G.R. No. 236686, February 5, 2020
Yokohama Tire Philippines, Inc., Petitioner, v. Sandra Reyes and Jocelyn Reyes, Respondents.

FACTS

Petitioner Yokohama Tire Philippines, Inc. filed a complaint for qualified theft against its former employees, respondents Sandra Reyes and Jocelyn Reyes, for allegedly taking ink cartridges from the company’s stock room. After preliminary investigation, an Information for attempted theft was filed before the Municipal Trial Court (MTC). After trial, the MTC acquitted the accused-respondents. Yokohama filed a petition for certiorari with the Regional Trial Court (RTC), arguing the MTC committed grave abuse of discretion by acquitting the accused on the basis that the ink cartridges were inadmissible evidence, having been obtained in violation of the right against unreasonable searches and seizures. The RTC dismissed the petition. Yokohama then elevated the case directly to the Supreme Court, contending the MTC gravely abused its discretion in applying the constitutional exclusionary rule, which it argued applies only to State agents, not private parties.

ISSUE

Whether the Supreme Court should grant Yokohama’s petition and reverse the acquittal of the accused-respondents.

RULING

The Supreme Court, through the ponencia, denied the petition. The concurring opinion of Justice Caguioa agrees with the denial but provides a distinct legal framework. The ponencia held that the petition was filed without the conformity of the Office of the Solicitor General and that the RTC correctly found no grave abuse of discretion by the MTC. It reasoned that any mistake by the MTC was an error of judgment, not jurisdiction, and that even if the evidence were admitted, the prosecution failed to prove the essential element of taking, as it did not present key witnesses or the alleged video recording. Justice Caguioa’s concurrence emphasizes that the right against double jeopardy bars any review or appeal of the acquittal. He traces this right from its incorporation into Philippine law via the Philippine Bill of 1902 and the Kepner doctrine, underscoring the finality-of-acquittal rule. This rule is absolute unless the prosecution was denied due process or a fair opportunity to be heard, which was not the case here. The acquittal, even if potentially erroneous, is final and places the accused-respondents in jeopardy, precluding any further appeal.