G.R. No. 236686 - Yokohama Tire Philippines, Inc. vs. Reyes

Petitioner: Yokohama Tire Philippines, Inc.
Respondents: Sandra Reyes and Jocelyn Reyes, who are former employees of the petitioner.
A third individual, Celeste Tagudin, was also involved as a former employee but later recommended for dismissal regarding the complaint.

On June 17, 2011, the petitioner filed a criminal complaint for qualified theft, alleging that respondents (with Tagudin’s involvement) took HP ink cartridges from the company’s stock room without proper consent.
The Assistant City Prosecutor (ACP) of Angeles City, in a Resolution/Recommendation dated March 22, 2012, advised that the complaint against Tagudin be dismissed for insufficiency of evidence while recommending that an Information for Attempted Theft be filed against the respondents.
The City Prosecutor approved this recommendation, and consequently, the case was docketed before the Municipal Trial Court (MTC) of Clarkfield, Pampanga as Criminal Case No. 12-5960.

During trial, the prosecution attempted to establish the crime by introducing evidence, notably a series of pictures purportedly lifted from a video recording showing the alleged theft.
The MTC, however, excluded the ink cartridges as evidence, reasoning that they were obtained in violation of the accused’s right against unreasonable search and seizure.
The MTC rendered its Decision on November 10, 2015, acquitting the respondents of the charge of attempted theft, based largely on the insufficiency of evidence.

In response to the acquittal, the petitioner filed a petition for certiorari with the Regional Trial Court (RTC) under Rule 65, contending that the MTC’s exclusion of evidence amounted to grave abuse of discretion and resulted in a decision that was either void or rendered without jurisdiction.
On July 10, 2017, the RTC issued a Decision dismissing the petition for lack of merit.
A Motion for Reconsideration was subsequently filed by the petitioner, but this was also denied by the RTC on November 7, 2017.

The petitioner argued that the exclusionary rule, which was used by the MTC to dismiss the evidence (HP ink cartridges), applies only as a restraint against the government and not against private entities.
It was further contended that the MTC committed grave abuse of discretion in excluding evidence that would have demonstrably shown the respondents’ conduct.
According to the petitioner, the RTC erred in affirming the MTC decision, thereby necessitating review.

In a concurring opinion, Judge Caguioa emphasized the need for a proper framework in evaluating evidentiary errors, distinguishing between errors in judgment and errors amounting to lack or excess of jurisdiction.
The concurring opinion also underscored that even if the ink cartridges were admitted as evidence, their probative value would still need to satisfy independent tests of reliability and sufficiency.
The concurring views reiterated the principle that the right of a private complainant is limited to the civil aspect of the case while the criminal aspect is exclusively the prerogative of the State through the Office of the Solicitor General.

Whether the trial court (MTC) committed grave abuse of discretion in excluding the HP ink cartridges as evidence on the ground that they were obtained in violation of respondents’ constitutional right against unreasonable search and seizure.
Whether the petitioner, as a private offended party, had the legal standing to question the criminal judgment (acquittal) and to file a petition for certiorari against the MTC’s ruling.
Whether the distinction between the admissibility of evidence and its probative value was correctly appreciated by the MTC, and if such determination is subject to review via certiorari.
Whether the principle of double jeopardy and the finality-of-acquittal doctrine preclude the petitioner's challenge, given that only the State, through the Office of the Solicitor General, may contest the criminal aspect of an acquittal.