GR 178104; (January, 2009) (Digest)
G.R. No. 178104, January 27, 2009.
Auto Prominence Corporation and Proton Pilipinas Corporation, Petitioners, vs. Prof. Dr. Martin Winterkorn, Dr. Horst Neumann, Dr. Andreas Schleef, Erich Schmitt, Rupert Stadler, Dr. Jochem Heizmann, and Ralph Weyler, Respondents.
FACTS
Petitioners Proton Pilipinas Corporation (PPC) and Auto Prominence Corporation (APC) are Philippine corporations engaged in the motor vehicle business. Respondents are officers of Audi AG, a German car manufacturer. In August 1996, PPC and Audi AG entered into several agreements (ALTAPS Agreement, License Fee Agreement, Sole Distributorship Contract) for the assembly and distribution of Audi cars in the Philippines under the government’s Motor Vehicle Development Program. Petitioners alleged that Audi AG failed to comply with its commitments under these agreements, such as establishing a full assembly operation and including the Philippines in its ASEAN Assembly Strategy, and prematurely terminated the agreements. Consequently, in March 2005, petitioners filed a criminal complaint for estafa through falsification of public documents against the respondent Audi AG officers with the Office of the City Prosecutor of Alaminos City, Pangasinan. The City Prosecutor found probable cause and filed an Information before the Regional Trial Court (RTC) of Alaminos City. The respondents filed motions for reconsideration and for the transfer of the preliminary investigation to the Department of Justice (DOJ). The Chief State Prosecutor, upon review, reversed the City Prosecutor’s finding and directed the withdrawal of the Information. The Secretary of Justice affirmed this reversal. Petitioners then filed a Petition for Certiorari with the Court of Appeals, which dismissed the petition, upholding the Secretary of Justice’s resolutions. Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in dismissing the Petition for Certiorari and in upholding the resolutions of the Secretary of Justice which found no probable cause to hold respondents criminally liable for estafa through falsification of public documents.
RULING
The Supreme Court denied the petition on the ground of mootness. The Court noted that during the pendency of the case, the RTC of Alaminos City, Branch 54, had already issued an Order dismissing the criminal complaint (Criminal Case No. 4824-A) against the respondents. Since the criminal case before the trial court had already been dismissed, the issue of whether the Secretary of Justice committed grave abuse of discretion in finding no probable cause had been rendered moot and academic. The Court emphasized that once a complaint or information is filed in court, any disposition of the case rests within the exclusive jurisdiction and discretion of the trial court. Therefore, the petition was denied.