G.R. No. 172142 - Campao, Jr. vs. Datuin

David B. Campanano, Jr., acting as president of Seishin International Corporation, filed a complaint for estafa against Jose Antonio A. Datuin.
An Information for violation of Batas Pambansa Blg. 22 was subsequently filed against Datuin in connection with the estafa complaint.
After trial, the Regional Trial Court of Pasig City (Branch 71) convicted Datuin of estafa in a decision dated May 3, 1999, which later on became final and executory on October 24, 2003.

Respondent Datuin later asserted that the complaint and testimony by Campanano were “false, unfounded and malicious.”
Datuin claimed that newly discovered evidence—a cash voucher dated June 28, 1993—proved he had paid in full for two roadrollers purchased from Seishin International Corporation, thereby negating the allegations of estafa.
Relying on the aforementioned evidence, Datuin filed a complaint for Incriminating Against Innocent Persons under Article 363 of the Revised Penal Code against Campanano and a certain Yasunobu Hirota.

The Office of the City Prosecutor of Quezon City dismissed Datuin’s complaint for incriminating innocent persons by Resolution dated January 20, 2004.

The dismissal was based on the determination that the estafa case was filed and prosecuted in Pasig City, not Quezon City, thereby invoking the principle of venue.
The investigating prosecutor also found that the complaint lacked merit as the Regional Trial Court had already adjudicated the estafa case and ruled in favor of the filing party.

The Department of Justice (DOJ) dismissed Datuin’s petition for review by Resolution on August 20, 2004, affirming the finding that no error had been committed by the prosecutor.
A motion for reconsideration by Datuin was likewise denied via DOJ Resolution of April 11, 2005.

On December 9, 2005, the Court of Appeals set aside the DOJ resolutions dismissing Datuin’s complaint.
The appellate decision held that, based on petitioner Campanano’s counter-affidavit executed in Quezon City (dated November 30, 2003), the City Prosecutor’s Office of Quezon City had acquired jurisdiction to conduct a preliminary investigation into the complaint.
The CA directed the case to be remanded to the Office of the City Prosecutor of Quezon City for further investigation.

The petition for review was raised by Campanano wherein he challenged the Court of Appeals for relying on the counter-affidavit as determinative of venue and jurisdiction.
The Supreme Court scrutinized the issue of whether the counter-affidavit could override the allegations made in Datuin’s complaint-affidavit.
The Court also analyzed whether the complaint, which did not allege that the crime or its essential ingredients occurred in Quezon City (merely noting Datuin’s residence there), could form a proper basis for invoking the jurisdiction of Quezon City’s prosecutor.

Whether the complaint-affidavit for incriminating innocent persons, which was filed in Quezon City solely on the basis of the respondent’s residence, sufficiently alleged that the essential ingredients of the crime occurred in Quezon City.
Whether the counter-affidavit executed by petitioner Campanano in Quezon City could confer jurisdiction on the City Prosecutor’s Office over a matter fundamentally tied to the venue of the original estafa complaint in Pasig City.

Whether the allegations in Datuin’s complaint for incriminating innocent persons clearly and adequately established probable cause for the commission of the crime under Article 363 of the Revised Penal Code.
Whether the newly discovered cash voucher evidencing a payment for the roadrollers was material to establishing a lack of criminal intent or a mistake in testimony.

Whether Article 363 should be construed broadly to include acts resembling malicious prosecution or false accusation beyond its clear reference to acts that “tend directly” to cause false prosecutions.
The proper ambit of criminal liability in cases where a complaint may be seen as baseless or without sufficient factual support.