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People of the Philippines, Petitioner, vs. Hon.

Basilio Gabo in his capacity as Presiding Judge of the RTC of


Malolos Bulacan Branch II, Respondent
G.R. No. 166411 | August 3, 2010 | Peralta, J.

SUMMARY: On May 14, 2001, around 12:15 a.m., a fire broke out inside the plant of Sanyoware Plastic Products
Manufacturing Corporation (Sanyoware). Investigations were conducted by the Philippine 3rd Regional
Criminal Investigation and Detention Group (CIDG) and the Inter Agency Anti-Arson Task Force (IATF) of the
Department of the Interior and Local Government and the respondent were accused of destructive arson. In
support of the accusation, petitioner submitted the Sworn Statements of Richard Madrideo, Jaime Kalaw,
Raymund Dy, Chit Chua, Jennifer Chua Reyes, Shanda Amistad, SPO1 Valeriano Dizon and Inspector Allan N.
Barredo, which contains the following:

That the respondent was threatened to write a sworn statement against his will wherein if anyone ask
about the fire he would say that it did not break out simultaneously and its cause was a defective wiring.
That a week before the fire occurred, almost 300 unserviceable molds were transferred to the burned
Sanyoware warehouse. A day before the fire, expensive finished products were loaded in delivery trucks
and saw the respondent took a rectangular shape object from his vehicle.
That saleable products from the burned warehouse were transferred to the Sanyo City Warehouse,
while unusable components from the Sanyo City warehouse were transferred to the burned warehouse
which was ordered to finish on May 12, 2001.
That an employee at the Accounting Department claimed that the company was indebted to many
banks and corporation.

Respondent submitted a Counter-Affidavit to refute the allegations, it states that the ocular inspection was not
conducted and the Inter Agency Anti-Arson Task Force (IATF) did not even conducted any investigation, except
to ask the witnesses of complainant to identify under oath their sworn statements executed before the
complainant and to ask respondents to submit their sworn statements and later to identify the same under
oath.

Respondents filed a Motion to Conduct Hearing to Determine Probable Cause and to Hold in Abeyance the
Issuance of Warrant of Arrest Pending Determination of Probable Cause. Due to lack of probable cause, the RTC
Dismissed the case which the Court of Appeals affirmed. And it is now a petition for certiorari to set aside the
previous resolution. Petitioner alleged that the respondent court lacked or exceeded its jurisdiction or
committed grave abuse of discretion in its resolution when it applies the equipoise rule in dismissing the case.

DOCTRINE:
The sole office of writ of certiorari is the correction of errors of jurisdiction, including the commission
of grave abuse of discretion amounting to lack of jurisdiction and does not include correction of public
respondent's evaluation of the evidence and factual findings based thereon. An error of judgment that
the court may commit in the exercise of its jurisdiction is not correctible through the original special civil action
of certiorari. The reliance of the RTC in equipoise rule is misplaced but does not equate to an abuse of discretion
on the part of the RTC, but merely an error of judgment

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