Dee v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Jose and Betty Chua filed a complaint for estafa through falsification of a commercial document against officers of China Banking Corporation (CBC), including Gilbert Dee, Peter Dee, Roberto Uyquienco, and Oscar Blaza. They alleged that the accused fraudulently made it appear they signed a P14,000,000.00 promissory note when it was intended for a bills purchase line not exceeding P2,000,000.00. The complainants had signed blank promissory notes and disclosure statements, which were later filled up by CBC employees upon instruction, allegedly in contravention of the complainants' written request to return the pre-signed blank promissory notes and cancel any authority to fill them up. Procedural History: The Prosecutor's Office found a prima facie case and filed an information for estafa through falsification of a commercial document. The accused petitioned for review with the Department of Justice (DOJ), which initially denied it. However, upon reconsideration, the Acting Secretary of Justice directed the City Prosecutor to move for the dismissal of the information. The Chuas moved for reconsideration, which was denied. Subsequently, the trial court ordered the withdrawal of the information upon manifestation of the Assistant City Prosecutor. The Chuas then filed a petition for certiorari before the Court of Appeals (CA) assailing the DOJ Secretary's resolution. The CA granted the petition, annulling and setting aside the DOJ resolutions and ordering the reinstatement of the information. The trial court, upon motion by the Chuas with the conformity of the City Prosecutor, ordered the reinstatement of the information. The accused filed a motion for reconsideration of the CA decision, which was denied. The Petition: Hence, the present petition for review.
Issue(s)
Whether the Court of Appeals erred in granting the petition for certiorari. Whether a petition for certiorari was the proper remedy for the Chuas to assail the resolutions of the Department of Justice. Whether the trial court committed grave abuse of discretion in ordering the withdrawal of the information based solely on the directive of the Acting Secretary of Justice without independent evaluation of the merits of the case.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding no reversible error. The petition for review was dismissed for lack of merit.
Ratio Decidendi
On the propriety of certiorari: The Supreme Court agreed with the private respondents that a petition for certiorari under Rule 65 of the Rules of Court was the proper remedy. Decisions and resolutions rendered by heads of executive departments are generally appealable only to the President. However, due to Memorandum Circular No. 1266, in relation to Memorandum No. 1294, appeals to the Office of the President in preliminary investigation resolutions are generally not given due course, except in specific instances not applicable here. Therefore, there was no plain, speedy, and adequate remedy in the ordinary course of law available to the private respondents, making the special civil action for certiorari before the Court of Appeals proper. The Court emphasized that the petitioners' contention that an ordinary appeal was the available remedy was incorrect given the limitations on appeals to the Office of the President. On the trial court's discretion and the role of the Department of Justice: The Supreme Court reiterated its ruling in Crespo v. Mogul and Manuel P. Martinez v. Court of Appeals, holding that once an information has been filed in court, any disposition of the case, including its dismissal, rests in the sound discretion of the court. The Secretary of Justice should, as far as practicable, refrain from entertaining petitions for review or appeal from the action of the fiscal once a complaint or information has been filed, as the matter should be left entirely for the determination of the court. The Court found that the trial court, in ordering the withdrawal of the information based solely on the directive of the Acting Secretary of Justice without an independent evaluation of the evidence or merits of the case, relinquished the discretion it was duty-bound to exercise. This action was deemed a violation of the private complainant's right to due process and an erroneous exercise of judicial discretion, thus constituting grave abuse of discretion. On the findings of the Court of Appeals: The Supreme Court stated that only questions of law may be raised in a petition for review of a Court of Appeals decision. The findings of the respondent court are rendered final and conclusive and cannot be reviewed by the Supreme Court unless they fall under specific exceptions, none of which were present in this case. The Court found no reversible error in the CA's conclusion that the Secretary of Justice committed grave abuse of discretion in ordering the withdrawal of the information. The subsequent events, such as the trial court's order of reinstatement and the Department of Justice's inaction, rendered the present recourse futile and the issues stale.
Main Doctrine
Once an information has been filed in court, any disposition of the case, such as its dismissal, rests in the sound discretion of the court, and the Secretary of Justice should refrain from entertaining petitions for review or appeal from the action of the fiscal, as the matter should be left entirely for the determination of the court.