Bbb v. Cantilla
REITERATIONFacts
The Antecedents: Respondent Amy B. Cantilla was charged with Child Abuse under Republic Act No. 7610, as amended, for allegedly inflicting physical harm on AAA, the three-year-old daughter of petitioner BBB, between January and April 2006. The alleged acts included hitting AAA with slippers and her hand, depriving her of meals, and pinching her arms, which were claimed to be prejudicial to the child's normal growth and development. The prosecution alleged that AAA was left in the care of respondent and another househelper while petitioner BBB, a flight attendant, was abroad. Procedural History: The Regional Trial Court (RTC), Branch 162, Pasig City, dismissed the criminal case against respondent after granting her demurrer to evidence, finding insufficient evidence for conviction. Petitioner moved for reconsideration and for the judge's inhibition, but both were denied by the RTC. Aggrieved, petitioner filed a petition for certiorari with the Court of Appeals (CA). The CA dismissed the petition, citing it was filed out of time, lacked a valid verification and certification of non-forum shopping, and failed to implead the People of the Philippines as a respondent. The Petition: Petitioner BBB seeks review of the CA's dismissal of her certiorari petition via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. Petitioner argues that the CA erred in dismissing her petition, that the RTC committed grave abuse of discretion in granting the demurrer to evidence, and that the RTC judge exhibited bias. The Supreme Court, however, denied the petition, primarily finding that the CA correctly dismissed the certiorari petition for being filed beyond the 60-day reglementary period, emphasizing that such periods are strictly applied and that no compelling reason for an extension was shown. The Court also noted that even if considered on the merits, the RTC's dismissal of the case was not attended by grave abuse of discretion, as the prosecution failed to present sufficient evidence, particularly an eyewitness, to establish guilt beyond reasonable doubt.
Issue(s)
Whether the Court of Appeals committed grave and serious error in dismissing the petitioner's petition for certiorari. Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting the demurrer to evidence. Whether the Presiding Judge of the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in refusing to inhibit from handling the case.
Ruling
The petition is denied for lack of merit. The Court of Appeals correctly dismissed the petition for certiorari.
Ratio Decidendi
On the dismissal of the petition for certiorari by the Court of Appeals: The Court affirmed the CA's dismissal of the petition for certiorari. The CA correctly found that the petition was filed beyond the 60-day reglementary period prescribed by Section 4, Rule 65 of the Rules of Court. The amendment to this rule deleted the provision for extensions, making the 60-day period inextendible to prevent delays and ensure speedy disposition of cases. The petitioner failed to show any compelling reason for an extension, and the explanation provided regarding counsel's circumstances was found insufficient, especially since the firm had multiple attorneys. The CA also correctly noted the procedural infirmities regarding the verification, certification against forum shopping, and the failure to implead the People of the Philippines. On the RTC's grant of demurrer to evidence: Even if the petition for certiorari were considered properly filed, it would still be denied on the merits. A petition for certiorari under Rule 65 is limited to correcting errors of jurisdiction or grave abuse of discretion. The petitioner failed to demonstrate that the RTC acted with grave abuse of discretion when it granted the demurrer to evidence. The RTC correctly noted that the prosecution failed to present sufficient evidence for conviction. The supposed eyewitness, Espiritu, was not presented, and the testimony of the victim, AAA, who testified about events from when she was three years old at the age of twelve, was found to be insufficient to establish guilt beyond reasonable doubt. The prosecution bears the burden of proving guilt beyond reasonable doubt, and failure to do so necessitates acquittal. On the RTC judge's refusal to inhibit: This issue was rendered moot by the dismissal of the petition on procedural grounds and the lack of merit in the substantive arguments. However, the Court reiterated that a judge may be compelled to inhibit if there is a showing of bias or prejudice. In this case, the petitioner's claim of prejudice was not sufficiently substantiated to warrant a reversal of the CA's decision, which focused on the procedural lapses.
Main Doctrine
A petition for certiorari under Rule 65 must be filed within the 60-day reglementary period, which is inextendible, absent a compelling reason. Failure to comply with this strict period, or other procedural requirements such as proper verification and impleading the People of the Philippines, warrants dismissal. Furthermore, a grant of demurrer to evidence, if not successfully assailed via certiorari for grave abuse of discretion, results in acquittal and invokes the protection of double jeopardy.