G.R. No. 210316 - Securities and Exchange Commission vs. CJH Development Corp.

The respondents, together with others, were charged with malversation of public funds in four separate criminal cases (Nos. 3896, 5897, 3898, and 5899) before the Court of First Instance of Leyte.
A joint hearing was held in which numerous witnesses were presented by both the prosecution and the defense.
On June 28, 1951, Judge Jose B. Rodriguez rendered his decision spanning 152 pages, acquitting all the accused except Treasurer Francisco Martinez, who was found guilty of malversation through negligence and imposed a single penalty.

On July 5, 1951, the clerk of the Court of First Instance of Leyte entered Judge Rodriguez’s decision into the criminal docket.
The docket entry noted that on July 3, 1951, Francisco Martinez was convicted to suffer 8 years, 1 day to 16 years, 5 months and 11 days imprisonment, perpetual disqualification, and was ordered to pay P655,965.69 plus proportionate costs; the remaining accused were acquitted.
While Martinez was required to appear for the reading of the sentence (and he later requested a postponement, resulting in only the dispositive part being read), no such requirement was imposed on the acquitted respondents whose copies of the decision were duly served.
Counsel for respondents Ildefonso Tierra and Delfin M. Reyes received copies of the decision on July 20, 1951.

One motion sought a modification of Judge Rodriguez’s June 28, 1951 decision by condemning the acquitted accused to pay, jointly and severally, as indemnity and reparation for the amount involved.
The other motion prayed that all the accused, except Baldomero Perez, be convicted.

In response, the corresponding oppositions were filed by the respondents, and Francisco Martinez filed a motion for a new trial.
The prosecution later supported its motions with a memorandum, contending that four separate judgments should have been rendered, that the result was inconsistent with the findings in the decision, and that the decision was not validly promulgated.

On December 26, 1951, the clerk of court notified that the reading of a new decision by Judge Sulpicio V. Cea (covering the same four cases) was scheduled for January 10, 1952.
Upon learning this, respondents filed a motion alleging that Judge Cea lacked jurisdiction or authority to render a new decision in these cases.
Judge Cea overruled the respondents’ motion on January 9, 1952, and rescheduled the promulgation for January 16, 1952, later moving it to February 7, 1952, and then issuing further orders.
On February 19, 1952, an order was set for the reading of his decision on March 4, 1952, with a warning that non-appearance by the accused would result in bond confiscation and arrest.
On March 4, 1952, Judge Cea issued several orders denying motions for new trial, disallowing an appeal on interlocutory grounds, and denying a motion to suspend the promulgation of a new decision.
Subsequently, on March 20, 1952, respondents filed a petition for certiorari in the Court of Appeals to nullify Judge Cea’s orders and to restrain him from rendering any new decision that would modify or derogate from the acquittal rendered by Judge Rodriguez.

The Court of Appeals, on August 51, 1953, granted the petition by declaring null and void all the orders issued by Judge Cea in those four criminal cases and enjoined him from rendering any new decision that would modify the already rendered acquittal.
The present appeal by certiorari was taken on behalf of Judge Cea, Fiscal Alberto Jimenez, and the People of the Philippines.
The central dispute is whether the new decision by Judge Cea, which intended to replace the previously promulgated acquittal of Judge Rodriguez, is valid and proper given that the acquittal was argued by petitioners to have been insufficiently promulgated.

Whether the acquittal decision rendered on June 28, 1951, by Judge Rodriguez was duly promulgated by virtue of its entry in the docket and the service of copies, despite the accused not being present for a full reading.
Whether the requirement of personal presence for the reading of the judgment under Rule 116 applies equally in acquittal cases as it does in conviction cases.

Whether Judge Sulpicio V. Cea had the proper jurisdiction or authority to render a new decision in these four criminal cases that sought to replace or modify Judge Rodriguez’s judgment of acquittal.
Whether the subsequent actions of Judge Cea, including issuing orders related to motions for new trial and reading of judgment in a conviction context, were procedurally and substantively valid.

Whether promulgating a new decision that convicts the respondents, in place of an already validly promulgated acquittal, violates the rule against double jeopardy.
Whether the principles governing the modification of judgments—especially the finality of an acquittal judgment—preclude any subsequent conviction without contravening due process rights.