Case Summary (G.R. No. 118653)
Motion for Reconsideration
Private complainant Lauro G. Vizconde moved for reconsideration on December 28, 2010, alleging denial of due process, misappreciation of facts, erroneous credibility findings (particularly regarding witness Jessica Alfaro), and grave abuse of discretion resulting in a miscarriage of justice.
Double Jeopardy Principle under the 1987 Constitution
Article III, Section 21 of the 1987 Constitution prohibits placing a person twice in jeopardy for the same offense. Once acquitted, an accused is immune from further prosecution or punishment on that charge, reflecting the State’s obligation to limit its power and prevent repeated litigation.
Exceptions to the Finality of Acquittal
Exceptional grounds permitting review of an acquittal are narrow: (a) grave abuse of discretion depriving the court of jurisdiction, (b) mistrial, or (c) special civil action by certiorari under Rule 65. Absent these, an acquittal is final.
Lack of Specific Allegations of Due Process Violations
Vizconde’s motion fails to identify any concrete due process violations or specific acts of grave abuse of discretion by the Court. General assertions of “tainted” evidence and “suspicious” defense proof are mere conclusions, not factual or legal grounds warranting reconsideration.
Distinction from Galman Case
In Galman v. Sandiganbayan, acquittal was set aside because the prosecution proved a sham trial and deprivation of due process. Here, no allegation of a “scripted” or “coerced” Supreme Court review exists; Vizconde does not claim deliberations were phony or jurisdictionally defective.
Prohibition on Re-Evaluation of Evidence
Complainant essentially seeks to have the Court reassess witness credibility and reweigh evidence—a form of repeated attempt to convict the same individuals. Constitutional double jeopardy prohibits such retrial or reapp
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Facts
- The Supreme Court, en banc, on December 14, 2010, reversed the Court of Appeals’ conviction and acquitted Hubert Jeffrey P. Webb, Antonio Lejano, Michael A. Gatchalian, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Gerardo Biong for lack of proof beyond reasonable doubt.
- On December 28, 2010, private complainant Lauro G. Vizconde filed a motion for reconsideration, alleging denial of due process, misappreciation of facts, grave abuse of discretion, and serious doubts as to the credibility of key defense evidence.
- Vizconde sought to impugn the Court’s assessment of Jessica Alfaro’s credibility and to have the evidence re-weighed in order to secure convictions of the accused anew.
Issue Presented
- Whether a judgment of acquittal may be reopened or reconsidered once rendered, consistent with the Double Jeopardy Clause of the 1987 Constitution (Article III, Section 21).
- Whether the exceptions to the finality of an acquittal judgment—namely grave abuse of discretion resulting in loss of jurisdiction, mistrial, or similar anomalies—apply in this case.
- Whether intervenors (VACC representatives and former Vice President Guingona) may present additional pleadings after the acquittal.
Ruling
- The Court DENIED the motion for reconsideration of the acquittal for lack of merit and in deference to the Double Jeopardy Clause.
- The Court DENIED the motions for leave to intervene by third parties for the same reasons.
- The acquittal of the accused is final and no further pleadings are allowed.
Legal Principles
- Article III, Section 21: “No person shall be twice put in jeop