Title
People vs. Santiago
Case
G.R. No. 80778
Decision Date
Jun 20, 1989
Accused acquitted without trial for squatting on U.P. land; Supreme Court nullified acquittal, citing lack of due process, and ordered trial on merits.
plea bargaining
stipulation of facts
fair and expeditious trial

Case Summary (G.R. No. 80778)

Factual Background

On June 2, 1987, an information for violation of P.D. No. 772 was filed by the Assistant City Fiscal of Quezon City, with the approval of the city fiscal, before the RTC of Quezon City against Segundina Rosario y Sembrano for acts allegedly committed on or about December 16, 1986, and for some time prior thereto and persisting up to the filing date. Upon arraignment, the accused pleaded not guilty, and a pre-trial conference was held on August 14, 1987. During the pre-trial, the accused informed the court that she had a title, a building permit, and a survey plan covering the subject land.

The RTC issued an order instructing both parties to submit their respective proffer of documentary exhibits together with their positions as to whether the case would be heard or dismissed. The private prosecutor submitted a position paper asserting that the property belonged to U.P. as shown by TCT No. 9462, covering approximately 493 hectares at Diliman, Quezon City, including the area in question, and that ownership of the U.P. campus under TCT No. 9462 had been sustained in prior Supreme Court decisions. The prosecutor further alleged that the accused’s supposed title had been cancelled, and that, granting arguendo that the accused had a title, the pivotal issue remained whether the land described in her title corresponded to the lot at Pook Amorsolo, U.P. Campus, which is adjacent to Bo. Kruz-na-Ligas, Diliman, Quezon City; the prosecutor also argued that the accused’s alleged title and tax declaration indicated a location in Bo. Gulod, Municipality of Marikina, Province of Rizal, and that the accused had paid real estate taxes in Marikina. The private prosecutor insisted that the criminal case should proceed because the accused’s construction was allegedly made on U.P. land without its knowledge and consent and in violation of P.D. No. 772.

In response, the accused submitted a proffer of exhibits and a manifestation intended to show that she had applied for a building permit to construct on the lot, that the lot was covered by her own title, that she paid the fees for the building permit, and that she had a relocation plan with supporting data. The accused also alleged that she had informed U.P. of her claim and asked it not to intrude into her property. U.P. opposed, arguing that the proffer was irregular and not supported because the evidence had not been marked in pre-trial, and because the proffer and manifestation were not authorized under Sections 1 and 2 of Rule 118 of the 1985 Rules on Criminal Procedure. U.P. maintained that only marking for identification of documentary evidence was contemplated, and asked that the proffer and manifestation be denied.

Despite this opposition, the RTC rendered its decision on October 27, 1987, acquitting the accused with costs de oficio.

RTC Acquittal and the Grounds Invoked

In the questioned decision, the respondent judge framed the core issue as whether the accused could be convicted for violation of P.D. No. 772. The decision acknowledged a “collision” between the parties’ claims of ownership, noting that both land titles were Torrens titles. It reasoned that the prosecution’s evidence failed to establish with certainty that the accused constructed the structure illegally. It invoked the rule that the moral conviction required for conviction must be the logical and inevitable result of the evidence, and it quoted People vs. Maisug, 27 SCRA 753, to stress the constitutional duty to acquit in the absence of sufficient proof. The RTC also stated that the Torrens title of the accused could not be collaterally attacked and cited the doctrine that issues regarding title validity must be raised in an appropriate action. Ultimately, the RTC held that the inadequacy and/or scantiness of the prosecution’s evidence was insufficient to sustain conviction and acquitted the accused without conducting a trial on the merits.

The Petition for Certiorari and the Issues Presented

The petition, filed by counsel for the private offended party U.P. on behalf of the People of the Philippines, sought to declare the RTC decision null and void for want of due process, asserting that the acquittal was rendered without a trial on the merits. The petition raised two issues: first, whether double jeopardy attached in the event of an acquittal rendered without a trial on the merits; and second, whether the private offended party in a criminal case could file a special civil action for certiorari questioning the validity of the acquittal without the intervention of the Solicitor General.

The Parties’ Contentions in the Supreme Court

The Supreme Court treated the case as involving a procedural deprivation of due process. It emphasized that the respondent judge acquitted the accused after a pre-trial, without allowing the prosecution to present and test evidence through a trial on the merits. The prosecution had objected to the disposition of the case without trial, contending that the proffered exhibits were not authorized under the governing provisions on pre-trial, and that the trial court had not ruled on admissibility or compliance with the rules before resolving the case.

The Court also recognized the procedural and representational concern posed by the petition: whether U.P., as private offended party, could seek certiorari and obtain the annulment of an acquittal without the Solicitor General’s direct participation. The petition maintained that certiorari lay as the questioned action allegedly constituted grave abuse of discretion amounting to lack of jurisdiction.

Legal Basis and Reasoning

The Supreme Court anchored its analysis on Rule 118 of the 1985 Rules on Criminal Procedure. It held that the purpose of pre-trial is to expedite trial and to consider matters expressly enumerated in Section 2, namely plea bargaining, stipulation of facts, marking for identification of evidence, waiver of objections to admissibility of evidence, and such other matters that promote a fair and expeditious trial. After pre-trial, Section 3 required that the court issue an order reciting the actions taken, facts stipulated, and evidence marked, and that the trial on the merits then proceed limited to matters not disposed of during pre-trial.

The Court ruled that a “proffer of exhibits” or “offer of evidence” was not among the subjects contemplated by Rule 118, Sections 1 and 2. It explained that evidentiary offerings are generally made when a party closes the presentation of evidence, with the adverse party given the opportunity to object and the court then ruling on admissibility. Even assuming that a proffer could be made at pre-trial, the prosecution still needed an opportunity to object to admissibility and to obtain a ruling on admissibility. In the case at bar, the prosecution opposed the proffer on the ground of lack of authority under Rule 118 and lack of marking at pre-trial, and U.P. highlighted additional factual issues regarding the alleged location of the accused’s titled property. The Court noted that the trial court did not even rule on the admissibility of the accused’s exhibits. Nevertheless, the respondent judge resolved the case and acquitted the accused without affording the prosecution its day in court.

Accordingly, the Supreme Court held that the respondent judge committed grave abuse of discretion in rendering the acquittal after pre-trial. It treated the acquittal as void for lack of due process because the prosecution was deprived of the opportunity to present and rebut evidence. The Court emphasized that the issue before the trial court involved whether the accused built a structure on land belonging to U.P. This determination required a trial on the merits, because it could not be resolved merely by examining the parties’ titles and documents submitted at pre-trial. The Court further reasoned that the respondent judge’s observation about inadequacy or scarceness of evidence demonstrated precisely that a trial was necessary to permit the prosecution to prove its case.

On the double jeopardy issue, the Supreme Court reiterated that double jeopardy requires, among others, that the accused be convicted or acquitted or that the case be dismissed or terminated without the accused’s express consent. It held that double jeopardy did not set in because the prosecution was deprived of due process, and the decision was void for lack of jurisdiction. It stated that the court was not one of competent jurisdiction when it precipitately rendered a decision of acquittal after pre-trial, contrary to the rules mandating that a trial should follow pre-trial.

On the second issue, the Court addressed who may file certiorari to annul an acquittal. It held that when the offended party is the State, the private complainant’s role in the prosecution is limited to civil liability and as a witness for the prosecution. In criminal matters, the authority to appeal an acquittal on the criminal aspect belongs to the State through the Solicitor General, and the private offended party may not take such appeal. However, the offended party

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