Del Rosario v. People
REITERATIONFacts
The Antecedents: Five employees of the National Irrigation Administration (NIA) filed a letter-complaint against petitioner, then NIA Administrator, for alleged violations of RA 6713 (Anti-Graft and Corrupt Practices Act), the Revised Penal Code, and other laws. The administrative aspect was dismissed, but the criminal aspect was initially dismissed and later revived upon a supplemental motion for reconsideration. Consequently, two informations were filed against petitioner: one for estafa through falsification of public document (Criminal Case No. 22715) and another for violation of RA 3019, Section 3(e) (Criminal Case No. 22716). Procedural History: Petitioner moved for the withdrawal of the informations, arguing the resolution reviving them was void. This motion was denied. The information in Criminal Case No. 22716 was withdrawn by the prosecution due to insufficiency of evidence. Petitioner's motion to quash the information in Criminal Case No. 22715 was denied by the Sandiganbayan. Petitioner filed a petition for certiorari (G.R. No. 131746) with the Supreme Court assailing the Sandiganbayan's denial of his motion to quash. However, this petition was dismissed for non-compliance with the Court's resolution requiring a reply to the respondents' comment. Petitioner's motion for reconsideration was also denied with finality. The Petition: The Sandiganbayan proceeded with the pre-trial conference in Criminal Case No. 22715. Petitioner assails the pre-trial order, arguing that the Sandiganbayan refused to allow him to mark certain documents for his defense and to raise the issue of the nullity and invalidity of the information. He questions whether the dismissal of his previous petition (G.R. No. 131746) constituted res judicata, barring him from presenting these documents and raising the issue of nullity.
Issue(s)
Whether the dismissal of G.R. No. 131746 for non-compliance with procedural rules constitutes res judicata as to the issues raised therein, thereby barring petitioner from marking documents and raising the issue of the nullity of the information in Criminal Case No. 22715. Whether a petition for review on certiorari under Rule 45 is the proper mode of appeal to assail a pre-trial order.
Ruling
The petition is denied. The dismissal of G.R. No. 131746 for non-compliance with procedural rules constitutes res judicata. A petition for review on certiorari under Rule 45 is not the proper mode to assail an interlocutory order like a pre-trial order.
Ratio Decidendi
On the applicability of res judicata: The Court disagreed with the petitioner's contention that the dismissal of his previous petition in G.R. No. 131746 for failure to file a reply did not constitute a judgment on the merits. The Court reiterated its ruling in Bernarte v. Court of Appeals, stating that minute resolutions of the Supreme Court denying due course to petitions or dismissing cases summarily for non-compliance with formal or substantial requirements are considered dispositions on the merits. Therefore, the dismissal of G.R. No. 131746, even if for procedural non-compliance, effectively affirmed the ruling being questioned and constituted res judicata, barring the relitigation of the issues raised therein. The Court emphasized that litigation must end, and final judgments must be laid to rest to ensure the effective administration of justice, even if there is an alleged erroneous application of a legal principle. On the propriety of the mode of appeal: The Court held that a petition for review on certiorari under Rule 45 is an inappropriate remedy to assail an interlocutory order. An interlocutory order is one that does not finally determine a cause of action but only decides an intervening matter requiring further steps for adjudication on the merits. In contrast, a petition for review on certiorari under Rule 45 is proper only for final judgments or orders that completely dispose of a case. The pre-trial order in question was an interlocutory order, making the chosen mode of appeal incorrect.
Main Doctrine
A petition for review on certiorari under Rule 45 is inappropriate to assail an interlocutory order, such as a pre-trial order. Furthermore, a dismissal of a petition by the Supreme Court, even if for non-compliance with procedural rules, constitutes a disposition on the merits and bars relitigation of the same issues under the doctrine of res judicata.