Title
Aguinaldo vs. Ventus
Case Decision Date
G.R. No. 176033 Mar 11, 2015
The Supreme Court rules in favor of the respondents, affirming the decision of the
Court of Appeals, stating that the public respondent erred in reinstating the case and
issuing an arrest warrant based on a motion filed by a non-party, and directs the
remand of the case to the trial court for trial on the merits with strict observance of the
rules on arraignment and completion of the preliminary investigation.
Case Digest (G.R. No. 176033)
Comprehensive
Facts:
Petitioners: Felilibeth Aguinaldo and Benjamin Perez.
Respondents: Reynaldo P. Ventus and Jojo B. Joson.
Date: December 2, 2002.
Complaint: Ventus and Joson filed a Complaint-Affidavit for estafa against Aguinaldo
and Perez before the Office of the City Prosecutor (OCP) of Manila.
Allegation: Aguinaldo and Perez convinced Ventus and Joson to part with PHP 260,000
in exchange for a pledge of two motor vehicles.
Misrepresentation: Vehicles were claimed to be owned by Aguinaldo but were actually
owned by Levita De Castro, manager/operator of LEDC Rent-A-Car.
Perez's Defense: Denied accusations, claiming his involvement was limited to
introducing the parties.
Prosecutor's Recommendation: Assistant City Prosecutor Renato F. Gonzaga
recommended indicting both petitioners for estafa under Article 315, paragraph (2) of
the Revised Penal Code (RPC).
Information Filed: July 16, 2003.
Perez Arrested: July 31, 2003.
Petitioners' Motions: Filed various motions, including a motion for reconsideration
and a motion to quash the arrest warrant.
Case Status: Archived pending resolution of their motion for reconsideration.
OCP's Action: Moved to set the case for trial.
Petition for Review: Filed with the Department of Justice (DOJ).
Public Respondent's Action: Issued an arrest warrant against Aguinaldo and set the
case for arraignment despite the pending petition.
Court of Appeals (CA): Dismissed petitioners' plea for lack of merit.
Supreme Court: Affirmed the CA's decision and directed the remand of the case to the
trial court for trial on the merits.
Issue:
1. Did the public respondent err in reinstating the case and issuing an arrest warrant
based on a motion filed by a non-party?
2. Can the procedural rule limiting the suspension of arraignment to 60 days be relaxed
in the interest of justice?
3. Was the preliminary investigation of the estafa case completed, thereby ensuring the
petitioners' right to due process?
Ruling:
1. Yes, the public respondent erred in reinstating the case and issuing an arrest warrant
based on a motion filed by a non-party.
2. No, the procedural rule limiting the suspension of arraignment to 60 days cannot be
relaxed in this case.
3. Yes, the preliminary investigation was completed, ensuring the petitioners' right to due
process.
Ratio:
Error in Reinstating Case: The Supreme Court found that the public respondent erred
in reinstating the case and issuing an arrest warrant based on a motion filed by Levita
De Castro, who was not a party to the case.
Role of De Castro: De Castro was merely a witness and not a private complainant, and
her motion should have been treated as a mere scrap of paper with no legal effect.
Erroneous Reliance: The Court noted that the public respondent erroneously relied on
a DOJ resolution dismissing a petition for review in a different case.
Procedural Rule on Arraignment: The Court held that the rule limiting the suspension
of arraignment to 60 days is mandatory and cannot be relaxed.
Jurisprudence: The Court cited previous jurisprudence emphasizing the importance
of adhering to reglementary periods to prevent needless delays and ensure the orderly
and speedy discharge of judicial business.
Completion of Preliminary Investigation: The Court found that the preliminary
investigation was completed, as petitioners were given the opportunity to be heard and
to file motions for reconsideration.
Due Process: The Court emphasized that due process demands an opportunity to be
heard, which was afforded to the petitioners in this case.
Affirmation and Remand: The Supreme Court affirmed the CA's decision and directed
the remand of the case to the trial court for trial on the merits, with strict observance of
the rules on arraignment and completion of the preliminary investigation.
