G.R. Nos. 228494-96. March 21, 2018.
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. HONORABLE SANDIGANBAYAN (FOURTH DIVISION) AND CAMILO LOYOLA SABIO, RESPONDENTS.

FACTS

Camilo Loyola Sabio, then Chairman of the Presidential Commission on Good Government (PCGG), was charged before the Sandiganbayan with one count of violating Section 3(e) of R.A. No. 3019 (Anti-Graft) and two counts of Malversation of Public Funds under Article 217 of the Revised Penal Code. The charges stemmed from two sets of alleged misappropriations. The first set involved the aggregate amount of ₱10,350,000.00, received by Sabio as cash advances from remittances of the Mid-Pasig Land Development Corporation, which were proceeds from the sale of sequestered shares. These funds were allegedly supposed to be remitted to the Bureau of Treasury as part of the CARP Fund but were instead converted for his personal use. The second set involved ₱1,555,862.03 in cash advances for litigation expenses and a trip to Kuala Lumpur, Malaysia, which were similarly alleged to have been misappropriated.
After trial, the Sandiganbayan acquitted Sabio of all charges. The anti-graft court found that the prosecution failed to prove his guilt beyond reasonable doubt. Specifically, it ruled that the funds in question were not public funds but were privately owned, being part of the ill-gotten wealth still under litigation, and thus could not be the subject of malversation. For the graft charge, the court found no evidence of evident bad faith or undue injury, noting that the disbursements were supported by vouchers and appeared to be for official purposes. The prosecution filed a petition for certiorari under Rule 65, alleging the Sandiganbayan committed grave abuse of discretion in acquitting Sabio.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in acquitting respondent Camilo Loyola Sabio.

RULING

The Supreme Court DISMISSED the petition and AFFIRMED the Sandiganbayan’s acquittal of Sabio. The Court held that the petition, filed under Rule 65, constituted an improper remedy. A writ of certiorari is only available to correct errors of jurisdiction, not errors of judgment. An acquittal rendered by a court with jurisdiction, even if based on a misappreciation of evidence, is final and immediately executory. It cannot be reviewed without placing the accused in double jeopardy. The prosecution’s remedy from an erroneous judgment of acquittal is not appeal or certiorari but a petition for the extraordinary remedy of the continuance of the trial under the grounds provided in Rule 119 of the Rules of Court, which was not availed of here.
The Court found no grave abuse of discretion. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The Sandiganbayan’s decision was based on its evaluation of the evidence, concluding the prosecution failed to meet the burden of proof. Its finding that the funds were not public money but private sequestered assets, and its determination on the lack of bad faith, were within its adjudicative power. The mere fact that the prosecution disagreed with the factual conclusions and legal interpretations of the Sandiganbayan did not equate to a jurisdictional error. The Sandiganbayan acted within its lawful jurisdiction, and its judgment, being one of acquittal, is beyond review.