G.R. No. 124140 . November 25, 1999
BERNARDO B. RESOSO, petitioner, vs. SANDIGANBAYAN, respondent.

FACTS

Petitioner Bernardo B. Resoso, then Executive Officer of the National Meat Inspection Commission (NMIC), was charged before the Sandiganbayan with seven counts of falsification of public documents under Article 171(6) of the Revised Penal Code. The informations alleged that he made unauthorized alterations in Veterinary Quarantine Clearances to Import, specifically changing the quality, quantity, and country of origin of the meat products authorized for importation, thereby causing damage to public interest. After the prosecution rested its case, Resoso filed a Demurrer to Evidence, arguing that the prosecution failed to prove his guilt beyond reasonable doubt. He asserted the defense of good faith, claiming the alterations were authorized by the then Undersecretary of Agriculture and were in accordance with prevailing NMIC practice.
The Sandiganbayan denied the demurrer in a Resolution dated February 2, 1996, holding that the issue of good faith was not yet apparent from the prosecution’s evidence. The court emphasized that the case involved alterations that authorized acts not originally permitted, touching on the integrity of public documents. Resoso’s Motion for Reconsideration was likewise denied. The Sandiganbayan, in its March 5, 1996 Resolution, noted that while former Secretary of Agriculture Senen Bacani explained how changes could procedurally be made, he categorically denied authorizing the specific alterations in question.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner’s Demurrer to Evidence.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the Sandiganbayan. The Court clarified that a petition for certiorari under Rule 65 is not the proper remedy to challenge the denial of a demurrer to evidence, as such a denial is an interlocutory order. The correct course of action for an accused is to proceed with the trial and, if convicted, to elevate the matter via appeal. Certiorari is not intended to correct errors of judgment or to review the trial court’s evaluation of the evidence’s sufficiency. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, which was not present here.
The Sandiganbayan, in exercising its jurisdiction, determined that the prosecution’s evidence—including testimonies from officials who denied authorizing the alterations—was sufficient to warrant the continuation of the trial. The factual finding that good faith was not yet established from the prosecution’s case was within the Sandiganbayan’s discretion. The Supreme Court, noting that factual findings of the Sandiganbayan are generally conclusive, found no exception to warrant its intervention, such as a conclusion based on speculation or a grave misapprehension of facts. The petition, being an improper remedy, was dismissed for lack of merit.