GR 208001 So; (June, 2017) (Digest)
G.R. No. 208001 , June 19, 2017
P/C SUPT. EDWIN A. PFLEIDER, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
This is a dissent from the majority decision. The case originated from a murder complaint against P/C Supt. Edwin Pfleider for the killing of Manuel Granados. The primary evidence was the extrajudicial confession of the direct perpetrator, Ryan Bautista, who in his First Affidavit implicated Pfleider as the mastermind who induced him with a promise of ₱60,000. Supporting affidavits from Rex Gillamac and Jimmy Atoy allegedly corroborated Pfleider’s involvement. However, Bautista later executed a Second Affidavit recanting his First, claiming it was prepared under pressure and threat. The Assistant State Prosecutor found probable cause, leading to the filing of an Information. The Regional Trial Court (RTC) initially dismissed the case for lack of probable cause, but the Court of Appeals (CA) reversed this, reinstating the charge.
ISSUE
Whether the Court of Appeals erred in finding the existence of probable cause to charge petitioner Pfleider with murder.
RULING
Justice Velasco, dissenting, voted to grant the petition and reverse the CA, holding that no probable cause existed. The legal logic centers on the insufficiency and unreliability of the prosecution’s evidence to engender a well-founded belief that a crime was committed and that the accused is probably guilty. The dissent emphasized that the core evidence—Bautista’s extrajudicial confession—was effectively withdrawn by his subsequent recantation and his plea of “Not Guilty” to an Amended Information, which charge implied conspiracy. This plea constituted a judicial denial of the very facts confessed in his First Affidavit, fatally undermining its credibility.
Furthermore, the dissent found the supporting affidavits of Gillamac and Atoy insufficient to independently establish probable cause, as they lacked corroborative weight without Bautista’s discredited confession. The prosecution’s theory was also weakened by its own procedural action of filing an Amended Information that charged Bautista with conspiring with “another person,” demonstrating uncertainty about the identity of the alleged co-conspirator. Probable cause requires more than bare suspicion, and the totality of the evidence here, marred by recantation and inconsistency, failed to meet that standard. Therefore, the RTC correctly dismissed the case.