G.R. No. L-12247 - Vda. Bagatua vs. Revilla

Lot No. 569 of the Piedad Estate, originally within Caloocan, Rizal and now part of Quezon City, covers approximately 43,371 square meters.
The property was initially registered in the name of Apolonio Bagatua under Transfer Certificate of Title No. 21411.
Upon Apolonio Bagatua’s demise, his widow, Beatriz Ramos, and their children—Rodrigo, Paz, Lydia, and Basilia Bagatua—executed a document titled “Settlement of Estate and Donation of Real Property” on June 2, 1953.
In that document, Beatriz Ramos donated the property to her children, and subsequently, a certificate of title (T. C. T. No. 21995) was issued in the names of the Bagatuas as common owners.

The Bagatuas decided to subdivide their lot among themselves and engaged Burgos L. Pangilinan, a real estate broker, for assistance.
On June 29, 1954, the Bagatuas, along with their spouses and their mother Beatriz Ramos, executed a public instrument duly registered, whereby they sold and conveyed a portion of the lot measuring 3,358 square meters to Pangilinan for the sum of P6,000.

On June 21, 1956, Rodrigo Bagatua, acting on behalf of himself and his sisters, accused Burgos L. Pangilinan of estafa, alleging that Pangilinan induced them to sign papers which, under the pretense of being required for the subdivision of their property, turned out to be a deed of sale.
The complainants claimed to have suffered a financial prejudice amounting to P13,432.
The complaint was filed with the City Attorney of Quezon City, and the Assistant City Attorney conducted a preliminary investigation involving testimonial and documentary evidence from both parties.
After the investigation and the filing of respective memoranda by the parties, the Assistant City Attorney recommended the dismissal of the complaint due to lack of merit.
Based on this recommendation, the City Attorney dismissed the complaint.

Dissatisfied with the dismissal, the petitioners (representing the Bagatuas) filed a petition for mandamus with the Court of First Instance of Quezon City, seeking to compel the City Attorney and the Assistant City Attorney to file a corresponding information for estafa against Pangilinan.
The respondents (City Attorney and Assistant City Attorney) filed a motion to dismiss, arguing that prosecutorial functions involve discretion that cannot be controlled by mandamus unless a grave abuse of discretion is established.
The Court of First Instance sustained the motion to dismiss on February 23, 1957, finding no clear indication that the respondents abused their discretion.

Section 28-(h) of Republic Act No. 537 (Revised Charter of Quezon City) mandates the City Attorney to investigate all charges of crimes, misdemeanors, and ordinance violations.
The Rules of Court (Section 4, Rule 106) provide that all criminal actions are to be prosecuted under the direction and control of the fiscal.
Precedents, such as Gonzales vs. Court of First Instance of Bulacan, People vs. Orias, and People vs. Natoza, were cited to underscore that a prosecuting officer may dismiss a case if the evidence does not, prima facie, warrant a criminal prosecution.

Whether the dismissal of the estafa complaint by the City Attorney and the Assistant City Attorney constituted a grave abuse of discretion warranting the issuance of a writ of mandamus.

Did the investigative findings provide sufficient grounds to negate the filing of criminal charges against Pangilinan?
Is the absence of improper motive in the preliminary investigation enough to establish a prima facie case for estafa?

Whether mandamus is the appropriate remedy to compel prosecutorial officials to file charges when they have exercised their discretion based on insufficient evidence.

Can the prosecutorial decision to dismiss a complaint, when the evidence is deemed inadequate, be reviewed through a mandamus petition?
To what extent does prosecutorial discretion protect the decisions of fiscal officers in charge of filing criminal charges?

Whether the lower court’s dismissal of the petition for mandamus was legally sound in light of the discretionary powers vested in the prosecuting officers.

Were the legal standards and precedents correctly applied to support the dismissal of the case for lack of merit?
Does the decision reaffirm the balance between avoiding baseless prosecutions and protecting public interest?