Case Summary (G.R. No. 137010)
Procedural History and Applicable Law
The City Prosecutor of Makati found probable cause to indict the private respondents, and Informations were filed in 1996. However, the Department of Justice (DOJ) reversed this finding in 1998, prompting a Motion to Withdraw the Informations. Subsequently, a motion for reconsideration was filed, and the DOJ reversed itself again, directing prosecution to proceed. The MTC denied the Motion to Withdraw, adhering to the DOJ's latest resolution and Supreme Court precedents, specifically Crespo v. Mogul, which provides that once an Information is filed, its disposition lies within the court’s discretion.
Private respondents challenged the MTC’s denial through certiorari to the Regional Trial Court (RTC) of Makati, which ruled that the MTC had abused its discretion by denying withdrawal of the Information without an independent evaluation of probable cause and declared the cases withdrawn. The RTC's denial of the petitioner’s motion for reconsideration was subsequently appealed to the Supreme Court.
This case is governed by the 1987 Philippine Constitution and the Rules of Court, including Rule 65 on certiorari and relevant procedural rules on criminal procedure.
Issues Presented
The main issue is whether the RTC committed grave abuse of discretion amounting to lack of or excess of jurisdiction when it nullified the MTC’s Orders, treated the criminal cases as withdrawn, and ordered their outright dismissal.
Procedural Remedies and Timeliness
The Supreme Court first addressed procedural concerns, concluding that certiorari was the proper remedy because the issue involved the jurisdiction of the RTC over cases pending at the MTC. Although initially filed late under the 1997 Rules of Civil Procedure, the petition was deemed timely due to the retroactive application of amendments to Rule 65 per A.M. No. 00-2-03, which extended the period for filing a certiorari petition to sixty days from denial of a motion for reconsideration.
The Court also recognized a valid exception to the principle of hierarchy of courts, granting direct cognizance to the Supreme Court in the interest of speedy justice, given the long-pending nature of the case.
Substantive Analysis: Duty of Trial Courts in Withdrawal of Informations
The Court reiterated the rule from Ledesma v. CA that a trial court confronted with a motion to withdraw an Information based on lack of probable cause, especially following a DOJ resolution, has a duty to conduct an independent evaluation of the merits rather than blindly relying on the DOJ’s findings. The court must embody this assessment clearly in its order.
The MTC’s Orders in this case were defective because:
- The June 10, 1998 Order denying withdrawal relied solely on the DOJ’s then-revoked resolution finding probable cause.
- The July 21, 1998 Order denying reconsideration referenced the Crespo doctrine without independently evaluating probable cause. Thus, the MTC committed grave abuse of discretion by failing to make an independent determination on probable cause.
Jurisdictional Error of the RTC
While the RTC correctly found the MTC’s failure to evaluate probable cause gravely abusive, it itself exceeded its jurisdiction by considering the criminal cases as withdrawn and dismissing them outright. The RTC’s role was limited to reviewing whether the MTC had committed grave abuse of discretion, not to presume jurisdiction and dismiss cases pending before the MTC.
Moreover, the RTC failed to perform the independent evaluation it mandated to the MTC, improperly nullifying the cases without assessing probable cause.
Probable Cause and Prejudicial Question Doctrine
Given that this case had long been pending and that the records had already been forwarded to the Supreme Court, the Court exercised its discretion to resolve the probable cause issue rather than remand it.
The Court outlined the five requisites for the crime of False Testimony under Article 182 RPC:
- The testimony must be given in a civil case.
- The testimony must relate to issues presented in the case.
- The testimony must be false.
- The false testimony must be knowingly given.
- The testimony must be malicious and intended to affect the issues.
The first two requisites were satisfied; the private respondents testified in the civil case concerning payment claims. However, the falsity, knowledge of falsity, and malicious intent were uncertain. The civil case was still pending; thus, the veracity of the testimonies was not yet established, making the determination of guilt in the criminal case dependent upon the outcome of the civil case.
The Court found that the issue of falsity constituted a prejudicial question under Section 7, Rule 111 of the Revised Rules of Criminal Procedure because the civil ca
Case Syllabus (G.R. No. 137010)
Nature of the Case and Procedural Posture
- The case involves a petition for certiorari under Rule 65 of the Rules of Court filed by petitioner Ark Travel Express, Inc. (Ark Travel), seeking to nullify orders issued by the Regional Trial Court (RTC) of Makati City, Branch 150, specifically:
- The Order dated October 2, 1998, which considered two criminal cases pending before the Metropolitan Trial Court (MTC) of Makati as withdrawn.
- The Order dated November 23, 1998, which denied Ark Travel’s Motion for Reconsideration of the October 2, 1998 order.
- The underlying criminal cases (Nos. 200894 and 200895) at the MTC concern charges of False Testimony filed by Ark Travel against respondents Violeta Baguio and Lorelei Ira under Article 182 of the Revised Penal Code.
- The petition addresses issues of court jurisdiction, the discretionary power of courts in motions to withdraw information, and procedural propriety in handling criminal cases overlapping with pending civil cases.
Factual Background
- Ark Travel filed criminal complaints for False Testimony against respondents Baguio and Ira, alleging that they gave false sworn testimony in Civil Case No. 95-1542 (a collection and damages suit filed by Ark Travel against New Filipino Maritime Agencies, Inc. [NFMA, Inc.]).
- The City Prosecutor of Makati found probable cause on November 20, 1996, and filed Informations charging both respondents before the MTC.
- The respondents petitioned for review of the City's Prosecutor resolution with the Department of Justice (DOJ), which initially reversed the probable cause finding in March 1998.
- Following further motions and reconsiderations, including an urgent petition and interlocutory orders, conflicting rulings were issued by the DOJ and the MTC regarding the existence of probable cause and withdrawal of the Informations.
- The respondents filed a petition before the RTC challenging the MTC’s denial of motions to withdraw the Informations, resulting in the RTC’s October 2, 1998 order setting aside MTC orders and considering the cases withdrawn.
- Ark Travel filed motions for reconsideration which were denied by the RTC on November 23, 1998.
- Ark Travel subsequently filed the present petition for certiorari with the Supreme Court.
Issues Presented
- Whether or not the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction by nullifying the Metropolitan Trial Court’s orders, and by dismissing the criminal cases pending before the MTC.
- Whether the Motion to Withdraw Information filed by the prosecution should have been granted based on the finding of no probable cause.
- Jurisdictional propriety of the RTC in intervening and considering the criminal cases as withdrawn when such cases are originally pending in the MTC.
- The appropriate remedy and procedural requirements for challenging the orders issued by the courts involved.
Procedural Legal Principles and Jurisdictional Analysis
- The Supreme Court confirmed certiorari as the proper remedy when:
- The court issued an order without or in excess of jurisdiction;
- There is patent grave abuse of discretion;
- Or when appeal is not an adequate or speedy remedy.
- The Court noted that denial of a prosecution’s motion to withdraw an information is generally interlocutory and unappealable unless jurisdictional or grave abuse of discretion exists.
- The RTC was found to have acted in excess of jurisdiction when it treated the criminal cases as withdrawn and ordered their dismissal, a power beyond its appellate function.
- The MTC’s denial of the Motion to Withdraw Information was based solely on the DOJ ruling that probable cause existed, without an independent judicial assessment.
- The Court ruled that trial courts must