Interest of parties in criminal prosecutions

In the case of Anlud Metal Recycling v. Ang[1], the Supreme Court ruled that the real party in interest in a criminal case is the People of the Philippines. Hence, if the criminal case is dismissed by the trial court, the criminal aspect of the case must be instituted by the Solicitor General on behalf of the State.[2]

As a qualification, however, the High Court recognizes that the private offended party has an interest in the civil aspect of the case.[3] Logically, the capability of the private complainant to question the dismissal of the criminal proceedings is limited only to questions relating to the civil aspect of the case.[4] It should ideally be along this thin framework that we may entertain questions regarding the dismissals of criminal cases instituted by private offended parties. Enlarging this scope may result in wanton disregard of the OSG's personality, as well as the clogging of our dockets, which the Supreme Court is keen to avoid.

Therefore, the litmus test in ascertaining the personality of the petitioner lies in whether or not the substance of the certiorari action it instituted in the CA referred to the civil aspect of the case.[5]

[1] ANLUD METAL RECYCLING V. ANG (G.R. NO. 182157. AUGUST 17, 2015)

[2] People v. Malayan Insurance Company, Inc.. GR. No. 193681, 6 August 2014.

[3] Cariño v. De Castro, 576 Phil. 634 (2008).

[4] Rodriguez v. Gadiane, 527 Phil. 691 (2006)

[5] People v. Santiago, 255 Phil. 851 ( 1989).