Case Digest (G.R. No. 128369)
Facts:
The case involves Rodolfo Caoili as the petitioner against the Honorable Court of Appeals and Honorable Rustico V. Panganiban, the Presiding Judge of the Regional Trial Court of Manila, Branch 51, as respondents. The events leading to this case began with an Information filed on March 15, 1995, in the Regional Trial Court of Manila, where Caoili was charged alongside Tony Yip for violating Presidential Decree No. 1612. Following the filing of the Information, on March 24, 1995, Caoili sought a review from the Secretary of Justice regarding a resolution dated February 16, 1995, by Assistant Prosecutor Antonio R. Rebagay, which found a prima facie case against him. On August 18, 1995, the Secretary of Justice ruled in favor of Caoili, stating that there was insufficient evidence to indict him, as the allegations did not indicate that he knowingly acquired stolen property. The Secretary emphasized that the prima facie presumption of fencing did not apply to Caoili since the comp...
Case Digest (G.R. No. 128369)
Facts:
Initiation of the Case: On 15 March 1995, petitioner Rodolfo Caoili, along with Tony Yip, was charged with violation of Presidential Decree (P.D.) No. 1612 (Anti-Fencing Law) in Criminal Case No. 95-141750 before the Regional Trial Court (RTC) of Manila, Branch 51.
Petitioner’s Request for Review: On 24 March 1995, petitioner sought a review by the Secretary of Justice of the resolution dated 16 February 1995, issued by Assistant Prosecutor Antonio R. Rebagay, which found a prima facie case against him.
Secretary of Justice’s Ruling: On 18 August 1995, the Secretary of Justice directed the exclusion of petitioner from the Information, stating that there was no sufficient evidence to indict Caoili. The Secretary noted that the allegations did not indicate that Caoili knew the skiving machines were stolen property, and the prima facie presumption of fencing did not apply to him.
Trial Court’s Refusal to Exclude Petitioner: Despite the Secretary of Justice’s ruling, the trial court refused to exclude petitioner from the Information, reasoning that once the Information was filed, the determination of guilt or innocence rested with the court, and the prosecution could no longer interfere.
Petitioner’s Appeal to the Court of Appeals: Petitioner appealed to the Court of Appeals, which affirmed the trial court’s decision, finding no grave abuse of discretion.
Petitioner’s Argument: Petitioner argued that the Secretary of Justice retains the authority to review and reverse the findings of subordinate prosecutors, even after the Information is filed, as long as the accused has not been arraigned. He cited cases like Marcelo vs. Court of Appeals and Roberts, Jr. vs. Court of Appeals to support his claim that Crespo vs. Mogul no longer holds.
Solicitor General’s Position: The Solicitor General countered that Roberts did not overturn Crespo but merely sustained the Secretary of Justice’s authority to review resolutions, cautioning against indiscriminate use of this power.
Issue:
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Ruling:
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Ratio:
Authority of the Secretary of Justice: The Secretary of Justice retains the power to review resolutions of subordinate prosecutors, but this authority is not absolute. Once a case is filed in court, the court has exclusive jurisdiction over the case, and the Secretary of Justice must refrain from interfering as far as practicable.
Primacy of Court Discretion: The trial court is the sole judge of what to do with the case before it. A motion to dismiss filed by the prosecution, even if based on the Secretary of Justice’s reversal, is subject to the court’s discretion.
Crespo-Marcelo-Roberts Rule: The Crespo doctrine, which emphasizes the court’s exclusive jurisdiction once a case is filed, remains valid. Subsequent cases like Marcelo and Roberts did not abandon Crespo but merely clarified the Secretary of Justice’s limited role in reviewing cases already filed in court.
No Grave Abuse of Discretion: The trial court did not commit grave abuse of discretion in refusing to exclude petitioner from the Information, as it acted within its exclusive jurisdiction and in accordance with the prevailing rules.