Case Summary (G.R. No. L-1034)
Factual Antecedents
In 2019, seven individuals, including the petitioners, filed a consolidated complaint for Estafa and Falsification against GITT with the Office of the City Prosecutor (OCP) of San Pablo City. The complainants claimed they had enrolled in courses offered by GITT which, upon investigation, was found to lack the necessary accreditation from the Technical Education and Skills Development Authority (TESDA).
Ruling of OCP-San Pablo City
On September 30, 2019, the OCP-San Pablo City found probable cause to indict the respondents for Estafa due to reliance on GITT's misrepresentation of holding the necessary government permits. The respondents were deemed to be liable as officers of GITT and the exact nature of the complaints led to a recommendation for filing charges based on Article 315 of the Revised Penal Code.
Ruling of ORP-Region IV
The private respondents subsequently appealed to the Office of the Regional Prosecutor (ORP) for Region IV, which on January 20, 2020, reversed the OCP's decision. The ORP determined that the evidence was insufficient to establish the respondents' guilt, positing that GITT had been operating in good faith and highlighting that the complainants did not provide adequate proof of payments towards their studies.
Ruling of the CA
The petitioners' move to elevate the case to the Court of Appeals was through Joint Petitions for Certiorari, which the CA dismissed outright in its resolution of November 20, 2020, due to multiple procedural deficiencies, including failure to pay docket fees and provide the necessary documentation as required by the Rules of Court. The CA upheld this ruling subsequently, reinforcing procedural diligence as crucial to jurisdictional matters.
Arguments of the Parties
The petitioners contended that the CA erred by not considering the merits of their case and argued in their appeals that the procedural deficiencies should not have led to an outright dismissal. They insisted that the CA overlooked grave abuse of discretion by ORP-Region IV. Conversely, the respondents maintained that the petitioners had not remedied their procedural errors and neglected to exhaust available administrative remedies prior to seeking judicial recourse.
Issues
Two principal issues emerged for judicial determination: (1) whether the CA erred in dismissing the Joint Petitions for Certiorari outright, and (2) whether the CA erred in dismissing on the grounds of failing to exhaust administrative remedies available within the DOJ-NPS appellate process.
Ruling of the Court
The Court upheld the CA's dismissal of the Joint Petitions for several compelling reasons, notably the failure of the petitioners to comply with jurisdictional requirements, such as the payment of docket fees and the absence of proper signatures and verifications, w
...continue readingCase Syllabus (G.R. No. L-1034)
Overview of the Case
- The case is a Petition for Review on Certiorari filed by petitioners Jhon Kenneth M. Porto, Chennie Ann Rose Elca, and Jomar Jonhedel B. Bruto, represented by Marife B. Bruto.
- The petitioners are contesting the Resolutions dated November 20, 2020, and June 14, 2021, from the Court of Appeals (CA) which dismissed their Joint Petitions for Certiorari.
- The dismissal was based on procedural grounds related to a prior Resolution from the Office of the Regional Prosecutor (ORP) for Region IV, which reversed indictments for Estafa against the petitioners.
Factual Antecedents
- In 2019, seven complainants, including the petitioners, lodged consolidated complaints for Estafa and Falsification against Grant Institute of Trade & Technology (GITT) and its Board of Directors.
- They alleged that they were misled into enrolling in a Cruise Ship Management Course that GITT was not authorized to offer, as confirmed by TESDA.
- The defense presented by GITT's management claimed that the complaints were unfounded and asserted their good faith in providing education.
Ruling of the Office of the City Prosecutor (OCP)
- On September 30, 2019, OCP-San Pablo City recommended the filing of seven Informations for Estafa against GITT's Board of Directors.
- The OCP found that the complainants relied on GITT's false pretenses regarding its authority and accreditation, leading to their enrollment in the unapproved course.
- The case for Falsification was dismissed as it was absorbed by the Estafa charge.
Ruling of the Office of the Regional Prosecutor (ORP)
- Following a Petition for Review by private respondents, the ORP reversed OCP's ruling on January 20