GR 141888; (July, 2009) (Digest)
G.R. No. 141888 ; July 13, 2009
MELBAROSE R. SASOT, Petitioner, vs. AMADO YUSON, ROMEO SUANINO, and MELODY DE GUZMAN, Respondents.
FACTS
Petitioner Melbarose R. Sasot filed a complaint for serious physical injuries against respondents, alleging her daughter Aileen suffered contusions inflicted by respondents as members of a religious group. During an inquiry at respondent Amado Yuson’s residence, NBI agents seized an unlicensed Colt .45 pistol, leading to his arrest for violating Presidential Decree No. 1866. The NBI subsequently filed a complaint based on this and a PNP certification stating Yuson had no firearm records. In their defense, respondents moved to dismiss, asserting Melbarose was not the proper party as Aileen was of age, and that the firearm was licensed, presenting supporting documents. Aileen later submitted affidavits detailing psychological harm from the group but did not specifically identify who caused her physical injuries.
The Investigating Prosecutor dismissed all complaints. For serious physical injuries, it was found that Aileen’s affidavits failed to name perpetrators or detail the incident, and other witness accounts were hearsay. For illegal possession of firearms, the PNP-FED later confirmed Yuson’s license was valid, negating the charge. Melbarose’s appeals to the Secretary of Justice and the Office of the President were denied. She then filed a petition for certiorari with the Court of Appeals, which was dismissed, prompting the petition to the Supreme Court.
ISSUE
Whether the Secretary of Justice committed grave abuse of discretion in affirming the dismissal of the criminal complaints for lack of probable cause.
RULING
No. The Supreme Court affirmed the Court of Appeals and held that the Secretary of Justice did not commit grave abuse of discretion. The Court emphasized that the determination of probable cause is an executive function, primarily vested in the prosecutor. Judicial review is limited to instances where such determination is tainted with grave abuse of discretion, meaning a capricious, whimsical, or despotic exercise of judgment equivalent to lack of jurisdiction.
The legal logic is clear: the prosecutor’s finding of no probable cause was based on a proper evaluation of evidence. For serious physical injuries, the alleged victim’s affidavits were insufficient as they did not identify the assailants or provide specific details of the incident, and corroborating testimonies were correctly deemed hearsay. For illegal possession of firearms, the positive certification from the PNP-FED establishing the validity of Yuson’s license conclusively overturned the initial presumption of illegality. The Secretary of Justice’s affirmation of these findings was neither arbitrary nor baseless. Consequently, absent a clear showing of grave abuse, the Court upheld the executive’s discretion and dismissed the petition.