GR 236686; (February, 2020) (Digest)
G.R. No. 236686 , February 5, 2020
Yokohama Tire Philippines, Inc., Petitioner, v. Sandra Reyes and Jocelyn Reyes, Respondents.
FACTS
Petitioner Yokohama Tire Philippines, Inc. filed a criminal complaint for qualified theft against its former employees, respondents Sandra Reyes and Jocelyn Reyes, and another individual, Celeste Tagudin, alleging they took HP ink cartridges from the company stockroom. The Assistant City Prosecutor recommended filing an Information for Attempted Theft only against the respondents, which was approved. The Municipal Trial Court (MTC) of Clarkfield, Pampanga, after trial, acquitted the respondents of Attempted Theft. The MTC ruled that the pieces of HP ink cartridges presented by the prosecution were inadmissible, having been obtained in violation of the law and the respondents’ right against unreasonable search and seizure. The petitioner filed a petition for certiorari under Rule 65 with the Regional Trial Court (RTC), seeking to annul the MTC’s acquittal decision, arguing the MTC committed grave abuse of discretion in excluding the evidence. The RTC dismissed the certiorari petition for lack of merit and denied the motion for reconsideration. The petitioner elevated the case to the Supreme Court via a petition for review on certiorari under Rule 45.
ISSUE
Whether the Regional Trial Court erred in dismissing the petitioner’s special civil action for certiorari, which sought to annul the Municipal Trial Court’s decision acquitting the respondents of Attempted Theft, particularly on the ground that the MTC committed grave abuse of discretion in excluding the HP ink cartridges as evidence.
RULING
The Supreme Court DENIED the petition and AFFIRMED the RTC’s Decision and Order. The Court held that the petitioner, as the private offended party, lacked the authority to file a special civil action for certiorari questioning the criminal aspect of the case (the acquittal). In a criminal case where the State is the offended party, the private complainant’s interest is limited to the civil liability. An appeal or a petition questioning the criminal aspect of a dismissal or acquittal may only be undertaken by the State through the Solicitor General. The private complainant may only question the civil aspect. The Court further ruled that, in any event, the petitioner failed to establish that the MTC committed grave abuse of discretion. The MTC’s exclusion of evidence and evaluation of the prosecution’s case constituted, at most, an error of judgment, not a capricious, whimsical, or arbitrary act equivalent to lack of jurisdiction. The Court noted the prosecution’s failure to present crucial evidence, such as the original video recording allegedly showing the theft, and found no patent gross abuse of discretion by the MTC.