Roberts v. Court of Appeals

G.R. No. 113930 (March 5, 1996)

Facts:

The case involves a group of petitioners, who are high-ranking officials of Pepsi Cola Products Philippines, Inc. (PEPSI), accused of estafa and other violations related to the "Number Fever Promotion" that the company conducted. The promotion involved a contest where consumers could win cash prizes by holding winning crowns from Pepsi products. Thousands of consumers filed complaints against the petitioners, alleging that they were defrauded when the winning number "349" was announced, but the company refused to honor the claims based on the mechanics of the promotion.

The complaints were initially investigated by the Quezon City Prosecutor's Office, which led to a Joint Resolution recommending the filing of an information for estafa against the petitioners while dismissing other complaints for lack of evidence. The City Prosecutor approved this recommendation, and the information was filed in the Regional Trial Court (RTC) of Quezon City.

The petitioners filed motions to suspend the proceedings and to hold in abeyance the issuance of warrants of arrest, arguing that the Department of Justice (DOJ) was reviewing their petition for reconsideration of the Joint Resolution. However, the RTC judge denied these motions and ordered the issuance of warrants of arrest against the petitioners, leading to their filing of a special civil action for certiorari and prohibition in the Court of Appeals.

The Court of Appeals dismissed the petition, stating that the case had become moot due to the DOJ's dismissal of the petitioners' appeal. The petitioners then sought relief from the Supreme Court, challenging the decisions of the lower courts and the DOJ.

Legal Issues:

1. Did the RTC judge commit grave abuse of discretion in ordering the arrest of the petitioners without examining the record of the preliminary investigation?
2. Did the DOJ act with grave abuse of discretion in dismissing the petitioners' petition for review?
3. Did the Court of Appeals err in upholding the RTC's order for the issuance of warrants of arrest without assessing the existence of probable cause?
4. Is there sufficient evidence to establish probable cause against the petitioners for the crime of estafa?

Arguments:

Petitioners' Arguments:

• The RTC judge failed to examine the records of the preliminary investigation before ordering the arrest, which constitutes grave abuse of discretion.
• The DOJ's "349" Committee acted with grave abuse of discretion by refusing to review the City Prosecutor's Joint Resolution and dismissing their appeal.
• The Court of Appeals erred in upholding the RTC's order without assessing whether probable cause existed based on the records.
• The facts on record do not establish prima facie probable cause, and the criminal case should have been dismissed.

Respondents' Arguments:

• The RTC judge acted within his discretion and relied on the Joint Resolution of the investigating prosecutor, which was sufficient to establish probable cause.
• The DOJ's dismissal of the petition for review was justified, as the trial court has the exclusive authority to determine the course of the case once an information is filed.
• The Court of Appeals correctly upheld the RTC's decision, as the judge enjoys a presumption of regularity in the performance of official duties.

Court's Decision and Legal Reasoning:

The Supreme Court granted the petition, setting aside the decisions of the Court of Appeals and the DOJ. The Court held that:

1. The RTC judge committed grave abuse of discretion by failing to personally evaluate the evidence and records before issuing the warrants of arrest. The judge must determine probable cause based on a thorough examination of the evidence, not merely rely on the prosecutor's certification.

2. The DOJ acted with grave abuse of discretion in dismissing the petitioners' petition for review without a proper evaluation of the merits, especially given the significant public interest involved in the case.

3. The Court of Appeals erred in dismissing the petition on the grounds of mootness, as the issue of probable cause remained unresolved and was critical to the petitioners' rights.

4. The Court emphasized that the determination of probable cause is a judicial function that cannot be delegated to the prosecutor. The judge must independently assess the evidence presented during the preliminary investigation.

Significant Legal Principles Established:

• The determination of probable cause for the issuance of warrants of arrest must be made by the judge based on a thorough examination of the evidence, not solely on the prosecutor's certification.
• The DOJ retains the authority to review resolutions of its subordinates, even after an information has been filed in court, particularly when there are allegations of grave abuse of discretion.
• The presumption of regularity in the performance of official duties does not absolve judges from the responsibility of making independent assessments of evidence.