G.R. No. 216824 - Villa Gomez vs. People

Gina Villa Gomez (“petitioner”) was charged with corruption of public officials (RPC Art. 212 in relation to Art. 211-A) for offering ₱10,000 to police officers in exchange for releasing a detainee.
After inquest, Assistant City Prosecutor (ACP) Rainald C. Paggao prepared an Information, certifying under oath probable cause and stating it was filed with the prior authority of City Prosecutor Feliciano Aspi.

The Makati City Office of the City Prosecutor issued a Resolution (Sept. 21, 2010), signed by ACP Paggao recommending prosecution and by City Prosecutor Aspi approving “the attached Information.”
On Sept. 22, 2010, the Information was filed with RTC Branch 57, Makati City, docketed as Criminal Case No. 10-1829.

Trial proceeded on the merits; both parties completed evidence, and the case was submitted for decision.
On Feb. 13, 2013, the RTC motu proprio dismissed the case for “lack of jurisdiction,” holding ACP Paggao had no authority because the Information lacked the City Prosecutor’s signature.
On Apr. 29, 2013, the RTC denied the Prosecution’s motion for reconsideration, reaffirming the dismissal for jurisdictional defect.

The Office of the Solicitor General filed a Rule 65 petition for certiorari with the CA, arguing the RTC gravely abused discretion and that the Resolution bore Aspi’s signature.
On Oct. 9, 2014, the CA granted certiorari, reversed the RTC orders, and reinstated Criminal Case No. 10-1829, holding the trial court could not quash the Information motu proprio after trial submission.
The petitioner’s motion for reconsideration (Nov. 13, 2014) was denied by CA Resolution (Feb. 4, 2015).

Petitioner filed a Petition for Review on Certiorari under Rule 45, challenging the CA’s decision and resolution as violating her right against double jeopardy.

Whether the trial court committed grave abuse of discretion—and thus lacked jurisdiction over the case—by motu proprio quashing the Information and dismissing the case for absence of the City Prosecutor’s signature on the Information.
Whether the CA correctly found that the trial court gravely abused discretion in (1) quashing the Information and (2) dismissing the case after submission without giving the Prosecution a hearing.
Whether the CA’s reinstatement of the case violated petitioner’s constitutional protection against double jeopardy.