G.R. No. 158370 - Spouses Uy vs. Ariza

Manuel T. Ubarra, Jr. (Ubarra), Vice-President for Litigation of CJH Development Corporation, filed a verified complaint-affidavit on July 4, 2012, before the Office of the Ombudsman, accusing Atty. Arnel Paciano D. Casanova (Casanova), CEO of BCDA, of violating RA No. 3019, RA No. 6713, and PD No. 807.
Ubarra alleged Casanova failed to promptly and correctly respond to letters from CJH, but those letters were addressed to other officials, not Casanova.
BCDA, through Casanova, filed a complaint charging Ubarra with perjury on September 13, 2012, leading to the filing of Information on July 1, 2013, alleging Ubarra willfully made false statements under oath in the Ombudsman complaint-affidavit.
The case was docketed as Criminal Case No. M-QZN-13-02420-CR in the Metropolitan Trial Court (MeTC), Quezon City.

Ubarra refused to enter a plea at arraignment; the court entered a plea of not guilty.
Prior to pre-trial, the prosecution filed the judicial affidavits of its four witnesses, including Casanova’s, on August 15, 2014, through registered mail.
Both parties enumerated their witnesses at pre-trial; the prosecution presented their witnesses, including Casanova, at trial.
The MeTC admitted the prosecution’s exhibits by order dated February 27, 2015.
Ubarra’s demurrer to evidence was denied; the defense then presented its witnesses and Ubarra’s judicial affidavit.
Ubarra admitted that the inclusion of Casanova in the complaint was an unintentional error prepared by his counsel.

On November 16, 2015, the MeTC rendered a Decision finding Ubarra guilty beyond reasonable doubt of perjury and sentenced him to incarceration.

Ubarra appealed to the RTC, Branch 92, Quezon City, which on August 17, 2016, acquitted him on the ground of reasonable doubt as to his identity as the person who committed perjury.
The RTC noted the absence of Casanova’s judicial affidavit in the records transmitted to it, despite the prosecution’s claim of filing it.
The RTC ordered the private prosecutors to explain in writing why they should not be held in contempt for misleading the court regarding the judicial affidavit’s filing.
The RTC held that Casanova failed to positively identify Ubarra in open court, which was fatal to the prosecution’s case.

The Office of the Solicitor General petitioned the CA for certiorari alleging grave abuse of discretion by the RTC.
The CA, in a Decision dated March 19, 2019, granted the petition, set aside the RTC’s acquittal, and directed the RTC to require the prosecution to explain the judicial affidavit’s absence and decide the case accordingly.
The CA held that the RTC disregarded due process and the basic tenets of justice by acquitting Ubarra without allowing the prosecution to explain the lost evidence.

Ubarra filed a petition to the Supreme Court claiming the CA violated his constitutional right against double jeopardy by reversing his acquittal.

Whether the Court of Appeals violated Ubarra’s right against double jeopardy when it reversed the RTC’s judgment of acquittal.