De los Reyes v. People
REITERATIONFacts
The Antecedents: The underlying dispute involves a criminal complaint filed by the Philippine Coconut Authority against Desiderio De los Reyes and Myrna Villanueva, along with others, for alleged violation of Republic Act No. 8048, the Coconut Preservation Act of 1995. The complaint accused the respondents of willfully, unlawfully, and feloniously cutting down and processing approximately 440 coconut trees without the requisite permit from the Philippine Coconut Authority. Procedural History: The case originated in the Municipal Trial Court (MTC) of Calauan, Laguna, where the complaint was filed. The MTC ordered the accused to file counter-affidavits, but the petitioners instead filed a Motion for Preliminary Investigation, which was denied. Subsequently, they filed a Motion To Quash the complaint, arguing it did not constitute an offense. The MTC denied this motion as well. Petitioners then elevated the matter to the Regional Trial Court (RTC) via a petition for certiorari, prohibition, and mandamus, alleging grave abuse of discretion by the MTC. The RTC dismissed their petition, finding the MTC's denial proper. Petitioners appealed to the Court of Appeals, which affirmed the RTC's decision and advised them to file a petition for review on certiorari with the Supreme Court. Their subsequent motion for reconsideration was denied. The Petition: The petitioners filed the instant petition for certiorari with the Supreme Court, assailing the RTC's Orders that dismissed their petition for certiorari. They argued that the MTC committed grave abuse of discretion. However, the Supreme Court noted that certiorari is not a substitute for a lost appeal and that the petitioners should have filed a petition for review on certiorari under Rule 45. Furthermore, the Court pointed out that the petition should have been filed with the Court of Appeals, not directly with the Supreme Court, violating the hierarchy of courts. The Court also found that the petition was filed beyond the prescribed period. Even on the merits, the Court stated that when a motion to quash is denied, the proper recourse is to proceed to trial, not to file a certiorari petition.
Issue(s)
Whether the MTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioners' Motion to Quash. Whether a petition for certiorari under Rule 65 is the proper remedy after the denial of a motion to quash in a criminal case; and whether the petition was timely filed. Whether petitioners observed the principle of hierarchy of courts in filing their petition for certiorari.
Ruling
The Supreme Court dismissed the petition for certiorari. Costs against petitioners.
Ratio Decidendi
On the issue of grave abuse of discretion: The Court did not explicitly address whether the MTC committed grave abuse of discretion. However, by ruling that certiorari was not the proper remedy and that the petition was filed out of time, the Court implicitly found that it was unnecessary to delve into the merits of the MTC's decision. The proper recourse was to proceed to trial and appeal any adverse decision, rather than filing an improper and untimely petition for certiorari. On the propriety and timeliness of the remedy: The Court reiterated that when a motion to quash in a criminal case is denied, the remedy is not certiorari, but for the petitioners to proceed to trial, with any adverse decision appealable thereafter. Filing a petition for certiorari is improper as it is not a substitute for a lost appeal. The petitioners had the option to appeal the MTC's denial or proceed to trial and appeal any adverse judgment. By choosing certiorari, they circumvented established procedures. Furthermore, the petition was filed out of time, more than one year after the denial of their motion for reconsideration, rendering it procedurally infirm. On the observance of the hierarchy of courts: Even assuming the petition was in order, the Court found that petitioners failed to observe the principle of hierarchy of courts. They should have filed their petition with the Court of Appeals, which has original jurisdiction to issue writs of certiorari. Filing directly with the Supreme Court, bypassing the appellate court, is a violation of this fundamental procedural rule, absent exceptional circumstances, which were not present.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a lost appeal, and the principle of hierarchy of courts must be observed. Furthermore, when a motion to quash in a criminal case is denied, the proper remedy is to proceed to trial, not to file a petition for certiorari.