People v. Pfleider
REITERATIONFacts
The Antecedents: This case stems from an Information for Murder filed on April 18, 2011, against petitioner P/C Supt. Edwin A. Pfleider and Ryan Bautista. The Information alleged that on or about September 15, 2010, the accused, conspiring and confederating, with intent to kill, and with treachery and evident premeditation, attacked and shot Manuel Granados with an unlicensed firearm, causing his death. The prosecution claimed Pfleider induced Bautista to commit the murder by offering a price or reward. Procedural History: The Regional Trial Court (RTC) of Tacloban City dismissed the case against petitioner Pfleider for lack of probable cause in a Resolution dated September 5, 2011. The prosecution's motion for reconsideration was denied on October 26, 2011. Subsequently, the People of the Philippines, through the Office of the Solicitor General (OSG), filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the RTC. The CA granted the petition, setting aside the RTC's dismissal and reinstating the Information for Murder against Pfleider in a Decision dated October 23, 2012. The CA denied Pfleider's motion for reconsideration in a Resolution dated June 26, 2013. The Petition: Petitioner P/C Supt. Edwin A. Pfleider (Ret.) filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. He argued that the CA erred in giving due course to the OSG's petition for certiorari, as it was not the proper remedy and was used as a substitute for a lost appeal. Pfleider also contended that the CA erred in finding that the RTC committed grave abuse of discretion by dismissing the case for lack of probable cause, and that the CA wrongly concluded that probable cause existed to link him to the murder of Manuel Granados.
Issue(s)
Whether the Court of Appeals gravely erred in giving due course to the petition for certiorari filed by the Office of the Solicitor General. Whether the Court of Appeals gravely erred in holding that the Regional Trial Court committed grave abuse of discretion when it dismissed the criminal case for murder for lack of probable cause. Whether the Court of Appeals erred in holding that the Regional Trial Court arrogated upon itself the executive function of determining probable cause. Whether the Court of Appeals erred in holding that probable cause exists and that the prosecution was able to proffer sufficient basis to establish the link between the petitioner and his co-accused with respect to the killing of the victim.
Ruling
The Supreme Court granted the Petition for Review on Certiorari, setting aside the Court of Appeals' Decision and Resolution. However, due to the demise of the petitioner, P/C Supt. Edwin A. Pfleider, the criminal action was dismissed as moot and academic.
Ratio Decidendi
On the propriety of the certiorari petition: The Court acknowledged that ordinarily, the determination of probable cause is not lodged with the Supreme Court, and its duty is confined to reviewing whether the executive or judicial determination of probable cause was done without or in excess of jurisdiction or with grave abuse of discretion. While the petitioner argued that certiorari was not the proper remedy, the Court, in its subsequent resolution granting the motion for reconsideration, implicitly allowed the review of the case on its merits, focusing on the issue of probable cause. On the grave abuse of discretion by the RTC: The Court noted the contrasting findings between the CA and the RTC regarding the existence of probable cause. The RTC dismissed the case outright for lack of probable cause, while the CA found probable cause and reinstated the information. The Supreme Court, in its initial resolution, affirmed the CA's finding of grave abuse of discretion by the RTC in dismissing the case despite the presence of probable cause. However, this was later revisited. On the RTC's alleged usurpation of executive function: The petitioner argued that the CA erred in holding that the RTC judge arrogated upon himself the executive function of determining probable cause. The Court's analysis of Section 6, Rule 112 of the Rules of Court indicates that a judge does have a role in evaluating the prosecutor's resolution and supporting evidence to determine probable cause. In cases of doubt, the judge may order the prosecutor to present additional evidence. The CA's finding that the RTC judge overstepped his bounds by dismissing the case outright, without ordering the presentation of additional evidence in case of doubt, was a key point. On the existence of probable cause and the final disposition considering the demise of the petitioner: The CA, in finding probable cause, raised questions about why a co-accused would implicate the petitioner and why other witnesses would associate the petitioner with the crime. The Supreme Court, in its initial resolution, agreed that these questions raised doubt and suggested that the RTC should have ordered the presentation of additional evidence rather than dismissing the case outright. This indicated a belief that the prosecution had presented a sufficient basis to establish, more likely than not, a link between the petitioner and the crime. Ultimately, the Supreme Court found it appropriate to remand the case to the trial court for a proper determination of probable cause. However, due to the intervening death of the petitioner, P/C Supt. Edwin A. Pfleider, the criminal liability was extinguished. Consequently, the criminal action was dismissed as moot and academic, as there was no longer a defendant to stand trial.
Main Doctrine
The Supreme Court may remand a case to the trial court for proper determination of probable cause, but if the accused dies during the pendency of the case, the criminal action is dismissed as moot and academic.