In People vs. Montilla, the Supreme Court addressed the complexities of probable cause, judicial stability, and the impact of an accused’s death on criminal liability. The Court affirmed the dismissal of double murder charges against one of the accused due to lack of probable cause, while also acknowledging the extinguishment of criminal liability for the other accused who had passed away during the pendency of the appeal. This decision underscores the importance of a thorough and independent judicial determination of probable cause before a person is formally charged with a crime, ensuring that accusations are grounded in sufficient evidence and not merely based on speculation or conjecture.

From Cotabato to Davao: A Case’s Journey and the Shifting Sands of Justice

The case began with the brutal killing of Richard Escobia and Aileen Palmes-Lustre in Maguindanao, leading to a double murder charge against several individuals. Over time, the case took numerous twists and turns. These included multiple reinvestigations, conflicting resolutions from different prosecutors, and a change of venue from Cotabato City to Davao City due to concerns of bias. Angelo Montilla and Doris Lapuz were eventually included as additional accused, triggering a series of legal challenges regarding the validity of the charges against them.

The RTC-Cotabato City, Branch 15, initially quashed the warrant of arrest against one of the accused, Imelda Reyes, and ordered a reinvestigation. This reinvestigation eventually led to the inclusion of Montilla and Lapuz as additional accused. However, the Provincial Prosecutor filed motions to recall and dismiss the Second Amended Information, alleging it was filed without his approval, thus violating the Rules of Court. Montilla then filed a Petition before the CA, questioning the validity of the Second Amended Information and warrants of arrest.

As the legal wrangling continued, the case was transferred to the RTC-Davao City, Branch 11, following a petition for a change of venue filed by Montilla. The RTC-Davao City, Branch 11, ordered another reinvestigation and suspended the implementation of the warrant of arrest against Montilla. On the other hand, the CA reversed these orders, leading to the issuance of alias warrants of arrest against both Montilla and Lapuz. The RTC-Davao City, Branch 16, then motu proprio dismissed the criminal charges against Montilla and Lapuz for lack of probable cause, setting the stage for the present legal battle.

The RTC-Davao City, Branch 15, reversed the dismissal, citing the doctrine of judicial stability. Montilla elevated the case to the CA, which reinstated the original dismissal. This resulted in the present petitions before the Supreme Court. The Supreme Court, in its decision, had to grapple with several key issues, including the proper application of the doctrine of judicial stability, the determination of probable cause, and the impact of Montilla’s death on the criminal proceedings. The Court’s analysis provides valuable insights into these important legal principles.

First, the Court addressed the issue of Montilla’s death. Citing Article 89 of the Revised Penal Code, the Court emphasized that the death of the accused pending appeal extinguishes their criminal liability, as well as the civil liability based solely on the offense. The Court quoted People v. Monroyo stating:

From this lengthy disquisition, we summarize our ruling herein:

1. Death of the accused pending appeal of his conviction extinguishes his criminal liability[,] as well as the civil liability[.] based solely thereon. As opined by Justice Regalado, in this regard, “the death of the accused prior to final judgment terminates his criminal liability and only the civil liability directly arising from and based solely on the offense committed, i.e., civil liability ex delicto in senso strictiore.”

Thus, the criminal case against Montilla was dismissed due to his death. The Court then proceeded to analyze the issue of probable cause as it relates to Lapuz.

Regarding the doctrine of judicial stability, the Court clarified that this principle, which prevents a court of concurrent jurisdiction from interfering with the judgments of another, was misapplied in this case. The Court noted that the change of venue, sanctioned by the Supreme Court, divested the RTC-Cotabato City, Branch 15, of its jurisdiction and transferred it to the RTC-Davao City, Branch 16. As such, the RTC-Davao City, Branch 16, had the authority to act on the case, including the power to amend or reverse prior orders pursuant to its inherent powers under Section 5(g), Rule 135 of the Rules of Court:

Sec. 5. Inherent powers of courts. – Every court shall have power:

x x x
(g) To amend and control its process and orders so as to make them conformable to law and justice[.]

The Court then addressed the crucial issue of probable cause. It acknowledged that while a Rule 65 Petition (certiorari) is not the proper remedy to question the denial of a motion to quash an Information, the absence of probable cause, as determined by the RTC-Davao City, Branch 16, justified the dismissal of the criminal charge for double murder. A motion to quash an Information is typically not reviewable via certiorari. This is because the accused has a plain, adequate, and speedy remedy available which is to proceed to trial and seek an acquittal.

However, the Court emphasized the importance of a judicial determination of probable cause, distinguishing it from the executive determination made by the public prosecutor. It referenced Leviste v. Alameda:

The judicial determination of probable cause is one made by the judge to ascertain whether a warrant of arrest should be issued against the accused. The judge must satisfy himself that based on the evidence submitted, there is necessity for placing the accused under custody in order not to frustrate the ends of justice. If the judge finds no probable cause. the judge cannot be forced to issue the arrest warrant. Paragraph (a), Section 5. Rule 112 of the Rules of Court outlines the procedure to be followed by the RTC.

In this case, the RTC-Davao City, Branch 16, found the evidence insufficient to indict Lapuz, a finding that the Court ultimately upheld. The Court reviewed the Resolution of the Asst. Pros. Yanson and the Order of the RTC-Davao City, Branch 16, and agreed with the latter’s finding of a lack of probable cause.

The Court noted that the recommendation to include Lapuz as an accused was primarily based on the allegations of Reyes, one of the accused in the prior Information. Additionally, the Court considered the lack of corroborating evidence for the alleged ill motive of Lapuz, as well as the implausibility of her involvement given her presence at the scene of the crime. As the Court stated, “Allegation is not proof.”

Ultimately, the Supreme Court found no factual circumstance that would lead a reasonable person to believe that Lapuz was probably guilty of the crime. The absence of a well-founded belief in Lapuz’s probable guilt justified the dismissal of the criminal charge against her.

FAQs

What was the key issue in this case?	The primary issue was whether the Court of Appeals erred in reinstating the dismissal of double murder charges against Angelo Montilla and Doris Lapuz due to lack of probable cause. The court also considered the impact of Montilla’s death on his criminal liability.
What is probable cause?	Probable cause is a reasonable ground for belief in certain alleged facts that would induce a reasonably intelligent and prudent person to believe that the accused has committed the crime charged. It is a lower standard than proof beyond reasonable doubt.
What happens when an accused person dies during the appeal process?	Under Article 89 of the Revised Penal Code, the death of the accused pending appeal extinguishes their criminal liability and any civil liability based solely on the offense. This means the case is dismissed and the accused’s estate is not liable for damages arising from the crime.
What is the doctrine of judicial stability?	The doctrine of judicial stability, also known as non-interference, prevents a court of concurrent jurisdiction from interfering with the judgments or orders of another court with jurisdiction over the same subject matter. The aim is to avoid confusion and maintain consistency in the administration of justice.
How does a change of venue affect jurisdiction?	A change of venue does not affect the jurisdiction of the court. Jurisdiction remains with the Regional Trial Court (RTC) of the area where the crime occurred. The change of venue merely moves the location where the trial is conducted.
What is the difference between executive and judicial determination of probable cause?	Executive determination of probable cause is made by the public prosecutor to decide whether to file charges. Judicial determination is made by a judge to decide whether to issue a warrant of arrest, ensuring the accused is not detained without sufficient cause.
Why was the criminal charge against Doris Lapuz dismissed?	The criminal charge against Doris Lapuz was dismissed because the court found a lack of probable cause to indict her. The evidence presented was insufficient to establish a reasonable belief that she was involved in the crime.
Can a motion to quash be questioned via certiorari?	As a rule, a special civil action for certiorari is not the proper remedy to assail the denial of a motion to quash information. The plain and speedy remedy is to proceed to trial and to determine the guilt or innocence of the accused.

This case illustrates the critical role of the courts in safeguarding individual liberties and ensuring that criminal charges are based on solid evidence. The Supreme Court’s decision reinforces the importance of independent judicial review and serves as a reminder that accusations alone are not sufficient to justify criminal prosecution. The ruling underscores that allegations must be substantiated by credible evidence to establish probable cause.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.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: PEOPLE OF THE PHILIPPINES VS. ANGELO O. MONTILLA, G.R. No. 241911, February 08, 2023