GR 168188; (June, 2006) (Digest)
G.R. No. 168188 , June 16, 2006
PEOPLE OF THE PHILIPPINES, Petitioner, vs. SANDIGANBAYAN (FIRST DIVISION), DOMINADOR T. BELAC, NOE V. DANNANG, JUAN M. BOGUEN and THOMAS B. TUBBAN, JR., Respondents.
FACTS
Provincial Governor Dominador T. Belac and other provincial officials of Kalinga were charged with Falsification of Public Document (Criminal Case No. 25391), Technical Malversation (Criminal Case No. 25392), and violation of Section 3(e) of R.A. 3019 (Criminal Case No. 25393). The charges stemmed from the 1998 purchase of a Nissan Safari vehicle. The prosecution alleged that the accused falsified an Advice of Allotment by wrongfully referencing Appropriation Ordinance No. 97-04, which pertained to salaries and not vehicle procurement, and subsequently diverted public funds for this unauthorized purchase.
During pre-trial, the parties stipulated that the purchase was procedurally regular and the vehicle was registered to the province. The core issue was narrowed down to whether the funds used were authorized by the Sangguniang Panlalawigan. The Sandiganbayan, after trial, acquitted all accused in the three cases. The prosecution filed a petition for review, arguing the acquittal was based on a misapprehension of facts.
ISSUE
Whether the acquittal of the respondents by the Sandiganbayan can be reviewed and reversed by the Supreme Court.
RULING
No. The petition is dismissed. The Supreme Court affirmed the Sandiganbayan’s acquittal, ruling that a judgment of acquittal is final and unappealable. This is a fundamental constitutional principle rooted in the right against double jeopardy. The Court emphasized that the rule against double jeopardy prohibits a second prosecution for the same offense after an acquittal or conviction, and protects against multiple punishments for the same act.
The legal logic is clear: an acquittal terminates the case with finality. The prosecution cannot appeal such a judgment, as doing so would place the accused in jeopardy for a second time. The Court held that the only exception to this rule is when the acquittal is rendered with grave abuse of discretion, which was not present in this case. The Sandiganbayan’s evaluation of the evidence, including the stipulations that narrowed the factual issue, fell within its discretion. Since the acquittal was based on its finding that the prosecution failed to prove guilt beyond reasonable doubt, the decision is immutable. To allow a review would violate the respondents’ constitutional right against double jeopardy.