Facts:

The case revolves around a petition for review filed by Victorias Milling Co., Inc. against respondents Luis J. Padilla, Emmanuel S. Duterte, Carlos Tupas, Jr., and Rolando C. Rodriguez. The origin of the case can be traced back to a complaint for falsification of private documents filed on various occasions from 21 January 1992 to 02 December 1996 by the Chief of Police of Victorias, Negros Occidental. The complaint alleged that the respondents conspired to commit falsification by executing untruthful Refined Sugar Delivery Orders (RSDOs) and false certifications to illegally obtain loans from multiple banks amounting to approximately US$15,274,956.40 and P692,322,644.86 without the authorization of the board of directors of the milling company.

The Municipal Trial Court in Cities, presided over by Judge Ricardo S. Real, dismissed the initial complaint for being duplicitous, which prompted the City Prosecutor, post-conversion of Victorias into a city, to file 64 separate inform

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Facts:

Background of the Case

• The controversy originated from a single complaint for falsification of private documents filed by the Chief of Police of the then Municipality of Victorias against four respondents: Luis J. Padilla, Emmanuel S. Duterte, Carlos T. Tupas, Jr., and Rolando C. Rodriguez.
• The complaint, docketed as Criminal Case No. 8069-V, alleged that the respondents, acting in conspiracy, executed, issued, and signed sugarless Refined Sugar Delivery Orders (RSDOs) and false certifications without proper authority, thereby causing damage to Victorias Milling Company (VMC).

Proceedings in the Lower Courts

• On 6 November 1998, the Municipal Trial Court in Cities (MTCC) Judge Ricardo S. Real, Sr. dismissed the complaint upon motions to quash filed by some respondents, noting issues such as duplicity of offenses and defects in the complaint.
• Following the conversion of the Municipality of Victorias into a city, the City Prosecutor filed 64 separate informations for falsification against the respondents on 13 November 1998, alleging conspiracy to falsify private documents in order to obtain loans totaling both in US dollars and Philippine pesos.
• The MTCC Judge issued arrest warrants only against those respondents whose signatures appeared on the sugarless RSDOs: 47 cases for Padilla, 10 for Duterte, 6 for Tupas, and 1 for Rodriguez.
• On 14 January 1999, the prosecution moved the issuance of 64 warrants of arrest for all respondents on the basis of a conspiracy charge; however, an Order dated 7 April 1999 denied this Motion to Defer Arraignment, stressing that conspiracy must be proved by the prosecution.
• Consequently, during the arraignment on 3 July 2000, the MTCC Judge proceeded to arraign respondents only on the specific informations where their signatures appeared, treating each as individually liable for only those RSDOs they had signed.

Petition for Certiorari and Related Motions

• On 30 August 2000, the petitioner (Victorias Milling Co., Inc.) filed a petition for certiorari and mandamus with the Regional Trial Court (RTC) challenging:
• The nullity of the respondents’ arraignment on alleged grounds.
• The issuance of the arrest warrants and the subsequent arraignment which, according to petitioner, did not reflect the alleged conspiracy encompassing all 64 informations.
• The petition’s prayer requested:
• The issuance of writs of certiorari and mandamus to set aside the arraignment orders.
• An ex-parte hearing to determine whether warrants of arrest should be issued against all accused based on the allegation of conspiracy.
• A temporary restraining order to enjoin further hearings or arraignments pending the Court’s decision.
• Procedural lapses were noted by the RTC, which denied the petition on the ground of:
• Lack of standing by the petitioner.
• Incomplete attachment of the assailed orders.
• Filing beyond the prescribed period.
• Notwithstanding, on appeal the petitioner subsequently argued that:
• The timeliness was measured from the 3 July 2000 arraignment rather than from earlier orders.
• The attached documents sufficiently complied with the Rules, given that they included the order and transcript of the stenographic notes from the arraignment.

Subsequent Court of Appeals Proceedings

• On 1 August 2001, the petitioner filed another petition for certiorari with the Court of Appeals, challenging the RTC’s denial.
• A Resolution directing the issuance of a temporary restraining order was rendered on 5 December 2001.
• The Court of Appeals later rendered a Decision on 13 June 2002 dismissing the petition, followed by a Motion for Reconsideration by the petitioner that was denied on 22 January 2003.

Issues with the MTCC Judge’s Handling of the Alleged Conspiracy

• The MTCC Judge ruled that each respondent was only liable for the RSDOs actually signed, citing the concept that “the act of one is not the act of all.”
• The Judge further maintained that the evidence for conspiracy was insufficient as it was not properly authenticated or marked as exhibits.
• The judge’s approach effectively dismissed the allegation of a conspiracy without making the required finding of probable cause for conspiracy as co-conspirators for falsification of private documents.

Issue:

Timeliness and Completeness of the Petition

• Whether the petition for certiorari was filed within the 60-day reglementary period, considering the petitioner’s argument that the period commenced on 3 July 2000, the date of the arraignment.
• Whether the petition was complete in that it adequately attached the assailed orders and relevant transcripts.

Legal Personality of the Petitioner

• Whether the petitioner (Victorias Milling Co., Inc.), as the private complainant, has the requisite standing or legal personality to challenge the orders of the MTCC Judge through a petition for certiorari.
• Consideration of jurisprudence (e.g., Paredes v. Gopengco, People v. Calo, Jr.) concerning the non-joinder of the People and the sufficiency of standing in such actions.

The Proper Issue Regarding Conspiracy

• Whether the MTCC Judge erred in requiring proof beyond reasonable doubt of conspiracy at the preliminary stage instead of merely establishing probable cause.
• Whether the issuance of arrest warrants only against the signatories of the documents, and the exclusion of a determination regarding the conspiracy charge, amounted to a miscarriage of procedural justice.

The Appropriateness of a Writ of Mandamus

• Whether the issuance of a writ of mandamus directing the MTCC Judge to conduct an ex-parte hearing to evaluate the allegation of conspiracy is proper under the Rules of Court.
• Whether such an order would remedy the procedural and substantive issues raised by the petitioner concerning the arraignment and the handling of the allegations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)