The Supreme Court ruled in this case that a verdict of acquittal is final and cannot be reversed, even if the lower court is alleged to have made errors in its judgment. This decision underscores the constitutional protection against double jeopardy, which safeguards individuals from being tried repeatedly for the same offense. The Court emphasized that allowing a review of an acquittal would essentially convert a petition for certiorari into an appeal, a practice strictly prohibited by the Constitution and legal precedents. This ruling reinforces the importance of respecting final judgments to protect the rights of the accused.

Can an Acquittal Be Questioned? The Limits of Certiorari in Criminal Cases

The case revolves around Joseph Terrado, who was accused of carnapping a tricycle. The prosecution alleged that Terrado, armed with a fan knife, forcibly took the tricycle from the driver, Leoncio Dalmacio. The defense countered that Terrado merely borrowed the tricycle, and when he was about to return it, he accidentally damaged it. The Regional Trial Court (RTC) acquitted Terrado, finding that the prosecution failed to prove intent to take the tricycle and intent to gain from it, essential elements of the crime of carnapping. Aggrieved by this decision, the prosecution, represented by private complainants Spouses Marilyn and Francisco Garcia, filed a petition for certiorari, arguing that the trial court had committed grave abuse of discretion in acquitting Terrado. The central legal question is whether a verdict of acquittal can be challenged through a petition for certiorari when the challenge is based on an alleged misapprehension of facts by the trial court.

The Supreme Court clarified the nature and scope of the special civil action for certiorari, stating that it is intended for the correction of errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. It emphasized that grave abuse of discretion implies a capricious and whimsical exercise of judgment, equivalent to a lack of jurisdiction. The Court noted that the imputation of grave abuse of discretion in this case was premised on the averment that the trial court reached its conclusions based on speculation, surmises, and conjectures, specifically regarding the element of intent to gain.

The Court underscored that a review of facts and evidence is not within the province of the extraordinary remedy of certiorari, which is extra ordinem – beyond the ambit of appeal. It stated that the mistakes ascribed to the trial court were not errors of jurisdiction correctible by certiorari but errors of judgment correctible by a petition for review on certiorari under Rule 45 of the Rules of Court. Jurisdiction, in this context, refers to the court’s authority to hear and decide a case, which the trial court undoubtedly possessed.

The Court distinguished between errors of jurisdiction and errors of judgment, explaining that the former involves a court acting without or in excess of its authority, while the latter involves mistakes in the court’s appreciation of the evidence or application of the law. In this case, the Court found that the alleged errors of the trial court pertained to its appreciation of the evidence, which falls under errors of judgment rather than errors of jurisdiction. As such, certiorari was not the proper remedy. Moreover, if the Supreme Court were to rule in favor of the petitioner, Joseph Terrado may have been exposed to double jeopardy which is unconstitutional.

“Verdicts of acquittal are to be regarded as absolutely final and irreviewable. The fundamental philosophy behind the principle is to afford the defendant, who has been acquitted, final repose and to safeguard him from government oppression through the abuse of criminal processes.”

The Court emphasized that allowing certiorari to correct an erroneous acquittal would run afoul of the constitutional right against double jeopardy. Double jeopardy, a fundamental principle of criminal law, protects an accused person from being tried twice for the same offense if they have already been acquitted or convicted. This principle is enshrined in the Constitution to ensure fairness and prevent government oppression. The Court explained that such recourse would be tantamount to converting the petition for certiorari into an appeal, which is prohibited by the Constitution, the Rules of Court, and prevailing jurisprudence on double jeopardy.

In light of these principles, the Supreme Court held that the instant petition for certiorari must be dismissed. It reiterated that an acquittal is final and cannot be reviewed without violating the constitutional guarantee against double jeopardy. The Court concluded that accused Joseph Terrado must be afforded the protection against repeated attempts for conviction, in faithful adherence to the constitutional rule against double jeopardy. This reaffirms the importance of respecting final judgments to protect the rights of the accused.

FAQs

What was the key issue in this case?	The key issue was whether a verdict of acquittal can be challenged through a petition for certiorari based on an alleged misapprehension of facts by the trial court, potentially violating the principle of double jeopardy.
What is double jeopardy?	Double jeopardy is a constitutional protection that prevents an accused person from being tried twice for the same offense after they have already been acquitted or convicted. This safeguard ensures fairness and prevents government oppression.
What is a petition for certiorari?	A petition for certiorari is a special civil action used to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction by a lower court. It is not a substitute for an appeal.
What is grave abuse of discretion?	Grave abuse of discretion refers to a capricious and whimsical exercise of judgment that is equivalent to a lack of jurisdiction, where the power is exercised arbitrarily or despotically. It must be so patent and gross as to amount to an evasion of positive duty.
What is the difference between errors of jurisdiction and errors of judgment?	Errors of jurisdiction involve a court acting without or in excess of its authority, while errors of judgment involve mistakes in the court’s appreciation of evidence or application of the law. Certiorari can only correct errors of jurisdiction.
Why was the petition for certiorari dismissed in this case?	The petition was dismissed because the alleged errors of the trial court pertained to its appreciation of the evidence (errors of judgment), not errors of jurisdiction. Also, reversing the acquittal would violate double jeopardy.
Can a private prosecutor file a petition for certiorari in a criminal case?	While a private prosecutor can participate in certain stages of a criminal case, challenging an acquittal through certiorari is generally the purview of the Office of the Solicitor General to prevent double jeopardy issues.
What does this case mean for those accused of crimes in the Philippines?	This case reinforces the protection against double jeopardy, ensuring that once acquitted, an individual cannot be tried again for the same offense, even if errors are alleged in the original trial.
What was the crime that the accused was acquitted from?	The accused was acquitted from violating Republic Act No. 6538, also known as the Anti-Carnapping Act of 1972, for allegedly taking a tricycle without consent.

The Supreme Court’s decision in this case serves as a crucial reminder of the fundamental principles protecting the rights of the accused in the Philippine legal system. It underscores the importance of respecting the finality of acquittals and adhering to the constitutional guarantee against double jeopardy to ensure fairness and prevent potential government oppression.

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: People vs Terrado, G.R. No. 148226, July 14, 2008