Case Summary (G.R. No. 181658)
Factual Background
The petitioner was President of Centillion Holdings, Inc. (CHI), a company affiliated with the CKC Group. The respondent was a majority stockholder and the Treasurer of CHI and was involved with petitioner in intra‑corporate disputes. On June 14, 1999, the petitioner, purportedly in his capacity with CHI, filed a verified petition in the Regional Trial Court of Manila for issuance of a duplicate Owners Copy of Transfer Certificate of Title No. 232238, alleging the owners duplicate copy was in his custody and had been inadvertently lost. The RTC, by Order dated September 17, 1999, granted the petition and directed issuance of a new owners duplicate copy. The respondent and her brother produced the original owners duplicate copy in open court and, by Omnibus Motion, the RTC recalled and set aside its September 17, 1999 Order on November 12, 1999.
Complaint and Criminal Information
On May 9, 2000 the respondent filed a Complaint‑Affidavit before the City Prosecutor of Manila alleging that the petitioner knowingly made false statements under oath in the RTC petition, affidavit of loss, and in testimony regarding the alleged loss of TCT No. 232238. The respondent later executed a Supplemental Affidavit specifying the acts of perjury complained of. The City Prosecutor filed Informations charging the petitioner with perjury under Article 183, Revised Penal Code, docketed as Criminal Case Nos. 352270‑71 CR before the Metropolitan Trial Court of Manila, Branch 28.
Trial Court Proceedings on Private Prosecution
At trial, Atty. Augusto M. Macam appeared as counsel for the respondent and as private prosecutor, with the consent and under the supervision and control of the public prosecutor. After the prosecution presented its first witness, petitioner moved to exclude the private prosecutor on the ground that perjury is a public offense and no private offended party may intervene. The Metropolitan Trial Court issued an Order on May 7, 2003 directing the parties to file motions and comments, and thereafter denied petitioner's Omnibus Motion to exclude the private prosecutor in an Order dated August 15, 2003. The MeTC denied petitioner's motion for reconsideration on November 5, 2003.
Motion Grounds and Trial Court Rationale
Petitioner argued that perjury is a crime against public interest and that the offense does not give rise to civil liability for a private offended party who may intervene in the prosecution. The MeTC relied upon the principle that an offended party may intervene in a criminal action to pursue civil liability and that such intervention is subject to the direction and control of the public prosecutor, citing the Court's prior pronouncements including Lim Tek Goan v. Yatco.
Court of Appeals Review and Holding
Petitioner sought certiorari relief in the Court of Appeals to enjoin the MeTC from allowing the private prosecutor to participate. By Decision dated May 31, 2007, the CA affirmed the MeTC Orders. The CA held that the private prosecutor's presence under the public prosecutor's supervision was not proscribed, that the respondent was an aggrieved party by virtue of her role as treasurer and stockholder of CHI, and that the intervention right exists even when no civil liability is expressly alleged, citing the MeTC's reliance on Lim Tek Goan v. Yatco and related authorities. The CA denied reconsideration by Resolution dated January 31, 2008.
Issues Presented to the Supreme Court
The petition to the Supreme Court raised two primary issues: whether the Court of Appeals committed grave error in upholding the MeTC's finding that there was a private offended party in a perjury prosecution; and whether the CA erred in allowing the respondent, an alleged stockholder of CHI, to intervene as a private complainant on behalf of the corporation without the corporation's authority.
Petitioner's Contentions
The petitioner maintained that perjury offends the public interest alone and does not injure a private person such that a private prosecutor may intervene. He argued that the CA misapplied Lim Tek Goan, that intervention requires an allegation and proof of civil liability or damage to private interests, and that the respondent lacked authority from CHI to act on the corporation's behalf. He prayed for exclusion of the private prosecutor and the setting aside of proceedings in which the private prosecutor participated.
Respondent's Contentions
The respondent asserted that she was an aggrieved party as stockholder, officer, and treasurer of CHI and that the private prosecutor's intervention was permitted under the Rules and controlling jurisprudence. She relied on the Court's precedent to support a private offended party's right to intervene in criminal proceedings to enforce civil liability arising from the offense even where no separate civil action was instituted.
Supreme Court Ruling
The Supreme Court denied the petition for review and affirmed the CA Decision and Resolution. The Court held that the presence of a private prosecutor in the prosecution was permissible under the Rules and established doctrine. The Court concluded that the MeTC did not commit grave abuse of discretion in allowing the respondent to intervene through a private prosecutor subject to the control and direction of the public prosecutor.
Legal Basis and Reasoning
The Court reaffirmed the foundational principle that a person criminally liable is also civilly liable (Article 100, Revised Penal Code). It emphasized that where a criminal action is instituted the civil action for recovery of civil liability is deemed instituted with the criminal action pursuant to Section 1, Rule 111, Revised Rules of Criminal Procedure, unless waived or reserved. The Court invoked Section 16, Rule 110 permitting the offended party to intervene by counsel in the prosecution of the offense when civil liability is joined. The Court relied on the statutory definition of offended party in Section 12, Rule 110 and on prior decisions, including Garcia v. Court of Appeals, Ramiscal, Jr. v. Hon. Sandiganbayan, Lim Tek Goan v. Yatco, and Chua v. Court of Appeals, to hold that a private individual or corporate entity that has a legal and substantial interest arising from the offense may intervene to enforce civil liability. The Court found that the petitioner's alleged false statements about custody and loss of CHI's TCT were injurious to the respondent's personal credibility and responsibilities as treasurer and could have prejudiced the corporation's property interests. The Court explained that the right to intervene is for the purpose of enforcing ci
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Case Syllabus (G.R. No. 181658)
Parties and Procedural Posture
- Lee Pue Liong a.k.a. Paul Lee filed a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure seeking reversal of the Court of Appeals' Decision dated May 31, 2007 and Resolution dated January 31, 2008 in CA-G.R. SP No. 81510.
- Chua Pue Chin Lee opposed the petition below as respondent and had been allowed to participate in the prosecution as a private prosecutor under the supervision of the public prosecutor.
- The Court of Appeals affirmed the Metropolitan Trial Court's Orders dated August 15, 2003 and November 5, 2003 denying petitioner’s Omnibus Motion to exclude the private prosecutor and denying petitioner’s motion for reconsideration.
- The Supreme Court resolved whether the CA committed grave abuse of discretion in upholding the lower courts' allowance of private prosecution in two perjury cases.
Key Factual Allegations
- Lee Pue Liong alleged that he possessed the owner's duplicate of Transfer Certificate of Title No. 232238 covering a CHI property and filed a verified petition on June 14, 1999 for issuance of a new duplicate on the ground of loss.
- The Regional Trial Court initially granted the petition and ordered issuance of a new owner's duplicate on September 17, 1999, and later recalled that order on November 12, 1999 after Chua Pue Chin Lee produced the owner's duplicate in open court.
- Chua Pue Chin Lee filed a Complaint-Affidavit dated May 9, 2000 and a Supplemental Affidavit dated June 7, 2000 accusing petitioner of perjury for his sworn statements and testimony regarding the alleged loss of the title.
- The City Prosecutor filed Informations as Criminal Case Nos. 352270-71 CR for perjury under Article 183 of the Revised Penal Code before the Metropolitan Trial Court, Branch 28, Manila.
Lower Court Proceedings
- Lee Pue Liong moved in the MeTC to exclude respondent and her counsel as private prosecutors on the ground that perjury is a public offense and there is no private offended party.
- The MeTC denied the Omnibus Motion by Order dated August 15, 2003 and denied the subsequent motion for reconsideration by Order dated November 5, 2003.
- Chua Pue Chin Lee appeared through Atty. Augusto M. Macam as private prosecutor subject to the direction and control of the public prosecutor.
- The Court of Appeals affirmed the MeTC in a Decision dated May 31, 2007 and denied petitioner's motion for reconsideration by Resolution dated January 31, 2008.
Issues Presented
- Whether the Court of Appeals committed grave error in holding that there was a private offended party in the crime of perjury, which petitioner contended is a crime against public interest.
- Whether the Court of Appeals erred in upholding