GR 83635; (February, 1989) (Digest)
G.R. Nos. 83635-53 February 28, 1989
DELIA CRYSTAL, petitioner, vs. THE HON. SANDIGANBAYAN & PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Delia Crystal, a Bureau of Internal Revenue collecting agent, was found during a September 1984 audit to have a cash shortage of P114,573.03. The Commission on Audit demanded a written explanation and the production of the missing funds by October 31, 1984. Crystal complied, producing and depositing the full amount, P115,214.53, on October 25, 1984. Despite this restitution, the Tanodbayan filed nineteen informations for malversation against her before the Sandiganbayan.
Subsequently, the Tanodbayan Special Prosecutor, upon reinvestigation, concluded that no prima facie evidence existed against Crystal and filed a Motion to Withdraw the Informations. The Sandiganbayan denied this motion, citing precedent where even immediate return of funds did not erase criminal liability. When Crystal refused arraignment to seek Supreme Court review, the Sandiganbayan entered a plea of not guilty on her behalf.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the Tanodbayan Special Prosecutor’s Motion to Withdraw the Informations against Delia Crystal.
RULING
The Supreme Court ruled that the Sandiganbayan did not gravely abuse its discretion. The legal logic is anchored on the established doctrine of judicial control over cases once filed in court. While the prosecuting fiscal retains direction and control over the prosecution, the discretion to grant or deny a motion to dismiss or withdraw an information rests solely with the court where the case is pending. This principle, settled in Crespo v. Mogul, ensures that the court’s jurisdiction to hear and determine the innocence or guilt of the accused is not undermined by the prosecutor’s unilateral actions.
The Court clarified that denying the withdrawal motion is not a denigration of the prosecutor’s authority but an affirmation of the court’s role as the best and sole judge of the case before it. To defer automatically to the prosecutor’s motion would improperly transfer the disposition of the case from the judiciary to the executive. Therefore, the Sandiganbayan acted within its sound discretion, and the petition was dismissed for lack of merit.