G.R. No. L-33628 and G.R. No. L-34162, December 29, 1987
Bienvenido A. Ebarle, et al., petitioners, vs. Hon. Judge Melquiades B. Sucaldito, et al., respondents. / Bienvenido A. Ebarle, petitioner, vs. Hon. Judge Asaali S. Isnani, et al., respondents.

FACTS

The petitioner, Bienvenido A. Ebarle, then the Provincial Governor of Zamboanga del Sur and a candidate for reelection in the 1971 local elections, filed two separate petitions for prohibition and injunction. He sought to enjoin further proceedings in multiple criminal cases and preliminary investigations before the Circuit Criminal Court and the City Fiscal of Pagadian City. These cases, initiated by the private respondent Anti-Graft League of the Philippines, Inc., charged Ebarle and other provincial officials with violations of the Anti-Graft and Corrupt Practices Act ( Republic Act No. 3019 ) and various provisions of the Revised Penal Code. The specific allegations included the simulation of public biddings for gravel and sand supply and a capitol building construction project, falsification of public documents, and giving unwarranted benefits to certain private entities.
The Supreme Court initially issued temporary restraining orders on June 16 and October 8, 1971, halting the proceedings. The petitions raised pure questions of law, centering on whether the courts and fiscal had jurisdiction and whether the criminal actions were politically motivated, filed to harass Ebarle during the election period.

ISSUE

The primary issue is whether a writ of prohibition or injunction may be issued to restrain the preliminary investigation and criminal prosecution of the petitioner for alleged graft and corrupt practices.

RULING

The Supreme Court dismissed the petitions and lifted the temporary restraining orders. The Court held that, as a general rule, injunction does not lie to enjoin criminal prosecutions. The exceptions to this rule are strictly construed and include: (1) for the orderly administration of justice; (2) to prevent the use of the strong arm of the law in an oppressive and vindictive manner; (3) to avoid multiplicity of actions; (4) to afford adequate protection to constitutional rights; and (5) when the statute relied upon is unconstitutional or otherwise void.
The Court found none of these exceptions applicable. The petitioner’s claim that the complaints were politically motivated and filed for harassment did not, by itself, justify judicial interference. The determination of whether the charges were baseless or malicious is precisely the function of the preliminary investigation and the subsequent trial. The proper venue for the petitioner to challenge the complaints is within the very proceedings he sought to enjoin—by participating in the preliminary investigation and raising his defenses there. The Court emphasized that it is not its business to resolve complaints whose disposition primarily belongs to the prosecutorial agencies and the trial courts, absent a clear showing of a grave abuse of discretion or a jurisdictional defect.