Facts:

The case involves the People of the Philippines as the petitioner against respondents Jessie B. Castillo, the Municipal Mayor of Bacoor, and Felicito R. Mejia, the Municipal Building Official. The events leading to this case began in September 1999 when Mejia issued Notices of Violation to stallholders leasing property owned by complainant Cesar Sarino, located in front of SM Bacoor, Cavite, for operating without the necessary building permits. Following repeated non-compliance, Mejia's office sent letters to the stallholders, warning them of impending closure. On January 24, 2000, a task force from the Bacoor Municipal Hall closed the stalls by erecting galvanized iron fences.

In response, lessees Pepito B. Aquino and Adriano G. Samoy filed a complaint against Castillo, Mejia, and two other municipal officials for violations of the Anti-Graft and Corrupt Practices Act. The Office of the Ombudsman dismissed this complaint on October 20, 2000, citing good faith in the a...

Facts:

Property Ownership and Lease

• Complainant Cesar Sarino is one of the registered owners of a piece of land covered by Transfer Certificate of Title No. T-450278, located in front of SM Bacoor, Cavite. The property is leased to Pepito B. Aquino and Adriano G. Samoy, who sublease it to several stallholders.

Notices of Violation

• In September 1999, respondent Felicito R. Mejia, Municipal Building Official of Bacoor, sent Notices of Violation to the stallholders for violating the National Building Code. The violations included erecting structures without building permits and occupying them without certificates of occupancy.

Closure of Stalls

• On January 17, 2000, Mejia's office informed the stallholders that their stalls would be closed on January 24, 2000, due to their failure to comply with the National Building Code and Business Permit and Licensing Office requirements.
• On February 16, 2000, a task force from the Bacoor Municipal Hall closed the stalls by installing galvanized iron fences.

Initial Complaint and Dismissal

• Lessees Aquino and Samoy filed a complaint before the Office of the Ombudsman against respondents Jessie B. Castillo (Municipal Mayor) and Mejia for violation of Section 3(e) and (f) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The case was docketed as OMB-1-00-0537.
• On October 20, 2000, the Ombudsman dismissed the complaint, ruling that the respondents acted in good faith.

Second Complaint

• On September 6, 2001, Sarino filed a complaint against Castillo and Mejia before the Ombudsman, charging them criminally for violation of Section 3(e) and (f) of R.A. No. 3019 and R.A. No. 6713, and administratively for oppression, grave misconduct, and acts contrary to law.
• Sarino claimed that the installation of the galvanized fence constituted an unlawful taking of property, causing undue injury, and that respondents refused to remove the fence despite demands.

Dismissal of Administrative Complaint

• On March 10, 2003, the Ombudsman dismissed the administrative complaint against Castillo for being moot due to his re-election as mayor and because the act complained of occurred more than one year before the complaint was filed.

Criminal Case

• On May 7, 2003, the Ombudsman filed an Information against respondents for violation of Section 3(e) of R.A. No. 3019 before the Sandiganbayan, docketed as Criminal Case No. 27789.
• The Sandiganbayan found probable cause and issued warrants of arrest. Respondents voluntarily surrendered and posted bail.
• After reinvestigation, the Ombudsman filed an Amended Information, which the Sandiganbayan admitted on November 3, 2004.

Sandiganbayan's Dismissal

• On October 10, 2005, the Sandiganbayan dismissed the case, ruling that it was a rehash of the previously dismissed case and that there was no evidence of bad faith, manifest partiality, or undue injury.
• The Ombudsman's motion for reconsideration was denied on January 18, 2006, prompting this petition.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Executive vs. Judicial Determination of Probable Cause:

   • The executive determination of probable cause is made during preliminary investigation by the public prosecutor, while the judicial determination is made by the judge to decide whether to issue an arrest warrant.
   • Courts should respect the prosecutor's discretion unless the information is invalid on its face or the prosecutor committed manifest error or grave abuse of discretion.

2. Sandiganbayan's Overreach:

   • The Sandiganbayan erred in making an executive determination of probable cause by overturning the Ombudsman's findings. Its role was limited to determining whether to issue arrest warrants, not to reassess the prosecutor's findings.

3. Premature Findings:

   • The Sandiganbayan prematurely concluded that there was no bad faith or undue injury without a full trial. The presence or absence of the elements of the crime is evidentiary and should be determined after a trial.

4. Non-Interference Policy:

   • Courts should not interfere with the Ombudsman's exercise of its investigatory and prosecutory powers unless there is grave abuse of discretion. The Sandiganbayan's actions violated this policy.

Conclusion:

The Supreme Court emphasized the separation of powers between the prosecutor and the judiciary, ruling that the Sandiganbayan overstepped its authority by reassessing the Ombudsman's determination of probable cause. The case was remanded for trial to properly determine the merits of the charges against the respondents.