G.R. No. 121422 February 23, 1999
NOEL CRUZ y DIGMA, petitioner, vs. PEOPLE OF THE PHILIPPINES, THE COURT OF APPEALS and THE REGIONAL TRIAL COURT, BRANCH VI, MANILA, respondents.

FACTS

On June 19, 1990, police officers arrested petitioner Noel Cruz y Digma without a warrant for illegal possession of a .38 caliber revolver with six rounds of ammunition while he was waiting outside the Manila Pavilion Hotel along U.N. Ave., Manila. An information for violation of Presidential Decree No. 1866 (Illegal Possession of Firearm and Ammunition) was filed against him. After his arraignment where he pleaded not guilty, the trial proceeded. The prosecution presented and formally offered its evidence, including the seized gun and ammunition. The trial court admitted this evidence over the petitioner’s objections. After the prosecution rested, the petitioner filed a demurrer to evidence, which the trial court denied, ordering him to present his evidence. The petitioner instead filed a motion for reconsideration, which was also denied. The petitioner then filed a petition for certiorari with the Court of Appeals seeking to annul three orders of the trial court: (a) the order admitting the prosecution’s formal offer of evidence; (b) the order denying his demurrer to evidence; and (c) the order denying his motion for reconsideration. The Court of Appeals denied the petition, ruling that the assailed orders were interlocutory and not reviewable by certiorari. Hence, this petition for review was filed.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari and in upholding the trial court’s interlocutory orders, particularly the order admitting the gun and ammunition as evidence and the order denying the demurrer to evidence, despite the petitioner’s claim that the evidence was inadmissible as the fruit of an illegal warrantless arrest and search and that the prosecution’s evidence was insufficient to sustain a conviction.

RULING

The Supreme Court denied the petition. It held that the rulings of the trial court on procedural questions and on the admissibility of evidence during trial are interlocutory in nature. Such orders may not be the subject of a separate appeal or review on certiorari but may be assigned as errors and reviewed in an appeal properly taken from the final decision on the merits. The Court found no reversible error in the decision of the Court of Appeals. It reiterated that when a court has jurisdiction over the case and the person of the accused, any error in the application of the law or appreciation of evidence committed after acquiring jurisdiction may be corrected only by appeal, not by certiorari. Regarding the denial of the demurrer to evidence, the Court ruled that the sufficiency of the prosecution’s evidence rests within the sound discretion of the trial court, and any error in its denial may likewise be corrected only by appeal. The Court acknowledged that exceptions to the general rule exist, such as when an interlocutory order is patently erroneous or issued with grave abuse of discretion, but found that the petitioner did not fall within these exceptions. The trial court had already addressed the petitioner’s contentions regarding the admissibility of the evidence and the sufficiency of the prosecution’s case, and the Supreme Court found neither error nor patent abuse of discretion in the trial court’s rulings. Accordingly, the Supreme Court ordered the trial court to continue with the proceedings in the criminal case.