G.R. No. 171188 - People vs. Castillo

The petition seeks a review of the Sandiganbayan's Resolution dated October 10, 2005, which dismissed the criminal complaint against respondents Jessie B. Castillo and Felicito R. Mejia.
The case involves a property owned by complainant Cesar Sarino, which was leased to stallholders and subsequently fenced off by municipal officials.
Respondent Mejia issued Notices of Violation to stallholders for lack of building permits, leading to the closure of their stalls in February 2000.
A complaint was filed against the respondents for violations of the Anti-Graft and Corrupt Practices Act, but the Ombudsman dismissed it, citing good faith.

Sarino filed a new complaint against the respondents in September 2001, alleging unlawful taking of property and refusal to remove the fence.
The Ombudsman dismissed the administrative complaint as moot due to Castillo's re-election and the timing of the complaint.
On May 7, 2003, the Ombudsman filed an Information against the respondents for violation of Section 3(e) of the Anti-Graft Law, leading to the issuance of arrest warrants.

The Sandiganbayan found probable cause and issued arrest warrants against the respondents.
Respondents voluntarily surrendered and sought reinvestigation, which the Sandiganbayan granted.
After reinvestigation, the Special Prosecutor filed an Amended Information, including additional injured parties and specifying damages.

The Sandiganbayan later dismissed the case, ruling it was a rehash of the previously dismissed complaint and found no evident bad faith or negligence by the respondents.
The Office of the Special Prosecutor's motion for reconsideration was denied, prompting the current petition.

The petition raises several issues regarding the Sandiganbayan's authority to conduct a second determination of probable cause and its consideration of evidentiary matters.
It questions whether the Sandiganbayan erred in ruling that the respondents acted in good faith and ignored claims of undue injury to the complainant.

The court distinguishes between executive and judicial determinations of probable cause, emphasizing the Ombudsman's broad discretion in preliminary investigations.
It asserts that the Sandiganbayan overstepped its authority by overturning the Ombudsman's determination of probable cause, which is not within the court's purview unless there is manifest error or grave abuse of discretion.

The court confirms that both the original and amended Informations were valid on their face and supported by substantial evidence.
The Ombudsman had adequately established probable cause, and the Sandiganbayan's dismissal was erroneous.

The court criticizes the Sandiganbayan for prematurely concluding there was no bad faith or undue injury before the parties presented their evidence.
It reiterates that the presence of crime...continue reading