
Photograph courtesy of the Supreme Court of the Philippines
The Supreme Court has ruled that private complainants cannot appeal the dismissal or acquittal of a criminal case without the approval of the State, reaffirming that criminal prosecutions are pursued in the name of the People of the Philippines.
In a 28-page decision dated 6 April 2026 and penned by Associate Justice Antonio Kho Jr., the Court affirmed the Court of Appeals’ ruling dismissing a perjury complaint against Standard Chartered Bank associate director Kathrina Sebastian.
The case stemmed from a complaint filed by Philippine Investment Two (PI Two), an affiliate of Lehman Brothers Holdings Inc., which accused Sebastian of lying under oath in a corporate rehabilitation case involving an P819-million loan.
Sebastian maintained she acted in good faith, arguing that a stay order issued by a US bankruptcy court rendered the loan guarantees and pledge agreements legally unenforceable at the time.
Although prosecutors initially found probable cause, the justice secretary later ordered the withdrawal of the criminal information. After conducting its own review, the Metropolitan Trial Court dismissed the case.
PI Two appealed the dismissal to the Regional Trial Court without securing the conformity of the public prosecutor or the Office of the Solicitor General.
The Court of Appeals nullified the appeal, ruling that PI Two had no legal standing to challenge the dismissal of the criminal aspect of the case.
Affirming the appellate court, the Supreme Court stressed that criminal cases are prosecuted to vindicate the State’s interest in enforcing the law, with the private complainant serving only as a witness for the prosecution.