G.R. No. 189402; May 6, 2010
Ligaya Santos and Robert Bunda, Petitioners, vs. Domingo I. Orda, Jr., Respondent.

FACTS

This case originated from the murder of Francis Orda, son of respondent Domingo Orda, Jr., on April 2, 2001. After initial investigations, Informations for murder were filed against several accused, including petitioners Ligaya Santos and Robert Bunda, based on witness statements. Key witnesses later recanted their testimonies. The Department of Justice (DOJ) subsequently issued a Joint Resolution directing the withdrawal of the Informations due to lack of credible evidence. The Regional Trial Court (RTC) initially allowed the withdrawal, but this was nullified by the Court of Appeals (CA) and ultimately affirmed by the Supreme Court, which ordered the RTC to conduct an independent evaluation of the records.
Upon re-evaluation, the RTC, Branch 274, issued an Order dated September 30, 2005, dismissing the murder case against petitioners. The court found no probable cause for their indictment, lifted the warrants for their arrest, and ordered their release. The prosecution’s motion for reconsideration was denied. Respondent then filed a Petition for Certiorari before the CA, arguing that the RTC committed grave abuse of discretion in dismissing the case.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s Orders which found no probable cause to hold petitioners for trial, thereby ruling that the RTC committed grave abuse of discretion.

RULING

The Supreme Court granted the petition and reversed the CA Decision. The Court held that the RTC did not commit grave abuse of discretion in finding no probable cause. The determination of probable cause is a function of the trial judge, who must independently assess whether a crime has been committed and whether the accused is probably guilty. The RTC meticulously evaluated the evidence, including the recantations of the original witnesses and the subsequent testimonies of new witnesses, Sabino Frias and Jonas Agnote.
The RTC found the new evidence insufficient to establish probable cause. It noted inconsistencies and a lack of corroborative detail, such as Sabino’s inability to identify the specific accused or their actions clearly, and Jonas’s testimony being uncorroborated and potentially self-serving. The Supreme Court emphasized that a finding of probable cause requires more than mere suspicion; it necessitates facts and circumstances that would lead a reasonably discreet person to believe the offense was committed by the accused. The RTC’s detailed Order demonstrated a logical application of legal principles to the facts, devoid of arbitrariness. The purpose of the judicial determination of probable cause is precisely to shield individuals from the ordeal of trial without sufficient basis. Therefore, the CA erred in substituting its own judgment for that of the trial court, as no grave abuse of discretion was present. The RTC Orders were reinstated.