A.M. No. 00-1258-MTJ - Spouses Sena vs. Villarin

On June 15, 1971, Lamberto Alcantara was slain inside the "Rosario Kiosk" at the poblacion of Rosario, Cavite.
Two separate criminal complaints for homicide were filed:

The first complaint was filed on June 16, 1971, in the Municipal Court of Rosario, Cavite by Enrique C. Banzon, chief of police of Rosario, against petitioner Bayani Quinto, based on the sworn statements of Arsenio Mira and Danilo Enriquez.
The second complaint was filed on June 18, 1971, directly with the Circuit Criminal Court of Pasig, Rizal by Lt. Petronilo Viceno of the Philippine Constabulary, against three accused – Bayani Quinto, Danilo Enriquez, and Valeriano "Billy" Reyes – based on affidavits of Leopoldo Camposanto and Oscar Alcantara.

In Rosario, Mayor Calixto Enriquez conducted a preliminary examination in the absence of the municipal judge and, finding reasonable ground to believe that Bayani Quinto probably committed the crime, issued a warrant of arrest against him.
On June 26, 1971, Judge Teofilo Pugeda of the Municipal Court of Rosario conducted a preliminary investigation.
On June 29, 1971, the record of the case was remanded to the Court of First Instance (CFI) of Cavite and docketed as Criminal Case No. TM-101.
Meanwhile, in Pasig, Judge Onofre A. Villaluz of the Circuit Criminal Court issued an order on June 21, 1971, instructing State Prosecutor Cornelio M. Melendres to conduct a preliminary investigation pursuant to Section 13 in relation to Section 2, Rule 112 of the Rules of Court.

Petitioners Quinto and Enriquez filed a motion for reconsideration on June 28, 1971, with the Circuit Criminal Court, contending that jurisdiction had already been acquired by the CFI of Cavite.
On June 29, 1971, Mrs. Teresita Alcantara, the widow of the victim, filed a motion in the CFI of Cavite to transfer Criminal Case No. TM-101 to the Circuit Criminal Court of Pasig, arguing that as of June 21, 1971, the Circuit Criminal Court had acquired jurisdiction over the accused.
Assistant Provincial Fiscal Ireneo S. Felix, after being ordered to comment, manifested his option to have the case prosecuted before the Circuit Criminal Court.
Consequently, on July 15, 1971, the record of Criminal Case No. TM-101 was transferred from the CFI of Cavite to the Circuit Criminal Court of Pasig.

Petitioners Bayani Quinto and Danilo Enriquez commenced the petition for certiorari against Judge Villaluz and State Prosecutor Melendres.
The objective was to restrain respondents from conducting the preliminary investigation and proceeding with the trial, arguing that the CFI of Cavite had already acquired exclusive jurisdiction over the case.

Petitioners argued that the filing of the original complaint and its remand to the CFI of Cavite gave that court exclusive jurisdiction over the case.
The petitioners’ contention was countered by the existence of Republic Act No. 5179, which conferred concurrent jurisdiction upon the circuit criminal courts for crimes that were once exclusively in the province of the courts of first instance.
It was noted that when the record was remanded to Cavite, a complaint had already been filed with the Circuit Criminal Court, thereby invoking the concurrent jurisdiction provided by law.

Whether the Circuit Criminal Court of Pasig properly exercised jurisdiction over Criminal Case No. TM-101 despite the initial proceedings in the CFI of Cavite.
Whether the filing of separate complaints in two different courts creates a conflict, or if it legally permits concurrent jurisdiction under the provisions of Republic Act No. 5179.

Whether the transfer of the case record from the CFI of Cavite to the Circuit Criminal Court was proper and in accordance with the law.
Whether Assistant Provincial Fiscal Ireneo S. Felix’s decision to file the information with the Circuit Criminal Court was within the scope of his discretion under the relevant rules and administrative orders.

Whether returning the case to the CFI of Cavite would result in the trial of petitioner Quinto separately from his co-accused, thereby leading to multiplicity of suits.
Whether such a separate trial would compromise the principles of a speedy and orderly administration of justice.