Title
Austria vs. AAA
Case
G.R. No. 205275
Decision Date
Jun 28, 2022
A teacher acquitted of lascivious acts due to a void judgment; private complainants challenged the acquittal, upheld by the Supreme Court, citing grave abuse of discretion and no double jeopardy violation.
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Case Digest (G.R. No. 205275)

Facts:

  1. Background of the Case:

    • Mamerto Austria, a school teacher, was convicted in 2006 by the Regional Trial Court (RTC) of five counts of acts of lasciviousness against two 11-year-old female students.
    • Mamerto filed a motion for reconsideration, but the presiding judge was promoted, and a new judge issued Joint Orders on August 15, 2008, acquitting Mamerto.
  2. Private Complainants' Response:

    • The private complainants (AAA and BBB) filed a special civil action for certiorari to the Court of Appeals (CA), alleging that the new judge committed grave abuse of discretion by merely parroting Mamerto's motion for reconsideration without providing factual or legal bases for the acquittal.
  3. Court of Appeals' Decision:

    • The CA ruled in favor of the private complainants, annulling the RTC's Joint Orders for failing to meet the constitutional requirement of clearly stating the facts and law on which the decision was based.
    • The CA reinstated the RTC's initial conviction.
  4. Mamerto's Argument:

    • Mamerto filed a Petition for Review on Certiorari before the Supreme Court, arguing that the private complainants lacked legal standing to question his acquittal and that doing so would violate his right against double jeopardy.

Issue:

  1. Whether private complainants (AAA and BBB) have the legal personality to question Mamerto’s acquittal in criminal proceedings.
  2. Whether the Court of Appeals correctly ruled that the RTC committed grave abuse of discretion in acquitting Mamerto.
  3. Whether Mamerto’s right against double jeopardy was violated by the CA’s decision to annul his acquittal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Guidelines for Private Complainants in Criminal Cases:

The Court provided the following guidelines to harmonize jurisprudence on the legal standing of private complainants in criminal cases:

  1. Private complainants may appeal the civil liability of the accused or file a petition for certiorari to preserve their interest in the civil aspect of the case.
  2. Private complainants cannot appeal or question the criminal aspect of the case without the OSG’s conformity.
  3. The reviewing court shall require the OSG to file a comment on private complainants’ petitions for certiorari questioning acquittals, dismissals, or interlocutory orders based on grave abuse of discretion or denial of due process.

Conclusion:

The Supreme Court denied Mamerto's petition, affirmed the CA’s decision, and remanded the case to the RTC for proper resolution of Mamerto’s motion for reconsideration in accordance with constitutional requirements.


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