G.R. No. 240012 - Urmaza vs. Rojas

Petitioner Meriam M. Urmaza filed a criminal complaint before the Office of the Provincial Prosecutor (OPP) of Tayug, Pangasinan.
The complaint charged respondent Ramon Torres Domingo with Intriguing Against Honor and/or Oral Defamation based on allegations that he spread rumors in their neighborhood claiming that Urmaza was a thief.

On the morning of January 22, 2012, Urmaza was invited by the barangay chairman for a confrontation with Domingo concerning a missing handgun entrusted to him by its owner.
During the confrontation:

Domingo allegedly accused Urmaza of stealing the gun, which she denied.
Susan Maneclang, Urmaza’s aunt, relayed that during a casual conversation, Domingo’s son, Gian Carlo, mentioned that there were suspicions regarding Urmaza’s involvement in the disappearance of the gun.

Subsequent to the confrontation, it was reported that every time Domingo passed Urmaza’s house he would allegedly shout “MAGNANAKAW, MAGNANAKAW SI MERIAM NG BARIL AT BALASUBAS KAYO.”

On January 24, 2013, the OPP dismissed Urmaza’s complaint for insufficiency of evidence.
Urmaza filed a motion for reconsideration on January 7, 2015, contending that she did not receive a copy of the said resolution; however, the motion was denied on January 12, 2015.

Urmaza then appealed to the ORP in San Fernando City, La Union.
Initially, the ORP dismissed her petition on procedural grounds on February 13, 2017.
A subsequent Resolution on April 26, 2017, by the ORP, gave due course to her petition and adjudicated the merits, affirming the dismissal for insufficiency of evidence, noting the absence of credible corroboration.
Her motion for reconsideration of the ORP ruling was again denied in a Resolution dated June 27, 2017.

Urmaza filed a petition for certiorari before the CA to challenge the ORP’s adverse resolution on the ground of an improper remedy.
The CA dismissed the petition in its Resolution dated September 29, 2017 for being filed as a petition for certiorari instead of the proper remedy as prescribed by the relevant DOJ circular and the Rules of Court.

Urmaza filed a motion for reconsideration of the CA ruling, which was denied in a Resolution dated May 25, 2018.
The matter was then elevated to the Supreme Court on certiorari.

Whether the Court of Appeals (CA) correctly dismissed Urmaza’s certiorari petition on the ground that it was the wrong remedy as provided under the DOJ guidelines and the Rules of Court.
Whether the failure to state the material dates for filing motions for reconsideration, as required by Section 3, Rule 46 of the Rules of Court, constituted sufficient ground for the dismissal of the petition on procedural infirmity.