People vs. Montilla

The doctrine of judicial stability or non-interference by co-equal courts does not apply when a case is transferred from one RTC branch to another pursuant to a valid change of venue ordered by the Supreme Court; jurisdiction over the case is vested in the court to which the venue is transferred, which may exercise all inherent powers, including amending or reversing prior orders. Furthermore, a judicial determination of lack of probable cause by the court to which the case is assigned is a valid ground for dismissal.

The case originated from a 2004 double murder charge filed in RTC-Cotabato City for killings that occurred in 2003. After a protracted procedural history involving multiple reinvestigations and conflicting prosecutorial resolutions, respondents Montilla and Lapuz were included as accused. Montilla successfully petitioned for a change of venue, which was granted by the Supreme Court in 2011, transferring the case to RTC-Davao City. The case was raffled to Branch 11, then to Branch 16 after the Branch 11 judge inhibited herself. In 2014, RTC-Davao City, Branch 16 motu proprio dismissed the case against both accused for lack of probable cause. This dismissal was challenged, leading to the present petitions.

• Nature of the Case: Criminal Case No. 034-SA for double murder was filed in RTC-Cotabato City, Branch 15, for the 2003 killings of Richard Escobia and Aileen Palmes-Lustre.
• Inclusion of Respondents: After reinvestigation, Assistant Provincial Prosecutor Yanson filed a Second Amended Information in 2007/2008 including Montilla and Lapuz as accused, based chiefly on the counter-affidavit of a co-accused (Imelda Reyes).
• Change of Venue: Montilla successfully petitioned the Supreme Court for a change of venue due to alleged bias. The case was transferred to RTC-Davao City, Branch 11, in 2011.
• Conflicting RTC Orders: The case was later raffled to RTC-Davao City, Branch 16. On October 10, 2014, Branch 16 motu proprio dismissed the case against Montilla and Lapuz, finding the evidence insufficient to establish probable cause. The prosecution moved for inhibition, and the case was re-raffled to Branch 15.
• Reinstatement and Appeal: On December 10, 2015, RTC-Davao City, Branch 15 granted the prosecution's motion for reconsideration, reinstated the case, and ordered the issuance of alias warrants, applying the doctrine of judicial stability. Montilla appealed to the CA.
• CA Ruling: The CA reversed Branch 15's order and reinstated Branch 16's dismissal, finding the doctrine of judicial stability misapplied as the conflict involved the same case transferred via a sanctioned change of venue.
• Death of Montilla: Montilla died on June 6, 2021, during the pendency of the petitions before the Supreme Court.

• People of the Philippines (G.R. No. 241911):
  • Proper Remedy: Argued that a Rule 65 petition for certiorari is not the proper remedy to assail an order denying a motion to quash an information; the proper recourse is to proceed to trial and appeal any adverse judgment.
  • Existence of Probable Cause: Maintained that probable cause to indict Lapuz existed based on the prosecutor's resolution, and the RTC-Davao City, Branch 16 erred in dismissing the case.
• Spouses Palmes (G.R. No. 242375):
  • Doctrine of Judicial Stability: Argued that RTC-Davao City, Branch 16 could not interfere with or reverse the orders of RTC-Cotabato City, Branch 15, which had previously found probable cause and issued warrants.
  • Violation of Due Process: Contended that the dismissal order was issued without affording the private complainants (Spouses Palmes) due process.

• Respondent Doris P. Lapuz:
  • Lack of Probable Cause: Countered that the evidence against her was insufficient, consisting mainly of uncorroborated allegations from a co-accused with a motive to implicate her.
  • Jurisdiction vs. Venue: Argued that the change of venue transferred jurisdiction to the RTC-Davao City, which had the inherent power to correct itself and dismiss the case for lack of probable cause.
  • Applicability of Doctrine: Maintained that the doctrine of judicial stability did not apply because the conflicting orders came from different branches handling the same case after a valid transfer of venue.

• Effect of Death: Whether the death of respondent Angelo Montilla during the appeal extinguished his criminal liability.
• Doctrine of Judicial Stability: Whether the doctrine of judicial stability prevented RTC-Davao City, Branch 16 from dismissing a case that had been previously acted upon by RTC-Cotabato City, Branch 15.
• Judicial Determination of Probable Cause: Whether the Court of Appeals erred in reinstating the dismissal order of RTC-Davao City, Branch 16 for lack of probable cause against respondent Doris Lapuz.

• Effect of Death: Yes. The death of the accused pending appeal of his conviction extinguishes both his criminal liability and the civil liability based solely thereon. Accordingly, Criminal Case No. 034-SA is dismissed insofar as Angelo Montilla is concerned.
• Doctrine of Judicial Stability: No. The doctrine of judicial stability or non-interference by co-equal courts is inapplicable. The transfer of the case from RTC-Cotabato City to RTC-Davao City was pursuant to a valid change of venue sanctioned by the Supreme Court. This transferred jurisdiction over the case to the receiving court. Consequently, RTC-Davao City, Branch 16, acting as the court with jurisdiction, had the inherent authority under Section 5(g), Rule 135 of the Rules of Court to amend or reverse prior orders, including its own, to conform to law and justice.
• Judicial Determination of Probable Cause: No. The Court of Appeals did not err. The judicial determination of probable cause is vested in the trial court judge. RTC-Davao City, Branch 16 personally examined the records and found no probable cause to indict Lapuz. This finding, absent a more recent contrary judicial determination, stands. Furthermore, a review of the evidence confirmed the lack of probable cause, as the accusation was based on the uncorroborated affidavit of a co-accused with a potential motive, and the alleged scenario defied common sense.

• Doctrine of Judicial Stability / Non-Interference by Co-Equal Courts — This doctrine holds that a court which acquires jurisdiction over a case and renders judgment therein has exclusive authority over its judgment, to the exclusion of all other coordinate courts. It is founded on the concept of jurisdiction. The Court clarified that this doctrine does not apply when a case is transferred from one RTC branch to another pursuant to a valid change of venue ordered by the Supreme Court; jurisdiction is vested in the court to which the venue is transferred.
• Judicial Determination of Probable Cause — This is the judge's personal determination, based on the evidence presented, of whether there is sufficient reason to believe that an accused probably committed the crime charged, necessitating the issuance of a warrant of arrest. The judge must personally examine the prosecution's evidence and findings. If the judge finds no probable cause, the information may be dismissed.
• Effect of Death of the Accused Pending Appeal — Pursuant to Article 89(1) of the Revised Penal Code, the death of the accused before final judgment extinguishes criminal liability and the civil liability ex delicto.

• "The doctrine of judicial stability is inapplicable and, absent a more recent judicial determination of probable cause, the RTC-Davao City, Branch 16's finding of lack of probable cause stands." — This passage encapsulates the Court's core reasoning for upholding the dismissal.
• "Allegation is not proof." — A succinct statement reinforcing the evidentiary standard required for a finding of probable cause.
• "No right-thinking person would place himself or herself in such a dangerous position, even to eliminate an enemy." — The Court's application of common sense to discredit the sole basis for implicating Lapuz.

• People v. Monroyo, G.R. No. 223708 (2019) — Cited to support the rule that death of the accused pending appeal extinguishes criminal and civil liability ex delicto.
• First Gas Power Corp. v. Republic, 717 Phil. 44 (2013) — Cited to define the doctrine of judicial stability or non-interference by co-equal courts.
• Radiowealth Finance Company, Inc. v. Pineda, 837 Phil. 419 (2018) — Cited to distinguish between jurisdiction (a matter of substantive law) and venue (a matter of procedural law).
• Tulfo v. People, G.R. No. 237620 (2021) — Cited to state the general rule that a special civil action for certiorari is not the proper remedy to assail a denial of a motion to quash an information; the proper remedy is to proceed to trial.
• Leviste v. Alameda, 640 Phil. 620 (2010) — Cited to explain the nature and procedure of the judicial determination of probable cause.

• Article 89(1), Revised Penal Code — Provides that criminal liability is totally extinguished by the death of the convict, as to personal penalties, and as to pecuniary penalties, liability therefor is extinguished only when death occurs before final judgment.
• Section 5(g), Rule 135, Rules of Court — Provides that every court has the inherent power "[t]o amend and control its process and orders so as to make them conformable to law and justice." This was cited as the basis for the authority of the court to which a case is transferred to amend or reverse prior orders.

• Justice Alfredo Benjamin S. Caguioa (Chairperson)
• Justice Japar B. Dimaampao
• Justice Henri Jean Paul B. Inting
• Justice Maria Filomena D. Singh (Ponente)
• Justice Ramon Paul L. Hernando (Note: Per the Division composition listed, but the decision text attributes the opinion to the Division. The listed concurring justices in the text are Caguioa, Inting, Gaerlan, and Dimaampao.)