Lee v. Lee
REITERATIONFacts
The Antecedents: The underlying dispute involves intra-corporate conflicts within Centillion Holdings, Inc. (CHI) and its affiliated companies, the CKC Group. These disputes escalated to criminal charges. Specifically, the petitioner, Lee Pue Liong, filed a petition for the issuance of a new owner's duplicate copy of Transfer Certificate of Title (TCT) No. 232238, claiming the original was lost. The respondent, Chua Pue Chin Lee, who is the Corporate Treasurer and a stockholder, opposed this, asserting she was in possession of the original title and that the petitioner intended to mortgage the property without proper authorization. This led to the filing of criminal cases for perjury against the petitioner. Procedural History: The petitioner's petition for a new TCT was initially granted by the Regional Trial Court (RTC) but was later recalled and set aside upon the respondent's motion, which produced the original title. Subsequently, the respondent filed a complaint-affidavit alleging perjury by the petitioner. After a review, the City Prosecutor filed Informations for perjury against the petitioner before the Metropolitan Trial Court (MeTC) of Manila. During the trial, the petitioner moved to exclude the private prosecutor representing the respondent, arguing that perjury is a crime against public interest with no private offended party. The MeTC denied this motion, as did the Court of Appeals (CA) on certiorari. The MeTC's denial was based on the principle that an offended party may intervene in criminal proceedings, subject to the public prosecutor's control, even in public crimes. The Petition: This case reaches the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Civil Procedure. The petitioner seeks to reverse the CA's decision, which affirmed the MeTC's orders denying his motion to exclude the private prosecutor. The core issues raised are whether the CA erred in upholding the MeTC's finding that there is a private offended party in the crime of perjury, and whether the CA erred in upholding the lower courts' rulings that the respondent, as a stockholder, has the right to intervene as a private complainant in the perjury case without explicit corporate authority. The petitioner argues that perjury, being a crime against public interest, does not have a private offended party and that the respondent, not having suffered direct damages, cannot intervene.
Issue(s)
Whether the Court of Appeals committed a grave error when it upheld the resolution of the Metropolitan Trial Court that there is a private offended party in the crime of perjury, a crime against public interest. Whether the Court of Appeals erred when it upheld the resolutions of the lower court which in turn upheld the right of respondent, an alleged stockholder of CHI, to intervene in the criminal case for perjury as private complainant on behalf of the corporation without its authority.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed and upheld.
Ratio Decidendi
On the issue of whether there is a private offended party in the crime of perjury: The Court held that while perjury is a public offense, the offended party, defined as the person against whom or against whose property the offense was committed, may be a private individual whose person, right, or property was directly injured. In this case, petitioner's alleged false statements regarding the TCT, if found to be perjured, could injure respondent's credibility as a corporate officer and CHI's property interests. The Court reiterated the principle that every person criminally liable is also civilly liable, and the offended party has the right to intervene through a private prosecutor, even if no civil liability is explicitly alleged or proven, as long as the intervention is subject to the control of the public prosecutor. The Court cited Lim Tek Goan v. Yatco and Chua v. Court of Appeals to support the right of intervention by an aggrieved private party. On the issue of respondent's right to intervene as private complainant on behalf of the corporation without its authority: The Court found that the respondent, as a stockholder and Treasurer of CHI, had a legal right and substantial interest in the subject matter of the action, as the alleged perjury directly concerned a corporate property (TCT No. 232238). Her personal credibility as a corporate officer was also implicated. The Court reasoned that the potential injury to the corporation's property rights and to the respondent's reputation as a corporate officer was sufficient to establish her standing as an aggrieved party entitled to intervene. The Court did not find merit in the argument that she needed specific authorization from CHI to intervene, given her direct interest and the nature of the alleged offense.
Main Doctrine
The offended party, even in public crimes like perjury where no civil liability is explicitly alleged or proven, has the right to intervene through a private prosecutor in the criminal proceedings, provided such intervention is subject to the control and supervision of the public prosecutor. This right stems from the potential injury to the offended party's person, rights, honor, or property, or to a corporate entity, which may arise from the commission of the crime.