Case Title: Ceferino S. Paredes, Jr. and Mansueto J. Honrada v. The Honorable Sandiganbayan, Second Division, et al.
G.R. No. 108251, January 31, 1996
Facts:
- Teofilo Gelacio filed a complaint against petitioners Paredes and Honrada for falsification of public documents.
- The complaint alleged that Honrada, in conspiracy with Paredes and Atty. Sansaet, falsely certified that an arraignment was held in Criminal Case No. 1393 when no such arraignment actually took place.
- After preliminary investigation, the Office of the Ombudsman filed three informations for falsification against petitioners with the Sandiganbayan.
- Petitioners moved to quash the informations and for reinvestigation, but these were denied.
- Petitioners filed this petition for certiorari and prohibition to enjoin the trial of the criminal cases.
Issues:
- Whether petitioners’ right to due process was violated during the preliminary investigation
- Whether the filing of the cases constitutes forum shopping
- Whether the cases were filed merely for political harassment and without probable cause
Ruling:
The Supreme Court dismissed the petition.
- There was no violation of due process. The fact that a different investigator made the resolution recommending prosecution does not violate due process, as long as the decision was based on the evidence on record. The investigators were not shown to be biased against petitioners.
- There is no forum shopping. Although several cases arose from the same incident (Paredes’ free patent application), they involve different facts, circumstances and causes of action. The dismissal of the administrative case does not bar the criminal prosecution.
- The claim of political harassment does not justify prohibition of prosecution if there is evidence to support the charges. A preliminary investigation was conducted where petitioners were heard. The Court will not interfere with the Ombudsman’s discretion unless clearly abused. Petitioners failed to show the prosecutors acted in bad faith or lent themselves to a scheme of persecution.
The petition was dismissed as the Court found no grave abuse of discretion by the Ombudsman in finding probable cause to file the criminal cases.