Case Summary (G.R. No. L-25513)
Antecedent Facts
On June 22, 2001, Serafin Saballegue was charged with violating the Social Security Act (Republic Act No. 8282) through an information filed by State Prosecutor Romulo SJ. Tolentino, which included a certification asserting that the required investigation had been conducted and that the filing had the prior approval of the Regional State Prosecutor. The information detailed Saballegue's failure to remit employee premiums to the Social Security System (SSS) along with specified amounts involved.
Proceedings at the Regional Trial Court
After being arraigned on September 24, 2001, and pleading not guilty, Saballegue filed a motion to dismiss on October 1, 2001, citing the lack of prior written authority from the city prosecutor as required by Section 4, Rule 112 of the Revised Rules of Court. The trial court examined the arguments from both sides and ultimately granted the motion to dismiss the information on February 26, 2002, asserting that the information had not been filed in compliance with the procedural rules.
Motion for Reconsideration
Following the dismissal, State Prosecutor Tolentino filed a motion for reconsideration. The trial court denied this motion on April 3, 2002, citing non-compliance with the notice of hearing requirements, thus reinforcing the initial dismissal order.
Legal Issues Presented
The central question presented to the Supreme Court was whether the information filed by the State Prosecutor without the city prosecutor's prior approval was jurisdictionally defective and if such a defect could still be raised after entry of the accused's plea. The petitioner argued that the rules had been circumvented through the previous directives issued to inhibit the city prosecutor from SSS cases, claiming the special prosecutor had the authority to file the information independently.
Findings of the Court
The Supreme Court upheld the principle that the requirement for prior written approval is mandatory and cannot be disregarded. It emphasized that the absence of this approval constitutes a jurisdictional defect that cannot be waived by mere silence or acquiescence from the accused. This ruling traced back to established precedents, particularly the Villa ruling, which clarified that the filing officer's authority is critical for conferring juris
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Case Overview
- The case revolves around a procedural law question regarding the validity of an information filed by a state prosecutor without prior written authority or approval from the city or provincial prosecutor or chief state prosecutor.
- The petitioner, the People of the Philippines, sought to reverse the orders of the Regional Trial Court of Naga City, which dismissed the case for lack of jurisdiction.
Background of the Case
- On June 22, 2001, Serafin Saballegue was charged with violating the Social Security Act (Republic Act No. 8282).
- The information against him was filed by State Prosecutor Romulo SJ. Tolentino, who certified having conducted the required investigation and obtained prior authority from the Regional State Prosecutor.
- The case was raffled to Branch 19 of the RTC in Naga City presided by Judge Zeida Aurora B. Garfin.
Procedural Developments
- After entering a plea of not guilty on September 24, 2001, Saballegue filed a motion to dismiss, claiming the information lacked the necessary prior written authority from the city prosecutor as mandated by Section 4, Rule 112 of the Revised Rules of Court.
- The trial court granted the motion to dismiss in its order dated February 26, 2002, emphasizing the requirement of prior approval for the filing of information.
Trial Court's Rationale
- The trial court referenced Section 4, Rule 112, asserting that no information may be filed without prior written authority from the relevant prosecutors.
- The court distinguished between formal objections to pleadings and jurisdict