MANILA — The Supreme Court (SC) has upheld the validity of a Department of Justice (DOJ) circular that raised the standard of evidence required in preliminary investigations and inquest proceedings.

In a six-page En Banc decision, the SC dismissed a petition filed by lawyer Hazel Meking, ruling that DOJ Department Circular 15 is a lawful exercise of the agency’s authority.

“DC 15 or the 2024 DOJ-NPS Rules regulates only the conduct of preliminary investigations and inquests by prosecutors, which are executive in nature. It does not dictate practice or procedure in court,” the SC said.

The court also emphasized that its constitutional rule-making authority over judicial proceedings remains supreme and retains the power to correct any prosecutorial rule or action that violates constitutional rights.

Under DC 15, issued in July 2024, the standard of proof in preliminary investigations was raised from probable cause to prima facie evidence with reasonable certainty of conviction.

The decision, authored by Associate Justice Japar Dimaampao, was promulgated in November 2025 and made public in March 2026.