Social Security System vs. Seno, Jr.

Once an information is filed in court, the grant or denial of a motion to withdraw the information rests exclusively on the sound discretion of the trial court, which must make an independent assessment of the evidence and not merely rely on the Secretary of Justice's findings; however, a trial court may not direct the conduct of a reinvestigation for the purpose of receiving additional evidence when the information is already filed, as this undermines the court's power to adjudicate and grants relief not prayed for in violation of due process.

JMA Transport Services Corporation, a covered member of the Social Security System (SSS), accumulated delinquent social security contributions from 1997 to 1999. After an initial settlement agreement involving postdated checks failed due to dishonor, the SSS filed a criminal complaint against its Board of Directors for violations of the Social Security Act. The Department of Justice later ordered the withdrawal of the Information, finding the corporation had ceased operations and obligations were settled, but the trial court refused to withdraw the Information based on evidence of continued operations.

• The Initial Delinquency and Settlement: JMA Transport Services Corporation, a domestic corporation and covered SSS member with Identification No. 03-9077846-6, failed to remit social security contributions for the period September 1997 to July 1999, amounting to P838,488.13 inclusive of the 3% monthly penalty. During the preliminary investigation, respondents proposed to settle the obligation through installment payments; respondent Manuel F. Seno, Jr. issued 24 postdated checks totaling P609,370.50. The SSS accepted the checks and provisionally withdrew the complaint.
• The Dishonored Checks and Second Complaint: Two postdated checks were dishonored by the drawee-bank due to its merger with another bank. The SSS notified JMA Transport to replace the checks, but the company failed to do so. Consequently, the SSS filed a second Complaint-Affidavit alleging unpaid obligations aggregating P4,903,267.52, which included the previous delinquency plus additional unpaid contributions from August 1999 to June 2004 (P2,200,470.26) and penalties thereon (P2,702,797.26).
• Respondents' Defense: Manuel Seno refuted the claims, asserting that JMA Transport had ceased operations in July 1999, thereby negating liability for contributions accruing after that date. He maintained that the delinquent contributions as of July 1999 had been settled by the postdated checks, and that the dishonor was caused by the bank merger, not by any breach on his part. Fernando Gorrospe and Gemma Seno denied participation in matters relating to SS contributions, claiming they never handled such matters as directors.
• DOJ Resolution: The DOJ reversed the OCP's finding of probable cause via Resolution dated January 31, 2006, holding that JMA Transport ceased operations in July 1999 and that the unpaid delinquent contributions had been settled by Manuel Seno's checks. The DOJ ordered the OCP to cause the withdrawal of the Information.
• RTC Proceedings: The prosecution filed a Motion to Withdraw Information before the RTC in accordance with the DOJ Resolution. In its Order dated May 29, 2006, the RTC denied the motion, finding that three Franchise Verifications issued by the LTFRB—attached to the SSS's Reply-Affidavit dated December 8, 2004—showed JMA Transport was in active status from August 13, 2003 or June 4, 2004 until March 31, 2006, contradicting respondents' claim of cessation in 1999. Respondants filed a Motion for Reconsideration, arguing that the Franchise Verifications were not attached to the Reply-Affidavit furnished to them. In its Order dated September 25, 2006, the RTC did not grant or deny the motion for reconsideration; instead, it directed the public prosecutor to conduct reinvestigation for the purpose of receiving respondents' controverting evidence regarding the Franchise Verifications.

• Existence of Franchise Verifications: SSS maintained that the Franchise Verifications were actually appended to its Reply-Affidavit and numbered accordingly, contrary to the CA's finding that they were absent from the records.
• Validity of the May Order: The trial court did not gravely abuse its discretion in denying the withdrawal of the Information; it correctly exercised its independent judicial discretion to assess the evidence, finding probable cause based on documents showing JMA's continued operations.
• Propriety of Reinvestigation: The directive to conduct reinvestigation in the September Order undermined the trial court's authority to adjudicate the case and improperly granted relief not prayed for by respondents, violating the SSS's right to due process.

• Absence of Evidence: Respondents insisted the Franchise Verifications were not appended to SSS's Reply-Affidavit, and their copies contained no such attachments, rendering the May Order based on non-existent evidence.
• Grave Abuse in May Order: The trial court gravely abused its discretion by relying on documents not presented as evidence during preliminary investigation and by contradicting the DOJ's findings without basis.
• Grave Abuse in September Order: The trial court erred in directing reinvestigation instead of resolving their motion for reconsideration, a relief they never prayed for, thereby violating their constitutional rights and usurping the executive department's function.

• Judicial Discretion to Deny Withdrawal: Whether the Court of Appeals erred in ruling that the Regional Trial Court gravely abused its discretion in denying the motion to withdraw the Information.
• Propriety of Judicially-Directed Reinvestigation: Whether the Court of Appeals correctly ruled that the Regional Trial Court gravely abused its discretion in directing the prosecution to conduct reinvestigation.

• Judicial Discretion to Deny Withdrawal: The CA erred in annulling the May 29, 2006 Order. The trial court did not gravely abuse its discretion in denying the motion to withdraw the Information. Pursuant to Crespo v. Mogul and Santos v. Orda, Jr., once an information is filed in court, the trial court becomes the sole judge of whether to grant or deny a motion to withdraw, and must make an independent assessment of the evidence rather than merely rely on the Secretary of Justice's findings. The Franchise Verifications were indeed attached to the Reply-Affidavit, giving the trial court factual basis to find probable cause and deny withdrawal.
• Propriety of Judicially-Directed Reinvestigation: The CA correctly declared the September 25, 2006 Order null and void. The trial court gravely abused its discretion by directing the prosecution to conduct reinvestigation to receive additional evidence. This directive undermined the court's power to adjudicate the case before it and granted relief not prayed for by respondents, violating the SSS's right to due process against surprise.

• Exclusive Judicial Discretion Post-Filing: Once a complaint or information is filed in court, any disposition—including dismissal or continuation—rests exclusively on the sound discretion of the trial court, which becomes the best and sole judge of the case. The trial court must make an independent assessment of the merits based on affidavits, counter-affidavits, documents appended to the information, and records of the public prosecutor, rather than merely relying on the findings of the prosecutor or Secretary of Justice.
• Prohibition on Judicially-Directed Reinvestigation: A trial court may not direct the public prosecutor to conduct reinvestigation for the purpose of receiving additional evidence once the information is already filed. Such a directive undermines the court's adjudicative authority and improperly delegates the court's duty to independently assess the evidence. The court should instead order parties to submit additional evidence and admit the same during hearings if warranted.
• Relief Limited to Prayer: Courts cannot grant relief not prayed for in the pleadings or in excess of what is sought. Due process requires that parties be afforded notice and opportunity to be heard regarding the specific relief sought; granting unprayed-for relief constitutes surprise and violates the "sporting idea of fair play."

• "It is a settled rule that only questions of law may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court. This Court is not a trier of facts. Hence, it will not entertain questions of facts as it is bound by the findings of fact made by the CA when supported by substantial evidence."
• "In Crespo v. Mogul, the Supreme Court held that once a complaint or information is already filed in court, any disposition of the case such as its dismissal or its continuation rests on the sound discretion of the court. It is the best and sole judge on what to do with the case before it."
• "Verily, to direct the prosecution to reinvestigate the case for the purpose of admitting additional evidence would clearly undermine the power of the trial court to adjudicate the case before it. Its directive gave the impression that the trial court might rely on the findings of the prosecution on whether respondents' motion for reconsideration of the assailed May Order denying the withdrawal of Information should be granted or not."
• "It is well-settled that courts cannot grant a relief not prayed for in the pleadings or in excess of what is being sought by a party to a case. Due process considerations justify this requirement. It is improper to enter an order which exceeds the scope of relief sought by the pleadings, absent notice which affords the opposing party an opportunity to be heard with respect to the proposed relief."

• Crespo v. Mogul, 235 Phil. 465 (1987) — Controlling precedent establishing that once an information is filed in court, the trial court has exclusive discretion to grant or deny motions to dismiss or withdraw, and must independently assess the evidence.
• Santos v. Orda, Jr., 481 Phil. 93 (2004) — Followed; reaffirmed the Crespo doctrine and applied it to motions to withdraw information filed before or after arraignment.
• Medina v. Asistio, Jr., 269 Phil. 225 (1990) — Cited for the enumeration of exceptions where the Supreme Court may review findings of fact by the Court of Appeals.
• Bucal v. Bucal, 760 Phil. 912 (2015) and Development Bank of the Philippines v. Teston, 569 Phil. 137 (2008) — Cited for the doctrine that courts cannot grant relief not prayed for in the pleadings.

• Section 22(a), Republic Act No. 1161 (Social Security Act), as amended by Republic Act No. 8282 — Mandates remittance of contributions within the first ten days of each calendar month; imposes penalty for non-remittance.
• Section 22(d), Republic Act No. 1161 — Presumption regarding last complete record of monthly contributions.
• Section 28(e), Republic Act No. 1161 — Penal provision for failure or refusal to comply with the Act or rules, including failure to deduct and remit contributions.
• Section 28(f), Republic Act No. 1161 — Liability of managing heads, directors, or partners of associations, partnerships, or corporations for offenses committed by the entity.
• Rule 45, Rules of Court — Governs petitions for review on certiorari, limited to questions of law.

Perlas-Bernabe (Chairperson), A. Reyes, Jr., Inting, and Delos Santos, JJ.