Enrile v. Manalastas
REITERATIONFacts
The Antecedents: This case arose from a mauling incident that occurred on January 18, 2003, outside the petitioners' residence. The complainants, Josefina Guinto Morano, Rommel Morano, and Perla Beltran Morano, alleged that the petitioners, Godofredo Enrile and Dr. Frederick Enrile, along with another individual, attacked and injured them. The complainants filed criminal charges for frustrated homicide and less serious physical injuries against the petitioners. Procedural History: The Municipal Trial Court (MTC) of Meycauayan, Bulacan, found probable cause to charge the petitioners with less serious physical injuries and scheduled their arraignment. The petitioners moved for reconsideration, arguing that the charges were dismissible due to insufficient proof of medical attention duration and that the cases should not be governed by summary procedure. The MTC denied this motion and subsequently denied their motion to quash the informations, stating that the issues raised were matters of defense to be ventilated during trial. The petitioners then filed a special civil action for certiorari with the Regional Trial Court (RTC), which dismissed their petition, finding that the MTC's denial was not an abuse of discretion and that the issues were premature for resolution. The petitioners' motion for reconsideration with the RTC was also denied. Subsequently, they filed a petition for certiorari and prohibition with the Court of Appeals (CA), seeking to nullify the RTC's orders. The CA dismissed this petition, deeming certiorari an improper remedy and advising an appeal. The CA also denied their motion for reconsideration. The Petition: The petitioners are seeking review of the Court of Appeals' decision through a petition for certiorari. They contend that the Court of Appeals erred in upholding the trial courts' denial of their motion to quash the complaints. Specifically, they argue that the complaints, on their face, lacked essential elements for the crime of less serious physical injuries, as the alleged injuries did not demonstrably meet the required duration for incapacitation or medical attendance. Furthermore, they question whether the injuries sustained by the private complainants were actually perpetrated by the petitioners.
Issue(s)
Whether the Court of Appeals erred in upholding the trial courts' ruling denying the petitioners' motion to quash the complaints for less serious physical injuries, and whether certiorari was the proper remedy. Whether the Court of Appeals erred in not ruling that the injuries sustained by the private complainants were not perpetrated by the petitioners, and whether the complaints sufficiently averred the elements of less serious physical injuries.
Ruling
The Supreme Court denied the petition for review on certiorari, affirmed the resolutions of the Court of Appeals, and ordered the petitioners to pay the costs of suit.
Ratio Decidendi
On the denial of the motion to quash and the propriety of the remedy: The Court held that the denial of a motion to quash is an interlocutory order and is not appealable. The proper remedy for the petitioners was to enter their plea, go to trial, and if the decision was adverse, to assign the denial of the motion to quash as an error on appeal. The Court emphasized that certiorari is not a substitute for appeal when the latter is available. The RTC correctly dismissed the petition for certiorari because the issues raised in the motion to quash were matters of defense that could only be threshed out in a full trial on the merits. It would be premature to dismiss the criminal cases when the basis thereof could only be determined after trial. The CA correctly ruled that the petitioners should have filed an appeal by notice of appeal within the reglementary period. On the sufficiency of the complaints for less serious physical injuries: The Court reiterated that a motion to quash is used to challenge a complaint or information for insufficiency on its face. The elements of less serious physical injuries under Article 265 of the Revised Penal Code are: (1) the offender inflicted physical injuries upon another; and (2) the injuries either incapacitated the victim for labor for 10 days or more, or required medical assistance for more than 10 days. The complaints sufficiently averred these elements by stating that the accused "wilfully, unlawfully and feloniously attack, assault" and inflicted injuries that "will require a period of 10 to 12 days barring healing and will incapacitate his customary labor for the same period of time" (for Josefina) and "will require Medical Attendance for a period of 12 to 15 days barring unforeseen complication" (for Perla). The Court clarified that the complaints only needed to aver ultimate facts, not evidentiary details, which are to be proven during trial. The medical certificates attached were sufficient to establish probable cause, and the actual duration of incapacity or medical attendance was a matter of proof during the trial on the merits, not at the preliminary investigation or during the pendency of a motion to quash. The petitioners' insistence that the medical certificates were speculative was a matter of defense to be presented during the trial.
Main Doctrine
The denial of a motion to quash is an interlocutory order and is not appealable; the proper remedy is to enter a plea, go to trial, and if the decision is adverse, to assign the denial as an error on appeal. A petition for certiorari is not the proper remedy when an appeal is available.