Billedo v. Wagan

G.R. No. 175091 (July 13, 2011)

Supreme Court upholds RTC's ruling to proceed with civil case despite dismissed criminal complaints.

Facts:

The case originated from the arrest of complainants Alberto Mina, Nilo Jay Mina, and Ferdinand Caasi on February 27, 2000, by police officers, including petitioners Police Chief Inspector Fernando Billedo, SPO3 Rodrigo Domingo, PO3 Jorge Lopez, Ferdinand Cruz, and Mariano Cruz. The complainants were allegedly caught in the act of drinking liquor in a public place, which led to their arrest under City Ordinance No. 265. The complainants contended that their arrest was unlawful and instigated by the unjust accusations of Ferdinand Cruz and Mariano Cruz.

Following their arrest, the complainants were charged with violating the aforementioned city ordinance in the Metropolitan Trial Court of Pasay City (MeTC). Subsequently, they filed a civil case for damages (Civil Case No. 00-0089) against the petitioners. The complainants also lodged criminal complaints against the petitioners for unlawful arrest and violations of Republic Act No. 7438, which defines the rights of persons under custodial investigation. The City Prosecution Office dismissed the complaints for lack of merit, while the Ombudsman recommended the filing of criminal informations for violations of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019) against some of the petitioners.

The criminal cases were later dismissed by the City Prosecution Office for lack of merit, and the complainants were found guilty of violating the city ordinance. The civil case proceeded to trial, during which Ferdinand Cruz filed a motion to dismiss, arguing that the Sandiganbayan had jurisdiction over the civil case and that the complainants were barred from filing a separate civil action under Section 4 of R.A. No. 8249.

The Regional Trial Court (RTC) denied the motion to dismiss, stating that the civil case did not fall under the jurisdiction of the Sandiganbayan as no criminal case had been filed against the petitioners. The RTC further explained that the absence of a criminal case meant there was no basis for transferring the civil case to the Sandiganbayan.

Legal Issues:

The primary legal issue was whether the Regional Trial Court had jurisdiction to try Civil Case No. 00-0089, given the provisions of Section 4 of R.A. No. 8249, which mandates the simultaneous institution and joint determination of civil and criminal actions.

Arguments:

  • Petitioners' Argument: The petitioners contended that the RTC lacked jurisdiction over the civil case because it should have been filed in conjunction with a criminal case in the Sandiganbayan. They argued that the complainants were barred from filing a separate civil action due to the provisions of R.A. No. 8249.

  • Respondents' Argument: The RTC maintained that the civil case did not fall under the purview of R.A. No. 8249 since no criminal action had been instituted against the petitioners. The RTC emphasized that the civil action could proceed independently of the criminal action, as the extinction of the penal action does not extinguish the civil action unless a final judgment declares that the facts giving rise to civil liability did not exist.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition, ruling that the RTC did not commit grave abuse of discretion in its orders. The Court found that Section 4 of R.A. No. 8249 was not applicable because no criminal action had been filed against the petitioners. The Court clarified that the civil case could proceed independently, as the complainants could establish their cause of action based on a preponderance of evidence.

The Court reiterated that an order denying a motion to dismiss is interlocutory and not appealable, emphasizing the importance of orderly procedure in judicial processes. The Court concluded that the petitioners should have continued with the trial of the civil case rather than seeking to dismiss it based on the alleged lack of jurisdiction.

Significant Legal Principles Established:

  1. Independence of Civil and Criminal Actions: The extinction of a penal action does not extinguish the corresponding civil action unless a final judgment states that the facts giving rise to civil liability did not exist.

  2. Jurisdictional Clarity: The provisions of R.A. No. 8249 regarding the simultaneous institution of civil and criminal actions apply only when a criminal case has been filed; in the absence of such a case, the civil action can proceed in the appropriate court.

  3. Interlocutory Orders: Orders denying motions to dismiss are considered interlocutory and are not subject to immediate appeal, reinforcing the principle of orderly judicial proceedings.