People v. Ocampo

Summary

J.S. Rustia filed a criminal complaint for dereliction of duty against Buenaventura Ocampo in the Court of First Instance of Bulacan. After preliminary investigation, the court denied the warrant of arrest and dismissed the complaint. When Rustia's appeal was denied, he filed a mandamus petition to compel the judges to forward the record and allow the appeal. The Supreme Court denied the petition, holding that no appeal lies from a Court of First Instance resolution denying a warrant of arrest and dismissing a complaint during preliminary investigation. The Court distinguished that appeals under section 14 of General Orders No. 58 apply only to justice of the peace courts, not Courts of First Instance. This case establishes important precedent on the non-appealable nature of certain preliminary investigation decisions and the limited scope of mandamus in compelling judicial appeals.