G.R. No. L-25885 - Luzon Brokerage Co., Inc. vs. Maritime Building Co., Inc.

Petitioner Lee Pue Liong, aka Paul Lee, is the President of Centillion Holdings, Inc. (CHI), affiliated with the CKC Group of Companies.
Respondent Chua Pue Chin Lee is petitioner's sibling, a majority stockholder, and Treasurer of CHI.
There were intra-corporate disputes among petitioner and siblings including respondent.

On July 19, 1999, petitioner’s siblings including respondent barricaded themselves inside CKC factory premises, denying petitioner and employees access.
This led to various criminal cases against petitioner’s siblings, pending in Valenzuela courts.

On June 14, 1999, petitioner filed a verified petition before RTC Manila for issuance of owner’s duplicate copy of Transfer Certificate of Title (TCT) No. 232238, covering CHI property.
Petitioner submitted an affidavit of loss stating that as CHI President, he had custody of the owner’s duplicate TCT which was inadvertently lost or misplaced, discovered in May 1999, after diligent search.
He also testified under oath to these facts during an ex-parte proceeding.
RTC Manila granted the petition in September 1999 and ordered issuance of a new owner’s duplicate TCT.

Respondent and her brother Nixon Lee filed an Omnibus Motion seeking to set aside the September 1999 RTC order, claiming petitioner knew respondent was in possession of the owner’s duplicate TCT, in her capacity as CHI Treasurer and custodian of documents.
They argued petitioner wanted the new title copy to mortgage the property without their knowledge.
Respondent produced the original owner’s duplicate TCT in open court.
On November 12, 1999, RTC recalled and set aside its earlier order.

On May 9, 2000, respondent filed a Complaint-Affidavit before the Manila City Prosecutor, accusing petitioner of perjury for allegedly making willful falsehoods in his verified petition, affidavit of loss, and testimony regarding the loss of the title.
She alleged petitioner falsely claimed custody and loss of the title, despite her possession of it as Treasurer.
The accusation was based on petitioner’s sworn statements and testimony that the TCT was lost when in fact respondent held the title.
On June 7, 2000, respondent executed a supplemental affidavit specifying three occurrences of perjury: verification of the petition, affidavit of loss, and testimony.

The Investigating Prosecutor recommended dismissal, but First Assistant City Prosecutor overturned this, and filed Informations for perjury against petitioner before the Metropolitan Trial Court (MeTC) of Manila.
Respondent, through counsel Atty. Augusto M. Macam, appeared as private prosecutor with consent and under supervision of the public prosecutor.
After prosecution’s presentation of first witness, petitioner moved to exclude the private prosecutor arguing perjury is purely a public offense with no private offended party, thus no private prosecution allowed.
MeTC gave both parties time to file motions and comments. Petitioner filed an Omnibus Motion seeking exclusion of private prosecutor citing absence of private offended party in perjury cases.
The public prosecutor opposed this motion.
MeTC denied the Omnibus Motion on August 15, 2003, reasoning that an offended party may intervene personally or by counsel even in public offenses, subject to public prosecutor’s control.
MeTC denied petitioner’s motion for reconsideration.

Petitioner sought relief from the CA via petition for certiorari and prayed for injunctions to exclude private prosecutor.
On May 31, 2007, the CA affirmed MeTC’s orders allowing private prosecutor’s participation, holding respondent as private complainant and aggrieved party had right to intervene even if no civil liability was alleged.
The CA emphasized the right of offended parties to intervene subject to supervision of public prosecutor, citing Lim Tek Goan v. Yatco.
CA ruled that petitioner’s right to fair trial was not violated since public prosecutor maintained authority.
CA denied petitioner’s motion for reconsideration on January 31, 2008.

Whether CA erred in upholding MeTC's ruling recognizing presence of private offended party in perjury, a crime against public interest.
Whether CA erred in allowing respondent, as alleged stockholder of CHI, to intervene as private complainant on behalf of corporation without its authority.

Whether the Court of Appeals gravely erred in holding that there is a private offended party in the crime of perjury, which is a public offense, thereby permitting private prosecution intervention.

Whether the Court of Appeals erred in upholding the intervention of respondent, an alleged stockholder and officer of CHI, as private complainant and counsel without the corporation’s express authorization.