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ALFREDO C. MENDOZA v. PEOPLE

FACTS:

This case revolves around a petition for review on certiorari challenging the Court of Appeals' decision that reversed the dismissal of a complaint against Alfredo Mendoza. The complaint had been filed by Juno Cars, Inc., asserting that Alfredo, who worked as Trade-In/Used Car Supervisor, had sold and released five cars without authorization and failed to remit the payments amounting to ?886,000.00. Furthermore, he was accountable for only 18 out of the 20 cars under his custody, and he neglected to turn over the files of two vehicles. The Provincial Prosecutor discovered probable cause and recommended the filing of an information against Alfredo. Although Alfredo's motion for reconsideration was rejected, he then filed a petition for review. During the pendency of his motion for reconsideration, two informations were lodged against him. Subsequently, Alfredo sought a motion for determination of probable cause and a motion to defer arraignment. In response, the trial court dismissed the complaint, stating that the evidence did not substantiate the presence of probable cause. The Court of Appeals later overturned the trial court's decision, thereby reinstating the case. Consequently, Alfredo filed a petition for review before the Supreme Court, contending that there was no probable cause.

ISSUES:

  1. Whether the judge must make an independent determination of probable cause before issuing a warrant of arrest

  2. Whether the judge may review the prosecutor's determination of probable cause

  3. Whether the evidence on record clearly fails to establish probable cause against the respondents.

  4. Whether Judge Capco-Umali correctly dismissed the case against Alfredo C. Mendoza.

RULING:

  1. Yes, the judge must make an independent determination of probable cause before issuing a warrant of arrest. The judge must satisfy himself that based on the evidence submitted, there is necessity for placing the accused under custody in order not to frustrate the ends of justice.

  2. No, the judge does not have the capacity to review the prosecutor's determination of probable cause. The judge's determination of probable cause is independent of the prosecutor's finding.

  3. The evidence on record clearly fails to establish probable cause against the respondents.

  4. Judge Capco-Umali correctly dismissed the case against Alfredo C. Mendoza.

PRINCIPLES:

  • The executive determination of probable cause concerns itself with whether there is enough evidence to support an Information being filed. The judicial determination of probable cause determines whether a warrant of arrest should be issued.

  • The judge does not act as an appellate court of the prosecutor and has no capacity to review the prosecutor's determination of probable cause.

  • Evidentiary matters should be presented and heard during the trial, and courts should refrain from dismissing an information for want of evidence when there is no showing of manifest error, grave abuse of discretion, or prejudice on the part of the public prosecutor.

  • If there is palpable error or grave abuse of discretion in the public prosecutor's finding of probable cause, the accused can appeal such finding to the justice secretary and move for the deferment or suspension of the proceedings until such appeal is resolved.

  • Jurisdiction over an accused is acquired when the warrant of arrest is served. Absent this, the court cannot hold the accused for arraignment and trial.

  • The right of the people to be secure in their persons against unreasonable searches and seizures shall be inviolable, and no warrant of arrest shall issue except upon probable cause personally determined by the judge.

  • The Constitution prohibits the issuance of search warrants or warrants of arrest where the judge has not personally determined the existence of probable cause.

  • Section 6, paragraph (a) of Rule 112 of the Rules on Criminal Procedure mandates the judge to "immediately dismiss the case if the evidence on record fails to establish probable cause."

  • Once a complaint or information is filed in court, any disposition of the case rests in the sound discretion of the court.

  • A judge must always proceed with caution in dismissing cases due to lack of probable cause.

  • If a judge finds probable cause, he or she must not hesitate to proceed with arraignment and trial.