G.R. No. 184337 ; August 7, 2009
HEIRS OF FEDERICO C. DELGADO and ANNALISA PESICO, Petitioners, vs. LUISITO Q. GONZALEZ and ANTONIO T. BUENAFLOR, Respondents.

FACTS

The Manila Police District filed a complaint-affidavit charging respondents Luisito Gonzalez and Antonio Buenaflor with the murder of Federico Delgado and frustrated murder of Annalisa Pesico. The complaint relied heavily on Pesico’s sworn statements identifying the respondents as the perpetrators. The case underwent preliminary investigation. The Investigating Prosecutor dismissed the complaint for lack of probable cause, noting Gonzalez’s alibi supported by hospital confinement records and multiple witness affidavits, and Buenaflor’s defense of being at work.
Petitioners filed a Petition for Review with the Secretary of Justice. Then Acting Secretary of Justice Agnes Devanadera reversed the prosecutor, finding probable cause based primarily on Pesico’s positive identification. She directed the filing of Informations for murder and less serious physical injuries, which were subsequently filed in the trial courts. Respondents then filed a petition for certiorari with the Court of Appeals, challenging the Secretary’s resolutions.

ISSUE

Whether the Court of Appeals committed reversible error in its Amended Decision which set aside the Informations filed against the respondents, thereby encroaching upon the authority of the trial courts.

RULING

The Supreme Court granted the petition and reinstated the Informations. The core legal principle is the doctrine of judicial independence once a criminal case is filed in court. The Court emphasized that while the Secretary of Justice has the authority to review the prosecutor’s finding of probable cause, this power ends once the Information is filed with the appropriate court. From that point, jurisdiction over the case is vested in the trial court.
The Court of Appeals’ Amended Decision, which nullified the Informations, constituted a grave abuse of discretion. It improperly intruded into the domain of the trial court, which has the sole prerogative to evaluate the evidence and determine the existence of probable cause for the purpose of issuing a warrant of arrest or dismissing the case. The trial court must make its own independent assessment and cannot be bound by the review findings of the Secretary of Justice. The appellate court’s action violated the established rule in Crespo v. Mogul, which mandates that a motion to dismiss filed by the prosecution, even upon instructions of the Secretary of Justice, must be addressed to the trial court, which has the option to grant or deny it based on its own judicial evaluation. Consequently, the case was remanded to the trial court to proceed with the criminal proceedings in accordance with this independent judicial authority.