstances in those cases differ significantly from the instant case.

Whether the 60-day period laid down in Section 11(c), Rule 116 should be strictly enforced, thereby precluding any extension of the suspension period on account of pending reviews or petitions.