GR L 112387; (October, 1994) (Digest)
G.R. No. L-112387 October 13, 1994
MANUEL P. MARTINEZ, petitioner, vs. COURT OF APPEALS, THE SOLICITOR GENERAL, and SALVADOR H. LAUREL, respondents.
FACTS
An Information for libel was filed against petitioner Manuel P. Martinez before the Regional Trial Court of Manila based on a complaint by then Vice-President Salvador H. Laurel. The charge stemmed from an article Martinez authored in his newspaper column. Martinez filed a petition for review with the Department of Justice (DOJ). Subsequently, the Acting Justice Secretary issued a resolution directing the City Prosecutor to cause the dismissal of the information, opining that the article constituted a privileged communication. Consequently, the prosecution filed a motion to dismiss in the trial court. Despite the private complainant not receiving a copy of this motion as ordered by the court, the trial judge granted the dismissal, stating the prosecution’s fresh stand was that there was insufficient evidence and that there was “no objection.”
ISSUE
Whether the Court of Appeals correctly set aside the trial court’s order dismissing the criminal case for libel.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the appellate court’s ruling, emphasizing the trial court’s grave abuse of discretion. The trial judge’s order was flawed on two primary grounds. First, it violated the private complainant’s right to due process. The order was issued despite the court’s own directive for the prosecution to furnish the private prosecutor a copy of the motion to dismiss, giving him ten days to respond. The dismissal was granted without this compliance, effectively depriving the private complainant of an opportunity to be heard. Second, and more fundamentally, the trial court abdicated its judicial duty. In a criminal case, the court must make its own independent assessment of the merits of a motion to dismiss; it cannot merely rely on the prosecution’s recommendation. The judge completely subordinated his judgment to the opinion of the Secretary of Justice, acting as a mere rubber stamp. This contravenes the doctrine established in Crespo v. Mogul, which holds that once a case is filed in court, any disposition rests in the court’s sound discretion. The prosecution’s control ceases, and the court must evaluate the evidence itself. Therefore, the dismissal was invalid, and the case was properly remanded for arraignment and trial.