Domdom v. Sandiganbayan
REITERATIONFacts
The Antecedents: Hilconeda P. Abril, State Auditor V of the Commission on Audit (COA) assigned at the Philippine Crop Insurance Corporation (PCIC), requested the Office of the Ombudsman to investigate transactions supporting Jaime S. Domdom's claims for miscellaneous and extraordinary expenses as a PCIC Director, alleging tampered receipts. Procedural History: The Office of the Ombudsman found probable cause to charge petitioner with nine counts of estafa through falsification of documents and directed the filing of Informations with the Sandiganbayan. The cases were raffled to different divisions of the Sandiganbayan. Petitioner moved for consolidation of these cases with the one bearing the lowest docket number (SB-07-CRM-0052) before the Third Division. The Third Division denied the consolidation, citing differences in evidence. The Fourth Division also denied a similar motion. Petitioner sought relief from the Supreme Court via a Petition for Certiorari. The Petition: Petitioner sought to enjoin the different divisions of the Sandiganbayan from proceeding with the cases against him, arguing that all cases arose from substantially identical series of transactions involving alleged overstatements of miscellaneous and extraordinary expenses.
Issue(s)
Whether the petition for certiorari is the proper remedy despite the absence of a prior motion for reconsideration. Whether a motion for extension to file a petition for certiorari is still allowed under the amended rules. Whether the cases against petitioner should be consolidated.
Ruling
The petition is GRANTED. The Third Division of the Sandiganbayan is DIRECTED to allow the consolidation of the cases against petitioner for estafa through falsification of documents with SB-07-CRM-0052, which has the lowest docket number pending with it. All other Divisions of the Sandiganbayan are accordingly ORDERED to forward the subject cases to the Third Division.
Ratio Decidendi
On the procedural issue of the necessity of a motion for reconsideration: The Court reiterated the general rule that a motion for reconsideration is a condition sine qua non for filing a petition for certiorari. However, it acknowledged well-defined exceptions. In this case, the Court found that the issue of consolidation was duly raised and passed upon by the Sandiganbayan Third Division, that further delay would prejudice the petitioner, and that the issue was purely one of law. Therefore, the Court found ample justification for relaxing the rule requiring a prior motion for reconsideration. On the allowance of a motion for extension to file a petition for certiorari: The Court clarified that the deletion of the provision explicitly allowing extensions for compelling reasons in Section 4 of Rule 65 by A.M. No. 07-7-12-SC does not absolutely prohibit motions for extension. The amended rule still allows for motions for extension, subject to the Court's sound discretion, absent an express prohibition. The petition was allowed as it was filed within the extension sought and had merit. On the consolidation of cases: The Court held that consolidation is proper when several actions pending before it arise from the same act, event, or transaction, involve the same or like issues, and depend largely or substantially on the same evidence, provided the court has jurisdiction and a joint trial will not give undue advantage or prejudice any party. The rule on consolidation is designed to avoid multiplicity of suits, prevent oppression or abuse, clear congested dockets, and simplify the work of the trial court. In this case, despite minor differences in transaction dates, entities, and amounts, the charge and core element of estafa through falsification of documents based on alleged overstatements of claims were the same, and the main witness was also the same. Therefore, consolidation would simplify proceedings, save time and resources, and prevent the possibility of conflicting decisions.
Main Doctrine
Consolidation of cases is proper when they arise from the same act, event, or transaction, involve the same or like issues, and depend largely or substantially on the same evidence, to avoid multiplicity of suits, prevent oppression or abuse, clear congested dockets, and simplify the work of the trial court, thereby attaining justice with the least expense and vexation to the parties-litigants.