GR 143044; (July, 2005) (Digest)
G.R. No. 143044 . July 14, 2005
WILLIAM MADARANG and EVANS KHO, Petitioners, vs. HON. COURT OF APPEALS, THE PEOPLE OF THE PHILIPPINES, HON. OFELIA ARELLANO-MARQUEZ, and JANICE YOUNG-CHUA, Respondents.
FACTS
Private respondent Janice Young-Chua filed a civil case for replevin against petitioners William Madarang and Evans Kho, alleging they forcibly took her car using a falsified deed of sale. Simultaneously, she initiated criminal complaints for Falsification of Public Document against Madarang and for Grave Coercion against both petitioners. During the pendency of the criminal cases, the Regional Trial Court (RTC) in the replevin case dismissed the complaint, finding the deed of sale genuine and the surrender of the car voluntary.
Relying on this RTC decision, petitioners moved to dismiss the criminal cases in the Metropolitan Trial Court (MeTC), arguing the findings absolved them of criminal liability. The MeTC initially granted the dismissal but later recalled its order upon the prosecution’s motion, noting the RTC decision was not final as it was on appeal. Petitioners then filed a motion to quash the criminal informations, which the MeTC denied, ruling the RTC decision lacked finality and that petitioners had waived their right to a motion to quash by filing it after arraignment.
ISSUE
Whether the MeTC committed grave abuse of discretion in denying the motion to quash the criminal informations for Falsification and Grave Coercion.
RULING
The Supreme Court denied the petition, affirming the lower courts. The MeTC did not commit grave abuse of discretion. First, a motion to quash under Rule 117 of the Rules of Court must be filed before the accused enters a plea. Petitioners were arraigned in 1994 but filed their motion to quash only in 1998, thereby waiving any grounds for a quashal, including the claim of res judicata. Second, the principle of res judicata requires a final and executory judgment. The RTC decision in the civil replevin case was pending appeal before the Court of Appeals and had not attained finality; thus, it could not constitute a bar to the criminal prosecution. Third, the civil action for replevin is independent of the criminal actions for falsification and coercion. A dismissal in a civil case does not automatically extinguish criminal liability, as the quantum of evidence and causes of action differ. The prosecution of criminal cases remains under the control of the State, and the pendency or result of a separate civil action does not generally preclude the criminal proceedings.