Rara v. Chan
REITERATIONFacts
The Antecedents: This case originated from an affidavit-complaint for estafa filed by Brenda Chan against petitioner spouses Rhoda Regina Reyes-Rara and Jose Emmanuel Rara. The petitioners allegedly failed to appear for scheduled hearings before the investigating prosecutor and to submit a counter-affidavit within the agreed timelines. Despite these omissions, they later sought to file a counter-affidavit and moved for a reconsideration of the prosecutor's finding of probable cause. Procedural History: Following the prosecutor's resolution finding probable cause and the subsequent filing of an Information for estafa, the petitioners moved to defer their arraignment before the Regional Trial Court (RTC) of Quezon City, Branch 126, citing the pendency of their motion for reconsideration with the Prosecutor's Office. The RTC initially deferred the arraignment but later denied the motion to suspend, issuing warrants of arrest. The petitioners then filed a petition for prohibition with the Court of Appeals (CA) to suspend the proceedings, and separately appealed the prosecutor's resolution to the Department of Justice (DOJ). The DOJ dismissed the appeal, and the CA eventually denied the petition for prohibition, holding that the RTC did not abuse its discretion in refusing to suspend proceedings or defer arraignment. The Petition: The petitioners seek review of the CA's decision, arguing that the respondent Judge committed grave abuse of discretion in denying their motions to defer arraignment and suspend proceedings. They specifically challenge the orders issued on July 27, 1999, August 10, 1999, and January 26, 2000. The core of their argument revolves around the alleged denial of due process and the pendency of their appeals with the Prosecutor's Office and the DOJ, as well as their petition before the CA. They contend that the trial court should have awaited the resolutions of these matters before proceeding with the arraignment and trial.
Issue(s)
Whether the respondent Judge gravely abused his discretion in denying petitioners’ motion to defer the arraignment and to suspend the proceedings. Whether the respondent Judge gravely abused his discretion in issuing the July 27, 1999 and August 10, 1999 Orders denying the motion to defer arraignment. Whether the respondent Judge gravely abused his discretion in issuing the January 26, 2000 Order setting the case for trial on the merits.
Ruling
The petition is DENIED and the April 18, 2000 Decision of the Court of Appeals in CA-G.R. SP No. 54111 is AFFIRMED.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the motion to defer arraignment and suspend proceedings: The Court found no grave abuse of discretion on the part of the respondent Judge. The petitioners' July 19, 1999 motion to defer arraignment was based on the pendency of their motion for reconsideration with the Prosecutor's Office. The trial court denied this motion on July 27, 1999, after the Prosecutor's Office had already resolved the motion for reconsideration on July 2, 1999. Therefore, the trial court's action was not arbitrary, as it had deferred the arraignment until the prosecutor's resolution. The subsequent denial of the August 10, 1999 oral motion to suspend arraignment was also justified because, at that time, the Court of Appeals had not issued a TRO to enjoin the arraignment, despite the pendency of the petition before it. The judge cannot be faulted for proceeding when the appellate court chose not to issue an injunctive writ. Furthermore, the provision mandating suspension of arraignment for a petition with the DOJ was not yet in effect in 1999; suspension was discretionary. The Court distinguished the present case from Roberts, Jr. v. Court of Appeals and Dimatulac v. Villon, where there were directives from the DOJ or significant procedural irregularities, respectively, which are absent here. The petitioners were not denied due process, as they had opportunities to file their counter-affidavits but failed to do so on time due to their own fault. Their arguments were also passed upon by the Court of Appeals in a separate petition, which was dismissed and became final. On the issue of grave abuse of discretion in issuing the July 27, 1999 and August 10, 1999 Orders denying the motion to defer arraignment: The Court reiterated that no grave abuse of discretion was committed. The July 27, 1999 order denying the motion to defer arraignment was issued after the prosecutor's resolution of the motion for reconsideration, indicating a procedural sequence rather than arbitrary action. The August 10, 1999 order denying the oral motion to suspend arraignment was proper because the Court of Appeals had not issued a TRO. The pendency of an appeal with the DOJ, without a directive to suspend, did not compel the trial court to halt proceedings, especially since the applicable rule at the time made such suspension discretionary. The Court noted that the petitioners failed to submit a copy of their appeal to the DOJ to the trial court, making their oral motion a bare allegation insufficient to warrant suspension. On the issue of grave abuse of discretion in issuing the January 26, 2000 Order setting the case for trial on the merits: The Court found no grave abuse of discretion in this order. By January 26, 2000, the TRO issued by the Court of Appeals had already lapsed, and the DOJ had dismissed the petitioners' appeal on January 3, 2000. Consequently, there were no longer any legal impediments preventing the trial court from proceeding with the trial on the merits. The trial court's order was a logical step to resume proceedings after the removal of the previous obstacles, and it acted within its authority to manage its docket and schedule trials.
Main Doctrine
A trial court judge does not commit grave abuse of discretion in denying a motion to defer arraignment or suspend proceedings when there is no directive from the Department of Justice to suspend, no pending TRO from a higher court enjoining the proceedings, and when the accused has been afforded ample opportunity to present their defense.