Case Summary (G.R. No. L-8014)
Trial Court Disposition
In a consolidated October 8, 1996 decision, RTC-Branch 89:
- Convicted Diego of murder and double frustrated murder
- Acquitted Galvez of murder and frustrated murder for insufficient evidence
- Dismissed illegal-firearm charge, finding no violation
Petition for Certiorari and Main Issues
The State filed a Rule 65 certiorari petition alleging that Velasco acted with grave abuse of discretion in acquitting Galvez. Two threshold issues arose:
- Whether certiorari is a proper remedy to challenge an acquittal on evidence grounds.
- Whether review of an acquittal on evidence merits violates the constitutional ban on double jeopardy.
Historical Growth of Double Jeopardy Doctrine
The Court traced double jeopardy from ancient Greek and Roman law through English common law (pleas of autrefois acquit/convict) into U.S. jurisprudence, noting key U.S. cases—Kepner v. United States (1900), United States v. Ball (1896), United States v. Wilson (1975), and United States v. Scott (1978). It underscored that U.S. law permits appeals of legal rulings not involving evidence but rule out any appeal when reversal would require a fresh factfinding and second trial.
U.S. Precedents on Appeals of Acquittals
- Kepner: Appeal of bench acquittal is equivalent to retrial and infringes double jeopardy.
- Ball/Fong Foo: Acquittal verdict is final, barring further prosecution.
- Wilson/Scott: Limited appeals permitted when based solely on questions of law or procedural defects that do not impinge on evidence or factual resolution.
Philippine Jurisprudence on Double Jeopardy
Since the 1902 Philippine Bill of Rights, Jones Law, and 1935/1973/1987 Constitutions, Philippine courts have uniformly held that:
- Acquittal—whether by judge or jury—is final on factual grounds and unappealable to protect the accused’s right to repose.
- Rule 117, Sec. 7 conclusively bars another prosecution once accused pleads and is acquitted by competent court.
- Certiorari under Rule 65 corrects only jurisdictional excesses or grave abuse, not mere errors in evidence appreciation.
Court’s Analysis and Ruling
The Court held that:
- The acquittal rested on factual consideration of evidence; a certiorari petition cannot reappraise evidence
Case Syllabus (G.R. No. L-8014)
Facts of the Case
- On a morning in San Ildefonso, Bulacan, gunshots killed Alex Vinculado, severely maimed his twin brother Levi (permanent loss of left vision), and wounded their uncle Miguel Vinculado Jr.
- Three (3) Informations for homicide and frustrated homicide were filed in RTC Malolos, Bulacan, against Honorato Galvez (Mayor) and co-accused Godofredo Diego.
- On 14 December 1993, charges were withdrawn and refiled upgrading the offenses to murder (Crim. Case No. 4004-M-93) and two counts of frustrated murder (Crim. Cases Nos. 4005-M-93 and 4006-M-93).
- A separate Information (Crim. Case No. 4007-M-94) charged Mayor Galvez with illegal carrying of firearm under PD 1866.
Procedural History
- Venue transferred to RTC Quezon City and raffled to Branch 103; later reassigned to Branch 89 under Judge Tirso D.C. Velasco.
- On 8 October 1996, the trial court convicted Diego for one murder and two frustrated murders, but acquitted Galvez on all charges for insufficiency of evidence and held that his firearm-carrying did not violate law.
- The People filed a Petition for Certiorari under Rule 65, seeking reversal of Galvez’s acquittal as grave abuse of discretion and lack of jurisdiction.
Issues
- Whether certiorari under Rule 65 is the proper remedy to challenge a trial court’s acquittal on the merits.
- Whether reviewing a judgment of acquittal on factual evidence violates the constitutional prohibition against double jeopardy.
Petitioner’s Arguments
- The acquittal was “patently gross judicial indiscretion,” ignoring crucial facts and evidence that would sustain conviction beyond reasonable doubt.
- U.S. Supreme Court precedents (Kepner, Wilson, Scott) allow review of acquittals without retrial, and Philippine doctrine should follow suit.
- Certiorari is proper because the trial court allegedly acted with grave abuse of discretion amounting to lack of jurisdiction.
Private Respondent’s Position
- The trial court thoroughly reviewed and evaluated all evidence (witness testimonies, wound trajectories, expert opinion) before