Buan v. Matugas
REITERATIONFacts
The Antecedents: Petitioner Nace Sue P. Buan filed a complaint for attempted rape against respondent Francisco T. Matugas, alleging that while accompanying him on a supposed work-related trip to Manila in July 1995, respondent invited her to his hotel room at the Heritage Hotel. Inside the room, after respondent emerged from the comfort room without a shirt, he suddenly grabbed petitioner, embraced and kissed her. Petitioner resisted, causing him to desist. Petitioner reported the incident to her mother but did not file a complaint immediately due to respondent's influence as Provincial Governor. Petitioner resigned and almost six years later, filed the complaint. Procedural History: The City Prosecutor of Pasay City dismissed the complaint for lack of probable cause. The Secretary of Justice reversed this, finding reasonable ground to believe a crime was committed and respondent was probably guilty, and denied respondent's motion for reconsideration. Respondent filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the Secretary of Justice. The CA reversed the Secretary of Justice's resolutions and ordered the dismissal of the criminal information for attempted rape. The Petition: Petitioner seeks review of the CA's decision and resolution, arguing that the CA erred in holding that the Secretary of Justice committed grave abuse of discretion.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in reversing the resolutions of the Secretary of Justice. Whether the Court of Appeals erred in substituting its judgment for that of the Secretary of Justice in a certiorari proceeding. Whether the Secretary of Justice committed grave abuse of discretion in finding probable cause for attempted rape.
Ruling
The petition is granted. The assailed decision and resolution of the Court of Appeals are reversed and set aside. The Supreme Court reinstated the resolutions of the Secretary of Justice finding probable cause and directing the filing of an information for attempted rape.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion: The Supreme Court held that the CA, in a petition for certiorari under Rule 65, is empowered to annul resolutions of the Secretary of Justice only on grounds of lack of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. The CA is not vested with appellate jurisdiction over the quasi-judicial functions of the Secretary of Justice. Therefore, the CA cannot substitute its own judgment for that of the Secretary of Justice on matters of fact and law, as this would be an improper exercise of its certiorari power. The CA's review was limited to determining if the Secretary of Justice acted capriciously or whimsically, not to re-evaluate the evidence or the wisdom of the Secretary's conclusions. On the Court of Appeals' substitution of judgment: The Court emphasized the distinction between the CA's appellate jurisdiction and its original jurisdiction in certiorari cases. In certiorari, the CA's power is confined to jurisdictional errors and grave abuse of discretion. The CA erred by engaging in a review of the evidence and defenses, effectively acting as a trier of facts and substituting its judgment for that of the Secretary of Justice, which is beyond the scope of a Rule 65 petition. The CA's pronouncements regarding the fairness and necessity of allowing the complaint, and its consideration of the respondent's political future, were deemed extraneous and improper for a certiorari proceeding. On whether the Secretary of Justice committed grave abuse of discretion: The Supreme Court found that the Secretary of Justice did not commit grave abuse of discretion. The determination of probable cause is an executive function vested in the public prosecutor. The Secretary of Justice's finding of probable cause was based on evidence that, at that stage, was sufficient to engender a well-founded belief that a crime had been committed and the respondent was probably guilty. The Court reiterated that probable cause requires less than evidence for conviction and that any doubt or conflicting evidence should be threshed out during a full-blown trial, not at the preliminary investigation or certiorari stage. The CA's reversal of the Secretary of Justice's finding was premature and constituted an encroachment on the executive's prosecutorial powers.
Main Doctrine
The Court of Appeals, in a petition for certiorari under Rule 65, is limited to reviewing errors of jurisdiction and grave abuse of discretion, and cannot substitute its own judgment for that of the Secretary of Justice on matters of fact and law, as this would constitute an exercise of appellate jurisdiction which it does not possess over quasi-judicial functions of the Secretary of Justice.