G.R. No. 176389 & G.R. No. 176864; January 18, 2011
Case Parties/Title:

ANTONIO LEJANO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent. ( G.R. No. 176389 )
PEOPLE OF THE PHILIPPINES, Appellee, vs. HUBERT JEFFREY P. WEBB, ANTONIO LEJANO, MICHAEL A. GATCHALIAN, HOSPICIO FERNANDEZ, MIGUEL RODRIGUEZ, PETER ESTRADA and GERARDO BIONG, Appellants. (G.R. No. 176864)

FACTS

On December 14, 2010, the Supreme Court reversed the judgment of the Court of Appeals and acquitted all accused (Hubert Jeffrey P. Webb, Antonio Lejano, Michael A. Gatchalian, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Gerardo Biong) of the charges against them on the ground of lack of proof of guilt beyond reasonable doubt. On December 28, 2010, private complainant Lauro G. Vizconde, an immediate relative of the victims, filed a motion for reconsideration. He claimed the Court’s decision denied the prosecution due process, seriously misappreciated facts, unreasonably regarded prosecution witness Jessica Alfaro as lacking credibility, was tainted and erroneous, resulted in a miscarriage of justice, and committed grave abuse in its treatment of evidence and witnesses. Motions for leave to intervene were also filed by Fr. Robert P. Reyes, Sister Mary John R. Mananzan, Bishop Evangelio L. Mercado, Dante L.A. Jimenez (representing the Volunteers Against Crime and Corruption), and former Vice President Teofisto Guingona, Jr.

ISSUE

Whether the Supreme Court can reconsider and set aside its judgment of acquittal dated December 14, 2010, based on the motion for reconsideration filed by the private complainant.

RULING

The Supreme Court DENIED the motion for reconsideration and the motions for leave to intervene.
A judgment of acquittal is final and cannot be reconsidered without placing the accused in double jeopardy, which is prohibited under Section 21, Article III of the Constitution . The policy against double jeopardy protects an accused from the State’s repeated attempts at conviction, which would subject them to embarrassment, expense, ordeal, anxiety, and insecurity.
Exceptions to this rule are narrow and exist only when the court that rendered the acquittal committed grave abuse of discretion resulting in a loss of jurisdiction, or when a mistrial has occurred. In such exceptional cases, the State may assail the decision via a special civil action for certiorari under Rule 65.
In this case, complainant Vizconde invoked these exceptions but failed to substantiate them. His claims were mere conclusions without specifying the alleged violations of due process or acts constituting grave abuse of discretion. He cited Galman v. Sandiganbayan as authority, but that case involved a proven sham trial where the judgment was “dictated, coerced and scripted,” depriving the prosecution of due process. No such allegation or proof exists here. Complainant essentially questioned the Court’s appreciation of evidence and assessment of witness credibility, particularly its finding that Jessica Alfaro was not credible. Allowing a review on these grounds would constitute a constitutionally prohibited repeated attempt to secure conviction.
The concurring opinion of Justice Sereno emphasized that the evidence tended to demonstrate Hubert Webb’s innocence and that Jessica Alfaro’s testimony was wholly rejected as not believable. It further explained that the trial court’s findings on credibility were not binding due to its inappropriate attribution of rights and duties, which affected its factual conclusions.
Therefore, the judgment of acquittal is final and can no longer be disturbed. No further pleadings shall be entertained.