Drilon v. CA

G.R. No. 115825 (July 5, 1996)

DOJ officials contest the Appeals Court's dismissal of charges against Dr. Aguila, prompting SC ruling on probable cause.

Facts:

On January 2, 1993, Godofredo AAonuevo was allegedly shot in the back by Manolo Ramos after being kidnapped and assaulted. AAonuevo was taken from Lipa City, beaten, and subsequently hospitalized for his injuries. During his hospitalization, he was confronted by Marcia Reyes, who questioned him about revealing her secrets regarding her debts. Following this, AAonuevo was taken to a poultry farm in Concepcion, Batangas, where he was shot again and later brought to Batangas Regional Hospital.

AAonuevo provided three statements over several days to narrate the events surrounding the crime. On February 13, 1993, AAonuevo's counsel requested the transfer of the preliminary investigation from Batangas to the Department of Justice in Manila, which was granted by then Justice Secretary Franklin Drilon. State Prosecutor Reynaldo Lugtu was designated to investigate the case.

On October 20, 1993, Prosecutor Lugtu found a prima facie case for kidnapping with frustrated murder against several individuals, including Dr. Rodolfo V. Aguila, Jr. An information was subsequently filed in the Regional Trial Court of Batangas City on November 11, 1993.

The accused filed a petition for certiorari and prohibition with the Court of Appeals, seeking to set aside the resolution of State Prosecutor Lugtu. The Court of Appeals issued a temporary restraining order against the prosecution of Dr. Aguila, finding that there was no prima facie case against him.

Legal Issues:

The primary legal issue was whether the Court of Appeals erred in finding that State Prosecutor Reynaldo Lugtu committed grave abuse of discretion in determining that there was probable cause to charge Dr. Rodolfo V. Aguila, Jr. with kidnapping with frustrated murder.

Arguments:

  • Petitioners' Argument: The petitioners, including Justice Secretary Franklin Drilon and State Prosecutor Reynaldo Lugtu, argued that the Court of Appeals erred in discharging Dr. Aguila from the information. They contended that the evidence presented during the preliminary investigation was sufficient to establish probable cause against Dr. Aguila, as he was implicated in the events leading to AAonuevo's shooting and subsequent treatment.

  • Respondents' Argument: Dr. Aguila and his co-accused argued that the evidence did not support a prima facie case against him. They claimed that his involvement was limited to providing medical treatment and that there was no direct evidence linking him to the kidnapping or the shooting.

Court's Decision and Legal Reasoning:

The Supreme Court granted the petition, ruling that the Court of Appeals erred in finding that there was no probable cause against Dr. Aguila. The Court emphasized that the purpose of a preliminary investigation is to determine whether there is sufficient ground to engender a well-founded belief that a crime has been committed and that the accused is probably guilty thereof.

The Court noted that probable cause does not require clear and convincing evidence of guilt but rather a reasonable belief that the accused may be guilty. The evidence presented, including AAonuevo's statements, indicated Dr. Aguila's presence during critical moments of the incident and suggested that he may have had a role in the conspiracy against AAonuevo.

The Court reiterated that the determination of probable cause is primarily the responsibility of the prosecutor, who is vested with quasi-judicial discretion. The findings of the prosecutor should be given credence unless there is a clear showing of arbitrariness.

Significant Legal Principles Established:

  1. Probable Cause: The Court clarified that probable cause is a lower standard than proof beyond a reasonable doubt and requires only a reasonable belief that a crime has been committed and that the accused is probably guilty.

  2. Role of Prosecutors: The decision reinforced the principle that prosecutors have the discretion to determine who should be charged with a crime, and their findings should be respected by the courts unless there is clear evidence of abuse of discretion.

  3. Preliminary Investigation: The Court emphasized that a preliminary investigation is not the venue for a full display of evidence but rather a means to ascertain whether there is sufficient basis to hold an accused for trial.