Case Summary (G.R. No. 228739)
Factual Antecedents
The Petitioner was the registered owner of the 2004 Mitsubishi Pajero, which was purportedly sold by the Respondent to Virgilio S. Ramos without her authorization. The Respondent executed an affidavit of loss regarding the vehicle's certificate of registration and original receipt, which was later found to bear a forged signature of the Petitioner. This fraudulent action allowed the Respondent to obtain a new certificate of registration in his name and subsequently conduct a sale of the vehicle. The Petitioner initiated criminal complaints against the Respondent for falsification of public documents.
Criminal Charges Initiated
On August 28, 2006, two Informations were filed against the Respondent for the crimes of falsification of public documents and use of falsified documents. The complaints alleged that the Respondent had knowingly executed documents bearing the forged signature of the Petitioner and had presented these to the Land Transportation Office (LTO), which resulted in the wrongful issuance of new vehicle registration documents.
Trial and Presentation of Evidence
The trial commenced with the Petitioner offering various pieces of documentary evidence related to her ownership of the vehicle, including the original receipt and the affidavit of loss. The Municipal Trial Court in Cities (MTCC) initially admitted some of Petitioner’s evidence. However, the Respondent later filed a demurrer to evidence, arguing that the Petitioner had failed to provide sufficient evidence proving the charges against him, including failing to present original copies of the forged documents.
MTCC Rulings
On May 6, 2014, the MTCC denied the Respondent's demurrer, acknowledging that while the evidence presented by the Petitioner was insufficient to prove falsification, the Respondent still bore the burden of explaining the vehicle's transfer and sale. Following a motion for reconsideration by the Respondent, the MTCC subsequently granted the demurrer and acquitted the Respondent regarding the charge of falsification.
Court of Appeals Decision
The Respondent filed a petition for certiorari before the Regional Trial Court (RTC), which affirmed the MTCC's decision and noted that the order denying the demurrer was not reviewable via certiorari. However, the appeal moved to the Court of Appeals (CA), which found that the MTCC had committed grave abuse of discretion by denying the demurrer, thereby ruling in favor of the Respondent. The CA dismissed the criminal cases against the Respondent, which included the charges of using falsified documents.
Petitioner’s Appeal
The Petitioner challenged the CA’s decision by arguing that the grant of Respondent’s demurrer was erroneous as it constituted a perceived error of judgment not correctable by certiorari. She maintained that sufficient circumstantial evidence existed to uphold the charges against the Respondent.
Respondent's Arguments
The Respondent contended that the correct legal remedy for challenging the dismissal of the criminal case should have been a petition for certiorari under Rule 65, not a petition for review on certiorari under Rule 45. He further argued that the evidence presented by the Petitioner was insufficient to establish the charges against him and emphasized that the existence of the driver's license and registration documents did not implicate him in wrongdoing.
Court’s Ruling and Legal Reasoning
The Supreme Court held t
...continue readingCase Syllabus (G.R. No. 228739)
Background and Legal Context
- The case involves a Petition for Review on Certiorari filed under Rule 45 concerning the decision and resolution of the Court of Appeals-Cebu City.
- The case revolves around allegations of falsification of public documents and the use of falsified documents by Donald William Alfred Bowden, the respondent, against Rosemarie Eribal Bowden, the petitioner.
Factual Antecedents
- Rosemarie Eribal Bowden was the registered owner of a 2004 Mitsubishi Pajero (Plate No. FFD 228) which was sold without her consent by her then-husband, Donald Bowden.
- Their marriage was dissolved via a Decree of Divorce dated June 12, 2006, when Rosemarie was in London. She had entrusted the Original Receipt-Certificate of Registration (OR-CR) of the vehicle to her niece.
- During their marriage, Donald executed an affidavit of loss of the OR-CR, leading to the issuance of a new OR-CR in his name, which he used to sell the vehicle.
- The affidavit of loss and subsequent deed of sale bore forged signatures of Rosemarie, prompting her to file criminal complaints against Donald.
Criminal Charges
- Two Informations were filed against Donald for falsification of public documents and use of falsified documents:
- Criminal Case No. C-06-15995-10: Falsification of the affidavit of loss.
- Criminal Case No. C-06-15996-10: Falsification of the deed of sale.
- Both charges alleged that Donald imitated Rosemarie's signature and presented the documents to the Land Transportation Office (LTO), leading to the issuance of new registrations in his name.