People v. Goyala
REITERATIONFacts
The Antecedents: AAA, a minor, filed a sworn statement accusing Adolfo A. Goyala, Jr. (respondent) of statutory rape. The complaint was docketed for preliminary investigation. Respondent filed a Counter-Affidavit and later a civil complaint for damages against AAA and her mother. Respondent then filed a Petition for Suspension on the Ground of Prejudicial Question before the Investigating Prosecutor, which was denied. The Investigating Prosecutor found probable cause and recommended the filing of an Information for Statutory Rape. An Information was filed in the Regional Trial Court (RTC), Pasig City. Respondent filed motions for reconsideration and to suspend proceedings before the RTC. The City Prosecutor inhibited himself and forwarded the records to the Department of Justice (DOJ). The Secretary of Justice designated an Acting Prosecutor to resolve the preliminary investigation. Procedural History: The RTC denied respondent's Motion to Suspend Proceedings and to Hold in Abeyance Issuance of Warrant of Arrest, reasoning that once an Information is filed, the disposition of the case rests with the court's discretion. The RTC found probable cause and issued a Warrant of Arrest. Respondent filed an Omnibus Motion, which was also denied by the RTC. Aggrieved, respondent filed a petition for certiorari with the Court of Appeals (CA). The CA reversed the RTC's orders, declared them void, and ordered the RTC to hold proceedings in abeyance and remand the case to the prosecution for completion of the preliminary investigation, revoking the warrant of arrest. The CA reasoned that respondent was deprived of his right to a full preliminary investigation, citing Office of the Ombudsman v. Castro and Torralba v. Sandiganbayan. The People of the Philippines (petitioner) filed a Motion for Reconsideration, arguing the issues were moot as the motion for reconsideration before the prosecutor was resolved against respondent, but the CA denied it, noting respondent's pending Petition for Review with the DOJ. The Petition: Petitioner contends that the RTC acted within its authority in denying the motion to suspend proceedings. Petitioner argues the CA mistakenly relied on Castro and Torralba, as the facts were incongruous, and that respondent was afforded due process. Petitioner also claims the RTC did not commit grave abuse of discretion. Respondent, in his Comment, argues the preliminary investigation remains incomplete due to his pending Petition for Review with the DOJ and rejects petitioner's reliance on Castro, Torralba, and Odilao.
Issue(s)
Whether the proceedings in Criminal Case No. 152682 should continue to be held in abeyance despite the lapse of the sixty (60)-day period provided for under Section 11(c), Rule 116 of the 2000 Revised Rules on Criminal Procedure. Whether the RTC committed grave abuse of discretion in denying respondent's Motion to Suspend Proceedings and to Hold in Abeyance Issuance of Warrant of Arrest.
Ruling
The Supreme Court GRANTS the petition, REVERSES and SETS ASIDE the Decision and Resolution of the Court of Appeals, REINSTATES the February 13, 2014 and March 26, 2014 Orders of the RTC, and ORDERS the RTC to continue with the proceedings in Criminal Case No. 152682 with dispatch.
Ratio Decidendi
On the issue of holding proceedings in abeyance despite the lapse of the 60-day period: The Court held that the 60-day period provided under Section 11(c), Rule 116 of the 2000 Revised Rules on Criminal Procedure is not merely directory. This period is intended to limit the deferment of arraignment when a petition for review of the preliminary investigation is pending. Upon the expiration of this 60-day period, the trial court is bound to arraign the accused or deny the motion to defer arraignment, regardless of whether the petition before the reviewing authority has been resolved. The Court cited Aguinaldo v. Ventus and Samson v. Judge Daway to emphasize that procedural rules on reglementary periods are strictly applied to prevent needless delays. The Speedy Trial Act, cited by respondent, does not apply to extend this specific period, as it pertains to time limits from arraignment to promulgation. The Court found that the suspension had been unconscionably long, and respondent failed to provide justifiable reasons to further suspend the proceedings. The Court reiterated the principle in Crespo v. Judge Mogul that once an Information is filed, the court acquires exclusive jurisdiction, and while the rules allow a suspension to give the Secretary of Justice an opportunity to review, this suspension is limited to 60 days. Therefore, the RTC has no discretion but to proceed with the arraignment after the period has expired. On the issue of whether the RTC committed grave abuse of discretion: The Court found that the RTC acted within its authority in denying the respondent's motion to suspend proceedings. The RTC correctly reasoned that once an Information is filed, the disposition of the case rests within the sound discretion of the court, which is mandated to independently evaluate the merits of the case. The RTC's determination of probable cause was based on its own scrutiny of the prosecutor's resolution and the supporting evidence. The CA's reversal was based on an erroneous application of Castro and Torralba, which were factually different from the present case. The respondent was afforded legal processes and avenues to contest the findings, including filing a motion for reconsideration. The RTC's denial of the motion to suspend was not a grave abuse of discretion, as a finding of probable cause was evident from the magistrate's own determination.
Main Doctrine
The 60-day period provided under Section 11(c), Rule 116 of the 2000 Revised Rules on Criminal Procedure for the suspension of arraignment due to a pending petition for review of the preliminary investigation is not merely directory and, upon its lapse, the trial court is bound to proceed with the arraignment, irrespective of the resolution of the petition by the reviewing authority.