G.R. No. 506 : February 16, 1903
Case Title: THE UNITED STATES, complainant-appellant, vs. THE MUNICIPAL COUNCIL OF SANTA CRUZ DE MALABON, defendant-appellee.

FACTS:
The Philippine Sugar Estates Development Company, Limited, a corporation domiciled in Manila, filed a petition in a voluntary jurisdiction proceeding. Through a supplementary prayer, it requested that a transcript of the minutes of a meeting of the Municipal Council of Santa Cruz, Cavite, be sent to the provincial fiscal for the filing of a corresponding criminal information. The minutes allegedly showed that the municipal council resolved to impose a tax of three pesos on each cavan of seed produced by landholders on a hacienda, to fund the expenses of a lawsuit, and appointed a collector for this tax. The provincial fiscal declined to file an information, not considering the facts to constitute a crime under the Penal Code articles cited. The judge subsequently dismissed the complaint in the preliminary investigation. The corporation’s representative, upon filing a formal complaint, was notified of the dismissal and appealed the order, invoking Articles 43 and 44 of General Orders No. 58.

ISSUE:
Whether the Philippine Sugar Estates Development Company, Limited, as a private corporation, has the right to initiate or appeal from the dismissal of a criminal prosecution against the Municipal Council for the alleged illegal exaction.

RULING:
No. The Supreme Court dismissed the appeal. It held that under the American system of criminal procedure established by General Orders No. 58, the prosecution of public offenses is reserved to the government. A private citizen or entity cannot institute a criminal action, except for the “private penal action” specifically reserved for the person actually injured by the offense, as recognized in Article 107 of the Order. This provision was maintained as a concession during the transition from Spanish law, primarily to allow the recovery of civil damages and to prosecute certain crimes requiring a private complaint. The right of the injured party is expressly included, thereby excluding other actions like the “popular penal action” (where any citizen could prosecute) known under the former Spanish law. The complainant corporation failed to demonstrate that it was an inhabitant of Santa Cruz, Cavite, or was otherwise injured by the municipal council’s resolution. Consequently, it had no standing to initiate the criminal prosecution or to appeal its dismissal. The order of the lower court was affirmed, with costs against the appellant.