G.R. No. 224650 , July 15, 2020
People of the Philippines, Petitioner, vs. Adolfo A. Goyala, Jr., Respondent.

FACTS

AAA, a minor, accused Adolfo A. Goyala, Jr. (respondent) of statutory rape. After preliminary investigation, Assistant City Prosecutor Pedro M. Oribe found probable cause and an Information was filed before the Regional Trial Court (RTC) of Pasig City, docketed as Criminal Case No. 152682. Respondent filed a Motion for Reconsideration with the Office of the City Prosecutor (OCP) of Pasig City. The City Prosecutor forwarded the records to the Department of Justice (DOJ) for further proceedings and inhibited himself. The DOJ designated Senior Assistant City Prosecutor Josefa D. Laurente to resolve the motion with finality. Meanwhile, respondent filed a Motion to Suspend Proceedings and to Hold in Abeyance Issuance of Warrant of Arrest before the RTC. The RTC denied the motion, finding probable cause to hold respondent for trial and issued a warrant of arrest. Respondent filed an Omnibus Motion, which was also denied. Respondent then filed a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, reversed the RTC Orders, and directed the suspension of proceedings and remand of the case to the prosecution to complete the preliminary investigation, revoking the warrant of arrest. The CA held that respondent was deprived of his right to a full preliminary investigation because his Motion for Reconsideration was still pending resolution. The People of the Philippines, through the Office of the Solicitor General, filed the present appeal by certiorari.

ISSUE

Whether the Court of Appeals erred in ruling that the trial court should suspend the criminal proceedings and remand the case to the prosecution for the completion of the preliminary investigation on the ground that the respondent’s right to a full preliminary investigation was violated due to a pending Motion for Reconsideration.

RULING

The Supreme Court granted the petition, reversed the Decision and Resolution of the Court of Appeals, and reinstated the Orders of the Regional Trial Court. The Court held that the right to a preliminary investigation is not a fundamental right and is not part of due process in the context of the Constitution’s guarantee. The filing of a Motion for Reconsideration of the prosecutor’s resolution is not an integral part of the preliminary investigation proper. Once a complaint or information is filed in court, the court acquires jurisdiction over the case, and any motion for reinvestigation or review should be addressed to the court’s sound discretion. The pendency of a Petition for Review with the Secretary of Justice does not divest the trial court of its jurisdiction to proceed with the case. The trial court is mandated to independently evaluate the existence of probable cause for the issuance of a warrant of arrest and for the purpose of holding the accused for trial. The trial court in this case had already made such an independent determination and found probable cause. Therefore, the CA erred in ordering the suspension of proceedings and the remand of the case. The trial court was correct in proceeding with the case.