Gatdula v. People
REITERATIONFacts
The Antecedents: The petitioner, Eduardo E. Gatdula, was charged with violation of Presidential Decree No. 1612, the Anti-Fencing Law. The information alleged that between January 9, 1994, and March 10, 1994, in Pasay City, Gatdula unlawfully bought a motor vehicle, an Isuzu Gemini Sonic Taxi valued at P140,000.00, knowing it to be derived from the proceeds of carnapping, with the intent to gain. Procedural History: After the prosecution rested its case and offered its exhibits on September 29, 1995, the petitioner objected to the admissibility of these exhibits, citing lack of counsel during their seizure and unlawful arrest, and hearsay. On October 11, 1995, the trial court admitted the prosecution's exhibits and allowed the petitioner to file a demurrer to evidence. The petitioner filed this demurrer on October 17, 1995. Subsequently, on October 19, 1995, the trial court issued orders admitting all prosecution evidence and deferring the resolution of the demurrer to evidence until after the petitioner presented his own evidence. Aggrieved, the petitioner filed a petition for certiorari with the Court of Appeals, challenging these orders. On February 17, 1999, the Court of Appeals denied the petition, affirming the trial court's orders. A motion for reconsideration was denied on September 8, 1999. The Petition: The petitioner seeks review via certiorari of the Court of Appeals' decision, arguing that the trial court's orders admitting the prosecution's evidence and holding the resolution on the demurrer to evidence in abeyance were issued with grave abuse of discretion amounting to excess or lack of jurisdiction. The petitioner contends that interlocutory rulings on the admissibility of evidence during trial should not be subject to separate appeal or certiorari, but rather assigned as errors in an appeal from the final decision. The Court finds the petition without merit, citing established principles that such rulings are interlocutory and that the sufficiency of evidence to establish guilt beyond reasonable doubt is within the trial court's discretion, not subject to certiorari unless there is grave abuse of discretion.
Issue(s)
Whether the trial court committed grave abuse of discretion amounting to excess or lack of jurisdiction in admitting the prosecution's evidence and holding in abeyance the resolution of the demurrer to evidence. Whether interlocutory orders admitting evidence and deferring resolution of a demurrer to evidence are subject to review by certiorari.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the decision of the Court of Appeals.
Ratio Decidendi
On the issue of whether the trial court committed grave abuse of discretion: The Supreme Court held that the petition is without merit. The established principle is that rulings of the trial court on procedural questions and on admissibility of evidence during the course of a trial are interlocutory in nature. Such rulings may not be the subject of a separate appeal or review on certiorari. Instead, they are to be assigned as errors and reviewed in the appeal properly taken from the decision rendered by the trial court on the merits of the case. If the rule were otherwise, there would be no end to the trial of cases, as any litigant dissatisfied with a ruling on evidence could indefinitely tie up the trial by elevating the ruling for appellate review. The Court reiterated that the question of whether the evidence presented by the prosecution is sufficient to convince the court of the defendant's guilt beyond reasonable doubt rests entirely within the sound discretion and judgment of the lower court. Furthermore, the Court cannot, in a special civil action for certiorari and prohibition, decide whether the evidence adduced by the prosecution has established beyond reasonable doubt the guilt of the accused, as held in Joseph v. Villaluz. The trial court has a specific duty under the Rules to act on the petitioner's demurrer to evidence, either by granting or denying the same. While the denial of a demurrer may be the proper subject of a petition for certiorari if there was grave abuse of discretion, the trial court's deferral of resolution until the petitioner has adduced evidence, while perhaps indicating an intent to deny the demurrer, does not constitute a jurisdictional error that warrants certiorari. Certiorari is not available to correct errors in judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction. On the issue of whether interlocutory orders admitting evidence and deferring resolution of a demurrer to evidence are subject to review by certiorari: As stated above, rulings of the trial court on procedural questions and on admissibility of evidence during the course of a trial are interlocutory in nature and may not be the subject of a separate appeal or review on certiorari.
Main Doctrine
Interlocutory rulings of the trial court on procedural questions and admissibility of evidence during trial are not subject to separate appeal or review by certiorari; they must be assigned as errors in the appeal from the final decision on the merits.