Villa Gomez vs. People

Facts:

The petitioner, Gina A. Villa Gomez (accused), was charged with corruption of public officials under Article 212 of the Revised Penal Code after her arrest on September 17, 2010. A complaint was filed on September 19, 2010 and received for inquest by the Office of the City Prosecutor (OCP) of Makati City. On September 21, 2010 the OCP issued a Resolution finding probable cause and stating that “The attached Information is recommended to be approved for filing in court,” and the Resolution bore the signature of City Prosecutor Feliciano Aspi under the word “Approved.” The formal Information, however, was filed in court on September 22, 2010 and was signed only by Assistant City Prosecutor Rainald C. Paggao, who certified in the Information that it was “being filed with the prior authority of the City Prosecutor.”

Trial proceeded and the case was submitted for decision after both parties rested. On February 13, 2013 the Regional Trial Court (RTC), Branch 57, Makati City, acting sua sponte and without any motion from the parties, dismissed the case and ordered the accused released on the ground that ACP Paggao lacked authority to file the Information because the Information itself did not bear the City Prosecutor’s signature; the RTC treated that absence as a jurisdictional defect. The RTC denied the prosecution’s motion for reconsideration on April 29, 2013.

The Office of the Solicitor General (on behalf of the People) filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), arguing among others that the OCP Resolution was signed by City Prosecutor Aspi, that the lack of signature on the face of the Information did not divest the RTC of jurisdiction, and that an Information may not be quashed motu proprio once trial and presentation of evidence are complete. On October 9, 2014 the CA granted the petition, annulled the RTC’s February 13 and April 29, 2013 Orders, and reinstated Criminal Case No. 10-1829. The petitioner’s motion for reconsideration before the CA was denied on February 4, 2015.

Petitioner then filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court seeking to set aside the CA’s decision reinstating the Information and criminal case. The issues presented concerned (1) whether the RTC gravely abused its discretion in q...(Pro-only)

Issues:

• Did the Court of Appeals correctly find that the RTC committed grave abuse of discretion when it quashed the Information and dismissed the criminal case on the ground that the Information did not bear the City Prosecutor’s signature or the word “approved,” thereby purportedly divesting the RTC of jurisdiction?

• Did the Court of Appeals correctly find that the RTC committed grave abuse of discretion in (a) motu proprio quashing the Information and (b) dismissing the criminal case after the parties had completed presentation of evidence and the case had been submitted for decision, wi...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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