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JCLV REALTY v. PHIL GALICIA MANGALI

FACTS:

In this case, Phil Mangali and Jerry Alba were charged with robbery committed against JCLV Realty & Development Corporation. After the prosecution rested its case, Mangali filed a demurrer to evidence claiming that the prosecution failed to establish intent to gain and ownership of the stolen items. The RTC granted the demurrer and dismissed the criminal case against Mangali. JCLV Realty elevated the case to the CA through a special civil action for certiorari, arguing that the RTC erred in granting the demurrer. However, the CA dismissed the petition, ruling that JCLV Realty had no personality to question the dismissal of the criminal case since only the OSG can bring or defend actions on behalf of the State in criminal proceedings. JCLV Realty sought reconsideration but was denied. Hence, this petition for review on certiorari.

ISSUES:

  1. Whether the petitioner has legal standing to file a petition for certiorari assailing the dismissal of a criminal case.

  2. Whether the petitioner's arguments pertain to the civil or criminal aspect of the case.

  3. Whether the private offended party can file a special civil action for certiorari to question the validity of the acquittal or dismissal of a criminal case.

  4. Whether the Office of the Solicitor General's (OSG) intervention is necessary in the filing of a special civil action for certiorari.

  5. Whether the trial court committed grave abuse of discretion in dismissing the case on a ground not raised in the demurrer to evidence, i.e. the prosecution's failure to identify the accused.

  6. Whether double jeopardy has set in.

RULING:

  1. The petitioner lacks legal standing to file a petition for certiorari assailing the dismissal of a criminal case. Only the People, represented by the Solicitor General, may question the dismissal or acquittal in a criminal case. The private offended party's standing is limited to the civil aspect of the case.

  2. The petitioner's arguments pertain to the criminal aspect of the case. Therefore, the petitioner does not have standing to question the dismissal of the criminal case.

  3. Yes, the private offended party can file a special civil action for certiorari to question the validity of the acquittal or dismissal of a criminal case.

  4. The intervention of the OSG is not necessary in the filing of a special civil action for certiorari.

  5. No, the trial court did not commit grave abuse of discretion in dismissing the case on a ground not raised in the demurrer to evidence.

  6. Yes, double jeopardy has set in.

PRINCIPLES:

  • Only the People, represented by the Solicitor General, may question the dismissal or acquittal in a criminal case. The private offended party's standing is limited to the civil aspect of the case.

  • The private offended party may only question the dismissal or acquittal of a criminal case if it pertains to the civil liability of the accused. Any arguments pertaining to the criminal aspect of the case are beyond the standing of the private offended party.

  • The acquittal or dismissal of a criminal case may be assailed through a Petition for Certiorari under Rule 65 of the Rules of Court on the grounds of grave abuse of discretion amounting to lack or excess of jurisdiction or a denial of due process rendering the judgment void. (People v. Judge Santiago)

  • The victim can avail certiorari to question the validity of acquittal. (People v. Judge Santiago)

  • The private offended party has the right to file a special civil action for certiorari in assailing the dismissal of a criminal case. (Dela Rosa v. CA)

  • The intervention of the OSG is not necessary in the filing of a special civil action for certiorari. (Dela Rosa v. CA)

  • The victim has legal standing to bring a special civil action for certiorari. (People v. Court of Appeals)

  • The trial court commits grave abuse of discretion if it dismisses a criminal case solely based on the recommendation of the Secretary of Justice without making an independent evaluation of the merits. (Perez v. Hagonoy Rural Bank, Inc.)

  • The victim has the legal personality to file a petition for certiorari on her own and not through the OSG. (David v. Marquez)

  • The identity of the offender is indispensably entwined to the commission of the crime. (Perez v. Hagonoy Rural Bank, Inc.)

  • A demurrer to evidence is an objection by one of the parties in an action, challenging the sufficiency of the whole evidence to sustain a verdict. (People v. Mangali)

  • The grant of demurrer to evidence is a judgment of acquittal which is final and executory, absent grave abuse of discretion or denial of due process. (People v. Mangali)