G.R. No. L-51354. January 15, 1986.
Wilfredo Asutilla, petitioner-appellee, vs. Philippine National Bank (Tagbilaran and Tubigon Branches, Bohol), then Acting Chief of Police Virgilio Dizon, Chief of Police Leopoldo R. Bagolor and the Municipal Judge of Tubigon, respondents-appellants.

FACTS

A vehicular collision occurred on March 1, 1971, in Tubigon, Bohol, involving a Toyota jeep owned by the Philippine National Bank (PNB) and a Volkswagen Kombi owned by private individuals. The PNB jeep, regularly assigned to driver Rene Arcaya, was being driven by another PNB employee, Emmanuel Ceballos, at the time. The Kombi was driven by petitioner Wilfredo Asutilla. Following the incident, two separate criminal complaints for Reckless Imprudence were filed. First, Acting Chief of Police Virgilio Dizon filed a complaint against Asutilla (Criminal Case No. 1396). Subsequently, Chief of Police Leopoldo Bagolor filed a complaint against Arcaya and Ceballos (Criminal Case No. 1397).
Asutilla filed a Petition for Prohibition and Mandamus with the Court of First Instance of Bohol, seeking to enjoin the prosecution of Criminal Case No. 1396 against him. He alleged the complaint was baseless, malicious, and intended to oppress and coerce him and his employers into an amicable settlement favorable to PNB. The trial court issued a restraining order, then a preliminary injunction, and ultimately granted Asutilla’s Motion for Judgment on the Pleadings. It rendered a Decision permanently enjoining the prosecution and ordering the dismissal of Criminal Case No. 1396. Respondents appealed, assigning errors regarding the propriety of the judgment on the pleadings.

ISSUE

Whether the trial court committed grave abuse of discretion in permanently enjoining the criminal prosecution against Asutilla.

RULING

Yes, the trial court committed grave abuse of discretion. The Supreme Court resolved the case on a fundamental principle, bypassing the technical question of the propriety of the judgment on the pleadings. The Court reiterated the long-standing doctrine that injunction generally will not lie to restrain criminal prosecutions, as public interest demands the investigation and prosecution of criminal acts for societal protection. Exceptions exist, such as to prevent the oppressive and vindictive use of the law or to protect constitutional rights, but these must be clearly established.
The Court found no clear and convincing evidence in the record to justify such an exception. There was no proof that the complaint filed by the Acting Chief of Police was false, malicious, unfounded, or filed out of personal or political motives. The mere allegation that the filing was intended to force a settlement was insufficient, especially given the indication that settlement talks may have failed due to a substantial monetary demand from the Kombi owners. Furthermore, the Court noted the inconsistency in Asutilla’s position, as the related case (Criminal Case No. 1397) against the PNB employees was proceeding normally. Justice would be better served by allowing both cases to proceed to trial on the merits, where evidence could be fully evaluated to determine criminal responsibility. Asutilla had adequate remedies within the ordinary course of law, including the right to seek acquittal at trial and to appeal if convicted. The trial court’s order permanently blocking the prosecution disrupted the machinery of justice. Accordingly, the appealed judgment was reversed and set aside, the injunction dissolved, and Criminal Case No. 1396 ordered reinstated for trial on the merits.