Corpuz v. Del Rosario
REITERATIONFacts
1. The Antecedents: The underlying dispute stems from an affidavit-complaint for libel filed by Assistant Solicitor General Roman G. del Rosario against Assistant Solicitor General Azucena B. Corpuz. Respondent del Rosario alleged that petitioner Corpuz maliciously issued a memorandum on June 13, 1997, intended to discredit his good name and impair his credibility and performance of official functions. 2. Procedural History: Following a preliminary investigation, the City Prosecutor's Office of Makati City found probable cause to indict petitioner for libel and filed an Information with the Regional Trial Court (RTC). Petitioner's appeal to the NCR Regional Prosecutor/Chief State Prosecutor was denied, as was her subsequent motion for reconsideration. An appeal to the Department of Justice (DOJ) was also denied with finality. Petitioner then filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the public prosecutors. The CA denied this petition on July 27, 2001. 3. The Petition: Petitioner seeks review of the CA's decision via a petition for certiorari under Rule 45 of the Rules of Court. She contends the CA erred in concluding that the prosecutor's findings were factual, that her arguments regarding privileged communication and absence of malice were matters for trial, and that certiorari was unavailable. Petitioner argues that the prosecutor's findings did not sufficiently establish probable cause for libel and lacked factual support. in her reply, conceded that the core issue is whether the CA correctly ruled that no grave abuse of discretion was committed by the prosecutor.
Issue(s)
Whether the Court of Appeals (CA) erred in concluding that the findings of the prosecutor in the preliminary investigation were essentially factual. Whether the CA erred in holding that petitioner's arguments regarding privileged communication and absence of malice are matters of defense to be resolved by the trial court. Whether the CA erred in ruling that the extraordinary writ of certiorari was not available since other remedies were obtainable with the trial court.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, holding that the findings of probable cause by the prosecutor and the Secretary of Justice were based on law, jurisprudence, and evidence on record, and that no grave abuse of discretion was committed.
Ratio Decidendi
On the issue of whether the CA erred in concluding that the findings of the prosecutor were factual: The Court found no merit in the petitioner's contention. The Court reiterated that the determination of probable cause is an executive function, and judicial review is limited to instances of grave abuse of discretion. The petitioner failed to establish any arbitrary or despotic exercise of power. The Court found that the prosecutor and the Secretary of Justice had clearly determined and carefully deliberated on the factual and legal antecedents of the case, and their resolution squarely addressed all arguments and evidence submitted. The evidence before the prosecutor served as the basis for her findings of fact. On the issue of whether the CA erred in holding that arguments on privileged communication and malice are matters of defense: The Court affirmed the CA's ruling. The Court stated that whether the subject memorandum is a privileged communication is a question requiring an examination of the parties' evidence, making it a matter of defense. The tenability of this challenge needs to be tested in a full-blown trial. The Supreme Court cannot assess the merit of such a claim as it is not a trier of facts. The Court emphasized that the elements of libel, as defined in Article 353 of the Revised Penal Code, were duly established during the preliminary investigation stage, showing a prima facie well-founded belief that the crime of libel had been committed and that the petitioner probably committed it. On the issue of whether the CA erred in ruling that certiorari was not available: The Court found no grave abuse of discretion or manifest error on the part of the public officers concerned. Their finding of probable cause to indict the petitioner was supported by the evidence on record. The Court reiterated that courts should give credence to the findings and determination of probable cause by prosecutors in a preliminary investigation, absent a clear showing of arbitrariness. The petitioner failed to establish the existence of exceptional circumstances that would warrant further calibration of the evidence presented during the preliminary investigation.
Main Doctrine
The determination of probable cause for the filing of an Information is an executive function, and judicial review is limited to determining if there was grave abuse of discretion. Matters of defense, such as whether a communication is privileged or made without malice, are for the trial court to resolve.