Case Digest (G.R. No. 241911)
Facts:
People of the Philippines v. Angelo O. Montilla, G.R. No. 241911; Spouses Rodolfo Palmes & Esmaelita Palmes v. The Honorable Court of Appeals, Angelo O. Montilla, and Doris P. Lapuz, G.R. No. 242375, February 8, 2023, Supreme Court Third Division, Singh, J., writing for the Court.On October 25, 2003, Richard Escobia and Aileen Palmes‑Lustre were killed in Buluan, Maguindanao. On August 9, 2004, the Office of the Provincial Prosecutor filed an information for double murder before the RTC–Cotabato City, Branch 15 (Crim. Case No. 034‑SA). Subsequent reinvestigations led to shifting inclusions and exclusions of suspects: Assistant Provincial Prosecutor Rodolfo S. Yanson (Asst. Pros. Yanson) in a June 12, 2007 Resolution included Angelo O. Montilla and Doris P. Lapuz as additional accused; Provincial Prosecutor Ringear B. Pinote (Pros. Pinote) then filed a June 22, 2007 Resolution dismissing charges against them and moved to recall the Second Amended Information alleging lack of his approval in its filing.
Montilla filed a Rule 65 petition in the Court of Appeals (CA) challenging the Second Amended Information and the warrants; the CA denied it as premature in August 2008, and this Court affirmed that denial on September 9, 2009. A change of venue petition by Montilla was granted on June 15, 2011, transferring the case ultimately to the RTC–Davao City; the matter was raffled among several branches of the Davao RTC over time (Branches 11, 16, 15 and 17).
On January 9 and August 30, 2012, RTC–Davao City, Branch 11 issued orders directing a re‑investigation and suspending arrest implementation, which the CA later reversed on March 18, 2014, holding a court cannot delegate its judicial function of determining probable cause to the prosecutor. On October 10, 2014, however, RTC–Davao City, Branch 16 motu proprio dismissed the case against Montilla and Lapuz for lack of probable cause after its own review of the preliminary investigation records. The prosecution moved for inhibition; the case was re‑raffled and Branch 15 (on December 10, 2015) reversed Branch 16, invoking the doctrine of judicial stability and ordered issuance of alias warrants. Montilla sought reconsideration and then elevated the matter to the CA.
In CA‑G.R. SP No. 07901‑MIN, the CA on January 22, 2018 granted Montilla’s petition and reinstated the October 10, 2014 dismissal by RTC–Davao City, Branch 16, reasoning the doctrine of judicial stability had been misapplied because the orders involved the same case after valid venue transfers. The Office of the Solicitor General (on behalf of the People) and the Spous...(Pro-only)
Issues:
- Did Montilla’s death while the petition was pending extinguish his criminal liability and require dismissal of the appeal as to him?
- Did the Court of Appeals commit error in reinstating the RTC–Davao City, Branch 16 Order dated October 10, 2014, which dismissed the criminal case against Montilla and Lapuz (i.e., was the doctrine of judicial stability misapplied)?
- Was a Rule 65 petition the proper remedy to assail a denial of a motion to quash an information, or was there a plain, adequate and speedy remedy available?
- Was there probable cause to indict ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)