Case Digest (G.R. No. L-21382)
Facts:
The case involves Jose Arenajo as the petitioner and Hon. Julian E. Lustre, Judge of the Court of First Instance of Tarlac, along with the People of the Philippines as respondents. The events leading to this case began in February 1961 when a criminal complaint for theft (Crim. Case No. 1317) was filed against Arenajo in the Justice of the Peace Court of Camiling, Tarlac. After a trial, the court rendered a decision on January 17, 1962, acquitting Arenajo of the theft charge but ordering the return of a wristwatch, valued at P85, to the complainant, Eustacio Damian. The court found that while Damian was the owner of the wristwatch, there was no direct evidence that Arenajo had taken it from him. The court accepted Arenajo's explanation that he had acquired the wristwatch through barter from a third party, who was not the true owner. Following this acquittal, Arenajo filed a notice of appeal on January 29, 1962, specifically contesting the civil aspect of the case regardin...
Case Digest (G.R. No. L-21382)
Facts:
The case involves Jose Arenajo, who was acquitted of a criminal charge for theft by the Justice of the Peace Court of Camiling, Tarlac. The complaint for theft (Crim. Case No. 1317) was filed against Arenajo in February 1961. After trial, the Justice of the Peace Court rendered a decision on January 17, 1962, acquitting Arenajo of the charge but ordering the return of the wrist watch (the subject of the theft) to the complainant, Eustacio Damian. Arenajo filed a notice of appeal to the Court of First Instance of Tarlac on January 29, 1962, limiting his appeal to the civil aspect of the case. On September 28, 1962, the respondent Judge of the Court of First Instance of Tarlac issued an order granting the refiling of the criminal complaint before it and docketed the case as Criminal Case No. 2631. Later, the respondent Judge denied petitioner's motion for reconsideration, arguing that the setting of the case for trial de novo does not place petitioner in jeopardy of being convicted a second time for the same offense of theft.
Issue:
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Ruling:
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Ratio:
In this jurisdiction, a judgment of acquittal is such a final verdict that once rendered and promulgated, it takes effect immediately. To hold that respondent Judge may retry the criminal aspect of the case would defeat the very essence and purpose of a judgment of acquittal. It would, in effect, place the accused in jeopardy of being convicted again for an offense of which he was already absolved. Petitioner had already been acquitted in the Justice of the Peace Court of Camiling and had confined his appeal to the Court of First Instance only to the civil aspect of the case. Therefore, it was error for the respondent Judge to have ordered the reopening or retrial of the case in both its criminal and civil aspect.