People v. Go
REITERATIONFacts
The Antecedents: The underlying dispute involves seven (7) Informations for Estafa through Falsification of Commercial Documents filed against Jose C. Go and Aida C. Dela Rosa, among other accused. These charges stemmed from a criminal complaint instituted by the Philippine Deposit Insurance Corporation (PDIC) and alleged that the respondents defrauded Orient Commercial Banking Corporation of P159,000,000.00. Procedural History: After arraignment and the commencement of trial, the proceedings were significantly delayed due to numerous postponements, primarily caused by the prosecution. Despite the lapse of nearly five years, the prosecution failed to conclude its presentation of evidence. This led to the respondents filing a Motion to Dismiss for failure to prosecute and violation of their right to speedy trial. The Regional Trial Court (RTC) initially granted this motion, dismissing the cases. However, the RTC later reconsidered and reinstated the criminal cases. The respondents then moved for reconsideration of the reinstatement, which was denied by the RTC. Subsequently, the respondents filed a petition for certiorari before the Court of Appeals (CA). The Petition: The People of the Philippines, through the Office of the Solicitor General (OSG), filed this petition for review on certiorari assailing the Decision and Resolution of the CA. The OSG argues that the CA gravely abused its discretion in granting the respondents' certiorari petition and dismissing the criminal cases without impleading the People of the Philippines as a party. The OSG contends that the People, represented by the OSG, is an indispensable party, and its absence in the CA proceedings violated its right to due process, rendering the CA's issuances void for want of jurisdiction.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in giving due course to the respondents' petition for certiorari without impleading the People of the Philippines, thereby violating the People's right to due process. Whether the Court of Appeals had the authority or jurisdiction to promulgate its issuances reversing the RTC Orders and dismissing the criminal cases without the People being impleaded as a party, rendering its decision void for want of jurisdiction.
Ruling
The petition is meritorious. The Court of Appeals committed grave abuse of discretion in resolving the respondents' petition for certiorari without impleading the People of the Philippines, represented by the OSG, as an indispensable party. Consequently, the CA's Decision and Resolution are set aside, and the case is remanded to the CA with directions to reinstate the petition and order the respondents to implead the People of the Philippines.
Ratio Decidendi
On the issue of impleading the People of the Philippines as an indispensable party and the Court of Appeals' grave abuse of discretion: The Court held that the petition for certiorari filed before the CA, which sought the dismissal of criminal cases, should not have been resolved without impleading the People of the Philippines, represented by the OSG. The People is an indispensable party in all criminal actions, as all criminal actions are prosecuted under the direction and control of the public prosecutor. The failure to implead the People meant that the OSG was not afforded an opportunity to comment on the petition, thereby violating the People's right to due process. On the issue of the Court of Appeals' authority and jurisdiction: The Court reiterated the principle that an indispensable party is one without whom no final determination can be had of the action, and their joinder is mandatory. The absence of an indispensable party renders all subsequent actions of the court null and void for want of authority to act, not only as to the absent parties but even as to those present. Therefore, the CA's decision and resolution, rendered without the People being impleaded, were void for want of jurisdiction. The Court emphasized that while the failure to implead an indispensable party is not per se a ground for dismissal, it is essential that such a party be impleaded before the court renders judgment, as the court's authority to act is contingent upon the presence of all indispensable parties. The Court cited Vda. de Manguerra v. Risos and Lotte Phil. Co., Inc. v. Dela Cruz to support its ruling on the mandatory nature of impleading indispensable parties and the consequence of their absence on the court's jurisdiction.
Main Doctrine
A petition for certiorari seeking the dismissal of criminal cases, filed by respondents, cannot be resolved by the Court of Appeals without impleading the People of the Philippines, represented by the Solicitor General, as an indispensable party, as the absence of such a party renders the court's judgment void for want of jurisdiction.