G.R. No. L-38453-54 March 25, 1975
PEOPLE OF THE PHILIPPINES, petitioner, vs. THE HON. JUDGE PEDRO C. NAVARRO, Presiding Judge of the Court of First Instance of Pasig, Rizal, Branch II, and JAIME CATUDAY, respondents.

FACTS

Respondent Jaime Catuday was convicted of light threat and frustrated theft in the Municipal Court of Makati. He appealed both convictions to the Court of First Instance (CFI) of Rizal, where separate informations were filed and the cases were assigned to Branch XI. While the frustrated theft case proceeded to trial with multiple hearings, the light threat case was repeatedly postponed. The records show that on February 24, 1970, the court issued a single order for both cases, resetting “the trial” for March 25, 1970. However, on March 25 and in all subsequent hearings, only the frustrated theft case was actually heard. The light threat case was never called for trial or presentation of evidence.
Upon Judge Navarro taking over the cases, a single decision was rendered on July 20, 1973, acquitting Catuday of both charges for lack of proof beyond reasonable doubt. The decision explicitly stated the two cases “were tried jointly.” The prosecution moved for reconsideration, arguing the light threat case was never tried, but the motion was denied. The State then filed this petition for certiorari, initially dismissed but later reconsidered.

ISSUE

Whether the respondent judge acted with grave abuse of discretion, tantamount to lack or excess of jurisdiction, in acquitting the accused in the light threat case despite the absence of any trial thereon, thereby denying the State due process.

RULING

Yes. The Supreme Court granted the petition, annulled the acquittal for light threat, and ordered the case reinstated for trial. The legal logic is anchored on due process and jurisdiction. A judgment rendered without a trial is void for lack of due process, which is equivalent to acting without jurisdiction. The Court meticulously examined the records and found no evidence that the light threat case was ever heard; the repeated resettings and a single, ambiguous order referring to “the trial” did not constitute a joint trial. A joint trial requires a conscious order from the court consolidating the cases for a unified proceeding, which never occurred here.
By dismissing the charge on the merits (lack of proof beyond reasonable doubt) without the prosecution ever being afforded an opportunity to present its evidence, the respondent judge effectively determined the case without a hearing. This constitutes a capricious and arbitrary exercise of judgment—a grave abuse of discretion. The State has a fundamental right to prosecute its case and present evidence. Denying this right, where no substantial right of the accused is prejudiced by a proper trial, results in a miscarriage of justice. Consequently, the acquittal was declared null and void ab initio as it was rendered by a court that had no power to do so under the circumstances, being coram non judice.