G.R. No. 191567; March 20, 2013
MARIE CALLO-CLARIDAD, Petitioner, vs. PHILIP RONALD P. ESTEBAN and TEODORA ALYN ESTEBAN, Respondents.
FACTS
Petitioner Marie Callo-Claridad is the mother of Cheasare Armani “Chase” Claridad, whose body was discovered on February 27, 2007, in the carport of an uninhabited house in Ferndale Homes, Quezon City. The victim was last seen alive with respondent Philip Ronald P. Esteban, who picked him up in a white Honda Civic. Witnesses placed Philip and a male companion at the subdivision gate near the time of the incident. The victim’s body was found between parked cars, including one frequently used by Philip, with blood smears on the vehicles. Security logs indicated respondent Teodora Alyn Esteban also arrived at the scene. The victim died from stab wounds. The City Prosecutor initially found probable cause for murder against the respondents.
ISSUE
Whether the Secretary of Justice committed grave abuse of discretion in reversing the City Prosecutor’s finding of probable cause and dismissing the murder complaint against the respondents.
RULING
No, the Secretary of Justice did not commit grave abuse of discretion. The determination of probable cause for filing a criminal information is an executive function vested in the prosecutor and the Secretary of Justice. Judicial review is limited to instances of grave abuse of discretion, which implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The Court found no such abuse here. The Secretary of Justice correctly evaluated the evidence, noting the circumstantial nature of the case. Key circumstances, such as the respondents’ presence near the scene and prior altercations over parking, did not directly and conclusively point to their guilt as perpetrators of murder. The evidence did not establish a clear motive or direct participation. The requirement for probable cause demands more than mere suspicion; it requires sufficient ground to engender a well-founded belief that a crime was committed and the accused is probably guilty. The Secretary’s finding that the evidence was insufficient to meet this standard was a reasonable exercise of prosecutorial discretion, not a whimsical or capricious one. Therefore, the Court of Appeals correctly upheld the Secretary’s resolution.