G.R. No. 154685 - Metropolitan Bank and Trust Company vs. Court of Appeals

Approximately thirty years prior, Manager Teofilo Fiesta submitted a letter-complaint to City Fiscal Raymundo Ponteras, accusing Antonio LaiAo (respondent) of swindling Metropolitan Bank and Trust Company (Metrobank).
Fiscal Ponteras, after a preliminary investigation, issued a Resolution on December 28, 1976, finding probable cause to charge LaiAo with estafa, primarily arising from a series of bank transactions.

Eduardo Tambis, Jr., acting as an agent or representative of Antonio LaiAo, was allowed by Metrobank to open a personal account (Account No. 123) even though the checks deposited—Check Nos. 1910 and 12450—were payable to ACL Engine Consultant, a company associated with LaiAo.
Tambis withdrew a total amount of ₱24,551.08 from the bank, wherein ₱22,900.00 was paid to Caspin Trading, purportedly for spare parts purchased for ACL Engine Consultant, leaving a discrepancy of ₱1,651.08. Tambis contended that the excess amount was used for operational expenses in Manila for the benefit of the partnership.
On January 26, 1976, LaiAo formally protested before Metrobank regarding the unauthorized deposits and withdrawals made by Tambis, asserting that such transactions lacked his authorization.
Despite this, on February 17, 1976, LaiAo withdrew ₱35,400.00 from Metrobank, seemingly disregarding Tambis’ earlier payment to Caspin Trading, further complicating the transactional records.

Following the Fiscal’s Resolution, an Information was filed at the Regional Trial Court (RTC), Branch 57, San Carlos City, in Criminal Case No. RTC-1015, charging both LaiAo and Tambis with estafa.
Through demurrer to evidence, the RTC dismissed the criminal case against LaiAo, citing the insufficiency of evidence to establish even a preponderance of guilt, while later dismissing the case against Tambis in its decision dated February 28, 1990, albeit holding Tambis civilly liable to Metrobank for ₱16,900.00.
On April 27, 1989, LaiAo initiated a civil complaint for damages against Metrobank, Gella, Fiesta, and Fiscal Ponteras for malicious prosecution. In their answer, Metrobank and the other respondents counterclaimed damages.
The RTC rendered a decision on July 28, 1992, dismissing LaiAo’s complaint and awarding damages, which was then appealed by LaiAo to the Court of Appeals (CA).

In its March 13, 2002 decision, the CA set aside the RTC’s decision, awarding LaiAo significant damages including moral, exemplary, and attorney’s fees, finding that the criminal case had been initiated without probable cause.
Metrobank and its representatives subsequently filed a motion for reconsideration, which was denied by the CA in its August 12, 2002 resolution.
The petitioners (Metrobank, Gella, and Fiesta) then elevated the issue before the Supreme Court by questioning the CA’s finding that the initiation of Criminal Case No. RTC-1015 amounted to malicious prosecution.

Whether the initiation of Criminal Case No. RTC-1015 against Antonio LaiAo was carried out without probable cause.

Did the reliance on an unverified affidavit from Eduardo Tambis, Jr. (claiming a partnership with LaiAo) suffice to establish probable cause?
Was it proper for Metrobank and its representatives to ignore their own banking protocols—particularly the requirement for written authorization—when they allowed the bank transactions to proceed?

Whether the filing of the criminal case was motivated by malice and intended to harass, annoy, or injure the respondent.

Does the evidence reveal that the petitioners acted with ill-intent, knowing that their complaint was unfounded?
How does the court reconcile the previous finding of probable cause by Fiscal Ponteras with subsequent evidence suggesting that the complaint was frivolous and intended for harassment?