G.R. No. 128297 January 21, 1999
PEOPLE OF THE PHILIPPINES, petitioner, vs. HONORABLE COURT OF APPEALS, HONORABLE ELSA I. DE GUZMAN, as Presiding Judge of the Metropolitan Trial Court, National Capital Judicial Region, Branch 33, Quezon City, C/INSP. ROBERTO V. GANIAS, INSP. JOHN A. MAMAUAG, SPO1 ROBERTO C. CARINO, SPO2 EUGENE V. ALMARIO, SPO1 VIVIAN FELIPE, AND SPO4 ERLINDA GARCIA, respondents.

FACTS

An Information for violation of Article 208 of the Revised Penal Code (Prosecution of Offenses; Negligence and Tolerance) was filed with the Metropolitan Trial Court (MTC) of Quezon City against the private respondents, who were members of the Philippine National Police. The Information alleged that on or about March 2, 1995, the respondents, despite a request for assistance, refused or failed to take appropriate action or cause the prosecution of a person caught red-handed for qualified theft. Upon arraignment, the private respondents pleaded not guilty and subsequently filed a Motion to Quash the Information. On November 21, 1995, the MTC granted the motion and quashed the Information on the ground that its averments did not charge an offense. The MTC denied the prosecution’s motion for reconsideration on January 8, 1996. The petitioner (People of the Philippines) then filed a petition for certiorari and mandamus directly with the Supreme Court (docketed as G.R. No. 123603), which was referred to the Court of Appeals. On April 19, 1996, the Court of Appeals dismissed the petition outright, holding that it should have been brought before the Regional Trial Court (RTC) in observance of the hierarchy of courts. The Court of Appeals also denied the petitioner’s motion for reconsideration, ruling further that certiorari was not the proper remedy because the petitioner had a plain, speedy, and adequate remedy at law by appealing the MTC order to the RTC, which right was lost due to failure to appeal within the reglementary period.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari and mandamus on the grounds of non-observance of the hierarchy of courts and the availability of the remedy of appeal.

RULING

Yes, the Supreme Court affirmed the Decision of the Court of Appeals. The Court upheld the doctrine of hierarchy of courts, which dictates that petitions for extraordinary writs against first-level courts (like the MTC) should be filed with the Regional Trial Court, and those against the RTC should be filed with the Court of Appeals. A direct invocation of the Supreme Court’s original jurisdiction is allowed only for special and important reasons clearly set out in the petition. This policy prevents inordinate demands on the Court’s time and docket congestion. The Supreme Court declined to rule definitively on whether appeal was the prescribed remedy over certiorari, stating that such an issue is better left to the RTC where the petition may be properly filed. The Court noted, however, that certiorari may be allowed even when appeal is available if the challenged orders were issued without or in excess of jurisdiction, or if the equities of the case warrant such action. The dispositive portion affirmed the Court of Appeals’ decision without prejudice to the filing of the petition with the appropriate Regional Trial Court.