G.R. No. 151912 - Philippine Savings Bank vs. Spouses Bermoy

Philippine Savings Bank (“petitioner”) filed Criminal Case No. 96-154193 in R.T.C. Manila for estafa through falsification of a public document, alleging that spouses Pedrito and Gloria Bermoy (“respondents”) forged an owner’s copy of TCT No. 207434 and used it as collateral to obtain a ₱1,000,000 loan.
Upon arraignment, respondents pleaded “not guilty.” A pre-trial was set for June 11, 1997.

On June 11, 1997, the court issued an Order stating that counsel for both sides admitted jurisdiction and identities of the accused. The one-page minutes, signed by respondents, merely noted: “Postponed. Upon joint agreement of counsels.” No express stipulation by respondents was recorded.
The hearing was reset for June 18, 1997 at 8:30 a.m.

On June 18 and September 3, 1997, petitioner presented two witnesses—Felisa Crisostomo and Hermenigildo Caluag—who testified on the loan application, presentation of the forged TCT, execution of mortgage, and petitioner’s failed attempt to register its certificate of sale.
After resting its case, the defense, with leave of court, filed a demurrer to evidence, arguing that the prosecution failed to identify respondents as the persons who obtained the loan.

In its April 21, 1998 Order, the trial court granted the demurrer, finding no proper witness identification nor express stipulation by respondents, dismissed the case for insufficiency of evidence, and acquitted respondents. A motion for reconsideration was denied on May 28, 1998.
Petitioner and the Solicitor General filed a petition for certiorari with the Court of Appeals. In a Decision dated November 14, 2001, the CA denied the petition, holding (a) witnesses did not properly identify respondents, (b) no valid pre-trial stipulation existed, and (c) double jeopardy bars review of the acquittal absent grave abuse of discretion. A Resolution of January 24, 2002 denied reconsideration.

Whether the Court of Appeals erred in holding that the trial court was not duty-bound to require respondents to sign the pre-trial order.
Whether the CA erred in refusing to treat the June 11, 1997 Order as a binding stipulation of identities.
Whether the CA erred in finding that respondents were not sufficiently identified during trial.
Whether the CA erred in holding that double jeopardy had already attached.