G.R. No. L-39211 - People vs. Atanacio

The Punzalan and the Plata families were neighbors in Hulo Bliss, Mandaluyong City.
Members of the Punzalan family (Rosalinda, Rainier, Randall) were involved in an altercation with individuals associated with the Plata family.
Dencio Dela PeAa, a house boarder of the Platas, became the initial focal point of the confrontation.

At approximately 11:00 p.m., a group composed of Rainier Punzalan, Randall Punzalan, Ricky Eugenio, Jose Gregorio, Alexander aTotoa Ofrin, and others arrived near a store by the Platas’ residence.
An exchange of provocative remarks ensued when Ricky Eugenio shouted at Dela PeAa about his physical appearance and his headwear.
Dela PeAa’s retort escalated tensions, leading to physical violence:

Jose Gregorio slapped Dela PeAa and Rainier punched him in the mouth.
The group ganged up, with one person shouting and Alexander aTotoa Ofrin kicking Dela PeAa and attempting to stab him with a balisong—a stab that missed as Dela PeAa managed to flee.

While fleeing, Dela PeAa encountered Robert Cagara (the Plata family driver) who was carrying a gun.
Dela PeAa grabbed the firearm from Cagara and pointed it at the pursuing group.
Michael Gamaliel Plata intervened, attempting to wrestle the gun away; during the struggle, the gun accidentally discharged, wounding Rainier Punzalan on the thigh.
The injured parties and intervenors retreated to safety and then sought police assistance.

Rainier Punzalan filed criminal complaints—specifically for attempted homicide (later classified as such) and illegal possession of firearms against Michael Plata and Robert Cagara.
Conversely, Michael Plata, Ruben Plata, and several others filed complaints against petitioners Rosalinda, Rainier, Randall, and other individuals.
The complaints covered a range of offenses including:

Slight Oral Defamation (charged against Rosalinda Punzalan on multiple occasions).
Light Threats and Grave Threats (allegedly by Rosalinda and others).
Attempted Homicide (involving allegations against Rainier, Randall, and others alongside conflicting criminal cases).
Malicious Mischief and Theft (alleged against multiple respondents).
Slight Physical Injuries (involving discrepancies in the witness affidavits provided by Robert Cagara and Dela PeAa).

On July 28, 1998, the Office of the City Prosecutor dismissed several complaints for lack of sufficient evidentiary basis.
On March 23, 2000, the DOJ issued a resolution ordering the filing of separate informations against petitioners for the various charges.
Subsequently, the DOJ reconsidered its position:

On April 28, 2000, a motion for reconsideration was filed.
On June 6, 2000, the DOJ reversed its earlier resolution, directing the withdrawal of the informations.
The denial of the petitioners’ subsequent motion for reconsideration was reaffirmed in the October 11, 2000 Resolution.

Petitioners elevated the matter by filing a petition for review on certiorari before the Court of Appeals (CA) claiming grave abuse of discretion on the part of the DOJ Secretary.
On September 29, 2003, the CA annulled and set aside the DOJ’s June 6, 2000 and October 11, 2000 Resolutions, reinstating the March 23, 2000 Resolution.
The CA’s decision detailed the evidence and issues surrounding the alleged acts of defamation, threats, attempted homicide, malicious mischief, and theft.
The contested issues eventually reached the Supreme Court for review, with the petitioners asserting errors in the CA determination and the DOJ’s alleged abuse of prosecutorial discretion.

Whether the Court of Appeals committed a grave abuse of discretion by setting aside the DOJ Resolutions of June 6, 2000 and October 11, 2000 and reinstating the March 23, 2000 Resolution.
Whether the alleged defamatory statements by petitioner Rosalinda Punzalan on multiple occasions truly constitute slight oral defamation or whether they were made under the influence of shock or anger due to the incident.
Whether the evidentiary basis provided by the complainants, including the alleged eyewitness identifications and conflicting affidavits, is sufficient to sustain charges of malicious mischief, theft, and attempted homicide against the petitioners.
Whether the CA improperly supplanted the prosecutorial discretion vested in the DOJ by intervening in the preliminary investigation and determination of probable cause.