Case Summary (G.R. No. 138291)
Facts
In June 1979, the bank initiated criminal proceedings against several individuals for violations under the General Banking Act and the Revised Penal Code. Following a preliminary investigation, the City Fiscal determined there was probable cause sufficient to file charges against the accused. Eventually, on June 29, 1991, a regional trial court acquitted all but one of the defendants (Bobby Cafe), and Hector Villanueva subsequently filed a civil case against the bank for malicious prosecution, claiming damages due to the impact on his reputation and professional life.
Court of Appeals Decision
The Court of Appeals reversed the Regional Trial Court's decision in favor of Hector Villanueva, finding that he had not met the burden of proving malicious prosecution. The appellate court determined that (1) the bank, as a complainant, did not prosecute the cases as that responsibility lay with the City Fiscal; (2) there existed probable cause for the prosecution; and (3) malice had not been sufficiently demonstrated.
Issues
The issues for consideration included the existence of probable cause in the criminal complaints filed against Hector, whether a complainant can be held liable under the doctrine of malicious prosecution when the prosecution is led by the public prosecutor, and the determination of malice in the prosecution.
Ruling of the Court
The Supreme Court upheld the Court of Appeals' decision, confirming that the petitioner failed to establish the elements necessary for malicious prosecution, including the absence of probable cause and malice.
First Issue: Probable Cause
The court defined probable cause as a reasonable belief that an individual is guilty of a crime based on the facts available at the time the prosecution was initiated. The court ruled that the bank’s complaints against Hector were based on a reasonable belief given the evidence presented during the preliminary investigation, thus fulfilling the requirement of probable cause.
Second Issue: Role of the Public Prosecutor
The court affirmed that the prosecution of criminal cases is under the jurisdiction of the public prosecutor, and thus the complainant's role as a mere instigator does not absolve it of liability in cases of malicious prosecution. However, in this instance, the bank acted in good faith based on findings from its investigations, negating any claims of malice.
Third Issue: Malice in Prosecution
The court reiterated that proving malicious prosecution requires establishing that charges were filed with a sinister motive. Th
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Case Overview
- This case revolves around a petition for review on certiorari regarding the decision of the Court of Appeals dated October 30, 1998, and its resolution on April 8, 1999.
- The primary issue is whether the petitioner's claim for damages due to alleged malicious prosecution by the respondent bank should be upheld or dismissed.
Background Facts
- In December 1978, Hermenegildo Villanueva, father of Hector C. Villanueva (the petitioner), obtained a loan from UCPB for agricultural purposes, securing it with a parcel of land.
- An audit by UCPB revealed fraud and irregularities in the loan application process, leading to further investigation.
- UCPB concluded that Hector Villanueva, along with others, conspired in these fraudulent activities.
- On June 8, 1979, UCPB filed several criminal complaints against Hector and others for violations of the General Banking Act and the Revised Penal Code.
- After a preliminary investigation, the City Fiscal found probable cause, leading to the filing of three consolidated criminal cases.
- The Regional Trial Court acquitted all accused except for one, Bobby Cafe, based on reasonable doubt.
The Petitioner’s Claim
- Following his acquittal, Hector Villanueva filed a complaint for damages against UCPB for malicious prosecution, alleging that the criminal charges were initiated with malice to injure his reputation and career.
- The complaint sought substantial damages, including actual, moral, exemplary, nominal damages, and attorney's fees.
Respondent's Defense
- UCPB denied the allegations, stating there was no malice in filing the criminal complaints and that the prosecution was conducted by the City Fiscal, who acted with probable cause.
- The bank contended