G.R. No. 216024 - Spouses Yu vs. Topacio, Jr.

On 19 October 1980, a criminal complaint (I.S. No. 80-198) was lodged at the Office of the City Fiscal of San Carlos City, Pangasinan with the following charges:

“Serious Physical Injuries” – filed by Bonifacio Menor against respondent Arnulfo (Arnold) Payopay.
“Slight Physical Injuries” – filed by Fred de la Vega against respondent Beda Acosta.
“Trespass to Dwelling” – filed by Pacita Tandoc against respondents Arnulfo (Arnold) Payopay, Beda Acosta, Manuel Cancino, Nadong Fernandez, and Arturo Syloria.

During the incident at the house of Pacita B. Tandoc on Rizal Avenue, an altercation ensued leading to the complainants’ helpers being injured when stones were thrown by respondents.

Following the initial case, on 2 December 1980, respondents (Arnulfo (Arnold) Payopay, his father Conrado Payopay, Sr., and Manuel Cancino) filed another criminal complaint (I.S. No. 80-233) with the Office of the City Fiscal alleging:

The investigating fiscal, on 10 December 1980, found reasonable ground to believe that, in relation to I.S. No. 80-198, the offenses of “Trespass to Dwelling,” “Serious Physical Injuries” (committed by Arnulfo Payopay) and “Slight Physical Injuries” (committed by Beda Acosta) were made out.
As a result, corresponding informations were filed with the City Court of San Carlos City under docketed Criminal Cases Nos. 1992, 2000, and 2001.

On 28 January 1981, an information for “Trespass to Dwelling” was filed with the City Court (Criminal Case No. 2017) based on a prima facie case against petitioner Pedro Tandoc.
On 28 July 1981, respondents directly filed criminal complaints with the City Court alleging:

Criminal Case No. 2105 – “Serious Physical Injuries” against Pedro Tandoc, Rogelio Ercella, Rudy Diaz, Juan Rosario, and Fred Menor (private complaint of Arnulfo Payopay).
Criminal Case No. 2106 – “Trespass to Dwelling” against Rudy Diaz, Juan Rosario, and Fred Menor (private complaint of Conrado Payopay, Sr.).
Criminal Case No. 2107 – “Less Serious Physical Injuries” against Pedro Tandoc, Rudy Diaz, Juan Rosario, and Fred de la Vega (private complaint of Manuel Cancino).
Criminal Case No. 2108 – “Grave Threats to Kill” against Pedro Tandoc, Rudy Diaz, Rogelio Ercella, Juan Rosario, and Fred Menor (private complaint of Arnulfo Payopay).

On 13 August 1981, the City Court of San Carlos City issued several orders after a preliminary examination finding reasonable ground to believe that petitioners (Pedro Tandoc, Rogelio Ercella, Rudy Diaz, Juan Rosario, and Fred Menor) were probably guilty of the offenses charged.
Warrants of arrest were ordered against the petitioners; however, these were subsequently suspended upon their motion.
Petitioners filed a motion for reconsideration as well as a motion for re-investigation by the Office of the City Fiscal, which were both denied.

Preliminary examination (conducted before the arrest) to determine if there is reasonable ground to issue a warrant of arrest.
Preliminary investigation proper (conducted after arrest) where the accused is informed of the complaint and allowed to examine the evidence and present counter-evidence.

The primary purpose of the preliminary investigation is to ascertain whether a crime has been committed and if there is probable cause to charge the accused, thereby protecting both the rights of the accused and the state from unnecessary trial expenditures.

The offenses charged (Trespass to Dwelling, Grave Threats, Less Serious Physical Injuries, and Serious Physical Injuries) fall within the jurisdiction of the City Court of San Carlos City.
The City Court, empowered to conduct a preliminary examination, assumed jurisdiction not only to initiate a trial on the merits but also to issue warrants based on the determination of probable guilt.
The fact that an earlier preliminary investigation by the Office of the City Fiscal was conducted and later dismissed did not preclude the City Court from conducting its own preliminary examination.

Whether the City Court of San Carlos City possesses the power to conduct a new preliminary examination of charges after an initial preliminary investigation by the Office of the City Fiscal has been dismissed.
Whether filing the complaints directly with the City Court, instead of solely relying on the fiscal’s investigation, is within the court’s jurisdiction.

Whether the preliminary examination conducted by a competent officer (the City Court) is sufficient to establish reasonable ground for charging the accused even if a prior fiscal investigation was already carried out.
How the two-stage process of preliminary investigation (preliminary examination and investigation proper) applies, given the context of the complaints filed.

Whether the results of a preliminary investigation, which is not a trial on the merits, may give rise to a double jeopardy defense when the case is subsequently tried in the City Court.
Clarification that double jeopardy requires a prior judgment (acquittal or conviction) by a competent court and cannot be invoked solely on the basis of a preliminary finding.