People v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondents Efren S. Almuete, Johnny Ila, and Joel Lloren were charged with violating Presidential Decree No. 705, as amended, for allegedly conspiring to gather, collect, remove, possess, smuggle, and transport 357 pieces of sawn timber valued at P57,012.00 without the necessary permits. The offense occurred in Barangay Uddiawan, Municipality of Solano, Province of Nueva Vizcaya, on August 15, 1993. Procedural History: The Regional Trial Court of Bayombong, Nueva Vizcaya, Branch 27, found the respondents guilty and sentenced them to 18 years, 2 months, and 21 days of reclusion temporal as minimum to 40 years of reclusion perpetua as maximum. The trial court proceeded with the promulgation of the decision despite the absence of the respondents, who claimed illness or lack of notification, and denied their subsequent motion for reconsideration. The respondents then filed a petition for certiorari with the Court of Appeals. The Petition: The People of the Philippines filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision that granted the private respondents' petition for certiorari. The Court of Appeals had acquitted respondent Almuete and ordered a re-promulgation of the trial court's decision for respondents Ila and Lloren. The People contend that the Court of Appeals acted beyond its jurisdiction in acquitting Almuete and erred in ordering the re-promulgation, arguing that the lower court's promulgation was justified and that the respondents should have appealed the merits of the case instead of filing a certiorari petition.
Issue(s)
Whether the Court of Appeals acted in excess of its jurisdiction or without jurisdiction when it acquitted private respondent Almuete in a petition for certiorari for the nullification of the trial court’s decision. Whether the RTC acted with grave abuse of its jurisdiction amounting to excess or lack of jurisdiction when it promulgated its decision, even in the absence of the private respondents.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision and resolution of the Court of Appeals, and reinstated the Decision of the Regional Trial Court dated September 8, 1998, and its Order dated October 12, 1998. The Court held that the CA acted with grave abuse of discretion in acquitting Almuete via certiorari and that the RTC did not abuse its discretion in proceeding with the promulgation.
Ratio Decidendi
On the issue of whether the CA acted in excess of its jurisdiction by acquitting Almuete in a certiorari petition: The Court held that the CA acted with grave abuse of discretion. A petition for certiorari under Rule 65 is limited to correcting errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction, not errors of judgment. The CA reviewed the RTC's assessment of evidence and findings of fact, which are matters that should be raised in an appeal by writ of error, not in a special civil action for certiorari. The Court emphasized that certiorari will not be issued to cure errors in the appreciation of evidence or conclusions of law, as these are errors of judgment correctible only by appeal. The CA's decision acquitting Almuete was deemed a nullity because it ventured beyond its authorized scope. On the issue of whether the RTC acted with grave abuse of jurisdiction in promulgating the decision in the absence of the respondents: The Court agreed with the RTC's reasoning that the absences of the respondents were not justified. The medical certificates presented were unverified and, in Almuete's case, indicated a condition that did not necessitate absence from promulgation. The RTC found the medical certificates to be a ploy to delay the proceedings, especially considering the respondents' subsequent evasion of arrest. The Court reiterated that under Section 6, Rule 120 of the Rules of Court, promulgation may proceed if the accused fails to appear without justifiable cause. The RTC's assessment of the medical certificates and the circumstances surrounding the respondents' absences demonstrated a valid exercise of discretion, not grave abuse thereof.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is limited to resolving errors of jurisdiction and grave abuse of discretion, and cannot be used to correct errors of judgment, which are proper subjects of an appeal. The appellate court acted with grave abuse of discretion when it acquitted a respondent on a petition for certiorari, as this involved a review of the trial court's assessment of evidence and findings of fact, which are errors of judgment.