Paredes v. Sandiganbayan

G.R. No. 108251 (January 31, 1996)

Facts:

This case involves a petition for certiorari, prohibition, and injunction filed by Ceferino S. Paredes, Jr. and Mansueto J. Honrada against the Sandiganbayan and various officials of the Office of the Ombudsman. The petitioners were charged with falsification of public documents stemming from a complaint filed by Teofilo Gelacio, the vice mayor of San Francisco, Agusan del Sur. Gelacio alleged that Honrada, as clerk of court, conspired with Paredes, Jr. and his counsel, Atty. Generoso Sansaet, to certify false documents indicating that an arraignment had occurred in Criminal Case No. 1393 when, in fact, no such arraignment took place.

The complaint was supported by a certification from Judge Ciriaco C. Ariño, stating that Criminal Case No. 1393 had never reached the arraignment stage before its dismissal. A preliminary investigation was conducted by Public Prosecutor Albert Axalan, who received counter-affidavits from the petitioners denying the charges and claiming political motivation behind the complaint. Atty. Sansaet initially supported the petitioners but later retracted his statement, claiming no arraignment had occurred.

Following the retraction, the investigation was reopened, and Graft Investigation Officer Gay Maggie Balajadia-Violan recommended filing charges against the petitioners. The Ombudsman approved the filing of three informations for falsification of public documents, which were subsequently docketed as Criminal Case Nos. 17791, 17792, and 17793 in the Sandiganbayan.

The petitioners moved to quash the informations, which was denied. They then sought a reinvestigation, arguing that the resolution recommending the charges was not prepared by the prosecutor who conducted the preliminary investigation and that the evidence was biased against them. The Sandiganbayan denied their motion for reinvestigation, leading to the present petition.

Legal Issues:

1. Whether the petitioners' constitutional right to due process was violated during the preliminary investigation.
2. Whether the charges against the petitioners constituted political harassment and lacked prima facie evidence.
3. Whether the Ombudsman and Special Prosecutor acted with grave abuse of discretion in denying the motion for reinvestigation.

Arguments:

Petitioners' Arguments:

• The petitioners contended that their due process rights were violated because the resolution recommending the charges was prepared by an investigator who did not conduct the preliminary investigation.
• They argued that the Ombudsman ignored evidence in their favor and that the charges were politically motivated, constituting harassment.
• They claimed that the certifications made by the clerk of court were conclusive and could not be altered by Atty. Sansaet's retraction.

Respondents' Arguments:

• The respondents maintained that the preliminary investigation was conducted properly, and the recommendation to file charges was based on a thorough review of the evidence.
• They argued that the petitioners failed to demonstrate any grave abuse of discretion or lack of jurisdiction on the part of the Ombudsman and Special Prosecutor.
• The respondents asserted that the existence of probable cause was established, and the charges were not politically motivated.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed the petition for certiorari and prohibition, ruling that the petitioners failed to establish that their due process rights were violated. The Court found that the preliminary investigation was conducted appropriately, and the recommendation to file charges was made after a thorough review of the evidence, including the retraction of Atty. Sansaet.

The Court emphasized that the mere fact that the charges were politically motivated does not preclude prosecution if there is sufficient evidence to support the charges. It also clarified that the determination of probable cause does not require absolute certainty or a full trial; it only necessitates a reasonable ground to believe that the accused committed the offense.

The Court further noted that the decision to charge the petitioners was not solely based on the actions of one individual but involved multiple officials in the Ombudsman’s office, indicating that there was no bias or abuse of discretion in the prosecution.

Significant Legal Principles Established:

• The Court reaffirmed the principle that a preliminary investigation is not a trial, and the standard for establishing probable cause is lower than that required for conviction.
• It clarified that political motivations behind a complaint do not automatically invalidate the prosecution if there is sufficient evidence to support the charges.
• The Court reiterated that the Ombudsman and prosecutors are expected to act impartially and that their discretion in prosecuting cases should not be interfered with unless there is clear evidence of abuse.