Marilao Medical v. Royales
CLARIFICATIONFacts
1. The Antecedents: Marilao Medical and Diagnostic, Inc. (Marilao Medical) filed a criminal complaint for Falsification of Private Documents against Dr. Jovith Royales (Dr. Royales), owner of Best Care clinic. Marilao Medical alleged that Dr. Royales, whose clinic was not authorized to issue Reverse Transcription Polymerase Chain Reaction (RT-PCR) tests, falsely used Marilao Medical's name to process and issue COVID-19 test results. During trial, the prosecution presented witnesses, including Dr. Alma Radovan-Onia (Dr. Onia), who identified the documents as printouts given to her after the alleged falsification. However, the Metropolitan Trial Court (MeTC) noted that the actual signatories did not identify the documents, and employees of Best Care did not testify to any direct order from Dr. Royales to falsify records. 2. Procedural History: On May 26, 2022, the MeTC granted Dr. Royales' Demurrer to Evidence and acquitted him, ruling that the evidence failed to establish a connection between the alleged scheme and the accused. Marilao Medical's Motion for Reconsideration was denied. Marilao Medical then filed a Rule 65 Petition for Certiorari before the Regional Trial Court (RTC) of Valenzuela City, bearing the express conformity of the Office of the City Prosecutor (OCP). The RTC dismissed the petition, ruling that Marilao Medical lacked the authority and standing to bring a special civil action questioning the criminal aspect of the case, as such authority allegedly rested solely with the State through the public prosecutor or the Office of the Solicitor General (OSG). 3. The Petition: Marilao Medical filed a Rule 45 Petition for Review on Certiorari before the Supreme Court, raising the sole legal issue of whether its Rule 65 petition, bearing the OCP's conformity, should have been given due course by the RTC. Marilao Medical argued that the OSG itself advised that it does not participate in Rule 65 petitions filed at the RTC level and that the OCP's conformity was sufficient to represent the State's interest. It further contended that the MeTC committed grave abuse of discretion by ignoring the presumption of authorship against Dr. Royales as the owner of the clinic that profited from the falsified documents.
Issue(s)
Whether the RTC erred in dismissing the Rule 65 Petition for lack of standing despite the express conformity of the Office of the City Prosecutor (OCP). Whether the MeTC committed grave abuse of discretion in granting the Demurrer to Evidence and acquitting Dr. Royales.
Ruling
The Petition for Review on Certiorari is PARTIALLY GRANTED. The RTC Orders are SET ASIDE regarding the procedural dismissal, but the MeTC Resolutions acquitting Dr. Royales are AFFIRMED.
Ratio Decidendi
On Issue 1: The RTC erred in ruling that Marilao Medical lacked standing. While the general rule is that only the State, through the Office of the Solicitor General (OSG), may question the criminal aspect of a case, there is a clear delineation of functions between the OSG and the Office of the City Prosecutor (OCP). As established in Isturis-Rebuelta v. Rebuelta and Fenequito v. Vergara, Jr., the public prosecutor (OCP) represents the State when a case is pending in the RTC, whereas the OSG acts as counsel before the Court of Appeals (CA) and the Supreme Court (SC). The Court clarified that the express conformity of the OCP, indicated on the signature page of the Rule 65 petition, satisfies the requirement that criminal actions be prosecuted under the direction and control of the public prosecutor. Therefore, the RTC should not have outrightly denied due course to the petition based on a lack of standing. On Issue 2: Despite the procedural error of the RTC, the MeTC did not commit grave abuse of discretion in granting the Demurrer to Evidence. A judgment of acquittal is final and unappealable under the double jeopardy clause, and it can only be assailed via Rule 65 if the petitioner proves the trial court acted in a capricious, whimsical, or arbitrary manner that amounted to a denial of due process. In this case, the MeTC's conclusion that the prosecution failed to establish a prima facie case was based on the fact that the alleged falsified documents were not identified by their signatories and no direct evidence linked Dr. Royales to the orders of falsification. The Court reiterated that the presumption of authorship cannot be applied solely based on an individual's status as a company officer; actual possession and direct benefit must be proven. Any perceived error in the MeTC's appreciation of evidence constitutes a mere error of judgment, not an error of jurisdiction, and thus does not warrant the issuance of a writ of certiorari.
Main Doctrine
A private complainant possesses the standing to question the criminal aspect of an acquittal via a Rule 65 petition for certiorari, provided they obtain the express conformity of the public prosecutor. At the Regional Trial Court (RTC) level, the conformity of the Office of the City Prosecutor (OCP) is sufficient to satisfy the requirement that criminal actions be prosecuted under the direction and control of the State, as the Office of the Solicitor General (OSG) is only mandated to represent the State before the Court of Appeals (CA) and the Supreme Court (SC). Substantively, however, such a petition can only succeed if it demonstrates grave abuse of discretion amounting to a denial of due process, as a judgment of acquittal is otherwise final and unappealable under the constitutional proscription against double jeopardy.