Case Digest
G.R. No. 129874, December 27, 2002
Joan M. Flores, Petitioner
vs.
Hon. Francisco C. Joven, Presiding Judge of Branch 29, Regional Trial Court, Bislig, Surigao del Sur, and
Emmanuel Navarro, Respondents.
Ponente: Justice Austria-Martinez
Topic: Special Civil Action for Certiorari, Quashal of Information, Criminal Procedure, and Personality of
the Offended Party to File Certiorari.
FACTS:
Petitioner Joan M. Flores filed a criminal complaint for rape against Emmanuel Navarro and other
individuals on January 23, 1996. After a preliminary investigation, an Information was filed against the
accused. On October 18, 1996, Navarro filed a motion to dismiss on grounds that the Information did not
describe the crime sufficiently. In November 1996, an Amended Information was filed but Navarro filed a
motion to quash it on several grounds, including that the Information failed to identify his participation
in the crime.
On March 4, 1997, the trial court granted Navarro's motion to quash, ruling that the Information did not
show Navarro’s particular participation in the crime. A motion for reconsideration filed by the petitioner
was denied on May 6, 1997. Petitioner then filed a special civil action for certiorari under Rule 65 of the
Rules of Court, challenging the trial court's decision.
Meanwhile, Navarro escaped detention on October 3, 1998, and the trial court later granted the motion
to withdraw the Informations for the other co-accused for insufficiency of evidence.
ISSUES:
1. Whether the petitioner has the personality to file the special civil action for certiorari.
2. Whether the trial court committed grave abuse of discretion in quashing the Information
against Emmanuel Navarro.
RULING:
1. Personality to File Certiorari: The Court ruled that the petitioner, as the private offended party,
has the personality to file a special civil action for certiorari. The Court emphasized that offended
parties in criminal cases, having a sufficient interest in the case, may file such actions, especially
when the ruling affects their right to demand civil liability arising from the offense.
2. Grave Abuse of Discretion: The Court ruled that the trial court committed grave abuse of
discretion in granting the motion to quash. Contrary to the trial court’s finding, the records
showed that Navarro was identified by the petitioner as one of the individuals who sexually
abused her. Petitioner identified Navarro both during the initial investigation and later during a
clarificatory questioning session. The Court also found that the Amended Information was
sufficient, as it properly described the elements of the crime of rape and sufficiently detailed
Navarro’s role in the offense.
DISPOSITIVE PORTION:
The Supreme Court granted the petition for certiorari, nullifying the trial court’s orders of March 4, 1997,
and May 6, 1997. It reinstated Criminal Case No. 1736-B and directed the trial court to proceed with the
case. The Court also directed the issuance of a warrant of arrest against Emmanuel Navarro and the
return of records of related cases to the trial court. Additionally, the Clerk of Court was ordered to
explain why they should not be cited for contempt for improperly elevating case records without
authority.
DOCTRINE:
1. Offended Party’s Right to File Certiorari: The offended party in a criminal case has the right to
file a special civil action for certiorari to question an order of dismissal or other rulings that
deprive them of due process or their rights arising from the criminal offense.
2. Sufficiency of Information: An Information is sufficient if it alleges the essential elements of the
offense, the identity of the accused, and the facts that enable the accused to understand the
charges and prepare their defense. In rape cases, the allegation must include details that
describe the means by which the act was committed.
