- Petitioner
- Drilon
- Respondent
- Court of Appeals
- Citation
- G.R. No. 106922
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- De Leon, Jr., J.
- Decided
- April 20, 2001
Summary
This Supreme Court case arose from civil damages suit filed by Sen. Juan Ponce Enrile against DOJ prosecutors who charged him with rebellion complexed with murder after the 1989 coup attempt. The prosecutors' motion to dismiss was denied by RTC and CA, but the Supreme Court reversed, ruling the complaint failed to state a cause of action for malicious prosecution. The Court held the civil suit was premature since filed before the criminal case ended, contained no factual allegations of malice (only legal conclusions), and prosecutors acted in good faith with probable cause despite their legal theory being later rejected. The decision establishes that prosecutors cannot be held liable for damages when acting within authority with probable cause, even if their legal interpretation proves incorrect, protecting prosecutorial discretion while requiring proper procedural compliance for malicious prosecution claims.
Intellegal Wiki · Key Holding
Granted the petition and nullified the lower courts, holding that the complaint failed to state a cause of action for malicious prosecution because it was filed prematurely before the criminal case ended, alleged only conclusions of malice rather than facts, and the prosecutors acted with probable cause and in good faith even though their legal theory was later rejected.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.