Title
Arenajo vs. Lustre
Case
G.R. No. L-21382
Decision Date
Jul 2, 1966
Jose Arenajo acquitted of theft; appeal limited to civil aspect. Retrial ordered, but court ruled it violated double jeopardy, barring reopening of criminal case.
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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.


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