G.R. No. L-159 - People vs. Ricarte

Petitioner Rosemarie Magbanua worked as a housemaid for respondent Pilar S. Junsay.
Rosemarie was charged with robbery (Criminal Case No. 28, RTC Branch XLI, Bacolod City) alongside two others, Ernesto Fernandez and a certain Gudo who remained at large.
The complaint alleged that on or about July 18, 1982, the accused persons conspired and forcibly entered Pilar’s house through the kitchen door, stealing assorted jewelries and cash worth P29,624.00.
The prosecution's case relied heavily on an alleged confession by Rosemarie admitting participation. The defense argued the confession was made under duress and challenged its admissibility.

On December 20, 1985, the RTC Branch XLI acquitted Rosemarie for insufficiency of evidence and ruled the alleged confession inadmissible due to maltreatment inflicted by investigating officers.
The court found other prosecution evidence insufficient and disbelieved the testimony that jewelry was found in Rosemarie's bag.

On March 9, 1987, Rosemarie, assisted by her father Conrado Magbanua and Artemio Taborada, filed a Complaint for Damages against Pilar, her husband Vicente Junsay, and police officers Ibarra Lopez and Juanito Jacela.
The complaint charged the respondents with malicious prosecution, false and illegal acts in filing the criminal case, and sought moral, exemplary damages, attorney’s fees, and expenses for Rosemarie’s defense.
Respondents Pilar, Ibarra, and Juanito filed motions to dismiss on the grounds of prescription under the four-year statute of limitations. Petitioners argued that prescription should be counted from Rosemarie's acquittal and denied prescription.

RTC denied the motion to dismiss, ruling the complaint was for malicious prosecution with a prescriptive period starting at the acquittal date.
Respondents denied allegations of maltreatment and malicious intent, claiming Pilar was not present during interrogation and only reported the robbery; police officers merely performed their duties.
Petitioners introduced medical certificates and decisions finding police officers guilty of grave misconduct and suspension for maltreating Rosemarie, including injuries documented by medico-legal officers.
Both parties stipulated the issue revolved around whether malicious prosecution existed.

On July 25, 1995, the RTC dismissed the complaint for malicious prosecution, finding no proof of malice or absence of probable cause.
The RTC emphasized that filing a criminal complaint based on reasonable grounds is not malicious prosecution and that respondent Pilar, as a robbery victim, had no legal malice in reporting the crime.
The Court of Appeals affirmed the RTC decision on January 26, 1998, finding probable cause existed because Rosemarie admitted participation during investigation and that the police acted pursuant to official duties without sinister motives.

Petitioners elevated the case to the Supreme Court via an Appeal by Certiorari, contesting the dismissal and urging that the prosecution was malicious and based on false affidavits and police reports, with maltreatment to extract confessions.

Whether the respondents are liable for damages for malicious prosecution in filing the criminal case against petitioner Rosemarie Magbanua.