Title
Supreme Court
Villanueva vs. United Coconut Planters Bank
Case
G.R. No. 138291
Decision Date
Mar 7, 2000
Hector Villanueva, acquitted in a fraud case, sued UCPB for malicious prosecution; SC ruled no liability, citing probable cause and lack of malice.

Case Digest (G.R. No. 138291)
Expanded Legal Reasoning Model

Facts:

Background of the Loan and Alleged Fraud:

  • In December 1978, Hermenegildo Villanueva, father of petitioner Hector C. Villanueva, applied for and was granted a loan by United Coconut Planters Bank (UCPB), Dumaguete City Branch, for agricultural coconut production and processing. The loan was secured by a mortgage on a parcel of land owned by Hermenegildo.
  • During a bank audit, UCPB discovered fraud, anomalies, and irregularities in the loan application, processing, and granting. The bank concluded that Hector Villanueva, his father Hermenegildo, UCPB Branch Manager Bobby Cafe, and Reynaldo Ramos conspired to defraud the bank.

Criminal Complaints Filed:

  • On June 8, 1979, UCPB filed six criminal complaints with the Office of the City Fiscal of Dumaguete City against Bobby Cafe, Hermenegildo Villanueva, Hector Villanueva, and Reynaldo Ramos for violations of the General Banking Act and the Revised Penal Code.
  • After a preliminary investigation, the City Fiscal found probable cause and filed three criminal cases in the Regional Trial Court (RTC) of Dumaguete City.

Acquittal of Hector Villanueva:

  • On June 29, 1991, the RTC acquitted Hector Villanueva and Reynaldo Ramos in all three cases, while Bobby Cafe was convicted in one case. Hermenegildo Villanueva’s cases were dismissed due to his death.

Civil Case for Damages:

  • Following his acquittal, Hector Villanueva filed a civil case for damages against UCPB, alleging malicious prosecution. He claimed that the criminal cases were filed with malice, damaging his reputation, political career, and business dealings.
  • The RTC ruled in favor of Hector Villanueva, awarding him moral damages, exemplary damages, and attorney’s fees. However, the Court of Appeals (CA) reversed this decision, dismissing the complaint for lack of evidence of malicious prosecution.

Issues:

  • Probable Cause: Was there probable cause against Hector Villanueva in the criminal cases filed by UCPB?
  • Liability of Private Complainant: Can UCPB, as the private complainant in the criminal cases, be held liable for malicious prosecution, even though the prosecution was handled by the fiscal?
  • Malice: Was the prosecution of Hector Villanueva motivated by malice?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court held that Hector Villanueva failed to prove the elements of malicious prosecution. The existence of probable cause and the absence of malice on the part of UCPB justified the dismissal of his claim for damages. The Court emphasized that the right to litigate must be protected, and liability for malicious prosecution cannot be imposed without clear evidence of improper motives.


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