Case Summary (G.R. No. 219468)
Factual Background
On April 26, 2012, Burgos filed a letter-complaint with the Office of the Provincial Prosecutor in Taytay, Rizal, accusing the respondents of falsely obtaining ownership of a property originally titled to him and his wife, Rubie S. Garcia-Burgos. The subject lot of 1,389 square meters was alleged to have been fraudulently transferred following signature on blank documents by the Burgoses, which included a receipt and a Deed of Absolute Sale. Notably, the title to the property was subsequently transferred to the respondents on April 1, 1998. Burgos claimed he discovered the alleged fraud in February 2011, leading to the filing of an Information against the respondents on February 11, 2013.
Procedural Posture
The respondents moved to quash the Information, asserting several defenses including the expiration of the criminal liability due to prescription, the omission of a specific charge against Amalia, and the lack of a preliminary investigation. The Regional Trial Court (RTC) ruled in favor of the respondents on August 14, 2013, citing that the ten-year prescriptive period had lapsed since the crime was deemed to have started upon the registration of the title on April 1, 1998. Following the denial of a motion for reconsideration, Burgos sought relief through a petition for certiorari in the Court of Appeals (CA).
Court of Appeals' Dismissal
The CA dismissed Burgos's petition on March 5, 2015, and reiterated this dismissal on July 2, 2015, primarily citing procedural flaws—the failure to include the Office of the Solicitor General (OSG) in the petition, as required by applicable law. The CA noted that the OSG did not consent to the filing of the petition, which is necessary for cases affecting the People of the Philippines.
Legal Framework and Findings
The primary issue resolved by the Court was whether the CA correctly dismissed the certiorari petition due to a lack of authority by the petitioner to represent the People of the Philippines. The ruling emphasized that only the OSG has the authority to represent the People in criminal appeals, pursuant to Section 35 of the Administrative Code of 1987. This principle is grounded in jurisprudence indicating that in criminal matters, the People are
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Case Information
- Citation: 786 Phil. 881
- Division: First Division
- Docket Number: G.R. No. 219468
- Date of Resolution: June 08, 2016
- Petitioner: Jose Burgos, Jr.
- Respondents: Spouses Eladio S.J. Naval and Arlina B. Naval, and Amalia B. Naval
Procedural Background
- This case arises from a petition for review on certiorari challenging the Resolutions dated March 5, 2015, and July 2, 2015, of the Court of Appeals (CA) in CA-G.R. SP No. 138203.
- The CA denied Burgos's petition for certiorari due to his lack of authority to initiate the case in the name of the People of the Philippines.
Facts of the Case
- Jose Burgos, Jr. filed a letter-complaint on April 26, 2012, with the Office of the Provincial Prosecutor in Taytay, Rizal, charging the respondents with Estafa through Falsification of Public Documents.
- Burgos and his wife were the registered owners of a 1,389 square meter lot, covered by Transfer Certificate of Title (TCT) No. 550579.
- The lot was mortgaged to Antonio Assad on November 19, 1996, and later, Burgos sought a loan from the respondents to avoid foreclosure, signing some blank documents.
- In February 2011, Burgos discovered TCT No. 550579 had been cancelled, and TCT No. 644582 was issued in favor of the respondents on April 1, 1998, alleging the documents