G.R. No. 208001, June 19, 2017
P/C SUPT. EDWIN A. PFLEIDER, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

An Information for Murder was filed against petitioner P/C Supt. Edwin Pfleider (Ret.) and Ryan Bautista before the RTC of Tacloban City. The prosecution alleged that petitioner conspired with Bautista by offering a price or reward for the killing of Manuel Granados. The RTC, however, dismissed the case against petitioner for lack of probable cause in a Resolution dated September 5, 2011. The prosecution’s motion for reconsideration was denied. The prosecution then filed a petition for certiorari under Rule 65 with the Court of Appeals, arguing the RTC committed grave abuse of discretion by ignoring vital evidence, including the extrajudicial confession of co-accused Bautista which implicated petitioner.
The CA granted the petition, set aside the RTC’s orders, and directed the reinstatement of the Murder case against petitioner. The CA found that the RTC arrogated upon itself the executive function of determining probable cause and erred in disregarding Bautista’s extrajudicial confession and other corroborative evidence. Petitioner’s motion for reconsideration was denied. Petitioner thus elevated the case to the Supreme Court via a Rule 45 petition.

ISSUE

Whether the Court of Appeals correctly ruled that the Regional Trial Court committed grave abuse of discretion in dismissing the Murder case against petitioner for lack of probable cause.

RULING

Yes, the Supreme Court affirmed the CA ruling. The Court held that the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction. The judge’s duty in the preliminary determination of probable cause for the issuance of a warrant of arrest is not to disregard the prosecutor’s findings without just cause, but to personally evaluate the prosecution’s evidence to decide whether it shows a prima facie case. Here, the RTC improperly supplanted the prosecutor’s finding by dismissing the case outright at the stage of determining probable cause for arrest, which is a judicial function, instead of proceeding to trial after finding probable cause to hold the accused for trial.
The RTC erroneously excluded the extrajudicial confession of Ryan Bautista, which squarely implicated petitioner as the mastermind. While an extrajudicial confession is binding only on the confessant, it can be considered alongside other independent evidence to establish probable cause against a co-accused. The prosecution presented sufficient corroborative evidence, including witness accounts and text messages, lending credence to Bautista’s confession and establishing a link to petitioner. The existence of probable cause does not require evidence proving guilt beyond reasonable doubt, but merely enough evidence to engender a well-founded belief that a crime was committed and the accused is probably guilty. The RTC’s dismissal at this early stage was thus a capricious and whimsical exercise of judgment, correctible by certiorari.