TL;DR
The Supreme Court affirmed the Sandiganbayan’s denial of a motion to quash in an anti-graft case, emphasizing that certiorari is not the proper remedy for interlocutory orders. The Court clarified that denials of motions to quash are not immediately appealable and should instead be addressed during a full trial and subsequent appeal if necessary. The petitioner’s claim that the information was invalid due to lack of proper Ombudsman approval was rejected, as such defects are considered formal and non-jurisdictional. The ruling underscores the principle that judicial processes should proceed efficiently, with procedural challenges addressed within the ordinary course of trial and appeal, rather than through premature certiorari petitions.
Procedural Hurdles: Radaza’s Certiorari Bid to Halt Graft Trial Fails at Supreme Court
In Radaza v. Sandiganbayan, the petitioner, a former city mayor, sought to overturn the Sandiganbayan’s denial of his motion to quash the amended information charging him with violation of the Anti-Graft and Corrupt Practices Act. Radaza argued that the Sandiganbayan committed grave abuse of discretion by proceeding with the case despite alleged defects in the information, specifically questioning the authority of the Ombudsman who approved the filing. This case highlights the crucial distinction between interlocutory orders and final judgments, and the limited scope of certiorari as a remedy in Philippine remedial law. The central legal question before the Supreme Court was whether the Sandiganbayan acted with grave abuse of discretion in denying the motion to quash, thereby warranting the extraordinary remedy of certiorari.
The Supreme Court firmly dismissed Radaza’s petition, citing the fundamental principle that motions to quash are interlocutory orders, and as such, are generally not reviewable via certiorari. The Court reiterated that the proper recourse for a denied motion to quash is to proceed with the trial, and if convicted, to raise the alleged errors as grounds for appeal. This procedural stance aims to prevent piecemeal appeals that would unduly delay the resolution of cases. The Court emphasized that certiorari is a remedy of last resort, available only when there is no other plain, speedy, and adequate remedy in the ordinary course of law. In this instance, proceeding to trial was deemed a readily available and adequate remedy, precluding the necessity for certiorari.
Moreover, the Supreme Court addressed Radaza’s assertion of grave abuse of discretion, clarifying the distinction between errors of judgment and errors of jurisdiction. An error of judgment, occurring within the court’s jurisdiction, is correctable via appeal, while an error of jurisdiction, exceeding or acting without jurisdiction, is the proper subject of certiorari. The Court found that Radaza’s arguments essentially challenged the Sandiganbayan’s appreciation of evidence and application of law, which constitute errors of judgment, not grave abuse of discretion. Grave abuse of discretion, the Court explained, implies a capricious, whimsical, or arbitrary exercise of judgment, tantamount to lack of jurisdiction, which was not evident in the Sandiganbayan’s resolutions.
Radaza contended that the Amended Information was invalid because it lacked the approval of the incumbent Ombudsman at the time of filing, arguing that the previous Ombudsman’s authority had become functus officio. However, the Supreme Court, referencing the precedent set in Gomez v. People, clarified that the lack of authority of the filing officer is not a jurisdictional defect. While Section 3(d), Rule 117 of the Rules of Court lists lack of authority as a ground to quash, the Court emphasized that this is a formal, non-jurisdictional defect, curable at any stage of the proceedings. The Court underscored that jurisdiction is conferred by substantive law, not by procedural formalities like the specific authorization of the filing officer. The Sandiganbayan, therefore, had properly acquired jurisdiction over the offense and the person of Radaza.
Furthermore, the Court noted that Radaza had actively submitted to the Sandiganbayan’s jurisdiction by filing motions, seeking bail, and even undergoing conditional arraignment to travel abroad. These actions, the Court reasoned, constituted a voluntary submission to the court’s authority, precluding any subsequent challenge to jurisdiction over his person. The Court also highlighted that the allegations in both the original and amended informations sufficiently established a prima facie case for violation of RA 3019, placing the case squarely within the Sandiganbayan’s jurisdiction. The Court presented a comparative table to illustrate the key allegations in both informations, demonstrating the consistent charges against Radaza:
| Original Information (Sec. 3(g)) | Amended Information (Sec. 3(e)) |
|---|---|
| Accused of violating Section 3(g) of RA 3019 for entering into a manifestly and grossly disadvantageous contract. | Accused of violating Section 3(e) of RA 3019 for causing undue injury or giving unwarranted benefit through manifest partiality, evident bad faith, or inexcusable negligence. |
| Action involved preparing and approving Program of Works and Detailed Estimates, conducting bidding, and awarding contract to FABMIK Construction. | Action involved preparing Program of Works and Estimates, Approved Budget for the Contract, conducting procurement without legal requirements, and awarding project at excessive price. |
| Contract was for street lighting facilities, deemed manifestly and grossly disadvantageous to the government due to overpricing. | Contract was for street lighting facilities, resulting in unwarranted benefits to FABMIK and damage to the government due to excessive pricing and irregular procurement. |
In conclusion, the Supreme Court’s decision in Radaza v. Sandiganbayan reinforces the procedural boundaries of certiorari and underscores the principle of judicial economy. It clarifies that interlocutory orders, such as denials of motions to quash, are not immediately reviewable by certiorari, and that formal defects in informations, like lack of specific Ombudsman approval, do not automatically invalidate criminal proceedings or deprive courts of jurisdiction. The ruling serves as a reminder that procedural challenges should generally be addressed within the framework of trial and appeal, allowing for the efficient administration of justice.
FAQs
| What is an interlocutory order? | An interlocutory order is a court order that does not finally resolve the entire case but deals with preliminary or intermediate matters. A denial of a motion to quash is considered an interlocutory order. |
| Why is certiorari generally not allowed for interlocutory orders? | To prevent delays and piecemeal appeals. Allowing certiorari for every interlocutory order would disrupt trial proceedings and prolong case resolution. |
| What is grave abuse of discretion? | Grave abuse of discretion is the capricious, whimsical, or arbitrary exercise of judgment, equivalent to lack of jurisdiction. It is more than just a simple error of judgment. |
| Is the lack of Ombudsman approval a fatal defect in an information? | No, according to Gomez v. People, it is a formal, non-jurisdictional defect that can be cured and does not invalidate the information or deprive the court of jurisdiction. |
| How does a court acquire jurisdiction over a criminal case? | Jurisdiction over a criminal case is determined by the allegations in the information and is conferred by substantive law, not procedural formalities. |
| What are the practical implications of this ruling for those accused in court? | Accused individuals cannot immediately appeal denials of motions to quash via certiorari. They must proceed to trial and raise their objections during a regular appeal if convicted. |
For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Radaza v. Sandiganbayan, G.R. No. 201380, August 04, 2021
Leave a Reply