Title
Navarro vs. Cornejo
Case
G.R. No. 263329
Decision Date
Feb 8, 2023
A 2014 case involving rape allegations by Deniece Cornejo against Ferdinand Navarro, dismissed due to inconsistencies and lack of probable cause, with Navarro claiming extortion.
deniece cornejo
secretary of justice
city prosecutor of taguig

Case Summary (G.R. No. 263329)

Factual Background

The complaints arise from encounters between Cornejo and Navarro allegedly occurring on January 17, 2014 and January 22, 2014, after they had known each other since a 2011 product launch and exchanged messages thereafter. In the First and Second Complaints Cornejo alleged that Navarro visited her condominium and committed acts amounting to rape on the said dates; her narratives varied across the three complaints. Navarro denied the allegations, asserted that the January 17 encounter was consensual oral sex, and counter‑accused Cornejo and several companions of serious illegal detention, grave coercion, and perjury. The parties exchanged detailed recountings including texts, alleged physical resistance, a purported video and items recovered by Cornejo's friends, and assertions that a beverage had been spiked.

Procedural History

Cornejo filed three separate complaints before the Office of the City Prosecutor of Taguig. A DOJ panel dismissed the First Complaint on April 4, 2014 for lack of probable cause while finding probable cause to charge Cornejo and others with serious illegal detention and grave coercion. The Second Complaint was dismissed on July 4, 2014 by the OCP Taguig for lack of probable cause. The Third Complaint was dismissed by a Review Resolution of OIC‑Prosecutor General Severino H. Gana, Jr. on September 6, 2017 for want of probable cause. Cornejo sought administrative review at the DOJ, which denied relief on April 30, 2018 and denied reconsideration on July 14, 2020. The Court of Appeals granted Cornejo’s petition for certiorari under Rule 65 on July 21, 2022, set aside the DOJ Resolutions, and directed the City Prosecutor to file Informations for rape and acts of lasciviousness; the CA denied reconsideration September 20, 2022. The OCP Taguig thereafter filed Informations and the trial courts received the cases in September 2022. Navarro filed a petition for review under Rule 45 in the Supreme Court, challenging the CA decision and seeking dismissal of the Informations.

The Parties’ Contentions

Cornejo argued that the DOJ committed grave abuse by evaluating credibility and admissibility at the preliminary investigation stage and thus deviated from jurisprudential parameters of probable cause, invoking the maxim that a woman's assertion of rape suffices to show commission of the crime. Navarro contended that certiorari was the wrong remedy, that the CA substituted its judgment for the prosecutor, and that Cornejo’s allegations were inherently implausible in light of prior dismissals and the countercharges against her. The DOJ and the prosecutor defended the dismissals as based on manifest inconsistencies among the three complaint‑affidavits and on an objective appraisal of the evidence.

Ruling of the Court of Appeals

The Court of Appeals concluded that it had jurisdiction under Rule 65 to review the DOJ Resolutions for grave abuse of discretion. The CA held that the Third Complaint sufficiently alleged the elements of rape by sexual intercourse under paragraph one of Article 266‑A and that the DOJ erred by relying on alleged inconsistencies and by intruding upon credibility determinations reserved for trial. The CA therefore reversed and set aside the DOJ Resolutions and directed the Office of the City Prosecutor of Taguig to file Informations for (a) rape by sexual intercourse under Article 266‑A(1), relative to the January 17, 2014 incident, and (b) acts of lasciviousness under Article 336, relative to January 22, 2014.

Issues Before the Supreme Court

The dispositive issue was whether the Court of Appeals erred in finding that the Department of Justice committed grave abuse of discretion amounting to lack or excess of jurisdiction when it sustained the prosecutor’s finding of lack of probable cause as to the Third Complaint.

Supreme Court’s Holding

The Supreme Court granted the petition. It held that the CA erred in reversing the DOJ Resolutions. The Court found no grave abuse of discretion by the DOJ in affirming the prosecutor’s dismissal for lack of probable cause. The Supreme Court therefore reversed and set aside the CA Decision dated July 21, 2022 and its September 20, 2022 Resolution, and dismissed the Informations against Navarro for lack of probable cause.

Legal Basis and Reasoning

The Court reiterated the principle that the determination of probable cause in a preliminary investigation is an executive function and a prosecutorial prerogative. The judiciary ordinarily must defer to the prosecutor’s factual assessment unless the exercise of discretion is tainted by grave abuse of discretion that is arbitrary, despotic, or a clear evasion of duty. The Court explained that a preliminary investigation is a summary judicial inquiry designed both to protect the innocent from baseless prosecution and to conserve the State’s resources by preventing futile trials. A prosecutor is therefore required to make a realistic judicial appraisal of the merits and may evaluate factual inconsistencies and the plausibility of allegations. The Court cited and applied doctrinal authorities including Duterte v. Sandiganbayan, Sales v. Sandiganbayan, and Cabahug v. People to define probable cause as “facts and circumstances as would excite the belief in a reasonable mind … that the person charged was guilty.”

Applying these standards, the Court found that the prosecutorial findings were reached by careful and objective evaluation. The prosecutor had catalogued material and glaring inconsistencies among the three complaint‑affidavits as to whether rape occurred on January 17, 2014, whether Cornejo consumed the wine offered, and whether the January 22, 2014 incident was rape, attempted rape, or omitte

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