G.R. No. L-33773 - Lorenzana vs. Macagba

Respondent-spouses Edgardo and Nelia Aguinaldo filed a complaint before the Office of the City Prosecutor (OCP) of Manila.
They alleged that petitioner Artemio T. Torres, Jr. falsified public documents by effecting the transfer of titles to certain properties (identified by Transfer Certificates of Title Nos. T-93596, T-87764, and T-87765) without their knowledge and consent.
The alleged falsification involved a forged Deed of Sale dated July 21, 1979.

Torres denied the allegations of forgery and maintained that the properties were legitimately sold to him.
He presented a Deed of Absolute Sale dated March 10, 1991 to substantiate his claim of a genuine sale.

Based on findings of probable cause from the OCP, an information for falsification of public document was filed against Torres before the Metropolitan Trial Court (MTC) of Manila, Branch 8, on October 3, 2001.
Torres moved for reconsideration of the proceedings, which was denied by the court.
On appeal, the Secretary of Justice reversed the investigating prosecutor’s findings and ordered the withdrawal of the information.
A motion for reconsideration by Aguinaldo was similarly denied.
A Motion to Withdraw Information was subsequently filed and granted by the MTC on June 11, 2003, noting that petitioner Torres had not been arraigned.

Independently, Aguinaldo filed a petition for certiorari before the Court of Appeals seeking the reinstatement of the April 30, 2001 resolution of the OCP of Manila.
The Court of Appeals, in its decision dated March 22, 2004, granted the petition, thereby reversing the resolutions of the Secretary of Justice.
The dispositive portion of the decision reinstated the April 30, 2001 resolution finding probable cause against Torres and set aside the Secretary’s resolutions dated November 12, 2002 and April 30, 2003.
Torres’ subsequent motion for reconsideration of the Court of Appeals decision was denied, prompting his petition for review on certiorari before the Supreme Court.

Torres asserted that the order of the MTC granting the motion to withdraw the information rendered moot the petition for certiorari filed by Aguinaldo.
He questioned whether provisional dismissal rules under Section 8, Rule 117 applied to the motion to withdraw information.
Torres raised several other issues including alleged forum shopping by the respondents and whether the Court of Appeals had overstepped by substituting its judgment for that of the Secretary of Justice.

Whether the order by the MTC on June 11, 2003, granting the motion to withdraw the information, effectively rendered moot and academic the petition for certiorari filed by respondents for reinstating the OCP resolution dated April 30, 2001.
Whether, alternatively, the rule on provisional dismissal under Section 8, Rule 117 of the Revised Rules of Criminal Procedure should apply.

Whether the respondents engaged in forum shopping by filing multiple cases against petitioner Torres on distinct causes of action.
The issue also touched on the necessity of a certificate of non-forum shopping in criminal cases versus civil complaints.

Whether the Secretary of Justice gravely abused his discretion in reversing the investigating prosecutor’s findings on the existence of probable cause.
Whether the reversal was legally proper given that the prosecution of criminal offenses, especially on matters of preliminary investigation, falls within the purview of the executive branch (the Department of Justice) and its established procedures.

Whether evidence presented by the respondent in a criminal case should be considered during the preliminary investigation stage in determining probable cause.
The issue also involved whether defenses initially raised should be left for trial rather than for preliminary inquiry.

Whether the Court of Appeals exceeded its authority by substituting its own judgment for that of the Secretary of Justice.
Whether the court’s action constituted a deliberate disregard of procedural rules, including Section 3, Rule 46 of the 1997 Rules of Civil Procedure.