G.R. No. 7856 - IN RE: Estate of Calderon vs. Eugenio

On September 12, 2002, petitioner Joseph C. Cerezo filed a complaint for libel against respondents Juliet Yaneza, Pablo Abunda, Jr., Vicente Afulugencia, and Oscar Mapalo.
The Quezon City Prosecutor’s Office (OP-QC) found probable cause and, on February 18, 2003, filed the corresponding Information before the RTC of Quezon City, Branch 92.

The respondents filed a Motion for Reconsideration and/or a Motion to Re-evaluate Prosecution as Evidence before the OP-QC.
On November 20, 2003, the OP-QC reversed its initial finding by recommending the withdrawal of the Information.
Consequently, a Motion to Dismiss and Withdraw the Information was submitted before the Regional Trial Court (RTC) on December 3, 2003.

Despite the ongoing motions, respondents were arraigned on November 24, 2003, where all entered “not guilty” pleas.
In line with the prosecutorial resolution, the RTC issued an Order dated March 17, 2004, dismissing the case based on the prosecutor’s prior decision not to pursue the case—emphasizing the prosecutor’s quasi-judicial discretion.

Petitioner filed a motion for reconsideration on the RTC’s dismissal, contending that the November 20, 2003 OP-QC resolution had not attained finality, as it was subject to a Petition for Review before the Department of Justice (DOJ).
The RTC deferred ruling on the motion pending the DOJ’s resolution.
On June 26, 2006, the Secretary of Justice issued a resolution reversing the OP-QC’s November 20, 2003 decision and directed that the Information for libel be refiled.
Accordingly, on October 24, 2006, the RTC issued a new Order that granted petitioner’s motion for reconsideration, effectively setting aside its previous dismissal and reinstating the case.

The respondents filed a motion for reconsideration against the October 24, 2006 RTC Order, which was denied on February 26, 2007.
Persisting in their challenge, respondents elevated the matter to the Court of Appeals (CA) through a Petition for Certiorari under Rule 65 of the Rules of Court, arguing that the reinstatement of the case was tantamount to double jeopardy.

The CA annulled the assailed RTC Orders, basing its decision on the thesis that all requisites of double jeopardy were met.
The CA held that there was a valid Information and that the dismissal of the case, having been executed without the respondents’ consent, constituted termination—thus, refiling the case would breach the constitutional protection against double jeopardy.
Petitioner interposed the present appeal on certiorari following the denial of his motion for reconsideration of the CA decision.

Whether the RTC’s dismissal and subsequent reinstatement of the case were effectuated with grave abuse of discretion by solely relying on the recommendations and resolutions of the Public Prosecutor and the Secretary of Justice, without an independent judicial evaluation.
Whether the termination of the case was valid, thereby triggering the constitutional bar against double jeopardy, despite the absence of a refiling or a new charge.
Whether respondents’ allegations of double jeopardy are sustainable given that the dismissal was not final due to the pending motion for reconsideration and the subsequent judicial interventions.