Case Digest (G.R. No. 80838) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 21, 1974, Yolanda Mendoza filed a complaint for Consented Abduction against Eleuterio C. Perez in Criminal Case No. 618, Court of First Instance of Pampanga, Branch VI. Perez pleaded not guilty. After trial, he was convicted on June 28, 1980, but upon appeal the Court of Appeals reversed the conviction and acquitted him on October 29, 1982, finding that the facts amounted to seduction rather than abduction. On July 22, 1983, Mendoza lodged a new complaint against Perez for Qualified Seduction before the Municipal Trial Court of Pampanga, Branch IV. Perez moved to quash based on double jeopardy and waiver/estoppel, but both the municipal court and its reconsideration denied relief. He then petitioned the Supreme Court (G.R. No. 68122) for certiorari and prohibition, which was referred to the Intermediate Appellate Court on August 8, 1984. The Intermediate Appellate Court dismissed the petition on December 16, 1985, advising Perez to refile in the proper Regional Trial Case Digest (G.R. No. 80838) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original criminal proceedings for Consented Abduction
- October 21, 1974: Yolanda Mendoza filed a criminal complaint for Consented Abduction against Eleuterio Perez (Criminal Case No. 618, CFI Pampanga, Branch VI).
- June 28, 1980: Trial court rendered judgment of conviction; Perez appealed.
- Court of Appeals acquittal
- October 29, 1982: The Court of Appeals reversed and acquitted Perez, ruling the facts constituted “seduction and not abduction.”
- Subsequent Qualified Seduction proceedings
- July 22, 1983: Mendoza filed a new criminal complaint for Qualified Seduction (Criminal Case No. 83-8228, MTC Pampanga, Branch IV).
- Perez’s motions to quash (invoking double jeopardy, waiver/estoppel) and for reconsideration were denied by the MTC.
- Special civil actions for certiorari and prohibition
- G.R. No. 68122: Perez petitioned the Supreme Court for certiorari and prohibition; case referred to the IAC, which on December 16, 1985 dismissed the petition without prejudice to refiling in the RTC.
- Special Civil Case No. 7623: Perez filed certiorari and prohibition in the RTC of Pampanga; petition and motion for reconsideration were dismissed.
- Petition for review with the Court of Appeals
- CA-G.R. CR No. 04789: Perez filed a petition for review; October 8, 1987: the CA denied it as inappropriate and final for lack of notice of appeal.
- November 12, 1987: CA denied his motion for reconsideration. Perez then filed the present petition.
Issues:
- Procedural remedies
- Whether Perez’s petition for review was the proper remedy from the RTC’s denial of certiorari and prohibition.
- Whether the CA correctly held that failure to file a notice of appeal within fifteen days rendered the RTC decision final.
- Substantive claims
- Whether the filing of an information for Qualified Seduction was barred by double jeopardy after Perez’s acquittal for Consented Abduction.
- Whether waiver, estoppel, or implied pardon by Mendoza precluded the Qualified Seduction prosecution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)