G.R. No. L-18562 - University of the Philippines vs. City Fiscal of Quezon City

Petitioners Tomas S. Fonacier and Leopoldo Y. Yabes are respectively the editor and managing editor of the Philippine Social Sciences and Humanities Review.
The Review is a scholarly publication primarily devoted to research papers and monographs in the Social Sciences and Humanities, associated with the University of the Philippines, and is circulated mainly among the university community and correspondent institutions abroad.

The disputed issue is the Golden Jubilee edition published in celebration of the University of the Philippines’ Golden Jubilee in July 1959.
Among the contents is an article partly entitled "The Peasant War in the Philippines," which discusses aspects of social unrest and provides an analysis rooted in the country’s political economy.
A total of 2,000 copies were printed:

500 copies were distributed to various correspondent institutions of learning and research abroad.
1,500 copies were circulated among faculty members, alumni, and students of the university.

On or about June 7, 1961, Carlos Albert filed a verified complaint with the respondent, the City Fiscal of Quezon City.
The complaint charged petitioners with inciting sedition as defined under Article 142 of the Revised Penal Code, connected with the publication and circulation of the Golden Jubilee issue.
A preliminary investigation was conducted by the City Fiscal’s assistant, Miguel Halili, Jr., on June 29, 1961.

Petitioners contended that the filing of a criminal information against them would constitute harassment and an abuse of public power.
They argued that such action, if taken, would be oppressive, vindictive, and in excess of jurisdiction, thereby infringing upon their academic freedom as guaranteed by the Constitution.
The petition asserted that the potential criminal prosecution would cause incalculable harm to the academic and research functions of the University of the Philippines.

Whether it is proper to enjoin, restrain, and prohibit the City Fiscal and his assistants from filing a criminal information under Article 142 of the Revised Penal Code, based on the allegations made in the petition.
The issue also hinges on whether evidence presented during the preliminary investigation justifies such filing, and if the exercise of prosecutorial discretion in this context would be considered an abuse of power.

Whether a court may issue an injunction to restrain a criminal prosecution when the prosecution is allegedly based on acts performed in good faith.

This includes the inquiry into whether prosecutorial action, when based on sufficient evidence from a preliminary investigation, amounts to an oppressive or vindictive use of public power.

Whether the filing of a criminal information by the City Fiscal, in the context of the investigation into the publication of an article on the peasant war, violates the academic freedom of the petitioners and harms the academic functions of the University of the Philippines.