- Petitioner
- Crespo
- Respondent
- Mogul
- Citation
- G.R. No. L-53373
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Gancayco, J.
- Decided
- June 30, 1987
Summary
This landmark case establishes the principle that once a criminal information is filed in court, the trial court has exclusive jurisdiction to determine whether to grant or deny motions to dismiss, even when filed upon instructions of the Secretary of Justice after review. Mario Crespo was charged with estafa, but after review, the DOJ directed dismissal. When the trial court refused to dismiss, citing judicial independence, Crespo challenged this through multiple appellate proceedings. The Supreme Court ruled that while prosecutors retain control over criminal cases, they cannot impose their opinions on trial courts. The court has discretionary authority over case disposition once jurisdiction is acquired. However, prosecutors must continue appearing for the People even when disagreeing with the court's decision, ensuring proper representation while maintaining the separation of prosecutorial and judicial functions.
Intellegal Wiki · Key Holding
Dismissed the petition: once a criminal information is filed, any disposition including dismissal rests in the court's sound discretion; the fiscal cannot impose his opinion and must continue to appear for the prosecution.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.