G.R. No. L-10651 - Buenaventura vs. Sto. Domingo

Plaintiffs (Luis Buenaventura, Dominador Linga, Santos Mascarenas, Luis Malagotnot, Efren Mascarenas, Bienvenido Mascarenas, Pedro Mandia, and Basilio Linga) gathered coconut nuts on parcels of land at barrio Bantay, Boac, Marinduque, under the instruction of Rufina Mandia, administratrix of the late Espiridion Llena’s estate.
Defendant Damaso Sto. Domingo claimed ownership of the land based on a deed of sale dated April 25, 1951, executed by Leoncia Largado, widow of Espiridion Llena, and enforced his claim with the assistance of the Chief of Police of Boac.

On July 23, 1953, upon Sto. Domingo’s direction (and through the accompaniment of the Chief of Police), the group was ordered to cease gathering due to his asserted ownership, which they initially complied with.
Following the incident, Rufina Mandia instructed the group to resume their activity, assuring responsibility for any repercussions.
On July 26, 1953, when the group returned to the premises, Sto. Domingo, again accompanied by the Chief of Police, confronted them—presenting documents purportedly evidencing his ownership—leading to another cessation and ultimate confrontation.

Shortly after the confrontation, Sto. Domingo, along with the Chief of Police, was involved in the filing of Criminal Case No. 501 for qualified theft, alleging that the group had taken approximately 1,901 coconut nuts valued at P158.76.
The Justice of the Peace Court of Boac, Marinduque, rendered judgment on August 26, 1953, establishing Rufina Mandia’s guilt while absolving the co-defendants (the other accused) based on their role as hired hands and the insufficiency of evidence for their inclusion in the complaint.

On January 19, 1954, the plaintiffs filed a civil action for damages against Damaso Sto. Domingo and Chief of Police Filemon Ignacio, alleging wrongful prosecution that resulted in the engagement of legal services, mental anguish, anxiety, reputational damage, and social humiliation.
They sought several heads of damages, including actual, moral, exemplary damages, attorney’s fees, and costs.
Defendants moved to dismiss the civil case on the grounds that no cause of action was stated and that a pending suit over the same controversy existed; these motions were denied by the Court of First Instance of Marinduque on March 13, 1954.

Damaso Sto. Domingo maintained his title over the land, relying on the deed of sale and previous judicial recognition, and denied any allegation that the plaintiffs were mere instruments hired by Rufina Mandia.
He asserted that his actions were a legitimate exercise of his rights as an owner, with no intent to cause embarrassment or humiliation to the plaintiffs.
The Chief of Police similarly argued that the criminal complaint was filed after proper investigation and based on his reasonable belief that the elements of the crime of qualified theft were present.

After hearing the arguments and reviewing the evidence, the lower court resolved to dismiss the civil complaint, holding that the evidence did not establish malice in the conduct of filing Criminal Case No. 501.
This dismissal subsequently formed the basis for the appeal filed by the plaintiffs.

Whether the evidence on record is sufficient to hold Damaso Sto. Domingo and the Chief of Police liable for damages due to alleged malicious prosecution in Criminal Case No. 501.
Whether the actions of the defendants, in filing the criminal complaint, constitute malice that is legally actionable for civil damages.
Whether the plaintiffs have demonstrated a wrongful or baseless prosecution motivated by a hostile intent to vex and humiliate, thereby entitling them to compensation for actual, moral, exemplary damages, and attorney’s fees.
Whether the proper legal standards for malicious prosecution have been met given that the defendants acted on an honest belief to protect property rights as supported by documentary evidence.