Gatdula vs. People of the Philippines

Rulings of a trial court on procedural questions and on the admissibility of evidence during trial are interlocutory and may not be the subject of a separate appeal or review on certiorari; they are to be assigned as errors and reviewed in the appeal from the decision on the merits. A trial court must rule on a demurrer to evidence, either granting or denying it; if it defers resolution until after the accused presents evidence, it must expressly deny the demurrer, but such error is not jurisdictional and certiorari is not available to correct errors of judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction.

Eduardo E. Gatdula was the accused in a criminal case for violation of Presidential Decree No. 1612 (Anti-Fencing Law) before the Regional Trial Court of Pasay City, with the People of the Philippines as the prosecution. The charge concerned the alleged purchase of a motor vehicle knowing it to have been derived from the proceeds of carnapping.

On August 24, 1994, the City Prosecutor of Pasay City filed with the Regional Trial Court, Pasay City an information charging Eduardo E. Gatdula with violation of Presidential Decree No. 1612 (Anti-Fencing Law). The information alleged that on or about and sometime during the period January 9, 1994 to March 10, 1994, in Pasay City, Gatdula, with intent to gain for himself, willfully, unlawfully, and feloniously bought a motor vehicle, an Isuzu Gemini Sonic Taxi with engine no. 235358 and Serial Chassis no. 5F69DOF203249 valued at P140,000.00, which he knew to have been derived from the proceeds of carnapping.

After presenting their case in chief, on September 29, 1995, the prosecution rested its case and filed its offer of exhibits. On October 9, 1995, Gatdula filed his comment/opposition specifically objecting to the offer of exhibits on the ground that they were taken from him without the presence and assistance of counsel, that they were obtained during his unlawful arrest, and that they were hearsay.

On October 11, 1995, the trial court ordered the admission of all the exhibits of the prosecution and granted Gatdula permission to file a demurrer to evidence. On October 17, 1995, Gatdula filed with the trial court a demurrer to evidence. On October 19, 1995, the trial court issued orders admitting all the evidence of the prosecution and holding the resolution on the demurrer in abeyance until Gatdula had presented evidence. Those orders became the subject of Gatdula's challenge before the appellate courts.

• Grave Abuse of Discretion: Petitioner assailed the trial court's two orders admitting all prosecution evidence and holding resolution on his demurrer in abeyance, arguing that they were issued with grave abuse of discretion amounting to excess or lack of jurisdiction.
• Admissibility Objections: In his comment/opposition to the offer of exhibits, petitioner specifically objected that the exhibits were taken from him without the presence and assistance of counsel, were obtained during his unlawful arrest, and were hearsay.

• Interlocutory Orders and Certiorari: Whether the trial court's orders admitting the prosecution's evidence and holding in abeyance the resolution on petitioner's demurrer to evidence may be challenged by a petition for certiorari.
• Grave Abuse of Discretion: Whether the trial court issued those orders with grave abuse of discretion amounting to excess or lack of jurisdiction.
• Duty to Resolve Demurrer: Whether the trial court must rule on the demurrer to evidence instead of holding its resolution in abeyance until after petitioner presents evidence.

• Interlocutory Orders and Certiorari: No. Rulings on procedural questions and on admissibility of evidence during trial are interlocutory and may not be the subject of a separate appeal or review on certiorari; they are to be assigned as errors in the appeal from the decision on the merits.
• Grave Abuse of Discretion: No. Certiorari is not available to correct errors in judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction.
• Duty to Resolve Demurrer: Yes as to the duty, but no certiorari relief. The trial court must rule either to grant or deny the demurrer; if it intended to deny, it should have expressly denied it. The deferral was not jurisdictional, and denial of a demurrer may be subject to certiorari only if there was grave abuse of discretion.

• Interlocutory Orders and Certiorari: The established principle is that trial court rulings on procedural questions and admissibility of evidence during trial are interlocutory and not subject to separate appeal or certiorari; otherwise, there would be no end to trial, as any litigant dissatisfied with an evidentiary ruling could indefinitely tie up the trial by elevating it for appellate review. They are to be assigned as errors and reviewed in the appeal from the decision on the merits. The question whether the evidence presented by the prosecution at the time it rests is sufficient to convince the court of guilt beyond reasonable doubt rests entirely within the sound discretion and judgment of the lower court. In Joseph vs. Villaluz, the court cannot, in a special civil action for certiorari and prohibition, decide whether the prosecution evidence has established guilt beyond reasonable doubt. Thus, certiorari was not proper.
• Grave Abuse of Discretion: The trial court must rule either to grant or deny the demurrer to evidence; it has a specific duty under the Rules to act on the demurrer. The denial of the demurrer may be the proper subject of a petition for certiorari if there was grave abuse of discretion. Here, the trial court may have intended to deny the demurrer by deferring resolution until petitioner adduced evidence; in such case, it must expressly deny the demurrer. Nevertheless, the error is not jurisdictional, and certiorari is not available to correct errors in judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction. The petition was therefore without merit.
• Duty to Resolve Demurrer: Under the Rules, the trial court has a specific duty to act on petitioner's demurrer, either granting or denying it. It cannot simply leave the demurrer unresolved indefinitely. However, its deferral until after petitioner presented evidence was treated as a possible intended denial, which should have been express. The error did not oust jurisdiction and did not amount to grave abuse correctable by certiorari.

• Interlocutory orders and the prohibition on certiorari — Trial court rulings on procedural questions and admissibility of evidence during trial are interlocutory; they may not be the subject of a separate appeal or review on certiorari. They are to be assigned as errors and reviewed in the appeal properly taken from the decision on the merits. The Court applied this to the orders admitting prosecution exhibits and deferring the demurrer.
• Rationale against piecemeal review — If interlocutory evidentiary rulings could be elevated immediately, there would be no end to trial, as any litigant dissatisfied with a ruling admitting or excluding evidence could indefinitely tie up the trial. This supported denial of certiorari.
• Sound discretion on sufficiency of prosecution evidence — Whether the evidence presented by the prosecution at the time it rests is sufficient to convince the court that the accused is guilty beyond reasonable doubt rests entirely within the sound discretion and judgment of the lower court. Certiorari and prohibition cannot be used to decide that question.
• Duty to resolve a demurrer to evidence — The trial court must rule either to grant or deny a demurrer to evidence; it has a specific duty under the Rules to act on the demurrer. If it defers resolution until after the accused presents evidence, it must expressly deny the demurrer. The denial may be a proper subject of certiorari only if there was grave abuse of discretion.
• Certiorari not available for errors of judgment — Certiorari is not available to correct errors in judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction. The trial court's deferral of the demurrer, though erroneous, was not jurisdictional.

• "The established principle is that rulings of the trial court on procedural questions and on admissibility of evidence during the course of a trial are interlocutory in nature and may not be the subject of separate appeal or review on certiorari, but are to be assigned as errors and reviewed in the appeal properly taken from the decision rendered by the trial court on the merits of the case." — This states the ratio decidendi for denying certiorari over the trial court's interlocutory evidentiary orders.
• "If the rule were otherwise, there simply would be no end to the trial of cases, for any litigant, not satisfied with the trial court's ruling admitting or excluding any profferred oral or documentary evidence, would then indefinitely tie up the trial while elevating the ruling for review by the appellate court." — This explains the policy against piecemeal review of evidentiary rulings.
• "On the other hand, the trial court must rule either to grant or deny the demurrer to evidence filed by petitioner. The trial court has a specific duty under the Rules to act on petitioner's demurrer to evidence, either by granting or denying the same." — This defines the trial court's duty on a demurrer to evidence.
• "Perhaps, the trial court really wanted to deny the demurrer to evidence that is why it deferred resolution thereon until petitioner has adduced evidence. In such case, the court must expressly deny the demurrer. Nevertheless, the error is not jurisdictional, and certiorari is not available to correct errors in judgment or conclusions of law and fact not amounting to excess or lack of jurisdiction." — This addresses the deferral of the demurrer and why certiorari did not lie despite the procedural error.

• Peza vs. Alikpala, 160 SCRA 31, 35 [1988]; Lamagan vs. de la Cruz, 148-B Phil. 86, 92 [1971]; Resoso vs. Sandiganbayan, 319 SCRA 238 [1999] — Cited for the established principle that trial court rulings on procedural questions and admissibility of evidence during trial are interlocutory and not subject to separate appeal or certiorari.
• Lamagan vs. de la Cruz, 148-B Phil. 86, 92 [1971] — Cited for the rationale that allowing immediate review of evidentiary rulings would lead to no end to trial and permit litigants to tie up proceedings.
• United States vs. Romero, 22 Phil. 565, 569 [1912]; People vs. Mercado, 159 SCRA 453, 459 [1988] — Cited for the rule that the sufficiency of the prosecution's evidence at the time it rests is addressed to the sound discretion and judgment of the lower court.
• Joseph vs. Villaluz, 89 SCRA 324 [1979] — Cited for the holding that a court cannot, in a special civil action for certiorari and prohibition, decide whether the prosecution's evidence has established the accused's guilt beyond reasonable doubt.

• Presidential Decree No. 1612 (Anti-Fencing Law) — The information charged petitioner with violation of this law for allegedly buying a motor vehicle knowing it was derived from the proceeds of carnapping.
• Rule 119, Section 15, 1985 Rules of Criminal Procedure, as amended — Cited as the basis for the trial court's specific duty to act on a demurrer to evidence, either by granting or denying it. The Court referenced it in discussing the trial court's obligation to rule on petitioner's demurrer.

Davide, Jr., C.J.; Puno, J.; Kapunan, J.; and Ynares-Santiago, J.