People v. Galzote
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a criminal information for robbery in an uninhabited place filed against Joel Galzote y Soriaga. The information alleged that on or about July 22, 1996, in Manila, the petitioner, along with a co-accused, unlawfully entered the Administration Office of Prince Town Inn Corporation by destroying a ceiling, and stole cash amounting to ₱109,000.00. The petitioner challenged the validity of this information. 2. Procedural History: The petitioner's motion to quash the information was denied by the Metropolitan Trial Court (MeTC). He then filed a petition for certiorari with the Regional Trial Court (RTC), arguing grave abuse of discretion by the MeTC. The RTC dismissed this petition, also denying the petitioner's motion for reconsideration. Subsequently, the petitioner filed another petition for certiorari with the Court of Appeals (CA), which dismissed his petition, citing failure to appeal within the reglementary period and failure to implead the People of the Philippines. The CA also denied the petitioner's motion for reconsideration. 3. The Petition: The petitioner seeks review of the CA's twin resolutions via a petition for review on certiorari under Rule 45 of the Rules of Court. He contends that his resort to a petition for certiorari before the CA was proper, asserting that both the MeTC and RTC committed grave abuse of discretion in denying his motion to quash due to alleged flaws in the information's form and substance. Furthermore, he argues that his failure to implead the People of the Philippines was not fatal to his petition.
Issue(s)
Whether the denial of a motion to quash is a proper subject of a petition for certiorari. Whether the MeTC and RTC committed grave abuse of discretion in denying the petitioner's motion to quash. Whether the Information filed against the petitioner was sufficient in form and substance. Whether the petitioner's failure to implead the People of the Philippines was fatal to his petition for certiorari before the CA.
Ruling
The Supreme Court denied the petition for lack of merit and affirmed the resolutions of the Court of Appeals. Treble costs were imposed against the petitioner.
Ratio Decidendi
On the propriety of certiorari to question the denial of a motion to quash: The Court reiterated that the denial of a motion to quash is an interlocutory order and is not appealable. A petition for certiorari under Rule 65 is a special civil action that is only available in the absence of an appeal or any other plain, speedy, and adequate remedy. The plain and speedy remedy upon denial of an interlocutory order is to proceed to trial. Resort to certiorari is an exception, requiring compelling reasons such as grave abuse of discretion amounting to lack or excess of jurisdiction, and where appeal would not afford adequate and expeditious relief. The petitioner failed to establish such compelling reasons. On whether the MeTC and RTC committed grave abuse of discretion: The Court found no grave abuse of discretion on the part of the MeTC in denying the motion to quash. The ground raised by the petitioner (conviction of his co-conspirator for a lesser offense) is not among the exclusive grounds enumerated under Section 3, Rule 117 of the Revised Rules of Criminal Procedure that warrant the quashal of an information. Such a ground is extraneous to the validity of the information itself. The RTC, in affirming the MeTC's denial, was also not committing grave abuse of discretion. On the sufficiency of the Information: A facial examination of the Information showed it to be valid and regular on its face, conforming to Section 6, Rule 110 of the Revised Rules of Criminal Procedure. It stated the name of the accused, the designation of the offense (robbery), the acts constituting the offense with particularity, the name of the offended party, the approximate date, and the place of commission. The allegation of conspiracy as a manner of incurring criminal liability, rather than as a separate offense, was also deemed sufficient. On the failure to implead the People of the Philippines: The Court affirmed the CA's finding that the petition for certiorari before the CA was procedurally infirm due to the failure to implead the People of the Philippines as a party-respondent. Furthermore, even on the substantive aspect, the petition would fail as the petitioner did not show any justifiable reason for his chosen mode of review, and the RTC did not commit grave abuse of discretion. The Court emphasized that parties cannot delay litigation by filing petitions for certiorari based on scant allegations of grave abuse of discretion.
Main Doctrine
A denial of a motion to quash is an interlocutory order and is generally not appealable. A petition for certiorari is not the proper remedy to question such denial unless there is grave abuse of discretion amounting to lack or excess of jurisdiction, and the remedy of appeal would not afford adequate and expeditious relief. Resort to certiorari must be firmly grounded on compelling reasons, and cannot be used to delay litigation.