G.R. No. 204063 . December 05, 2016
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. DR. DAVID A. SOBREPEÑA, SR., DR. MONA LISA DABAO, DR. POLIXEMA ADORADA, DEOBELA FORTES AND LIRIO CORPUZ, RESPONDENTS.

FACTS

Respondents, officers and employees of Union College of Laguna, were charged with Estafa and Large Scale Illegal Recruitment before the RTC of Santa Cruz, Laguna. They filed a Petition for Bail, contending the evidence of guilt was not strong. The prosecution opposed, presenting witnesses led by Adelfo Carandang. He testified that respondents, through advertisements and personal assurances, promised employment in Canada for a fee, inducing him and others to enroll and pay substantial amounts. However, on cross-examination, Carandang admitted the flyer’s full text promoted skills training for future work, not a direct job guarantee. He confirmed the fees were for attended courses under Canadian instructors and that his claim of a 12-million-peso victim payment was a mere estimate without personal knowledge.
The RTC, after a summary hearing, denied the bail petition, finding the evidence of guilt strong. Respondents filed a Petition for Certiorari with the Court of Appeals. The CA granted the petition, nullifying the RTC Orders. The CA ruled the RTC committed grave abuse of discretion, as the prosecution’s own evidence, particularly the witnesses’ admissions on cross, created doubt regarding the promise of overseas employment for a fee—an essential element of illegal recruitment.

ISSUE

Did the Court of Appeals err in granting the Petition for Certiorari and overturning the RTC’s finding that the evidence of guilt was strong for the purpose of denying bail?

RULING

Yes, the Supreme Court granted the Petition, reinstating the RTC Orders denying bail. The Court held that the CA overstepped its jurisdiction in a certiorari proceeding under Rule 65. A writ of certiorari corrects only errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction, not errors of judgment. The RTC’s assessment of the evidence’s strength during a bail hearing is a preliminary determination for the sole purpose of deciding the bail application; it does not constitute a final judgment on the merits.
The CA erroneously re-evaluated the evidence and made its own factual findings, which is prohibited in a certiorari review. The RTC did not act whimsically or arbitrarily. It conducted the requisite summary hearing and, based on the prosecution’s presented evidence, made a preliminary finding that the evidence of guilt was strong for the capital offense. This exercise of discretion was in complete accord with law and jurisprudence. Any alleged error in the RTC’s appreciation of evidence was an error of judgment, correctible by appeal, not by certiorari. Thus, the CA decision was declared null and void.