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  • VILLANUEVA and SOJ Vs Caparas

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    Dia Ispail Esmael
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    An altercation between Renato Caparas and Villanueva led to Caparas' death. Villanueva was charged with homicide based on a criminal complaint filed by Caparas' wife. The prosecutor found probable cause but the Secretary of Justice set aside this finding and ordered the case withdrawn. The Court of Appeals reinstated the homicide charge, finding the Secretary exceeded his jurisdiction. The Supreme Court affirmed, holding that probable cause requires only facts sufficient for a prima facie case, not certainty of guilt, and this threshold was met.

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    1. VILLANUEVA and SOJ vs Caparas

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    An altercation between Renato Caparas and Villanueva led to Caparas' death. Villanueva was charged with homicide based on a criminal complaint filed by Caparas' wife. The prosecutor found probable cause but the Secretary of Justice set aside this finding and ordered the case withdrawn. The Court of Appeals reinstated the homicide charge, finding the Secretary exceeded his jurisdiction. The Supreme Court affirmed, holding that probable cause requires only facts sufficient for a prima facie case, not certainty of guilt, and this threshold was met.

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    © All Rights Reserved
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    106 views1 page

    VILLANUEVA and SOJ Vs Caparas

    Uploaded by

    Dia Ispail Esmael
    An altercation between Renato Caparas and Villanueva led to Caparas' death. Villanueva was charged with homicide based on a criminal complaint filed by Caparas' wife. The prosecutor found probable cause but the Secretary of Justice set aside this finding and ordered the case withdrawn. The Court of Appeals reinstated the homicide charge, finding the Secretary exceeded his jurisdiction. The Supreme Court affirmed, holding that probable cause requires only facts sufficient for a prima facie case, not certainty of guilt, and this threshold was met.

    Copyright:

    © All Rights Reserved
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    of 1

    VILLANUEVA and SECRETARY OF JUSTICE 

    v.  CAPARAS
    G.R. No. 190969 : January 30, 2013

    Facts:
    An altercation occurred between Renato Caparas and Villanueva in the
    morning of August 24, 2005, which altercation led to the death of Renato.
    On September 7, 2005, Edna, wife of Renato, filed a criminal complaint for
    murder against Villanueva. During preliminary investigation, the prosecutor
    found probable cause and filed a criminal information for homicide against
    Villanueva.  Before he could be arraigned, Villanueva filed a petition for
    review before the Department of Justice. The Secretary set aside the
    prosecutor’s resolution and directed the prosecutor to move for the
    withdrawal of the information on the ground that the evidence against
    Villanueva is insufficient to support a prima facie case. The CA reversed the
    Secretarys resolution and ordered the reinstatement of the prosecutors
    resolution and the corresponding information.

    Issue:

    Whether or not the CA correctly ruled that the Secretary exceeded the
    bounds of his jurisdiction when he reversed the prosecutors resolution
    finding probable cause and ordered the withdrawal of the resolution.

    Held:

    Yes. We find the CA decision and resolution in accord with law and
    jurisprudence in finding that the Secretary acted with grave abuse of
    discretion when he reversed the prosecutors resolution finding probable
    cause to charge Villanueva with homicide.
    Probable cause, for purposes of filing criminal information, pertains to facts
    and circumstances sufficient to incite a well-founded belief that a crime has
    been committed and the accused is probably guilty thereof. Only such facts
    sufficient to support a prima facie case against the respondent are required,
    not absolute certainty. Probable cause implies mere probability of guilt, i.e.,
    a finding based on more than bare suspicion but less than evidence that
    would justify a conviction. The strict validity and merits of a party's
    accusation or defense, as well as admissibility of testimonies and pieces of
    evidence, are better ventilated during the trial proper of the case.

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