GR 214163; (July, 2019) (Digest)
G.R. No. 214163 July 1, 2019
RONALD GERALINO M. LIM and THE PEOPLE OF THE PHILIPPINES, Petitioners vs. EDWIN M. LIM, Respondent
FACTS
Ronald Lim filed a criminal complaint for grave threats against his brother, Edwin Lim. An Information was filed, and Edwin pleaded not guilty. During pre-trial proceedings at the Municipal Trial Court in Cities (MTCC), the prosecution failed to submit the Judicial Affidavits of its witnesses at least five days before pre-trial as mandated by the Judicial Affidavit Rule. On the day of the pre-trial, the prosecution moved for leave to submit the affidavits later that same day, offering the explanation “for whatever reason.” Over Edwin’s objection, the MTCC granted the motion and allowed submission by 5:00 p.m., later imposing a fine on the prosecution for the delay. Edwin filed a Petition for Certiorari with the Regional Trial Court (RTC), arguing the MTCC committed grave abuse of discretion.
ISSUE
Whether the RTC correctly granted the Petition for Certiorari, finding that the MTCC committed grave abuse of discretion in allowing the belated submission of Judicial Affidavits.
RULING
Yes, the Supreme Court affirmed the RTC’s decision. The Court held that the MTCC’s order constituted grave abuse of discretion amounting to lack or excess of jurisdiction, which is properly assailable via a petition for certiorari under Rule 65. The Judicial Affidavit Rule clearly requires the prosecution to submit judicial affidavits not later than five days before pre-trial. The prosecution’s failure to comply, despite multiple pre-trial postponements, was unjustified. Its proffered reason, “for whatever reason,” was not a valid justification under the Rule. By disregarding this mandatory procedural rule without a compelling reason, the MTCC exercised its power in an arbitrary and capricious manner. The Court emphasized that while rules of procedure exist to ensure the orderly administration of justice, they must be followed faithfully. The allowance of the belated submission, under the circumstances, prejudiced Edwin’s right to due process by depriving him of adequate time to prepare his defense against the affidavits. The availability of an eventual appeal from a final judgment does not bar a certiorari petition when the interlocutory order is issued with grave abuse of discretion. Thus, the RTC correctly set aside the MTCC orders and expunged the belatedly filed judicial affidavits from the record.