### Facts:
On September 28, 2000, seven Informations were filed before the Regional Trial Court (RTC) of Manila against several individuals, including Jose C. Go and Aida C. Dela Rosa, for Estafa through Falsification of Commercial Documents involving P159,000,000.00 from Orient Commercial Banking Corporation. Delays predominantly caused by the prosecution marked the trial. Despite the nearly five-year lapse, the prosecution hadn’t finished presenting evidence. Thus, on December 11, 2007, the respondents moved to dismiss the case, citing failure to prosecute and violation of their right to speedy trial. The RTC initially dismissed the case on January 9, 2008, for violation of said rights. However, upon the prosecution’s motion for reconsideration, these criminal cases were reinstated on December 10, 2008. The respondents’ subsequent motion for reconsideration was denied on February 12, 2009, leading them to file for certiorari with the Court of Appeals (CA) but failing to implead the People of the Philippines.
### Procedural Posture:
The CA reversed the RTC’s orders without first ordering the respondents to implead the People of the Philippines and dismissed the charges for violation of the right to speedy trial. PDIC advised the OSG of this decision and resolution, prompting the OSG to file the current petition for review on certiorari with the Supreme Court (SC), challenging the CA’s jurisdiction and due process for not impleading the People as an indispensable party.
### Issues:
1. Whether the CA erred in resolving the dismissal of the criminal cases against the respondents without first having the People of the Philippines, as represented by the OSG, impleaded as an indispensable party.
### Court’s Decision:
The Supreme Court found the petition meritorious, emphasizing that the People of the Philippines is an indispensable party in criminal proceedings, and their absence in the CA’s proceedings rendered the decision and related orders null and void for lack of authority. The judgment and resolution by the CA were set aside, and the case remanded for proper inclusion of the People as a party.
### Doctrine:
The presence of indispensable parties is mandatory for the court to exercise its jurisdiction. An indispensable party is a party-in-interest without whom no final determination can be had of an action. The court’s authority to act is nullified in the absence of such parties, affecting the validity of its proceedings and judgments.
### Class Notes:
– **Indispensable Party Principle:** Essential for the validity of proceedings; absence invalidates court actions.
– **Right to Speedy Trial:** Protects against oppressive delays; violation may result in dismissal of charges.
– **Certiorari Requirements:** Petition must include all indispensable parties to be jurisdictionally valid.
### Historical Background:
This case underscores the tension between the right to speedy trial and the procedural rigor in criminal prosecutions in the Philippines. It illustrates the judicial mechanisms to correct process errors (e.g., failure to include an indispensable party) and to ensure that the right to a fair trial is protected, balancing the interests of both the state and the accused within the Philippine legal system.
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