G.R. No. L-48011 - Peralta vs. Court of 1st Instance of La Union, Branch I

In October 1974, private respondent Napoleon S. Arrieta filed a complaint for disbarment against petitioner Pedro G. Peralta before the Supreme Court, alleging perjury and other unethical conduct that allegedly discredited the legal profession.
Arrieta’s complaint included serious charges against petitioner, such as betraying and attempting to prostitute the noble profession of law.

Before any action was taken on the disbarment complaint, on October 7, 1978, Arrieta distributed copies of his complaint in San Fernando, La Union.
One of the recipients of the circulated complaint was Atty. Manuel Sanglay, who was the counsel for petitioner in a separate damage suit against Arrieta.
Shortly thereafter, petitioner initiated criminal libel charges against Arrieta.

The Office of the Provincial Fiscal of La Union formed a panel of three fiscals to conduct the preliminary investigation on the libel case, which lasted nearly nine (9) months.
On July 23, 1975, after due deliberation, the panel found a prima facie case against Arrieta and recommended the filing of an information for libel.
Arrieta filed a motion for reconsideration regarding the investigation findings, which was promptly denied.

The Provincial Fiscal filed the information for libel against Arrieta on September 25, 1975, formally initiating the criminal libel action in the Court of First Instance (CFI) of La Union, Branch I.
On October 6, 1975, Arrieta elevated the resolution of the investigative panel by appealing to the Secretary of Justice.
On October 13, 1975, the Secretary of Justice ordered the Provincial Fiscal to comment, elevate the record, and temporarily suspend further proceedings pending his review.

In anticipation of the effect of the Secretary’s directive, petitioner filed a special civil action for Certiorari, Prohibition, and Mandamus with a Preliminary Injunction (Civil Case No. 2774) before the CFI of La Union, Branch II.
This action sought the annulment of the Secretary of Justice’s order and enjoined both the Secretary and the Provincial Fiscal from filing a motion to dismiss the libel information.
A writ of preliminary injunction was duly issued on February 21, 1977, directing the authorities to refrain from dismissing the libel complaint.

Despite the injunction, the Provincial Fiscal, responding to the evolving circumstances, filed an “Urgent Ex Parte Motion to Withdraw Motion to Dismiss.”
Subsequently, Arrieta’s legal team opposed the withdrawal by urging the trial court to grant the previously filed motion to dismiss.
On October 13, 1977, the trial court dismissed the libel case against Arrieta.
Petitioner’s later motion for reconsideration of the dismissal was denied by a minute resolution dated February 25, 1978.

The petition for review primarily challenges the propriety of the Secretary of Justice’s intervention under Presidential Decree No. 911, questioning his power to review the findings of the inquest fiscals and to influence the disposition of a case after the formal filing of a complaint or information in court.
Petitioner contends that once the fiscal has exercised his judicial function by filing an information based on the established prima facie case, further review should lie solely with the court and not with the Secretary of Justice.

Whether the Secretary of Justice possesses the power under Presidential Decree No. 911 to review and direct the dismissal of a criminal libel case after the information has already been filed in court.
Whether the filing of a criminal libel information by the Provincial Fiscal, after conducting a preliminary investigation and establishing a prima facie case, should be subject exclusively to the discretion of the court, free from administrative intervention.
Whether the special civil action for Certiorari, Prohibition, and Mandamus challenging the Secretary of Justice’s order is a proper remedy in such a situation.
The extent to which prior decisions, particularly Crespo v. Hon. Mogul, et al., govern the interplay between the fiscal’s investigative findings and the trial court’s prerogative regarding motions to dismiss.