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CUYCO v. PEOPLE

FACTS:

In this case, petitioner Anselmo Cuyo and Alejo Cuyo are estranged brothers. Petitioner filed a complaint against Alejo for illegal possession of firearms, which led to proceedings for a search warrant. During these proceedings, petitioner made untruthful statements under oath.

Alejo, in response, filed a complaint for perjury against petitioner. The Municipal Trial Court in Cities (MTCC) found petitioner guilty of perjury and sentenced him to imprisonment.

Petitioner filed a Motion for Reconsideration before the MTCC, but it was denied. He then filed a Motion for Probation, which was also denied by the MTCC on the grounds that it was filed beyond the reglementary period of 15 days. Petitioner sought reconsideration of the denial, requesting a liberal interpretation of the rules on probation, but the MTCC denied this motion as well.

In turn, petitioner filed a Petition before the Regional Trial Court (RTC) asserting that there was grave abuse of discretion on the part of the MTCC. However, the RTC denied the Petition, stating that petitioner failed to comply with procedural requirements.

Petitioner then escalated the case by filing a Petition for Review before the Supreme Court, challenging the RTC's decision.

ISSUES:

  1. Whether the MTCC court erred in denying the petitioner's Motion for Probation on the ground that it was filed beyond the reglementary period of fifteen (15) days.

  2. Whether the RTC erred in dismissing the petition on procedural grounds for failing to implead the private complainant as a respondent in the Petition for Certiorari.

RULING:

  1. The Supreme Court found merit in the petition with respect to the computation of the 15-day period for the petitioner to file a Motion for Probation. The MTCC court incorrectly computed the period and deemed the motion to be filed beyond the reglementary period. The Supreme Court upheld the petitioner's argument that the 15-day period should be reckoned from the receipt of the Order denying the Motion for Reconsideration, and not from the promulgation of the judgment.

  2. The Supreme Court upheld the dismissal of the petition on procedural grounds for the failure to implead the private complainant as a respondent in the Petition for Certiorari. The petitioner violated Rule 65, Section 5 which requires the joinder of the private complainant as a respondent in the petition.

PRINCIPLES:

  • The 15-day period to file a Motion for Probation should be reckoned from the receipt of the Order denying the Motion for Reconsideration, not from the promulgation of the judgment.

  • Rule 65, Section 5 of the Rules of Court mandates the joinder of the private complainant as a respondent in a petition if the petition relates to the acts or omissions of a judge, court, quasi-judicial agency, tribunal, corporation, board, officer, or person.