Case Digest (G.R. No. 263329)
Facts:
In a petition under Rule 45, FERDINAND "VHONG" H. NAVARRO, PETITIONER, assailed the Court of Appeals' July 21, 2022 Decision reversing DOJ Resolutions (April 30, 2018 and July 14, 2020) that had dismissed for lack of probable cause complaints by DENIECE MILINETTE * CORNEJO alleging rape (under Article 266-A as amended by RA 8353) and attempted rape/acts of lasciviousness (under Article 336), arising from incidents of January 17 and 22, 2014; the CA directed the Taguig City Prosecutor to file Informations. The DOJ had earlier dismissed three complaints (April 4, 2014; July 4, 2014; Sept. 6, 2017) for lack of probable cause; the Supreme Court, in a February 8, 2023 decision, reviewed the CA ruling.
Issues:
- Did the Court of Appeals err in holding that the DOJ committed grave abuse of discretion in affirming the prosecutor’s finding of lack of probable cause?
- May a prosecutor, in a preliminary investigation, consider glaring inconsistencies in multiple complaints when determining whether probable cause exists?
Ruling:
The petition was GRANTED. The Court held that the CA erred and reversed and set aside the CA Decision and Resolution. The Supreme Court found no grave abuse of discretion in the DOJ’s affirmance of the prosecutor’s dismissal and accordingly DISMISSED the Informations against FERDINAND "VHONG" H. NAVARRO for lack of probable cause.
Ratio:
The Court reiterated the executive nature of the prosecutorial prerogative to determine probable cause and the judicial policy of non‑interference, allowing court review only where there is patent, capricious, or despotic action amounting to grave abuse of discretion. A preliminary investigation is a realistic judicial appraisal that must screen meritless cases; prosecutors may objectively evaluate the evidence, including manifest and glaring inconsistencies in successive complaint‑affidavits, without unlawfully usurping the trial court’s role on witness demeanor, and the DOJ’s thorough, reasoned dismissal here did not exhibit arbitrariness warranting certiorari relief.
Doctrine:
- The existence of probable cause for filing an information is primarily within the prosecutorial prerogative, and courts must defer absent grave abuse of discretion.
- A preliminary investigation is a *realistic judicial appraisal* that permits the prosecutor to weigh evidence and dismiss cases that lack sufficient probability of guilt.
- Prosecutors may consider glaring and material inconsistencies in multiple affidavits when determining probable cause and need not ignore them on the ground that credibility is solely for trial.
- Certiorari under Rule 65 is an extraordinary remedy and will not lie to correct mere errors of judgment or to substitute the court’s view for that of a quasi‑judicial body.