Title
Anlud Metal Recycling Corp. vs. Ang
Case
G.R. No. 182157
Decision Date
Aug 17, 2015
SMC-MCLP awarded Anlud an exclusive scrap purchase contract. Anlud accused SMC-MCLP employee Alday and others, including Joaquin Ang, of attempted estafa via unauthorized scrap transactions. RTC dismissed charges against Ang for lack of probable cause, upheld by CA and SC, citing Anlud's lack of standing to appeal criminal dismissal.
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Case Digest (G.R. No. 182157)

Facts:

  1. Contractual Background: San Miguel Packaging Products-Metal Closures Lithography Plant (SMC-MCLP) awarded Anlud Metal Recycling Corporation (petitioner) an exclusive contract to purchase aluminum- and tin-based scrap materials from 20 March 2003 to 31 January 2004.
  2. Discovery of Unauthorized Transaction: On 23 January 2004, the President of Anlud discovered that SMC-MCLP employee Conrado Alday allowed Nenita B. dela Cruz to load scrap materials onto two trucks owned by respondent Joaquin Ang, operated by his drivers Edjanel Jose Paniergo and Renato Bagaua.
  3. Misrepresentation: Dela Cruz allegedly pretended to be an agent of Anlud, coordinating with Alday to load the trucks. The trucks were not able to leave the premises of SMC-MCLP.
  4. Criminal Complaint: Petitioner filed a Complaint for attempted estafa through falsification of commercial/private documents against Alday, Dela Cruz, Paniergo, Bagaua, and Ang. The Investigating Prosecutor filed an Information for estafa under Article 315, paragraph 2(a) of the Revised Penal Code.
  5. Procedural Developments:
    • The RTC issued a Warrant of Arrest against Ang and his co-accused.
    • Ang filed a Petition for Reinvestigation and a Motion for Preliminary Investigation. The RTC denied his motion, but the City Prosecutor's Office later absolved him, citing lack of evidence of conspiracy.
    • The DOJ reversed the City Prosecutor's decision, leading to a Second Amended Information naming Ang as an accused.
    • The RTC eventually dismissed the case against Ang for lack of probable cause, a decision affirmed by the CA.

Issue:

  1. Procedural Issue: Whether petitioner Anlud Metal Recycling Corporation has the legal personality to appeal the dismissal of the criminal case against Ang without the participation of the Office of the Solicitor General (OSG).
  2. Substantive Issues:
    • Whether the RTC had jurisdiction to determine probable cause.
    • Whether the RTC abused its discretion in entertaining Ang's Omnibus Motion despite a defective Notice of Hearing.
    • Whether the RTC erred in dismissing the charge of estafa against Ang for lack of probable cause.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

The Supreme Court denied the Petition for Review, affirming the CA's decision to uphold the RTC's dismissal of the estafa charge against Joaquin Ang for lack of probable cause. The Court emphasized that the determination of probable cause is a judicial function and that the RTC did not abuse its discretion in dismissing the case. Petitioner's lack of standing to appeal the dismissal of the criminal case was also highlighted, as the appeal pertained to the criminal aspect, which is the exclusive domain of the OSG.


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