GR 167025; (December, 2005) (Digest)
G.R. No. 167025 December 19, 2005
HERMINIO C. PRINCIPIO, Petitioner, vs. THE HON. OSCAR BARRIENTOS, IN HIS CAPACITY AS PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF MANILA, BRANCH 26, PEOPLE OF THE PHILIPPINES, BANGKO SENTRAL NG PILIPINAS, and HILARIO SORIANO, Respondents.
FACTS
Petitioner Herminio C. Principio, a BSP bank examiner, was charged with violation of Section 3(e) of R.A. No. 3019 . The charge stemmed from his examination report on the Rural Bank of San Miguel, Inc. (RBSMI), which found legal reserve deficiencies and recommended a substantial monetary penalty approved by the BSP Monetary Board. RBSMI’s president, Hilario Soriano, filed a complaint alleging the report was made with manifest partiality, bad faith, or gross negligence, causing undue injury to the bank. The Office of the Ombudsman found probable cause and filed an Information. The RTC denied Principio’s motions, including one to suspend proceedings pending his motion for reconsideration with the Ombudsman, and ordered his 60-day suspension. The Court of Appeals dismissed his certiorari petition, ruling that the denial of a motion to quash is interlocutory and not subject to certiorari absent grave abuse of discretion.
ISSUE
Whether the Court of Appeals erred in not granting the petition for certiorari and in affirming the trial court’s orders, despite alleged errors in the finding of probable cause.
RULING
The Supreme Court granted the petition and ordered the dismissal of the criminal case. The Court acknowledged that while certiorari is generally not the proper remedy against the denial of a motion to quash, it constitutes an exception when the prosecution is clearly devoid of legal basis, leading to a grave and manifest injustice. The legal logic rests on the principle that courts should prevent an unnecessary and oppressive trial where the accused’s innocence is evident from the undisputed facts.
The Court found that the evidence patently demonstrated Principio’s innocence. It highlighted that in a prior administrative case (Reyes v. Rural Bank of San Miguel), the Court had already exonerated Principio, ruling he performed his duties in good faith and without undue haste. The factual findings central to the administrative case—the existence of the legal reserve deficiency and the propriety of the penalty—were identical to those in the criminal complaint. The subsequent confirmation of these findings by the BSP Monetary Board negated any imputation of bad faith, gross negligence, or partiality required for a violation of R.A. No. 3019 . To allow the prosecution to proceed under these circumstances would be tantamount to persecution. Thus, the Court exercised its supervisory authority to correct a misapprehension of facts and prevent a manifest miscarriage of justice.