G.R. No. L-6807, November 14, 1911
WILLIAM A. GRATTAGE, plaintiff-appellant, vs. THE STANDARD FUEL COMPANY, defendant-appellee.

FACTS

William A. Grattage, a former collector for The Standard Fuel Company, filed a civil action for damages against the company. He alleged that after resigning and preparing to depart for the United States, the company maliciously and without probable cause filed a criminal complaint for estafa against him over an alleged unremitted collection of P22. This led to his arrest on board his ship, detention, and subsequent release when the municipal court dismissed the charge for lack of evidence. Grattage claimed moral and pecuniary damages totaling P7,500.79 due to humiliation, legal expenses, and missed travel. The defendant company demurred, arguing the complaint failed to state a cause of action. The trial court sustained the demurrer and, after Grattage refused to amend, dismissed the case. Grattage appealed.

ISSUE

Whether a civil action for damages based on malicious prosecution can prosper without a prior judicial certification in the criminal case that the accusation was false and libelous.

RULING

No. The Supreme Court affirmed the trial court’s orders sustaining the demurrer and dismissing the complaint.
The Court held that under Article 326 of the Penal Code, a civil action for damages arising from a malicious prosecution (false accusation) requires, as a prerequisite, that the court which dismissed the criminal complaint must have certified in its final order or sentence that the accusation was false and libelous. This certification is essential to initiate either a criminal action for false accusation or a civil action for damages based thereon. In this case, the municipal court that dismissed the estafa charge against Grattage did not issue such a certification. Consequently, his civil action for damages could not be maintained. The Court cited its precedent in Gonzales Quiros vs. Palanca Tan-Guinlay, which established that no civil action for malicious prosecution damages is allowable unless the acquitting or dismissing court orders a prosecution for false accusation or certifies the complaint as malicious. Since Grattage failed to secure this requisite certification, his complaint correctly failed to state a cause of action.