G.R. No. 249681, August 31, 2022
ESTATE OF MURRAY PHILIP WILLIAMS, AS REPRESENTED BY DENIS MICHAEL STANLEY, PETITIONER, V. WILLIAM VICTOR PERCY, RESPONDENT.

FACTS

The case originated from a complaint for carnapping and estafa filed by Denis Michael Stanley, representing the estate of Murray Philip Williams, against respondent William Victor Percy. The complaint alleged that Williams, prior to his death, entrusted two vehicles to Percy for safekeeping, which Percy failed to return upon demand. The Office of the City Prosecutor of Olongapo recommended the filing of two counts of carnapping, leading to the filing of Informations and the commencement of trial before the Regional Trial Court (RTC). After the prosecution formally rested its case, Percy filed a Demurrer to Evidence.
The RTC granted the demurrer in an Order dated October 16, 2018, ruling that the prosecution failed to meet the quantum of proof required for conviction. Without securing the conformity of the Office of the Solicitor General (OSG), Stanley filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA), arguing the RTC committed grave abuse of discretion in granting the demurrer despite the prosecution having allegedly established all elements of the crime. The CA initially dismissed the petition for failure to serve a copy to Percy’s correct address but, upon reconsideration, noted Percy had voluntarily submitted to its jurisdiction by filing a Comment. The CA ultimately denied the petition, prompting the estate to elevate the matter to the Supreme Court.

ISSUE

Whether the Petition for Certiorari filed by the private complainant to challenge the RTC Order granting the demurrer to evidence and acquitting the accused violates the respondent’s constitutional right against double jeopardy.

RULING

Yes, the petition violates the constitutional right against double jeopardy. The Supreme Court, through the concurring opinion of Justice Caguioa, affirmed the ponencia’s denial of the petition. The legal logic rests on the strict application of double jeopardy principles. For double jeopardy to attach, the following requisites must concur: (1) a valid indictment before a competent court, (2) the accused has been arraigned and has pleaded, and (3) the case is terminated without the express consent of the accused, such as by an acquittal. All these requisites are present here. The RTC’s grant of the demurrer to evidence is a judgment on the merits equivalent to an acquittal.
The right against double jeopardy is fundamental and enshrined in the Constitution. A judgment of acquittal is final and unappealable the moment it is promulgated. The only narrow exception to this finality-of-acquittal rule is when the prosecution, representing the sovereign people, is denied due process—that is, denied its day in court. In this case, the prosecution was afforded full opportunity to present its evidence and formally offer it. The RTC’s evaluation of that evidence, even if allegedly erroneous, does not constitute a denial of due process to the State. Consequently, the acquittal was validly terminated, and any further challenge, including the certiorari petition filed by the private complainant without OSG conformity, constitutes a prohibited second jeopardy for the same offense. The petition’s solitary ground—challenging the RTC’s evaluation of the evidence—confirms it is an impermissible attempt to appeal an acquittal, which the Constitution expressly forbids.