G.R. No. 149199 - People vs. Bon

In November 1971, Aurea Yasoaa, accompanied by her son Saturnino, sought financial assistance from Jovencio de Ramos at his residence to pay off her bank loans with the Philippine National Bank (PNB) to avoid foreclosure of her residential house and lot.
Being his aunt, Aurea received assistance from Jovencio, and the parties agreed that once Jovencio paid the loan, half of Aurea’s property would be sold to him.

On December 29, 1971, Jovencio paid the bank loan, and in accordance with their agreement, Aurea executed a deed of absolute sale in favor of Jovencio for half of the 123-square-meter lot.
Following the transaction, the lot was surveyed and subsequently divided. Separate titles were issued by the Register of Deeds of Sta. Cruz, Laguna: one in the name of Aurea (TCT No. 73252) and one in the name of Jovencio (TCT No. 73251).
From 1973 onward, Jovencio paid the realty taxes on the portion registered in his name, and various transactions—including using his property portion as bond and the mortgaging of Aurea’s remaining lot—further indicated an acknowledgment of the sale.

Twenty-two years after the sale, in August 1993, Aurea initiated an estafa complaint against brothers Jovencio and Rodencio de Ramos, alleging deceit in connection with her mortgaged property.
Specifically, Aurea contended that Rodencio had induced her to sign a blank paper under the pretext that it would be used for the redemption of her mortgaged property, a paper which she later claimed was associated with the deed of sale of half the lot.
Nimpha Yasoaa Bondoc, a relative, later discovered the discrepancy when she found out from the Register of Deeds that the lot had been divided pursuant to an executed deed that impeccably evidenced the sale of half to Jovencio.

On February 21, 1994, Assistant Provincial Prosecutor Rodrigo B. Zayenis dismissed the criminal estafa complaint filed by Aurea for lack of evidence.
In response, Jovencio and Rodencio de Ramos filed a civil complaint for damages for malicious prosecution against petitioners, asserting that the unfounded estafa case had irreparably harmed their reputations.
The Regional Trial Court of Sta. Cruz, Laguna, Branch 91, ruled on October 5, 2000, in favor of Jovencio and Rodencio, awarding them moral damages, exemplary damages, attorney’s fees for defending the dismissed estafa case, and litigation expenses, while dismissing the claim for actual damages.

Petitioners, represented by Violeta Yasoaa (personally, as heir of Pelagia Yasoaa and on behalf of other siblings and their mother), filed a petition for certiorari under Rule 65 of the Rules of Court with the Court of Appeals, which dismissed the petition on June 14, 2002, on the ground that an inappropriate remedy was availed.
Their subsequent motion for reconsideration was denied, leading ultimately to the petition before the Supreme Court.
The principal factual contention was the alleged absence of knowledge regarding Jovencio’s clear ownership of his portion, despite ample evidence supporting the sale executed in 1971.

Whether the filing of the criminal complaint for estafa by petitioners constituted malicious prosecution.

Did the evidence demonstrate that petitioners acted with malice and absence of probable cause in initiating the estafa case?
Is the filing of the complaint merely an alternate remedy or a substitute for a lost appeal under Rule 65, which would render the initiation of the case procedurally improper?