CASE DIGEST : PEOPLE v. RUFINO RAMOY GR No. 212738 GAERLAN

 FACTS : The case involves a petition for review on certiorari under Rule 45 filed by Atty. Anna Liza R. Juan-Barrameda, Mischaella Savari, and Marlon Savari, seeking to reverse the Court of Appeals’ (CA) September 27, 2013 Decision and May 27, 2014 Resolution, which granted the respondents’ petition for certiorari under Rule 65 and quashed three criminal Informations filed against them for election-related offenses during the 2010 Barangay Elections. The petitioners, who served as pollwatchers, initially filed complaints against respondents and others for unlawful electioneering and campaigning outside the official period, leading the Assistant City Prosecutor to issue a Resolution finding probable cause and prompting the filing of three criminal Informations before the RTC of Quezon City. The RTC denied motions to quash, but the respondents’ petition for certiorari to the CA succeeded, with the CA holding that the Informations charged more than one offense, interpreting the use of “and” as indicating separate offenses rather than continuous acts. The petitioners now allege that the CA erred in quashing the Informations, arguing that the RTC correctly ruled that each Information charged only one offense, that the CA improperly found grave abuse of discretion, and that the respondents failed to comply with procedural requirements for filing a petition for certiorari. The core issue is whether the CA erred in quashing the subject Informations on the ground that they allegedly charged multiple offenses.

ISSUE : WON the CA erred in ordering the quashal of the subject Informations on the ground that they charge more than one offense

HELD : The Supreme Court partly granted the petition, ruling that the Informations in Criminal Cases Nos. Q-11-169068 and Q-11-169069 must be quashed because the facts charged did not constitute an offense, as premature campaigning under Section 80 of the Omnibus Election Code is no longer punishable; this quashal applies to all accused, even those who did not appeal. Meanwhile, the Motion to Quash in Criminal Case No. Q-11-169067 was denied, as the acts of soliciting votes inside a polling place and unauthorized presence therein constitute a single offense under the doctrine of absorption, making the Information valid. The Court emphasized that election offenses under special laws like these are mala prohibita, requiring only intent to perform the prohibited act, not criminal intent. The case is remanded to the RTC for further proceedings on Q-11-169067, while the other two cases are dismissed. The Court also highlighted the limitations on reviewing interlocutory orders, the presumption of innocence, and the necessity of speedy disposition given the long pending nature of the cases.