G.R. No. A.C. No. 11533, June 6, 2017
Spouses Edwin and Greta Chua, Complainants vs. SACP Teresa Belinda G. Tan-Sollano, et al., Respondents

FACTS

The complainants, Spouses Edwin and Greta Chua, filed a criminal complaint for Perjury and False Testimony against several individuals before the Office of the City Prosecutor (OCP) of Manila. They alleged that a co-respondent, Luz O. Talusan, committed perjury in her sworn statements regarding the issuance date and purpose of certain checks. The complainants contended the checks were replacement checks issued on February 23, 2009, not payment checks issued on July 11, 2009 as claimed by Talusan.
In a Resolution dated December 28, 2015, respondent SACP Teresa Belinda G. Tan-Sollano recommended the dismissal of the complaint for lack of probable cause, a recommendation subsequently approved by respondents DCP Maria Gene Z. Julianda-Sarmiento and SDCP Eufrosino A. Sulla. The Spouses Chua filed a Motion for Reconsideration, which was denied in a Resolution dated August 9, 2016 issued by respondent SACP Suwerte L. Ofrecio-Gonzales and approved by respondent DCP Joselito D.R. Obejas. Aggrieved, the Spouses Chua filed this administrative complaint for disbarment, accusing the respondent prosecutors of grave abuse of discretion, ignorance of the law, abuse of authority, and gross misconduct for dismissing their complaint.

ISSUE

Whether the respondent prosecutors should be administratively disciplined for their dismissal of the Spouses Chua’s criminal complaint for lack of probable cause.

RULING

The Court DISMISSED the administrative complaint. The Court emphasized that in administrative proceedings, the burden of proof lies with the complainant to establish the allegations by substantial evidence. Here, the Spouses Chua failed to present clear and preponderant evidence to prove that the respondents committed any infraction against the Code of Professional Responsibility. Their mere allegations of error in the prosecutors’ assessment of evidence do not constitute proof of administrative culpability. The Court noted the possibility that the complaint was retaliatory, filed because the prosecutors participated in dismissing the underlying criminal case.
Crucially, the Court applied the principle that alleged errors committed by quasi-judicial officers in the exercise of their adjudicative functions, such as determining probable cause, cannot be corrected through an administrative proceeding. This holds true for prosecutors. The proper remedy for an aggrieved party is a judicial recourse, such as a petition for certiorari, not an administrative complaint. The Court observed that the Spouses Chua still had such judicial remedies available to them. In the absence of contrary evidence, the presumption of regularity in the performance of official duties by the respondent prosecutors stands.