Simplicio Cruz v. People of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Simplicio Cruz was charged with corruption of minors under Article 340 of the Revised Penal Code, as amended by Batas Pambansa Bilang 92. The information alleged that the accused promoted or facilitated the prostitution or corruption of Toinette Marie Ronquillo, a minor 15 years of age, to satisfy the lust of another. Procedural History: During the trial, the prosecution presented three police officers and documentary evidence, including affidavits of the complainant, photographs of nude models, and police reports. However, the complainant, Toinette Marie Ronquillo, never appeared in court nor testified despite notices, compelling the prosecution to rest its case. The defense filed a demurrer to evidence, which the respondent Judge Ernesto S. Tengco denied, leading the defense to file a petition for certiorari with the Supreme Court, arguing that the denial was not in accordance with law and evidence. The Petition: The petition sought to set aside the order of the respondent Judge denying his demurrer to evidence, claiming grave abuse of discretion.
Issue(s)
Whether the denial of the demurrer to evidence in a criminal case can be assailed via a special civil action for certiorari. Whether the respondent Judge committed grave abuse of discretion in denying the petitioner's demurrer to evidence.
Ruling
The petition for certiorari is dismissed. The challenged order of the respondent Judge denying the demurrer to evidence is sustained, and the criminal case is remanded to the trial court for further proceedings. The petitioner is given the option to present his evidence or to submit the case for decision based solely on the prosecution's evidence.
Ratio Decidendi
On the propriety of certiorari to assail denial of demurrer to evidence: The Supreme Court reiterated the long-settled rule that certiorari does not lie to challenge an interlocutory order denying an accused's motion to dismiss or demurrer to evidence in a criminal case. The Court emphasized that the question of whether the prosecution's evidence is sufficient to establish guilt beyond reasonable doubt rests within the sound judgment of the trial court. Any error committed by the denial of a demurrer to evidence can only be corrected by appeal after judgment is rendered. The Court cited Joseph vs. Villaluz and People vs. Romero to support this principle. The orderly procedure requires the accused to present evidence, and if convicted, to appeal the judgment. The denial of a demurrer to evidence is an interlocutory order from which no appeal lies, and it cannot be corrected by certiorari unless there is a grave abuse of discretion amounting to lack of jurisdiction. On whether the respondent Judge committed grave abuse of discretion: The Court found that the respondent Judge did not commit grave abuse of discretion in denying the petitioner's demurrer to evidence. The Court noted that under the 1964 Rules of Court, while there was no specific rule for criminal cases, courts had applied the rule in civil procedure where a defendant may move for dismissal on the ground of insufficiency of evidence. If denied, the defendant may offer evidence. The Court also pointed out that under the 1985 Rules on Criminal Procedure, a demurrer to evidence waives the right to present evidence, but this rule was not applicable to the case at bar as the challenged order was issued prior to its effectivity. The Court concluded that the denial order was supported by jurisprudence and that the petitioner failed to show entitlement to the relief prayed for.
Main Doctrine
A special civil action for certiorari under Rule 65 of the Rules of Court is not the proper remedy to assail an interlocutory order denying a demurrer to evidence in a criminal case; the proper recourse is to proceed with the trial and, if convicted, to appeal the judgment.