University of the Philippines v. the City Fiscal of Quezon City
REITERATIONFacts
The Antecedents: The underlying dispute concerns the publication and circulation of an article titled "The Peasant War in the Philippines" within the Golden Jubilee issue of the Philippine Social Sciences and Humanities Review. This article was alleged to have constituted incitement to sedition under Article 142 of the Revised Penal Code. Procedural History: Following a complaint filed by Carlos Albert, the City Fiscal of Quezon City initiated a preliminary investigation against Tomas S. Fonacier and Leopoldo Y. Yabes, the editor and managing editor of the Review, respectively. The petitioners were informed that an information charging them with incitement to sedition was imminent. The Petition: Petitioners filed an original petition seeking to prohibit and enjoin the City Fiscal from filing the criminal information. They argued that such action would constitute harassment, an abuse of discretion, and an infringement upon their academic freedom, as the Review was primarily an academic publication distributed within the University of the Philippines and to correspondent institutions abroad, not to the general public.
Issue(s)
Whether the respondent City Fiscal may be enjoined from filing a criminal information against the petitioners for the publication of an allegedly seditious article, notwithstanding the petitioners' claim of academic freedom.
Ruling
The petition for preliminary injunction and the main petition for prohibition are denied for lack of merit.
Ratio Decidendi
On Issue 1: The Supreme Court held that the general rule in Philippine jurisdiction is that neither an injunction nor a writ of prohibition may be issued by the courts to restrain a criminal prosecution. This principle, reaffirmed from Kwong Sing v. City of Manila, rests on the duty of the public prosecutor to investigate and prosecute crimes once they are convinced of probable cause. The Court emphasized that it is the sworn duty of the City Fiscal to file the corresponding information if the evidence presented sufficiently proves that a criminal offense occurred. While exceptions exist for 'extreme cases' where the law is used in an oppressive or vindictive manner, as noted in Dimayuga v. Fernandez, the Court found that the facts alleged by the petitioners did not fall under these exceptions. The Court reasoned that if the Fiscal decides to file the information, the legal presumption is that his action was justified by the evidence and that official duty was regularly performed. Consequently, the petitioners' arguments regarding harassment and academic freedom were insufficient to stop the criminal process at this stage.
Main Doctrine
Courts will generally not issue injunctions or prohibitions to restrain criminal prosecutions, except in extreme cases of harassment, oppression, or grave abuse of discretion that would impede the orderly administration of justice.