The Supreme Court ruled that a judgment of acquittal, once promulgated, is immediately final and cannot be recalled, even if based on a misapprehension of facts. This decision underscores the constitutional right against double jeopardy, protecting individuals from being tried again for the same offense after an acquittal. It clarifies the boundaries of judicial authority in criminal cases, emphasizing the importance of finality in judgments to safeguard individual liberties.

When a Mistake Becomes a Matter of Constitutional Right

This case revolves around Lino Alejandro, who was initially acquitted of two counts of rape by the Regional Trial Court (RTC). The acquittal was based on an error: the RTC mistakenly believed that the victim, AAA, had not testified. Upon realizing this error, the RTC recalled its decision and subsequently convicted Alejandro. The Court of Appeals (CA) affirmed the conviction, but the Supreme Court (SC) reversed this decision, holding that the recall of the acquittal violated Alejandro’s right against double jeopardy.

The central legal question is whether a trial court can recall a judgment of acquittal based on its own error, without violating the constitutional right against double jeopardy. The Constitution protects individuals from being placed in jeopardy of punishment twice for the same offense. Section 7, Rule 117 of the Rules of Criminal Procedure, which strictly adheres to the constitutional proscription against double jeopardy, specifies the requisites for double jeopardy to attach. The elements are: (1) a valid information sufficient in form and substance to sustain a conviction of the crime charged; (2) a court of competent jurisdiction; (3) the accused has been arraigned and had pleaded; and (4) the accused was convicted or acquitted or the case was dismissed without his express consent. Chiok v. People, et al., 774 Phil. 230, 247-248 (2015).

The Supreme Court emphasized the importance of the finality-of-acquittal doctrine, which states that a judgment of acquittal is final and unappealable. In this case, all elements of double jeopardy were present: a valid information, a competent court, arraignment and plea, and a judgment of acquittal. The Court acknowledged the RTC’s error but held that it did not negate the fact that a judgment of acquittal had already been promulgated. As stated in Villareal v. Aliga, 724 Phil. 47, 62 (2014), a judgment of acquittal, whether ordered by the trial or the appellate court, is final, unappealable, and immediately executory upon its promulgation.

While the rule on double jeopardy has exceptions, such as deprivation of due process, a finding of mistrial, or grave abuse of discretion, none of these exceptions applied here. The prosecution had the opportunity to present its case and witnesses, and there was no mistrial. The Court also noted that a mere manifestation is insufficient to assail a judgment of acquittal; a petition for certiorari under Rule 65 of the Rules of Court is required. If the petition merely seeks an ordinary review of the court’s findings, it violates the accused’s right against double jeopardy as per Villareal v. Aliga, 724 Phil. 47, 60 (2014).

The Supreme Court cited People v. Laguio, Jr., 547 Phil. 296 (2007), which clarifies that double jeopardy does not attach only when the trial court acted with grave abuse of discretion amounting to lack or excess of jurisdiction. This includes instances where the prosecution was denied the opportunity to present its case or where the trial was a sham. The manifestation of the prosecutor, which led to the recall of the acquittal, did not demonstrate such grave abuse of discretion. The RTC was merely apprised of a mistake it had committed.

The Court also referred to Argel v. Judge Pascua, 415 Phil. 608 (2001), where a judge was sanctioned for gross ignorance of the law for recalling a judgment of acquittal. In that case, the judge recalled the acquittal after being informed by the private complainant’s counsel that there was a witness who positively identified the accused. The Supreme Court held that a decision, once final, is no longer susceptible to amendment or alteration, except to correct clerical errors or clarify ambiguities. As the Supreme Court stated, complainant herein was already acquitted of murder by respondent in a decision promulgated on 13 August 1993. Applying the aforestated rule, the decision became final and immutable on the same day.

In the case of Lino Alejandro, the RTC recalled the judgment of acquittal based on its realization that the victim had testified. This prompted the RTC to rectify its error and convict the accused-appellant for two counts of rape. Such action was deemed impermissible as it violated the accused-appellant’s constitutionally-enshrined right against double jeopardy. The Supreme Court thus reversed the Court of Appeals’ decision, setting aside the conviction, and ordered the immediate release of Lino Alejandro, unless he was being held for another lawful cause. The ruling serves as a reminder of the paramount importance of protecting an individual’s right against double jeopardy, even in the face of judicial errors.

FAQs

What was the key issue in this case?	The central issue was whether a trial court could recall a judgment of acquittal based on its own error, without violating the constitutional right against double jeopardy. The Supreme Court ruled that it could not.
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. It prevents the state from subjecting an accused to the harassment of multiple trials.
What is the finality-of-acquittal doctrine?	The finality-of-acquittal doctrine states that a judgment of acquittal is final, unappealable, and immediately executory upon its promulgation. This means that once a person has been acquitted, they cannot be tried again for the same crime.
Were there exceptions to the double jeopardy rule in this case?	No, the Supreme Court found that none of the exceptions to the double jeopardy rule applied in this case. There was no deprivation of due process, mistrial, or grave abuse of discretion.
Why was the RTC’s recall of the acquittal considered a violation of double jeopardy?	The RTC’s recall of the acquittal was considered a violation of double jeopardy because it effectively subjected the accused to a second trial for the same offense. The initial acquittal was final and could not be overturned based on a mere manifestation of error.
What is the proper procedure for assailing a judgment of acquittal?	A judgment of acquittal can only be assailed through a petition for certiorari under Rule 65 of the Rules of Court. The petition must demonstrate that the trial court acted with grave abuse of discretion amounting to lack or excess of jurisdiction.
What was the basis for the RTC’s initial acquittal?	The RTC’s initial acquittal was based on a mistaken belief that the victim had not testified during the trial. This was due to a mix-up of orders with a different case involving the same accused-appellant.
What was the effect of the Supreme Court’s decision?	The Supreme Court reversed the Court of Appeals’ decision, set aside the conviction, and ordered the immediate release of Lino Alejandro. This upheld the principle of double jeopardy and the finality of acquittals.

The Supreme Court’s decision in this case reaffirms the fundamental constitutional right against double jeopardy. It serves as a crucial reminder to the judiciary of the importance of upholding this right and respecting the finality of judgments, particularly those of acquittal. This safeguards individuals from potential abuses of power and ensures that the justice system operates fairly and equitably.

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 v. Alejandro, G.R. No. 223099, January 11, 2018