### Facts:
Respondent-spouses Edgardo and Nelia Aguinaldo lodged a complaint with the Office of the City Prosecutor (OCP) of Manila against petitioner Artemio T. Torres Jr., accusing him of falsifying public documents to unlawfully transfer property titles to his name. Torres countered that he legally acquired the properties via a legitimate sale. The OCP found probable cause to charge Torres with falsification, leading to the filing of an information in the Metropolitan Trial Court (MTC) of Manila. Torres sought reconsideration and, upon denial, appealed to the Secretary of Justice, who reversed the OCP’s decision and ordered the information’s withdrawal—a motion later granted by the MTC.
The Aguinaldos then filed a petition for certiorari with the Court of Appeals (CA), which reinstated the OCP’s initial resolution, finding probable cause against Torres, who subsequently petitioned the Supreme Court for review on certiorari, raising multiple legal questions.
### Issues:
1. Did the MTC-Manila’s order, allowing information withdrawal, render the Aguinaldo’s certiorari petition moot?
2. Did the Aguinaldos engage in forum shopping?
3. Did the CA err in finding that the Secretary of Justice gravely abused his discretion by reinstating the OCP-Manila’s order?
### Court’s Decision:
The Supreme Court ruled in favor of petitioner Torres, granting the petition. It held that the CA erred in disregarding the evidence presented by both the complainant and the accused during the preliminary investigation. The decision to focus solely on the complainant’s affidavit and NBI report without considering Torres’ counter-affidavit and evidences was a misstep. The Court found that the Justice Secretary did not abuse his discretion in examining all available evidence to determine the lack of probable cause. It concluded that the Aguinaldos failed to establish a direct link between Torres and the alleged forgery and reinstated the Secretary of Justice’s resolution finding no probable cause against Torres.
### Doctrine:
The Supreme Court elucidated on the principle that in determining probable cause in a preliminary investigation, it is imperative to consider all evidence presented by both parties, not just that of the complainant. Moreover, it reiterated the significant discretion allowed to the Department of Justice and its officers in controlling the prosecution of criminal offenses, such discretion subject only to judicial review in instances of grave abuse.
### Class Notes:
– **Probable Cause in Preliminary Investigation**: Probable cause should be determined based on the totality of evidence presented by both the complaint and defense.
– **Judicial Review of Prosecutorial Discretion**: The decisions of the Secretary of Justice in reviewing findings of a public prosecutor are persuasive but not binding on courts, which must independently assess the merits of the case.
– **Grave Abuse of Discretion**: Defined as whimsical and arbitrary judgment equivalent to lack or excess of jurisdiction; subject to review under Rule 65 of the Revised Rules of Civil Procedure.
### Historical Background:
In the context of checks and balances within the Philippine judicial system, the case provides insight into the delineation of powers and discretion among prosecutors, secretaries of justice, and judicial courts in criminal proceedings. It highlights the procedural dynamics involving preliminary investigations, judicial reviews, and the prosecutorial discretion in filing, withdrawing, or proceeding with criminal charges.
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