G.R. No. L-48011 January 29, 1988
PEDRO G. PERALTA, petitioner, vs. COURT OF FIRST INSTANCE OF LA UNION, BRANCH I, PEOPLE OF THE PHILIPPINES, NAPOLEON S. ARRIETA, respondents.

FACTS

The case originated from a disbarment complaint filed by private respondent Napoleon S. Arrieta against petitioner Pedro G. Peralta with the Supreme Court. Arrieta subsequently circulated copies of this complaint in San Fernando, La Union. Peralta, in response, filed a criminal complaint for libel. After a preliminary investigation, a panel of provincial fiscals found a prima facie case, leading to the filing of an information for libel before the Court of First Instance of La Union. However, Arrieta appealed the fiscals’ resolution to the Secretary of Justice. After review, the Secretary directed the Provincial Fiscal to move for the dismissal of the case. The Provincial Fiscal complied by filing a Motion to Dismiss. Peralta then filed a special civil action to annul the Secretary’s order and enjoin the dismissal, which initially resulted in a preliminary injunction. Despite this, the trial court eventually granted the prosecution’s motion to dismiss the libel case, prompting Peralta’s petition for review.

ISSUE

The central issue is whether the Secretary of Justice retains the power to review and reverse the findings of a prosecuting fiscal after the corresponding information has already been filed and admitted in court, and whether the trial court acted within its discretion in granting the motion to dismiss based on the Secretary’s directive.

RULING

The Supreme Court dismissed the petition, upholding the trial court’s dismissal order. The ruling is anchored on the principle of judicial discretion once a case is filed in court. The Court, citing its recent decision in Crespo v. Mogul, held that once a complaint or information is filed in court, any disposition of the case, including its dismissal, rests within the sound discretion of that court. This judicial prerogative is paramount, regardless of whether a motion to dismiss originates from a fiscal’s reinvestigation or from instructions issued by the Secretary of Justice following a review. The Court clarified that while the Secretary of Justice may review a fiscal’s actions, such review power should not be entertained after the information is already filed in court, to prevent conflict with judicial authority. In this case, the trial court exercised its discretion by granting the fiscal’s motion to dismiss, which was based on the Secretary’s finding of insufficient evidence. The Supreme Court found no reason to reverse this action, emphasizing that the matter was correctly left to the trial court’s determination after the filing of the information. The Court deemed it unnecessary to address other ancillary issues raised in the petition.