Catuira v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioner, Teodora Catuira, was charged with ten (10) counts of violating the Bouncing Checks Law (B.P. Blg. 22). The alleged offenses occurred on September 30, 1982. The core of the dispute revolves around the validity of amended informations filed by the prosecution and whether the criminal actions had prescribed before the informations were filed. 2. Procedural History: The petitioner filed motions to quash the informations in the Regional Trial Court (RTC) of Calamba, Laguna, arguing that the informations did not charge an offense and that the criminal actions had prescribed. The RTC denied these motions, finding that the amended informations were timely filed before arraignment and that the crimes had not prescribed, as the prescriptive period for offenses punishable by reclusion temporal is fifteen (15) years. The petitioner then sought a review of the RTC's ruling via a petition for certiorari, mandamus, and prohibition, which was referred to the Court of Appeals (CA). The CA dismissed the petition for being insufficient in form and substance, stating that the errors raised were not jurisdictional and that the petitioner had a plain, speedy, and adequate remedy in the ordinary course of law. 3. The Petition: Alleging grave abuse of discretion by the Court of Appeals, the petitioner filed this special civil action of certiorari under Rule 65 of the Rules of Court. The petition argues that the CA erred in dismissing her case. The Supreme Court, however, found the petition to be without merit, noting that the CA's dismissal was proper due to the petitioner's failure to submit certified true copies of the assailed orders, a mandatory requirement under Rule 65. The Court also affirmed the RTC's rulings, finding that the amended informations were validly filed and that the crimes had not prescribed, although it clarified that the prescriptive period for the offenses, considering the penalty under PD 818, is twenty (20) years, not fifteen (15) years as initially held by the RTC.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari for insufficiency in form and substance. Whether the trial court committed grave abuse of discretion in denying the motion to quash the informations. Whether the amended informations were validly filed and admitted. Whether the crimes charged had prescribed.
Ruling
The petition is denied for lack of merit. The dismissal of the petition by the Court of Appeals was proper.
Ratio Decidendi
On the dismissal by the Court of Appeals for insufficiency in form and substance: The Supreme Court affirmed the Court of Appeals' dismissal, holding that the petitioner's failure to comply with the mandatory requirement of Section 1, Rule 65 of the Rules of Court to submit certified true copies of the assailed orders rendered her petition deficient in form and substance. This procedural defect alone was sufficient ground for dismissal. On whether the trial court committed grave abuse of discretion in denying the motion to quash: The Court found no grave abuse of discretion. The admission of amended informations before arraignment is sanctioned by Section 14, Rule 110 of the New Rules of Criminal Procedure, and the trial court correctly ruled that the first ground of the motion to quash had become moot and academic. The jurisdiction of the Regional Trial Court over the criminal cases was indubitable, and its order admitting the amended informations was a valid exercise of that jurisdiction, correctable by appeal, not by certiorari. On whether the amended informations were validly filed and admitted: The Court held that the fiscal's authority to file amended informations in the trial court before the accused was arraigned is sanctioned by the Rules of Court (Sec. 14, Rule 110). Therefore, the lower court did not abuse its discretion in admitting the amended informations, as the amendments were filed before the petitioner pleaded. On whether the crimes charged had prescribed: The Supreme Court agreed with the trial court that the crimes had not prescribed, but corrected the prescriptive period. Considering Presidential Decree No. 818, which increases the penalties for estafa committed by means of bouncing checks, the penalty imposable for amounts over P12,000 but not exceeding P22,000 is reclusion temporal. Under Article 90 of the Revised Penal Code, offenses punishable by reclusion temporal prescribe in twenty (20) years, not fifteen (15) years as erroneously held by the trial court. Even if the shorter prescriptive period of twelve (12) years under Act No. 3763 were applicable, it had not yet expired when the informations were filed.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to assail an order admitting amended informations or an order denying a motion to quash based on prescription, as these involve errors in the exercise of jurisdiction correctable by appeal, and the failure to submit certified true copies of assailed orders renders the petition deficient in form and substance.