G.R. No. 148226 ; July 14, 2008
PEOPLE OF THE PHILIPPINES and SPOUSES MARILYN and FRANCISCO GARCIA, Petitioners, vs. JOSEPH TERRADO, and HONORABLE SALVADOR P. VEDAÑA, Presiding Judge, Regional Trial Court, Branch 68, Lingayen, Pangasinan, Respondents.

FACTS

Accused Joseph Terrado was charged with Carnapping under Republic Act No. 6538 . The prosecution alleged that on August 8, 1997, Terrado, armed with a fan knife, forcibly took a tricycle from its driver, Leoncio Dalmacio. The case underwent procedural complexities, including a motion to dismiss based on an affidavit of desistance from the private complainant, which was later revived. After trial, the Regional Trial Court (RTC) acquitted Terrado in its Decision dated April 6, 2001. The trial court found that the prosecution failed to prove the essential elements of the crime, particularly the accused’s intent to gain and intent to take the motor vehicle. The court gave credence to the defense’s version that the tricycle was merely borrowed, noting that it was returned, albeit damaged, on the same night, and that the accused had made partial payment for repairs.
Aggrieved by the acquittal, the People of the Philippines and the private complainants filed a Petition for Certiorari directly with the Supreme Court. They assailed the RTC’s decision, arguing that it was rendered with grave abuse of discretion amounting to lack or excess of jurisdiction. The petitioners contended that the trial court ignored the evidence presented by the prosecution and misappreciated the facts of the case.

ISSUE

Whether the acquittal of the accused by the trial court can be reviewed and reversed through a petition for certiorari.

RULING

The Supreme Court DISMISSED the petition. The Court held that a petition for certiorari is not the proper remedy to challenge a judgment of acquittal. The constitutional right of the accused against double jeopardy is immediately invoked upon such an acquittal. For an acquittal to be reviewed, the petitioner must clearly demonstrate that the trial court committed grave abuse of discretion by acting in a capricious, whimsical, or despotic manner equivalent to a denial of due process, or where the prosecution was deprived of a fair opportunity to present its case. Mere errors of judgment or evaluation of evidence do not constitute grave abuse of discretion.
In this case, the Court found that the trial court’s decision was based on its evaluation of the evidence and the credibility of witnesses. The conclusion that the prosecution failed to prove guilt beyond reasonable doubt was a judgment call within the court’s discretion. The petitioners’ arguments essentially questioned the trial court’s factual findings and the weight given to the evidence, which is not permissible in a certiorari proceeding attacking an acquittal. To grant the petition would be to convert it into a prohibited appeal, violating the finality of an acquittal and the constitutional protection against double jeopardy. Verdicts of acquittal are final and irreviewable to afford the accused repose and safeguard against governmental oppression.