GR 41859; (March, 1989) (Digest)
G.R. No. 41859 March 8, 1989
CENTRAL BANK OF THE PHILIPPINES and THE PEOPLE OF THE PHILIPPINES, petitioners, vs. THE COURT OF APPEALS, FELIPE PLAZA CHUA and MELCHOR AVILA CHUA, respondents.
FACTS
Private respondents Felipe Plaza Chua and Melchor Avila Chua were the President and Treasurer, respectively, of the Surigao Development Bank. Following a Central Bank examination in 1961 which revealed a substantial shortage in the bank’s funds, the Monetary Board issued resolutions directing the private respondents to refund the amount and imposing sanctions, including their permanent separation from the bank. The Central Bank subsequently initiated legal action, and an information for estafa was filed against the Chuas in 1968, alleging they withdrew funds from the bank’s depository but failed to account for them.
The trial court convicted the private respondents of estafa. On appeal, the Court of Appeals reversed the conviction and acquitted them. The appellate court found that the prosecution failed to prove the elements of estafa, particularly the existence of a trust or agency relationship and the intent to defraud, noting that the withdrawals appeared to be for legitimate bank operations and that the funds were deposited in the bank’s own account. The People, through the Solicitor General, and the Central Bank then filed this petition for certiorari under Rule 65, seeking to annul the Court of Appeals’ decision of acquittal.
ISSUE
Whether a petition for certiorari under Rule 65 is a proper remedy to challenge a judgment of acquittal rendered by the Court of Appeals.
RULING
No. The Supreme Court dismissed the petition. The Court held that a judgment of acquittal is final and unappealable. The constitutional right of the accused against double jeopardy bars any appeal by the prosecution from an acquittal, as it would place the accused in a second jeopardy for the same offense. The petitioners’ argument that the acquittal was rendered with grave abuse of discretion, and was therefore void, was rejected. The Court distinguished between errors of judgment and errors of jurisdiction. Any error committed by the Court of Appeals in evaluating the evidence or interpreting the law, even if flagrant, constitutes merely an error of judgment. Such an error does not affect the court’s jurisdiction and does not render its decision a nullity open to collateral attack via certiorari. A writ of certiorari under Rule 65 is only available to correct errors of jurisdiction, not errors in the court’s findings or conclusions. Since the Court of Appeals had jurisdiction over the appeal and to render the judgment of acquittal, its decision, whether right or wrong on the merits, is final and places the accused in jeopardy. Therefore, the remedy of certiorari is not available to nullify an acquittal.