G.R. No. 140633 ; February 4, 2002
PEOPLE OF THE PHILIPPINES, petitioner, vs. THE SANDIGANBAYAN (Fourth Division) and GERONIMO Z. VELASCO, respondents.

FACTS

The Presidential Commission on Good Government (PCGG) filed an Information before the Sandiganbayan charging Geronimo Z. Velasco, then Minister of Energy and Chairman/President of the Philippine National Oil Company (PNOC), with violation of Section 3(e) of R.A. 3019. The accusation alleged that from 1977 to 1986, Velasco, in evident bad faith and through shameless abuse of his official functions, caused the use of PNOC funds, equipment, and personnel worth ₱3,032,993.00 for the construction and maintenance of his privately-owned Telin Beach Resort in Bataan, thereby giving himself unwarranted benefits and causing undue injury to the government corporation.
After pleading not guilty and after the prosecution rested its case, Velasco filed a Demurrer to Evidence on the ground of insufficiency of evidence. The Sandiganbayan initially denied the demurrer but, upon Velasco’s Motion for Reconsideration, issued the assailed Resolution dated October 11, 1999, granting the demurrer and dismissing the criminal case. The People, through the Office of the Ombudsman, filed the instant petition for certiorari, contending that the Sandiganbayan committed grave abuse of discretion in dismissing the case and that the Resolution was void for failing to state a summary of the facts proved by the prosecution, in violation of constitutional and statutory requirements.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting the Demurrer to Evidence and dismissing the criminal case against respondent Velasco.

RULING

The Supreme Court dismissed the petition, ruling that the Sandiganbayan did not commit grave abuse of discretion. The grant of a demurrer to evidence is within the trial court’s sound discretion, and its ruling will not be disturbed absent a grave abuse thereof. Critically, an order granting a demurrer to evidence amounts to an acquittal, and any further prosecution would violate the constitutional prohibition against double jeopardy. This rule is fundamental and seeks to protect the accused from the state’s immense resources and power to make repeated attempts at conviction.
The Court emphasized that the only exception to this finality-of-acquittal rule is when the trial court acted with grave abuse of discretion amounting to a denial of due process, such as where the prosecution was not afforded an opportunity to present its evidence, or where the trial was a sham. In this case, the prosecution fully presented its evidence and rested its case before the demurrer was filed; thus, there was no denial of due process. The petitioner’s ancillary argument that the Sandiganbayan’s Resolution was void for lacking a factual basis was also unavailing. The Court examined the Resolution and found it contained a sufficient discussion and evaluation of the prosecution’s evidence, concluding it was inadequate to prove guilt beyond reasonable doubt. No blatant abuse of authority was demonstrated to warrant the extraordinary remedy of certiorari to nullify an acquittal.