G.R. No. 223099 - People vs. Alejandro y Pimentel

The case involves an appeal from the Decision of the Court of Appeals affirming the Regional Trial Court's (RTC) conviction of Lino Alejandro y Pimentel for two counts of rape against a 12-year-old minor, referred to as AAA.
The charges were based on Article 266-A, paragraph 1 (a) of the Revised Penal Code, in relation to Republic Act No. 8369.
During the trial, AAA testified that the accused followed her, assaulted her, and threatened her life if she disclosed the incidents.
Medical examination by Dr. CCC revealed physical evidence consistent with sexual intercourse.

On July 26, 2011, the RTC initially acquitted the accused, mistakenly believing that AAA had not testified.
The RTC later recalled this decision upon realizing that AAA had indeed testified, which was crucial for a proper verdict.
The recall was justified by the RTC as necessary to prevent a miscarriage of justice, citing the need for accurate findings based on all relevant facts.

The accused-appellant filed a Motion for Reconsideration, arguing that a judgment of acquittal is final and cannot be modified without violating the principle of double jeopardy.
The RTC denied this motion, asserting that its initial decision was based on an error regarding the testimony of AAA, which warranted correction to align with the facts and law.

Following the recall, the RTC rendered a Joint Decision convicting the accused of two counts of rape, sentencing him to reclusion perpetua and ordering damages to AAA.
The accused appealed to the Court of Appeals, claiming that the RTC erred in recalling the acquittal and in convicting him despite insufficient evidence.

The Court of Appeals dismissed the appeal, agreeing with the RTC that the initial acquittal lacked a factual basis due to the omission of AAA's testimony.
It emphasized that judges must provide complete findings of fact and that the initial decision was null and void due to the incomplete record.

The accused-appellant contended that the RTC's error could not justify recalling the acquittal, which had attained finality.
He argued that the public prosecutor's manifestation was akin to a motion for reconsideration, which should not have been allowed post-acquittal.

The Office of the Solicitor General (OSG) supported the RTC's recall, asserting that it did not constitute double jeopardy as it merely corrected an oversight regarding the evidence presented.
The OSG maintained that the recall was necessary to prevent injustice to the victim and did not involve new evidence against the accused.

The court reiterated the doctrine of finality of acquittal, stating that a judgment of acquittal is final, unappealable, and immediately executory.
It outlined the elements required for double jeopardy to attach, confirming that all elements were present in this case.
The court found no exceptions to the double jeopardy rule applicable here, as there was no deprivation of due process or mistrial.