GR 149357; (March, 2005) (Digest)
G.R. No. 149357 & G.R. No. 149403. March 04, 2005.
MOBILIA PRODUCTS, INC., Petitioner, vs. HAJIME UMEZAWA, Respondent. PEOPLE OF THE PHILIPPINES, Petitioner, vs. HON. JUDGE RUMOLDO R. FERNANDEZ and HAJIME UMEZAWA, Respondents.
FACTS
Hajime Umezawa, President and General Manager of Mobilia Products, Inc. (MPI), organized a competing company, Astem Philippines Corporation. While still heading MPI, he allegedly stole prototype furniture from MPI’s premises, using a supplier’s truck to spirit them away for exhibition at an international fair under Astem’s name. He also allegedly caused the manufacture of furniture using MPI’s materials, supplies, and personnel for the benefit of Astem. MPI filed criminal complaints for qualified theft and estafa against Umezawa.
The prosecutor found probable cause and filed Informations. Umezawa filed a petition for certiorari with the Court of Appeals (CA), arguing the complaints were filed under a board resolution from an invalidly constituted MPI board. The CA initially dismissed his petition but later reversed itself, granting the petition and annulling the criminal proceedings, holding the board resolution was void for lack of a proper quorum.
ISSUE
Whether the alleged invalidity of the corporate board resolution authorizing the filing of the criminal complaint deprives the court of jurisdiction over the criminal cases for qualified theft and estafa.
RULING
No. The Supreme Court reversed the CA’s subsequent resolution and reinstated its initial decision dismissing Umezawa’s petition. The Court held that the validity or invalidity of the corporate board resolution authorizing the filing of the complaint is irrelevant to the court’s jurisdiction over the criminal cases. Jurisdiction over criminal cases is conferred by law and is determined by the allegations in the information. The crimes of qualified theft and estafa are public offenses prosecuted in the name of the People of the Philippines, not as private crimes.
Once the public prosecutor has conducted a preliminary investigation, found probable cause, and filed the corresponding information in court, the criminal action is prosecuted under the direct control and supervision of the state. The role of the private complainant becomes subsidiary; the suit is between the state and the accused. Any defect in the corporate act authorizing the initiation of the complaint does not affect the court’s authority to try the case, as the state has already taken up the cause. The preliminary investigation established a prima facie case, and the legality of the board’s constitution is a separate intra-corporate matter that does not invalidate the criminal proceedings.