Case Summary (G.R. No. 121422)
Arrest and Charges
Upon his arrest on June 19, 1990, law enforcement officers seized a .38 caliber revolver along with six rounds of ammunition from the petitioner. An information was filed by Assistant Prosecutor Tranquil P. Salvador, Jr. on June 25, 1990, outlining the charges against him for illegal possession of firearms. The prosecution claimed the petitioner possessed the firearm without requisite licenses or permits, detailing that the incident occurred in the City of Manila.
Legal Proceedings and Initial Actions
Prior to the petitioner's arraignment, his parents filed a habeas corpus petition in Quezon City on his behalf. The petitioner was later arraigned in Manila and pled not guilty. Subsequently, the trial court allowed the prosecution to formally offer evidence, which included the firearm and ammunition, despite the petitioner's objections. The trial progressed with the court issuing various orders regarding the admissibility of evidence.
Issuance of Court Orders
The Regional Trial Court issued three significant orders: the first on January 18, 1993, admitting the prosecution's evidence; the second on December 20, 1993, denying the petitioner's demurrer to the evidence; and the third on July 8, 1994, which denied the petitioner’s motion for reconsideration of the second order. The petitioner subsequently attempted to challenge these orders through a petition for certiorari filed with the Court of Appeals.
Court of Appeals Decision
On August 8, 1995, the Court of Appeals denied the petition for a lack of merit, classifying the orders in question as interlocutory—which are generally not subject to separate appeals. The appellate court ruled that these matters could only be contested following an ultimate decision on the merits after the trial court's proceedings were concluded. The Court of Appeals stated that the issues raised related to evidentiary rulings and procedural matters that do not warrant certiorari review at this stage.
Petitioner's Contentions
The petitioner maintains that the Court of Appeals erred in upholding the admission of evidence obtained from what he claims was an illegal search and seizure incident to an unlawful arrest. He argued that the evidence presented was insufficient for a conviction and insisted that the interlocutory orders should be reviewed to prevent potential harm to his rights.
Ruling on Certiorari and Future Proceedings
The Supreme Court found no reversible error in the Court of Appeals
...continue readingCase Syllabus (G.R. No. 121422)
Case Overview
- The case involves a petition for review filed by Noel Cruz y Digma (petitioner) against the People of the Philippines, the Court of Appeals, and the Regional Trial Court Branch VI, Manila (respondents).
- The petition seeks to annul three specific orders issued by the Regional Trial Court in Criminal Case No. 90-85059, which pertain to the admission of evidence, denial of a demurrer to evidence, and denial of a motion for reconsideration.
Background of the Case
- On June 19, 1990, the petitioner was arrested without a warrant for illegal possession of a .38 caliber revolver with six rounds of ammunition outside the Manila Pavilion Hotel, Manila.
- Following the arrest, on June 25, 1990, an information was filed against the petitioner for violating Presidential Decree No. 1866 concerning illegal possession of firearms.
- The petitioner’s parents filed a petition for habeas corpus on June 26, 1990, before the Regional Trial Court, Quezon City.
Proceedings in the Trial Court
- The petitioner was arraigned and pleaded not guilty. The trial court then proceeded with the trial.
- On January 18, 1993, the trial court admitted the prosecution's formal offer of evidence, including the firearm and ammunition seized from the petitioner.
- After the prosecution rested its case, the petitioner filed a demurrer to evidence, which was denie