In Leonardo U. Flores v. Hon. Raul S. Gonzalez and Eugene Lim, the Supreme Court reaffirmed the principle that once a criminal case is filed in court, the judiciary has the ultimate authority to decide whether to proceed with the trial, regardless of the Department of Justice’s (DOJ) recommendations. This means that even if the DOJ directs the withdrawal of charges, the trial court can independently assess the evidence and determine if there is sufficient reason to hold the accused on trial. The ruling underscores the court’s duty to ensure justice and prevent the dismissal of cases based solely on the prosecution’s shifting stance, thereby safeguarding the rights of the parties involved.

Flipping Fortunes: Can the Justice Secretary’s Change of Heart Trump a Court’s Finding of Probable Cause?

The case began with Leonardo U. Flores filing a complaint-affidavit against Eugene Lim for estafa, alleging that Lim defrauded Flores and other incorporators of Enviroboard Manufacturing, Inc. (EMI) during the pre-incorporation stage. Flores claimed that Lim, connected with the exclusive distributor of Compak System Limited, Inc. (Compak), induced them to purchase an equipment, CP14, at an inflated price. The City Prosecutor of Cebu City initially dismissed the complaint for lack of probable cause, a decision that Flores challenged by filing a petition for review with the Secretary of Justice.

The Secretary of Justice initially dismissed Flores’s petition but later reversed this decision, directing the City Prosecutor to file an information for “Other Deceits” under Article 318 of the Revised Penal Code. Consequently, the Cebu City Prosecutor filed an Information against Lim with the Municipal Trial Court in Cities (MTCC). However, the Secretary of Justice then reconsidered his position again, directing the withdrawal of the Information. In response, the Cebu City Prosecutor filed a Motion to Withdraw Information with the MTCC.

The MTCC denied the Motion to Withdraw Information, asserting its own independent assessment of the evidence and concluding that there was probable cause to hold Lim for trial. Flores, seeking to nullify the Secretary of Justice’s second resolution, filed a petition for certiorari with the Court of Appeals (CA). The CA found no grave abuse of discretion on the part of the Secretary of Justice, prompting Flores to elevate the matter to the Supreme Court.

The Supreme Court framed the central issue as whether the MTCC’s resolution denying the motion to withdraw the information and finding probable cause rendered the disposition of the petition before the CA academic. The Court also considered whether the Secretary of Justice could rule on the validity, weight, admissibility, and merits of parties’ defenses, evidence, and accusation during a preliminary investigation. This case hinges on the interplay between executive and judicial discretion in criminal proceedings.

The Supreme Court, in its analysis, cited the landmark case of Crespo v. Mogul, emphasizing that once a complaint or information is filed in court, the disposition of the case rests in the sound discretion of the court. The Court stated:

[O]nce a complaint or information is filed in Court, any disposition of the case as its dismissal or the conviction or acquittal of the accused rests in the sound discretion of the Court. Although the fiscal retains the direction and control of the prosecution of criminal cases even while the case is already in Court, he cannot impose his opinion on the trial court. The Court is the best and sole judge on what to do with the case before it. The determination of the case is within its exclusive jurisdiction and competence. A motion to dismiss the case filed by the fiscal should be addressed to the Court who has the option to grant or deny the same. It does not matter if this is done before or after the arraignment of the accused or that the motion was filed after a reinvestigation or upon instructions of the Secretary of Justice who reviewed the records of the investigation.

The Court acknowledged that while the Secretary of Justice has the power to review resolutions of his subordinates, this power is not absolute once the case is filed in court. The Court reasoned that the review process, whether on appeal or motion for reconsideration, is an act of supervision and control by the Secretary of Justice. The Court also noted that the doctrine of exhaustion of administrative remedies allows higher administrative authorities to correct mistakes or abuses committed in the initial steps of an administrative activity.

However, the grant of a motion to dismiss or withdraw the information, filed after the Secretary of Justice reverses the finding of probable cause, is subject to the discretion of the court. This discretion allows the court to independently assess the merits of the case. Citing People of the Philippines v. Odilao, Jr., the Court emphasized that the trial court is not bound to adopt the resolution of the Secretary of Justice.

In this case, the MTCC denied the Motion to Withdraw Information based on its own assessment that there existed probable cause to hold Lim for trial. The Supreme Court found that the MTCC acted correctly. This illustrates the principle that the judiciary has the final say on whether a case should proceed to trial, even if the executive branch recommends otherwise.

The Supreme Court also addressed the issue of whether the Secretary of Justice overstepped his jurisdiction by ruling on the validity, weight, admissibility, and merits of the parties’ evidence during the preliminary investigation. The Court stated that these matters are best addressed to the MTCC, where they will be thoroughly ventilated during the trial on the merits.

The Court emphasized that the petition for certiorari before the Court of Appeals had become moot and academic upon the issuance by the MTCC of its June 20, 2007 Resolution. Even if the Court of Appeals affirmed the Secretary of Justice’s decision, the MTCC was not bound to dismiss the case or withdraw the Information. The Supreme Court ultimately granted the petition, declaring the Court of Appeals’ decision moot and academic and setting aside its ruling.

FAQs

What was the key issue in this case?	The key issue was whether a trial court is bound by the Secretary of Justice’s resolution to withdraw an information after the court has already determined probable cause.
What is the Crespo doctrine?	The Crespo doctrine states that once a complaint or information is filed in court, any disposition of the case, such as dismissal or conviction, rests in the sound discretion of the court. This means the court, not the prosecutor, has the final say.
Can the Secretary of Justice review resolutions of prosecutors?	Yes, the Secretary of Justice has the power to review resolutions of subordinates as an act of supervision and control. However, this power is not absolute once the case is filed in court.
Is a trial court bound by the Secretary of Justice’s finding of probable cause?	No, the trial court is not bound by the Secretary of Justice’s finding and must independently assess the merits of the case to determine if probable cause exists. The court can agree or disagree with the Secretary’s recommendation.
What is the effect of the MTCC’s denial of the Motion to Withdraw Information?	The MTCC’s denial of the motion to withdraw means that the court found sufficient basis to proceed with the trial, irrespective of the Secretary of Justice’s directive to withdraw the Information.
What is the significance of the doctrine of exhaustion of administrative remedies in this case?	The doctrine allows higher administrative authorities to correct errors made in initial steps, but judicial intervention is allowed after exhausting these remedies. This means Flores could appeal to the Secretary of Justice, but the court ultimately decides the case.
What remedy is available to a party aggrieved by the Secretary of Justice’s resolution?	An aggrieved party may file a petition for certiorari under Rule 65 of the Rules of Court, alleging grave abuse of discretion amounting to excess or lack of jurisdiction on the part of the Secretary of Justice.
What was the outcome of the petition for certiorari before the Court of Appeals?	The Supreme Court declared the petition for certiorari before the Court of Appeals moot and academic because the MTCC had already denied the Motion to Withdraw Information and decided to proceed with the trial.

The Supreme Court’s decision reinforces the independence of the judiciary and its power to ensure that cases are decided based on merit and not merely on the changing positions of the executive branch. This ensures a fair and impartial administration of justice, protecting the rights of all parties involved.

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: Leonardo U. Flores v. Hon. Raul S. Gonzalez, G.R. No. 188197, August 03, 2010