G.R. No. 205275 , June 28, 2022
Mamerto Austria, Petitioner, vs. AAA and BBB, Respondents.

FACTS

In 2006, the Regional Trial Court convicted Mamerto Austria, a public school teacher, of five counts of acts of lasciviousness against two 11-year-old female students. Austria filed a motion for reconsideration. Subsequently, the original trial judge was promoted, and a new presiding judge was assigned to the case. On August 15, 2008, the new judge resolved the pending motion by issuing Joint Orders that acquitted Austria. The acquittal was based on a re-evaluation of the evidence, citing inconsistencies in the complainants’ testimonies, the defense’s alibi and documentary evidence, and the failure of the prosecution to present corroborating witnesses. The private complainants, through the Office of the Solicitor General, challenged these Joint Orders, arguing that the new judge gravely abused his discretion by effectively reviewing and overturning the factual findings and credibility assessments of the original judge who had heard the witnesses testify.

ISSUE

The core issue is whether the private offended parties have the legal personality to question, via certiorari, the Joint Orders of acquittal rendered by a judge who resolved a motion for reconsideration without having personally heard the witnesses during trial.

RULING

Yes, the private offended parties possess the requisite legal personality to file the petition for certiorari. The Supreme Court, sitting en banc, clarified and harmonized jurisprudence on the standing of private complainants in criminal cases. The Court ruled that while a judgment of acquittal is immediately final and unappealable, it may still be assailed through a petition for certiorari under Rule 65 if it is proven that the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction. In such a scenario, the private offended party retains an interest in the civil liability arising from the crime and has a stake in ensuring the correct application of criminal procedure. Therefore, they are considered real parties-in-interest who may file the certiorari petition, with the conformity of the Solicitor General representing the People. The Court emphasized that this remedy is exceptional and strictly confined to correcting jurisdictional errors, not for reviewing factual findings or the wisdom of the acquittal. In this specific case, the Court found that the new judge who issued the acquittal did not commit grave abuse of discretion, as the re-evaluation of evidence based on the cold records of the case was within his authority when resolving the motion for reconsideration. Consequently, while the private complainants had standing to file the petition, the substantive challenge to the acquittal failed on its merits.