Facts:

On October 9, 1968, Benjamin H. Aquino, the Provincial Fiscal of Rizal, filed an information in the Court of First Instance at Pasig, Rizal, under Criminal Case No. 18425, titled "The People of the Philippines vs. Rodolfo Cenidoza, Jose R. Baricua, Cesario B. Ong, Lucio Adriano, Jr., and Adriano Castillo." This case stemmed from allegations of estafa through the falsification of official and/or public documents, which arose due to a significant expansion of land following a resurvey and subdivision of a registered parcel in Muntinlupa, Rizal. The corresponding plans and technical descriptions were approved by officials of the Land Registration Commission. The case was assigned to Judge Pedro Revilla.

On October 27, 1968, Lucio Adriano, Jr., one of the defendants, filed a petition for mandamus in the same court, seeking an order to compel Fiscal Aquino to include additional defendants in the information, particularly former Commissioner Antonio Noblejas of the Lan...

Facts:

1. Filing of Criminal Case: On October 9, 1968, Rizal Provincial Fiscal Benjamin H. Aquino filed an information in the Court of First Instance at Pasig, Rizal, docketed as Criminal Case No. 18425, against Rodolfo Cenidoza, Jose R. Baricua, Cesario B. Ong, Lucio Adriano, Jr., and Adriano Castillo for estafa through falsification of official and/or public documents. The case arose from a resurvey and subdivision of a parcel of registered land in Muntinlupa, Rizal, and the approval of the corresponding plans and technical descriptions by officials of the Land Registration Commission.

2. Petition for Mandamus: On October 27, 1968, Lucio Adriano, Jr., one of the defendants, filed a petition for mandamus in the Court of First Instance of Rizal, seeking to compel Fiscal Aquino to include as defendants all persons against whom he found a prima facie case, particularly Commissioner Antonio Noblejas of the Land Registration Commission, who had resigned.

3. Decision on Mandamus: The mandamus case, docketed as Civil Case No. 11307, was assigned to Branch X, presided by Judge Herminio C. Mariano. On March 28, 1969, Judge Mariano granted the petition, ordering Fiscal Aquino to include Commissioner Noblejas and others as accused in Criminal Case No. 18425.

4. Fiscal’s Change of Position: Fiscal Aquino initially recommended in a June 20, 1968 indorsement that a prima facie case existed against Commissioner Noblejas. However, in a September 2, 1968 memorandum, he stated that Noblejas’ responsibility was only administrative, leading to the exclusion of Noblejas from the information.

Issue:

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Ruling:

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Ratio:

1. Mandamus as an Extraordinary Remedy: Mandamus is only appropriate when there is no other plain, speedy, and adequate remedy in the ordinary course of law. It cannot be used if other remedies, such as administrative appeals or motions, are available.

2. Exhaustion of Administrative Remedies: Before resorting to mandamus, a party must exhaust all administrative remedies. Adriano, Jr. failed to do so by not requesting Fiscal Aquino to include Noblejas and not appealing to the Secretary of Justice.

3. Avoidance of Multiplicity of Suits: Filing a motion in the criminal case is a more efficient and adequate remedy than initiating a separate mandamus action, as it avoids unnecessary delays and procedural complications.

4. Prima Facie Evidence vs. Proof Beyond Reasonable Doubt: A motion to include additional defendants based on prima facie evidence does not equate to prejudgment, as a conviction requires proof beyond a reasonable doubt.