Case Digest (G.R. No. 248567)
Facts:
Erwin Torres y Castillo was charged in Quezon City with violation of Section 5(b) of R.A. 7610 for allegedly sexually abusing AAA, then a 12-year-old, on October 14, 2012. After Torres pleaded not guilty and trial proceeded, the RTC of Quezon City, Branch 107 acquitted him on April 17, 2018 for failure of the prosecution to prove guilt beyond reasonable doubt, citing alleged inconsistencies in AAA’s testimony and lack of proof of coercion or influence.
AAA then filed a Rule 65 petition for certiorari in the Court of Appeals, which on March 7, 2019 annulled the acquittal and convicted Torres, ruling that the RTC committed misappreciation and failed to consider AAA’s complete affidavit. Torres sought reconsideration, denied on July 24, 2019, and filed a Rule 45 petition to annul the CA conviction on the ground of double jeopardy.
Issues:
- Whether the CA violated Torres’ constitutional right against double jeopardy when it convicted him under Section 5(b) of R.A. 7610 after the RTC acquitted him.
Ruling:
The Court granted Torres’ petition and declared the CA’s Decision and Resolution NULL and VOID for violating his constitutional right against double jeopardy.
The Court held that the certiorari remedy against a judgment of acquittal is a very narrow exception, which requires a clear showing of grave abuse of discretion amounting to a due process violation that rendered the acquittal void. Because the CA merely found evidentiary errors constituting an error of judgment, not a jurisdictional defect, the CA could not disturb the final and unappealable acquittal.
Ratio:
A judgment of acquittal—whether from the trial court or an appellate court—is final, unappealable, and immediately executory, and it may be overturned only when the acquittal is void for grave abuse of discretion that violates the prosecution’s due process, such as when the trial is a sham or the prosecution is denied the opportunity to present evidence.
Here, the CA set aside the RTC acquittal by re-evaluating the evidence and concluding that the RTC misappreciated testimony and improperly assessed the affidavit. The Court ruled that such misappreciation reflects an error of judgment, which does not qualify as the due process-based exception; thus, Torres’ double jeopardy protection already attached upon the RTC’s acquittal.
Doctrine:
- A judgment of acquittal is final, unappealable, and immediately executory upon promulgation, and the right against double jeopardy attaches upon acquittal.
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