FACTS:

This case involved a complaint filed by petitioner Jose Burgos, Jr. before the Office of the Provincial Prosecutor, Taytay, Rizal, charging respondents spouses Eladio and Arlina Naval and their daughter, Amalia Naval, with Estafa through Falsification of Public Documents. Burgos alleged that he and his wife were the registered owners of a lot, which was later mortgaged to a certain Antonio Assad. Respondents agreed to help Burgos obtain a loan by asking him to sign blank documents, which turned out to be a receipt and a Deed of Absolute Sale over the subject lot in favor of the respondents. Subsequently, an Information was filed before the Regional Trial Court (RTC) accusing respondents of the crime. Respondents filed a motion to quash, claiming prescription, failure to charge Amalia with an offense, and lack of opportunity for a preliminary investigation. The RTC granted the motion and dismissed the case. Burgos moved for reconsideration but was denied. He then filed a petition for certiorari before the Court of Appeals (CA), which was dismissed for failure to join the People in the petition. Burgos filed a motion for reconsideration, but it was also denied. Hence, the present petition for review on certiorari before the Supreme Court. The issue in this case is whether or not the CA correctly dismissed the certiorari petition for failure to implead the People as a party.

ISSUES:

RULING:

PRINCIPLES:

• The People, as represented by the Office of the Solicitor General, must be impleaded as a party in the petition for certiorari in criminal cases. (Administrative Code of 1987)

• Due process requires that all parties directly affected be given an opportunity to be heard and the right to defend their interests.