FENEQUITO VS. VERGARA, JR., 677 SCRA 113
Respondent filed a case against the petitioner for falsification of public document, the City Prosecutor filed the information to the MeTC. The Petitioner filed a Motion to Dismiss the Case Based on Absence of Probable Cause. The MeTC dismissed the case on the ground of lack of probable cause. Respondent appealed to the RTC. RTC granted the appeal and ordered the MeTC to proceed with the trial. Petitioner petitioned to the CA to review the RTC decision. CA affirmed the RTC ruling. Petitioner when to the SC to petition the review of the decision of the CA. Hence this case.
Whether the PNP Crime Laboratory Questioned Document Report submitted as evidence by respondent to the prosecutor’s office, showed that the findings therein are not conclusive and, thus, insufficient to support a finding of probable cause.
No, a finding of probable cause needs only to rest on evidence showing that, more likely than not, a crime has been committed by the suspects. It need not be based on clear and convincing evidence of guilt, not on evidence establishing guilt beyond reasonable doubt, and definitely not on evidence establishing absolute certainty of guilt. In determining probable cause, the average man weighs facts and circumstances without resorting to the calibrations of the rules of evidence of which he has no technical knowledge. He relies on common sense. What is determined is whether there is sufficient ground to engender a well-founded belief that a crime has been committed, and that the accused is probably guilty thereof and should be held for trial. It does not require an inquiry as to whether there is sufficient evidence to secure a conviction.