GR 109205; (April, 1997) (Digest)
G.R. No. 109205. April 18, 1997.
ROSARIO LAO and GEORGE FELIPE, JR., petitioners, vs. COURT OF APPEALS and FRANK DEUNA, respondents.
FACTS
On December 30, 1988, George Felipe, Jr., driving a jeep, bumped Eduardo Antonio. Felipe fled, threatening to get a gun. The injured Antonio sought the assistance of Barangay Councilman Frank Deuna. Deuna accompanied Antonio to the police station to report the incident. Police officers, with Deuna pointing out the parked jeep, later seized the vehicle from in front of Felipe’s house and brought it to the police station for safekeeping in connection with the investigation of Felipe for frustrated homicide. Subsequently, Rosario Lao, Felipe’s mother, filed a criminal complaint for carnapping against Deuna and Antonio before the Anti-Carnapping Task Force. After investigation, the Department of Justice dismissed the carnapping complaint for lack of probable cause. Deuna then filed a civil case for damages against Lao and Felipe for malicious prosecution.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s decision holding petitioners liable for damages arising from malicious prosecution.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. Petitioners contended the appellate court misapprehended the facts, but the Court found this argument unmeritorious. The established facts demonstrated the essential elements for a successful action for malicious prosecution: that the prosecution was initiated by the defendant; that it ended in acquittal or dismissal; that it was brought without probable cause; and that it was motivated by malice. The Department of Justice resolution, which dismissed the carnapping complaint for lack of evidence and absence of intent to gain—an essential element of the crime—conclusively proved the absence of probable cause. The filing of the baseless criminal complaint, which subjected Deuna to the anxiety and inconvenience of a criminal investigation, constituted legal malice. The Court upheld the factual findings of the lower courts, which are generally binding, noting petitioners failed to prove any compelling reason to deviate from this rule. Consequently, petitioners were correctly held jointly and severally liable for the damages suffered by Deuna due to their malicious prosecution.