The Supreme Court has affirmed that the proper recourse against the denial of a motion to quash is to proceed to trial, and if the decision is adverse, to raise the denial as an error on appeal. The denial of a motion to quash, being an interlocutory order, is not immediately appealable or subject to a petition for certiorari because there are other remedies available under the law. This ruling underscores the importance of adhering to established procedural rules and respecting the trial court’s jurisdiction to hear and receive evidence.

When Neighbors Clash: Can a Motion to Quash Sidestep a Trial?

This case stems from a mauling incident between neighbors, Godofredo Enrile and Dr. Frederick Enrile, and the Morano family. Criminal complaints for less serious physical injuries were filed against the Enriles. The petitioners, Godofredo and Dr. Frederick Enrile, sought to quash the informations filed against them, arguing that the complaints lacked essential elements of the crime. When the Municipal Trial Court (MTC) denied their motion to quash, they filed a special civil action for certiorari with the Regional Trial Court (RTC), which was also dismissed. The Enriles then elevated the matter to the Court of Appeals (CA), which similarly dismissed their petition, leading to the present appeal before the Supreme Court.

At the heart of the Enriles’ argument was the contention that the complaints for less serious physical injuries were deficient because they lacked sufficient evidence to establish that the medical attendance rendered to the complainants lasted for a period exceeding ten days. The petitioners claimed that the medical certificates attached to the complaints merely stated the ‘probable disability period of healing’ and were speculative. This raised a critical question: When can a motion to quash be successfully invoked to prevent a trial on the merits? The Supreme Court, in resolving this issue, reiterated fundamental principles of criminal procedure.

The Supreme Court emphasized that a motion to quash is a procedural tool used to challenge the validity of a complaint or information on its face. Section 3, Rule 117 of the Rules of Court provides an enumeration of the grounds for quashing a complaint or information. The grounds include situations where the facts charged do not constitute an offense, the court lacks jurisdiction, the complaint does not conform to the prescribed form, or the criminal action has been extinguished, among others. The Court highlighted that the sufficiency of a complaint or information is determined by whether the facts alleged, if hypothetically admitted, constitute the elements of the offense.

In this case, the crime charged was less serious physical injuries, as defined under Article 265 of the Revised Penal Code:

Article 265.  Less serious physical injuries – Any person who shall inflict upon another physical injuries x x x which shall incapacitate the offended party  for labor for ten days or more, or shall require medical assistance for the same period, shall be guilty of less serious physical injuries and shall suffer the penalty of arresto mayor.

The elements of less serious physical injuries are: (1) the offender inflicted physical injuries upon another; and (2) the physical injuries incapacitated the victim for labor for 10 days or more, or required medical assistance for more than 10 days. The Court found that the complaints sufficiently averred these elements. The complaints stated that the petitioners attacked the complainants, inflicting physical injuries that would require medical attention and incapacitate them for a period of ten days or more. According to Section 6, Rule 110 of the Rules of Court, the complaints only needed to aver the ultimate facts constituting the offense. Evidence, such as the medical certificates, is more appropriately presented during trial.

Building on this principle, the Court disagreed with the petitioners’ insistence that the complaints should be dismissed for lack of evidence regarding the duration of medical attendance. The Court clarified that the presentation of medical certificates to prove the duration of the victims’ need for medical attention should take place only at the trial, not during the preliminary investigation. Citing Cinco v. Sandiganbayan, the Court reiterated that a preliminary investigation is merely inquisitorial, intended to determine whether there is probable cause to charge a person with a crime, not to serve as a trial on the merits.

Furthermore, the Supreme Court found that the petitioners had disregarded the fundamental conditions for initiating a special civil action for certiorari. The petitioners failed to demonstrate that the MTC lacked jurisdiction or gravely abused its discretion in denying the motion to quash. Additionally, because the denial was an interlocutory order, the petitioners had a plain, speedy, and adequate remedy in the ordinary course of law: to proceed to trial and, if convicted, raise the denial of the motion to quash as an error on appeal. The Court cited Lalican v. Vergara, emphasizing that certiorari is not available when an appeal or another adequate remedy exists.

The decision underscores that the proper venue for resolving factual disputes and presenting evidence is the trial court. The role of the trial court is to hear and receive evidence, and to render judgment based on the merits of the case. The Enriles prematurely sought to dismiss the criminal cases against them without allowing the trial court to perform its function. The Supreme Court’s decision reinforces the principle that procedural shortcuts are not favored, and that parties must follow the prescribed legal process.

FAQs

What was the key issue in this case?	The key issue was whether the denial of a motion to quash could be immediately challenged through a petition for certiorari, or whether the proper remedy was to proceed to trial and raise the issue on appeal. The Court affirmed the latter, emphasizing the interlocutory nature of the order.
What is a motion to quash?	A motion to quash is a legal pleading filed by the accused to challenge the validity of a complaint or information before entering a plea. It argues that the charges are insufficient in law or have defects apparent on their face.
What is an interlocutory order?	An interlocutory order is a court order that does not fully and finally resolve all the issues in a case. It is provisional and subject to further review, typically after a final judgment is rendered.
What does it mean to file a certiorari?	Certiorari is a special civil action filed to correct errors of jurisdiction or grave abuse of discretion committed by a lower court. It is an extraordinary remedy, available only when there is no other plain, speedy, and adequate remedy in the ordinary course of law.
What are the elements of less serious physical injuries under the Revised Penal Code?	The elements are (1) the offender inflicted physical injuries upon another; and (2) the physical injuries incapacitated the victim for labor for 10 days or more, or required medical assistance for more than 10 days. These elements must be alleged in the complaint.
When should evidence like medical certificates be presented?	Evidence, such as medical certificates, is typically presented during the trial on the merits, not during the preliminary investigation or in a motion to quash. The trial is the proper forum for establishing facts.
What is the significance of ‘probable cause’ in this context?	Probable cause is a reasonable ground to believe that a crime has been committed and that the accused is likely guilty. It is the standard required for initiating a criminal prosecution and is determined during the preliminary investigation.
What are the implications of this ruling for future cases?	This ruling reinforces the procedural requirement that denials of motions to quash are not immediately appealable. It directs parties to exhaust all available remedies at the trial level before seeking extraordinary relief, ensuring judicial efficiency.

In conclusion, the Supreme Court’s decision in Enrile v. Manalastas clarifies the proper procedural steps when a motion to quash is denied. The Court emphasizes that the appropriate remedy is to proceed to trial and, if necessary, raise the issue on appeal, rather than resorting to premature special civil actions. This decision ensures that the trial court retains its jurisdiction to hear and receive evidence, and that the prescribed legal process is followed.

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: Godofredo Enrile and Dr. Frederick Enrile vs. Hon. Danilo A. Manalastas, G.R. No. 166414, October 22, 2014