Case Summary (G.R. No. 224650)
Overview of Proceedings
This appeal by certiorari is directed against the Decision and Resolution of the CA that reversed earlier Orders issued by the RTC regarding Criminal Case No. 152682, wherein Goyala, Jr. faced charges of statutory rape. The CA ordered a halt to proceedings, revocation of the arrest warrant, and remittance of the case to the prosecution to complete the preliminary investigation.
Antecedent Facts
A minor, referred to as AAA, accused Goyala, Jr. of statutory rape, leading to a sworn statement filed with the police. The complaint was transferred to the Office of the City Prosecutor in Pasig City, resulting in a preliminary investigation. Goyala, Jr. presented a counter-affidavit and subsequently initiated a civil action against AAA and her mother, seeking to suspend the criminal proceedings based on a claim of a prejudicial question. Following the prosecutor's determination of probable cause, Goyala, Jr. experienced several motions to defer proceedings, all of which were denied by the RTC.
Judgment of the Trial Court
The RTC, in its February 13, 2014 Order, denied Goyala, Jr.'s motion for a suspension of proceedings. The court asserted its exclusive jurisdiction over the case post-filing, indicating that issues surrounding preliminary investigations do not impede the court's authority to proceed once the information is lodged. The court's findings led to the issuance of a warrant for arrest. After subsequent motions from Goyala, Jr., both of which were denied, he sought relief from the CA.
Judgment of the Court of Appeals
The CA concluded that Goyala, Jr. was deprived of a complete preliminary investigation. It cited precedents asserting that the right to a full investigation includes the opportunity to pursue a motion for reconsideration of the prosecutor’s findings. The CA therefore issued an order to remand the case back to the Office of the City Prosecutor and to hold proceedings in abeyance until the preliminary investigation was finalized, alongside revocation of the arrest warrant.
Arguments of the Parties
The petitioner contended that the RTC acted within its jurisdiction when it denied Goyala, Jr.'s motion to suspend proceedings, emphasizing that the case facts differed significantly from those in cited precedential cases (Torralba and Castro). It stressed that Goyala, Jr. had been afforded ample opportunity to contest the findings against him.
In contrast, the respondent asserted that the preliminary investigation was incomplete as he had an ongoing appeal with the Department of Justice against the prosecutor's findings, positing that the lapse of the 60-day period for the motion for suspension should be considered invalid due to delays caused by the petitioner.
Ruling of the Court
The Supreme Court rul
...continue readingCase Syllabus (G.R. No. 224650)
Overview of the Case
- This case involves an appeal by certiorari challenging the Decision and Resolution of the Court of Appeals (CA) regarding the orders of the Regional Trial Court (RTC) in a criminal case for statutory rape.
- The CA reversed and set aside the RTC's Orders, which had denied the respondent's motion to suspend proceedings and to hold in abeyance the issuance of a warrant of arrest.
- The Supreme Court ultimately ruled that the RTC acted within its authority and reinstated the orders of the RTC, allowing the criminal proceedings to continue.
Antecedents
- A minor, referred to as AAA, filed a sworn statement accusing Adolfo A. Goyala, Jr. of statutory rape with the assistance of her mother on June 17, 2013.
- The complaint was endorsed to the Office of the City Prosecutor of Pasig City, which initiated a preliminary investigation.
- Goyala submitted a Counter-Affidavit on July 30, 2013, and subsequently filed a civil complaint for damages against AAA and her mother.
- He sought to suspend the criminal proceedings based on a "prejudicial question" due to the civil case but was denied by the prosecutor.
Proceedings in the RTC
- On November 12, 2013, the Assistant City Prosecutor (ACP) found probable cause for statutory rape and recommended filing an Information against Goyala.
- The RTC received the Information on November 27, 2013, and Goyala filed motions to suspend the proceedings and to hold the issuance of the warrant of arrest in abeyance.
- The RTC denied these motions, asserting that it had the discretion to