The Supreme Court affirmed the Sandiganbayan’s acquittal of Camilo Loyola Sabio, emphasizing the constitutional right against double jeopardy. This decision clarifies that an acquittal cannot be overturned on appeal unless there is grave abuse of discretion or a denial of due process. The ruling underscores the importance of finality in acquittals, protecting individuals from repeated attempts by the State to secure a conviction and reinforces the principle that errors in evidence evaluation are not grounds for certiorari.

Acquittal Stands: Can Grave Abuse of Discretion Overturn a Verdict?

This case revolves around the charges filed against Camilo Loyola Sabio, former Chairperson of the Presidential Commission on Good Government (PCGG), for violation of Section 3(e) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act, and two counts of Malversation of Public Funds under Article 217 of the Revised Penal Code. The prosecution alleged that Sabio misappropriated over ten million pesos in remittances and failed to liquidate cash advances. After a trial, the Sandiganbayan acquitted Sabio due to insufficiency of evidence, leading the People of the Philippines, represented by the Office of the Ombudsman, to file a petition for certiorari, arguing grave abuse of discretion. The central legal question is whether the Sandiganbayan’s acquittal can be overturned through a certiorari proceeding, given the constitutional protection against double jeopardy.

The heart of the matter lies in the constitutional guarantee against double jeopardy, which protects individuals from being twice put in jeopardy of punishment for the same offense. Section 21 of the Bill of Rights under the 1987 Constitution clearly states:

Section 21. No person shall be twice put in jeopardy of punishment for the same offense. If an act is punished by a law and an ordinance, conviction or acquittal under either shall constitute a bar to another prosecution for the same act.

This principle is further elaborated in Section 7 of Rule 117 of the Rules of Court on Criminal Procedure, emphasizing that an acquittal serves as a bar to another prosecution for the same offense. Generally, a judgment of acquittal is immediately final and executory, preventing the prosecution from appealing the decision.

However, the Supreme Court acknowledges two exceptions to this rule, where a certiorari proceeding under Rule 65 of the Rules of Court may be warranted. These exceptions are: (1) when the judgment of acquittal is rendered with grave abuse of discretion by the court; and (2) when the prosecution has been deprived of due process. The petitioner in this case attempted to invoke the first exception, arguing that the Sandiganbayan committed grave abuse of discretion in acquitting Sabio.

The Supreme Court, however, found the petitioner’s arguments unpersuasive. While the petition framed its arguments as grave abuse of discretion, the Court noted that it essentially sought a review of the Sandiganbayan’s appreciation of facts and evidence. This, the Court emphasized, falls outside the scope of a certiorari proceeding. The Court cited People v. Hon. Tria-Tirona, which clearly distinguishes between errors of judgment and errors of jurisdiction.

Any error committed in the evaluation of evidence is merely an error of judgment that cannot be remedied by certiorari. An error of judgment is one in which the court may commit in the exercise of its jurisdiction. An error of jurisdiction is one where the act complained of was issued by the court without or in excess of jurisdiction, or with grave abuse of discretion which is tantamount to lack or in excess of jurisdiction and which error is correctible only by the extraordinary writ of certiorari. Certiorari will not be issued to cure errors by the trial court in its appreciation of the evidence of the parties, and its conclusions anchored on the said findings and its conclusions of law. Since no error of jurisdiction can be attributed to public respondent in her assessment of the evidence, certiorari will not lie.

In Sabio’s case, the prosecution had ample opportunity to present its evidence and witnesses. The Sandiganbayan, after considering this evidence, concluded that there was insufficient proof to establish Sabio’s guilt beyond a reasonable doubt. Specifically, the Sandiganbayan found that Sabio’s participation was limited to signing transmittal letters, checks, and vouchers, and that the funds in question were intended for the operational expenses of the PCGG, not for remittance to the Bureau of Treasury (BOT).

The Court also highlighted the testimony of Escorpizo, who indicated that the cash advance was made in Sabio’s name as PCGG Chairperson, based on the instructions of PCGG Commissioners Abcede and Conti, who promised to issue a board resolution authorizing the advance. Furthermore, the charge of malversation was dismissed because the prosecution failed to prove that Sabio did not liquidate the cash advance of P1,550,862.03 despite demand. Therefore, the Supreme Court concluded that the Sandiganbayan’s decision was based on its appreciation of the evidence presented and did not constitute grave abuse of discretion.

The Supreme Court reiterated that grave abuse of discretion involves a capricious or whimsical exercise of judgment equivalent to a lack of jurisdiction. The petitioner failed to demonstrate that the Sandiganbayan blatantly abused its discretion in acquitting Sabio, thereby depriving it of the authority to dispense justice. Thus, an action for certiorari is not meant to correct errors of judgment but only errors of jurisdiction. The Court emphasized that misapplication of facts and evidence, and erroneous conclusions based on evidence, do not, in themselves, rise to the level of grave abuse of discretion.

FAQs

What is double jeopardy?	Double jeopardy is a constitutional right that protects individuals from being tried or punished more than once for the same offense.
What does grave abuse of discretion mean in a legal context?	Grave abuse of discretion implies a capricious, whimsical, or arbitrary exercise of power, equivalent to a lack of jurisdiction, indicating a disregard for established rules or legal principles.
Under what circumstances can an acquittal be challenged?	An acquittal can only be challenged in cases of grave abuse of discretion by the court or when the prosecution has been deprived of due process.
What is a petition for certiorari?	A petition for certiorari is a legal remedy used to correct errors of jurisdiction, not errors of judgment, made by a lower court.
What was the main issue in People v. Sandiganbayan and Sabio?	The main issue was whether the Sandiganbayan’s acquittal of Sabio could be overturned through a certiorari proceeding based on alleged grave abuse of discretion.
Why did the Supreme Court dismiss the petition?	The Supreme Court dismissed the petition because the Sandiganbayan’s decision was based on its appreciation of evidence and did not constitute grave abuse of discretion.
What was Sabio accused of in the Sandiganbayan?	Sabio was accused of violating the Anti-Graft and Corrupt Practices Act and malversation of public funds.
What role did Sabio’s position as PCGG Chairperson play in the case?	As PCGG Chairperson, Sabio was accountable for public funds and property, which led to the charges of malversation when funds were allegedly misappropriated.
What is the significance of the Tria-Tirona case cited in this decision?	The Tria-Tirona case clarifies the distinction between errors of judgment, which cannot be remedied by certiorari, and errors of jurisdiction, which can be.

In conclusion, the Supreme Court’s decision in People v. Sandiganbayan and Sabio underscores the importance of the constitutional right against double jeopardy and clarifies the limited circumstances under which an acquittal can be challenged. The ruling reinforces the principle that errors in the evaluation of evidence are not grounds for certiorari, emphasizing the need to protect individuals from repeated attempts by the State to secure a conviction.

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 OF THE PHILIPPINES VS. HONORABLE SANDIGANBAYAN, G.R. Nos. 228494-96, March 21, 2018