The Supreme Court held that a private prosecutor can participate in a perjury case even if no civil damages are claimed, as long as the private complainant’s rights were affected and the intervention is under the public prosecutor’s supervision. This decision affirms the right of an offended party to protect their interests in criminal proceedings, ensuring a fair trial while recognizing the state’s primary role in prosecuting public offenses. It emphasizes that the offended party may intervene to ensure justice, particularly when their reputation and rights are at stake.

Perjury and Private Rights: When Does Public Offense Affect Personal Interests?

This case revolves around a dispute between Lee Pue Liong (petitioner) and Chua Pue Chin Lee (respondent), siblings involved in intra-corporate battles concerning Centillion Holdings, Inc. (CHI). The respondent accused the petitioner of perjury for falsely claiming the loss of a land title owned by CHI. The respondent, as a stockholder and treasurer of CHI, argued that the petitioner’s false statements jeopardized her position and the company’s interests. The central legal issue was whether a private prosecutor, representing the respondent, could intervene in the criminal case for perjury, a crime against public interest, even without an explicit claim for civil damages.

The petitioner argued that perjury is a crime against public interest, and therefore, no private party could claim to be directly injured. He contended that the respondent’s intervention through a private prosecutor was unwarranted because there was no allegation of damage to private interests that required compensation. The petitioner further argued that the CA’s reliance on Lim Tek Goan v. Yatco was misplaced, as that case involved a direct threat to an individual, unlike the alleged perjury, which he claimed only affected public order. The petitioner pointed out that the respondent did not allege or prove any damages suffered by her or CHI that could be satisfied through restitution, reparation, or indemnification.

The respondent countered that her role as a stockholder, officer, and treasurer of CHI made her an aggrieved party, directly affected by the petitioner’s alleged perjury. She argued that the petitioner’s false statements undermined her credibility and threatened the corporation’s assets. The respondent maintained that her intervention was justified to protect her interests and ensure justice, even if no civil liability was explicitly pursued. She cited Lim Tek Goan to support her claim that an offended party has the right to intervene, regardless of whether civil liability exists, as long as they have not waived or reserved their right to a separate civil action.

The Supreme Court denied the petition, holding that the CA did not err in upholding the MeTC’s decision to allow the private prosecutor’s intervention. The Court emphasized the principle that every person criminally liable is also civilly liable, highlighting that a crime injures both society and the individual whose rights or property are directly affected. The Court cited Section 1, Rule 111 of the Revised Rules of Criminal Procedure, which states that a civil action for the recovery of civil liability arising from the offense is deemed instituted with the criminal action unless waived or reserved.

Furthermore, the Court referenced Section 16 of Rule 110, allowing the offended party to intervene by counsel in the prosecution of the offense when a civil action is instituted in the criminal action. Drawing from Garcia v. Court of Appeals, the Court affirmed that the offended party is the individual to whom the offender is civilly liable. In Ramiscal, Jr. v. Hon. Sandiganbayan, the Court further clarified that the offended party could be a private individual whose rights or property were directly injured by the accused’s actions.

In the case at hand, the Court found that the petitioner’s false statements regarding the lost land title were indeed injurious to the respondent’s credibility and her performance as a Board Member and Treasurer of CHI. The Court recognized the potential injury to the corporation as a whole, noting that the issuance of a new title was only prevented by the respondent’s timely intervention. Even without proven civil liability, the Court reiterated its stance in Lim Tek Goan v. Yatco, affirming the offended party’s right to intervene to enforce civil liability arising from the criminal act, subject to the public prosecutor’s direction.

The Court also cited Chua v. Court of Appeals, where private prosecutors were allowed to participate in a falsification case based on the private respondent’s complaint. The Supreme Court emphasized that the right to intervene exists when the offended party has not waived or reserved the right to institute a separate civil action. In conclusion, the Supreme Court found no grave abuse of discretion by the MeTC in allowing the private prosecutor to participate, thereby affirming the CA’s decision.

FAQs

What was the key issue in this case?	The key issue was whether a private prosecutor could intervene in a perjury case, a crime against public interest, on behalf of a private complainant who did not explicitly claim civil damages. The Court addressed whether the private complainant had sufficient personal interest to warrant such intervention.
Who was the petitioner in this case?	The petitioner was Lee Pue Liong, also known as Paul Lee, who was accused of perjury by his sibling, Chua Pue Chin Lee. He sought to exclude the private prosecutor from representing the respondent in the criminal case.
Who was the respondent in this case?	The respondent was Chua Pue Chin Lee, a stockholder and treasurer of Centillion Holdings, Inc., who filed the perjury complaint against her brother, Lee Pue Liong. She sought to maintain the presence of a private prosecutor to represent her interests in the case.
What is the significance of the Lim Tek Goan v. Yatco case?	Lim Tek Goan v. Yatco establishes that an offended party has the right to intervene in a criminal case, whether it involves public or private crimes. This right exists to enforce civil liability arising from the criminal act, subject to the direction and control of the public prosecutor.
What is the basis for civil liability arising from a crime?	The basis for civil liability arising from a crime is the principle that every person criminally liable is also civilly liable. This principle recognizes that a crime injures both society and the individual whose rights or property are directly affected.
What does Rule 111 of the Revised Rules of Criminal Procedure state?	Rule 111 states that when a criminal action is instituted, the civil action for the recovery of civil liability arising from the offense is deemed instituted with the criminal action unless waived or reserved. This rule allows the offended party to seek damages within the criminal case.
What was the court’s final decision in this case?	The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, which upheld the MeTC’s ruling allowing the private prosecutor to participate in the perjury case. The Court found no grave abuse of discretion in the lower court’s decision.
How does this case affect future perjury cases?	This case clarifies that a private prosecutor can intervene in perjury cases even without explicit claims for civil damages, provided the private complainant’s personal or proprietary rights are affected. It reinforces the right of the offended party to protect their interests in criminal proceedings, subject to the supervision of the public prosecutor.

This case underscores the balance between public interest and individual rights in criminal proceedings. It reinforces the principle that private parties whose rights are affected by a crime have the right to participate in the pursuit of justice, even in the absence of explicit civil damages. The ruling ensures a more comprehensive approach to justice, acknowledging the interconnectedness of criminal and civil liabilities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LEE PUE LIONG A.K.A. PAUL LEE VS. CHUA PUE CHIN LEE, G.R. No. 181658, August 07, 2013