G.R. No. 201643 - Office of the Ombudsman vs. Capulong

Technical Sergeant Vidal D. Doble, Jr. (Doble), an ISAFP member, filed a complaint-affidavit dated 15 June 2005 charging petitioners Wilson Fenix, Rez Cortez, Angelito Santiago, and former NBI Deputy Director Samuel Ong with serious illegal detention.
The alleged detention occurred from 10 to 13 June 2005 at San Carlos Seminary, Makati City. Doble claimed he was brought there and closely guarded by Ong and his men, prevented from leaving despite his pleas.
On 13 June 2005, Doble informed priests that he was being held against his will. Subsequently, Bishop Socrates Villegas intervened and Doble was released to ISAFP custody.
Supporting affidavits were submitted by Doble's wife (Arlene Sernal-Doble), brother (Reynaldo D. Doble), and companion (Marietta C. Santos).

Cortez denied involvement, claiming he was only at the seminary briefly for moral support.
Ong and Santiago submitted counter-affidavits stating they and Doble voluntarily sought sanctuary at the seminary to avoid government forces after Ong's media revelation about the "Garci tape." They denied any illegal detention or armed guards.
Santos recanted her prior affidavits, stating she was coerced into signing them and that their stay at the seminary was voluntary and not restrictive.
Bishop Teodoro C. Bacani, Jr. executed an affidavit confirming Ong and Doble sought sanctuary, no signs of coercion were evident, and there were no armed guards accompanying Doble and Santos.

The DOJ investigating panel found probable cause against petitioners and Ong for serious illegal detention, heavily relying on Doble's testimony and disregarding counter-affidavits (due to failure of Ong and Santiago to affirm them in person).
An Information was filed on 9 September 2005 before the RTC for serious illegal detention.

Petitioners filed a motion to dismiss arguing lack of probable cause and submitted evidence (including Santos’s recantation and Bishop Bacani’s affidavit).
The RTC ordered submission of all affidavits and counter-affidavits omitted from the Information before ruling.
On 17 April 2006, the RTC dismissed the case for lack of probable cause, accepting the recantation and the affidavit of Bishop Bacani as credible and rejecting the panel’s exclusion of counter-affidavits.
The panel’s motions for reconsideration and for judge’s inhibition were denied by the RTC.

The Office of the Solicitor General (OSG) filed a certiorari petition before the CA challenging the RTC dismissal.
The CA admitted the late-filed petition, denying motions to dismiss it for untimeliness in the interest of substantial justice.
On 20 April 2009, the CA held that the RTC gravely abused its discretion by dismissing the case, ruling that judges should only determine probable cause and not evaluate the weight of evidence prematurely. The CA reinstated the Information.
Petitioner’s motion for reconsideration was denied on 13 October 2009 by the CA.

Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court.
The OSG, upon manifestation, abandoned its earlier position supporting the CA and acknowledged the RTC acted properly under the rules.
The DOJ did not file a comment, waiving its position on the matter.

Whether the Court of Appeals erred in ruling that the Regional Trial Court committed grave abuse of discretion in dismissing the serious illegal detention case for lack of probable cause.