GR 109920; (August, 2000) (Digest)
G.R. No. 109920 ; August 31, 2000
CEFERINO A. SORIANO, petitioner, vs. HON. ADORACION C. ANGELES, in her capacity as Presiding Judge of the Caloocan City, Regional Trial Court, Branch CXXI, and RUEL GARCIA, respondents.
FACTS
Petitioner Ceferino Soriano, a barangay captain, filed a criminal case for direct assault against private respondent Ruel Garcia, a policeman. The prosecution alleged that Garcia, with his uncle, barged into the barangay hall, punched Soriano four times while pointing a gun at him, and cursed him. Four barangay tanods present allegedly could not assist as they were held at bay. Garcia denied the assault, claiming he went to inquire about his arrested brother. He testified that Soriano blocked and pushed him, causing Soriano to fall on nightsticks and injure himself during a mutual shoving incident.
The trial court acquitted Garcia. The judge found the prosecution’s version incredible, noting Soriano’s lack of resistance and the minor nature of his injuries. She also excluded the testimonies of Soriano and a tanod for the prosecution’s alleged failure to formally offer them as evidence. Soriano filed this petition for certiorari, alleging the decision was void due to the judge’s bias. He cited instances where the judge urged settlement before arraignment and trial, and her exclusion of evidence which he claims was improperly done.
ISSUE
Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in acquitting private respondent Ruel Garcia, thereby warranting the issuance of a writ of certiorari to annul the decision.
RULING
The Supreme Court dismissed the petition. Certiorari under Rule 65 is not a remedy for correcting errors of judgment but for rectifying errors of jurisdiction. The court emphasized that an erroneous evaluation of evidence does not equate to a lack of jurisdiction. The trial court’s assessment of the witnesses’ credibility and the weight of the evidence is beyond the scope of certiorari review, absent a clear showing of arbitrariness or a despotic exercise of power.
The Court found no grave abuse of discretion. The trial judge’s actions, such as encouraging a settlement between public officers, did not prove bias or prejudgment. Furthermore, the petitioner’s failure to file a motion for the judge’s inhibition at the trial stage weakened his claim of partiality. The petition essentially sought a re-evaluation of the factual findings, which is not permissible in a certiorari proceeding. The acquittal, having attained finality, places the private respondent under the protection of the constitutional right against double jeopardy.