G.R. No. 166414 ; October 22, 2014
GODOFREDO ENRILE AND DR. FREDERICK ENRILE, Petitioners, vs. HON. DANILO A. MANALASTAS (AS PRESIDING JUDGE, REGIONAL TRIAL COURT OF MALOLOS BULACAN, BR. VII), HON. ERANIO G. CEDILLO, SR., (AS PRESIDING JUDGE, MUNICIPAL TRIAL COURT OF MEYCAUAYAN, BULACAN, BR.1) AND PEOPLE OF THE PHILIPPINES, Respondents.

FACTS

A mauling incident occurred on January 18, 2003, involving petitioners Godofredo Enrile and Dr. Frederick Enrile and their neighbors. The complainants (Josefina Guinto Morano, Rommel Morano, and Perla Beltran Morano) filed three criminal cases in the Municipal Trial Court (MTC) of Meycauayan, Bulacan: frustrated homicide (Criminal Case No. 03-275) and two counts of less serious physical injuries (Criminal Case Nos. 03-276 and 03-277). The MTC found probable cause for the two less serious physical injuries charges against the petitioners and set their arraignment. The petitioners filed a motion for reconsideration, arguing the complainants failed to present proof of medical attention lasting 10 days or more, a required element for less serious physical injuries, and that the cases should not be governed by the Rules on Summary Procedure. The MTC denied the motion. The petitioners then filed a motion to quash the informations. On February 11, 2004, the MTC denied the motion to quash, ruling the grounds raised were matters of defense to be ventilated at trial and ordered the cases tried under ordinary procedure. The MTC denied their motion for reconsideration on March 25, 2004.
The petitioners filed a special civil action for certiorari with the Regional Trial Court (RTC) to assail the MTC orders. The RTC, through Judge Danilo A. Manalastas, dismissed the petition on May 25, 2004, agreeing with the MTC that the issues were evidentiary matters for trial. The RTC denied their motion for reconsideration on July 9, 2004.
The petitioners then filed a petition for certiorari and prohibition with the Court of Appeals (CA) to nullify the RTC orders. The CA dismissed the petition on August 31, 2004, ruling it was the wrong remedy; the proper recourse from the RTC’s final order was an appeal by notice of appeal. The CA denied their motion for reconsideration on December 21, 2004.

ISSUE

1. Whether the Court of Appeals erred in upholding the trial courts’ denial of the petitioners’ motion to quash the complaints for allegedly lacking an essential element of the crime of less serious physical injuries.
2. Whether the Court of Appeals erred in not ruling that the injuries sustained by the private complainants were not perpetrated by the petitioners.

RULING

The Supreme Court denied the petition and affirmed the resolutions of the Court of Appeals.
1. On the propriety of the remedy: The Supreme Court ruled that the petitioners availed of the wrong remedy. The RTC’s order dismissing their petition for certiorari was a final order that completely disposed of the case. The proper remedy from such a final order of the RTC, exercising its original jurisdiction, was an appeal by notice of appeal under Rule 41 of the Rules of Court, not a petition for certiorari under Rule 65. Certiorari is an extraordinary writ available only when there is no appeal or any plain, speedy, and adequate remedy in the ordinary course of law. Since an appeal was available, the CA correctly dismissed their petition.
2. On the denial of the motion to quash: The Supreme Court upheld the denial. A motion to quash challenges the sufficiency of the complaint or information on its face. The grounds raised by the petitioners—that the complaints lacked an allegation that the injuries required medical attendance for at least 10 days—pertained to matters of evidence or defense that must be proven during trial. The test for sufficiency is whether the facts alleged in the information, if hypothetically admitted, constitute the offense. The informations for less serious physical injuries under Article 265 of the Revised Penal Code sufficiently alleged the acts constituting the offense. The duration of medical attendance or incapacity is a factual matter to be established during trial, not a deficiency apparent on the face of the information. Therefore, the MTC did not gravely abuse its discretion in denying the motion to quash.
The Court emphasized that the remedy against the denial of a motion to quash is for the accused to enter a plea, proceed to trial, and if the decision is adverse, to raise the denial as an error on appeal from the final judgment. The denial, being an interlocutory order, is not appealable and generally cannot be the subject of a petition for certiorari due to the availability of other remedies.