G.R. No. 225410 , June 17, 2020
BBB, PETITIONER, VS. AMY B. CANTILLA, RESPONDENT.

FACTS

Petitioner BBB hired respondent Amy B. Cantilla as a househelper and co-caretaker of her then three-year-old daughter, AAA. Sometime between January and April 2006, respondent was alleged to have committed acts of child abuse against AAA, including hitting her with slippers and her hand, feeding her only twice a day, spanking her face, and pinching her arms. The incident was reportedly witnessed by the yaya of petitioner’s friend, Maria Antonina C. Espiritu, during a visit. Petitioner terminated respondent’s services in August 2006 after being advised by Espiritu. On August 15, 2010, petitioner, after seeing respondent again, interviewed AAA, who confirmed the abuses. An Information was filed charging respondent with Child Abuse under Section 10(a) of Republic Act No. 7610 . During trial, the prosecution presented petitioner and AAA as witnesses. Respondent filed a Demurrer to Evidence, arguing insufficiency of evidence, particularly the non-presentation of the alleged eyewitness (Espiritu’s yaya) and the delay in filing the case. The Regional Trial Court (RTC) granted the demurrer and dismissed the case in an Order dated July 10, 2015. Petitioner’s motion for reconsideration and motion for inhibition of the judge were denied in an Order dated October 12, 2015. Petitioner filed a Petition for Certiorari with the Court of Appeals (CA), which was dismissed in Resolutions dated February 9, 2016, and June 23, 2016, for being filed out of time, for defective Verification and Certification of Non-Forum Shopping, and for failure to implead the People of the Philippines. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

1. Whether the Court of Appeals committed grave error in dismissing the Petition for Certiorari.
2. Whether the RTC committed grave abuse of discretion in granting the Demurrer to Evidence.
3. Whether the presiding judge of the RTC committed grave abuse of discretion in refusing to inhibit himself.

RULING

The Supreme Court denied the petition, affirming the CA’s dismissal.
1. On the procedural issue, the Supreme Court held that the CA correctly dismissed the Petition for Certiorari for being filed beyond the 60-day reglementary period under Section 4, Rule 65 of the Rules of Court. The Court emphasized that the 60-day period is now inextendible to prevent delay and ensure the speedy disposition of cases. Petitioner failed to show any compelling reason for an extension. The CA’s dismissal on additional grounds—defective verification/certification and non-joinder of the People of the Philippines—was also proper.
2. On the substantive issue, the Court ruled that the grant of a demurrer to evidence is tantamount to an acquittal, and the rule on double jeopardy generally bars an appeal. While an acquittal may be reviewed via certiorari under Rule 65 for grave abuse of discretion amounting to lack or excess of jurisdiction, petitioner’s failure to timely file the certiorari petition precluded such review. Consequently, the Court did not reach the merits of whether the RTC committed grave abuse of discretion in granting the demurrer.
3. Similarly, the issue regarding the judge’s inhibition was not reached due to the procedural default in filing the certiorari petition.
The Court stressed that procedural rules on reglementary periods are strictly applied to prevent needless delays and are indispensable to the orderly and speedy discharge of judicial business. The petition was bereft of merit.