Title
Supreme Court
Tiu vs. Court of Appeals
Case
G.R. No. 162370
Decision Date
Apr 21, 2009
Two consolidated criminal cases involving assault and grave threats; MeTC acquitted Postanes, RTC nullified acquittal, but CA and SC upheld double jeopardy, affirming finality of acquittal.

Case Summary (G.R. No. 170626)

Facts of the Case

The controversy arose from two consolidated criminal cases: Criminal Case No. 96-412 for slight physical injuries filed by Edgardo Postanes against Remigio Pasion, and Criminal Case No. 96-413 for grave threats filed by David Tiu against Edgardo Postanes. Both cases were filed with the MeTC, Pasay City. The incidents allegedly occurred on the same date and in the same place, leading to the consolidation and joint hearing of the cases.

Trial Proceedings and Evidence

During the consolidated trial, Postanes testified in his capacity both as a private complainant in the slight physical injuries case and as the accused in the grave threats case. He offered testimony and affidavits of eyewitnesses that were admitted as evidence. Despite filing a late formal offer of evidence in the grave threats case, the MeTC denied admission of this late submission and expunged it from the record.

Decision of the Metropolitan Trial Court

The MeTC dismissed both cases for insufficiency of evidence in its decision dated January 26, 1999, effectively acquitting Postanes in the grave threats case. The dismissal was affirmed by the MeTC upon motion for reconsideration.

Proceedings Before the Regional Trial Court

Petitioner Tiu filed a certiorari petition with the RTC challenging the acquittal in the grave threats case. The RTC annulled the MeTC’s judgment and remanded the case for reconsideration, reasoning that a certiorari petition was a proper remedy to challenge dismissal.

Petition for Certiorari Before the Court of Appeals

Postanes filed a petition for certiorari with the Court of Appeals to annul the RTC's decision. The Court of Appeals nullified the RTC’s decision on the ground that the State has no right to appeal an acquittal, which would violate the constitutional protection against double jeopardy. The appellate court reaffirmed the MeTC’s dismissal for insufficiency of evidence.

Petition Before the Supreme Court

Tiu filed a petition for review under Rule 45 assailing the Court of Appeals’ decision. The Supreme Court addressed two principal issues: whether the RTC's annulment of the MeTC's acquittal decision violated the constitutional right against double jeopardy, and whether Postanes committed forum shopping in filing a motion to suspend proceedings in the MeTC after the Court of Appeals denied a temporary restraining order.

Supreme Court’s Ruling on Legal Standing

The Supreme Court first held that the petition was defective because it was not filed by the Solicitor General. Under the Administrative Code of 1987 and established jurisprudence, only the Solicitor General may prosecute or appeal on behalf of the State before the Court of Appeals and the Supreme Court. Since Tiu was the private complainant and not the Solicitor General, he had no legal personality to bring this petition.

Elements and Application of Double Jeopardy

The Court emphasized the four elements of double jeopardy: a sufficient complaint or information, court jurisdiction, arraignment and plea by the accused, and dismissal or acquittal without the accused's consent. These were all present: the Information against Postanes was sufficient; the MeTC had jurisdiction; Postanes was arraigned and pleaded not guilty; and the MeTC dismissed the case for insufficiency of evidence, effectively acquitting him. The Court ruled that forcing the MeTC to reconsider its dismissal would subject Postanes to double jeopardy, thus violating the Constitution.

Due Process Considerations

The Court agreed with the Court of Appeals that the prosecution was not denied due process. There was no lack of jurisdiction by the MeTC, and the dismissal was based on an assessment of the evidence, not on procedural infirmities. Therefore, the constitutional bar against appealing an acquittal applied.

Assessment of Evidence and Application of Revised Rules on Summary Procedure

Tiu argued that because Postanes’ defense failed to submit a formal offer of evidence in the grave threats case, no evidence existed to justify acquittal, and that the MeTC erred in considering evidence formally offered in the slight physical injuries case to dismiss the grave threats case. The Court rejected this argument, noting that since the cases were properly consolidated and jointly tried, the MeTC was entitled to consider the evidence from both cases. This method aligned with the purpose of the Revised Rules on Summary Procedure to promote expeditious and inexpensive case resolution.

Testimonial Evidence and Admissibility

Although the affidavits were not formally offered in the grave threats case, the testimonies of Postanes and his witnesses were properly presented and admitted during the trial. This testimonial evidence was sufficient to support the dismissal for insufficiency of evidence. The Court found no grave abuse of discretion on the part of the MeTC in considering the evidence from both consolidated cases.

Final Disposition

The Supreme Court denied the petition, upheld the Court of Appeals’ annulment of the RTC decision, and affirmed the dismissal of Crimi

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