GR 140904; (October, 2000) (Digest)
G.R. No. 140904 ; October 9, 2000
RENE S. ONG, MAGDALENO B. ALBARRACIN, JR., PETRONIO C. AALIWIN and J. O. NERIT, petitioners, vs. PEOPLE OF THE PHILIPPINES and COURT OF APPEALS, respondents.
FACTS
Petitioners were charged with estafa under Article 318 of the Revised Penal Code before the Metropolitan Trial Court (MeTC) of Makati. The charge stemmed from the sale of a paper bag-making machine to Zeny Alfonso for P362,000.00. The machine, however, could not be delivered as it was previously mortgaged to a creditor who refused to release it. Petitioners offered to refund the payment, but Alfonso refused and filed a criminal complaint. After the prosecution rested its case, presenting only Alfonso as a witness and offering several documentary exhibits, petitioners filed a demurrer to evidence. They argued that the documents, being mere unauthenticated photocopies with unidentified signatures, were inadmissible. The MeTC denied the demurrer, finding a prima facie case based on these documents, which suggested the machine was mortgaged.
ISSUE
Whether the MeTC committed grave abuse of discretion in denying the demurrer to evidence despite the prosecution’s evidence being allegedly inadmissible and insufficient to prove guilt beyond reasonable doubt.
RULING
The Supreme Court granted the petition, reversing the Court of Appeals and affirming the Regional Trial Court’s dismissal of the criminal case. The legal logic centers on the propriety of a demurrer to evidence and the protection against double jeopardy. A demurrer challenges the sufficiency of the prosecution’s evidence. The Court found the MeTC’s denial of the demurrer constituted grave abuse of discretion because its prima facie finding relied on inadmissible evidence—uncertified photocopies lacking proper authentication, which have no probative value. Without these documents, the sole testimony of the complainant was insufficient to establish the elements of the crime charged. Consequently, the RTC’s grant of the demurrer was a valid acquittal. An appeal by the prosecution from such a dismissal places the accused in double jeopardy, which is prohibited. The State must be shielded from useless litigations, and an accused has the right to be spared from the anxiety of a trial when the evidence presented fails to prove guilt. The dismissal is without prejudice to any appropriate civil action.