Case Summary (G.R. No. 171643)
Administrative Complaint and Dismissal
The dismissal of Verzano by Wyeth was based on allegations of violations of company policy regarding the sale of drug samples and channeling. Respondents Paro and Florencio filed affidavits supporting the complaint against Verzano. Following his dismissal, Verzano initiated a case for illegal dismissal against Wyeth and subsequently, he sought to file criminal charges against the respondents based on their affidavits.
Criminal Complaint and Prosecutorial Decisions
Verzano's criminal complaint for perjury was initially filed with the City Prosecutor, who dismissed the case due to insufficient evidence, despite the absence of counter-affidavits from the respondents. Verzano moved for reconsideration, which the City Prosecutor denied. Subsequently, he appealed to the Regional State Prosecutor, who reversed the City Prosecutor’s decision and instructed the filing of perjury charges against the respondents.
Respondents’ Legal Maneuvers
In response to the Regional State Prosecutor’s decision, respondents Paro and Florencio filed a petition for certiorari with the Court of Appeals (CA) challenging the prosecutor's directive. They also sought a temporary restraining order (TRO) against the prosecution. The CA granted the TRO, which froze the prosecution proceedings while the appeal was pending.
Court of Appeals Decision
The CA ruled in favor of the respondents, reversing the decisions of the Regional State Prosecutor. The court criticized the prosecutor for committing grave abuse of discretion by reversing the City Prosecutor's dismissal based solely on the lack of counter-affidavits from the respondents. The CA emphasized that a fair assessment of the evidence rather than the mere absence of counter-affidavits should guide the determination of probable cause.
Petitioner’s Arguments and Court's Analysis
Petitioner Verzano advanced several arguments, asserting that the CA's decision was moot following the filing of Informations in the Municipal Trial Court (MTCC) and that the Regional State Prosecutor had not abused his discretion. The Supreme Court, however, upheld the CA’s analysis, reaffirming that the prosecutor’s actions could be subject to review even after the filing of criminal in
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Case Overview
- Petitioner: Filemon A. Verzano, Jr.
- Respondents: Francis Victor D. Paro, Janet A. Florencio, Hon. Regional State Prosecutor, Hon. City Prosecutor of Bacolod
- Case Number: G.R. No. 171643
- Date of Decision: August 08, 2010
- Court: Supreme Court of the Philippines
Background of the Case
- On March 14, 2002, petitioner Filemon A. Verzano, Jr., a former District Manager at Wyeth Philippines, Inc., was dismissed due to an administrative complaint.
- The complaint, filed by respondents Paro and Florencio, accused Verzano of violating company policies regarding the sale of drug samples and unauthorized "channeling" of stocks.
- Following his dismissal, Verzano filed a complaint for illegal dismissal against Wyeth with the Regional Labor Arbitration Board.
- In retaliation, he filed a criminal complaint against respondents for perjury and false testimony related to their affidavits submitted in the labor case.
Procedural History
- The City Prosecutor initially dismissed Verzano's complaint due to a lack of probable cause.
- Verzano filed a motion for reconsideration, which was denied, prompting an appeal to the Regional State Prosecutor.
- The Regional State Prosecutor overturned the City Prosecutor's decision and directed the filing of Informations for perjury against the respondents.
- Respondents then filed a petition for certiorari with the Court of Appeals (CA) challenging the Regional State Prosecutor&#