GR 45419; (January, 1937) (Digest)
G.R. No. L-45419; January 19, 1937
MATEO SANTOS, MATEO SABALLA and EULOGIO HIPOLITO, petitioners, vs. THE PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioners were charged with forcible abduction. After trial, the Court of First Instance convicted them only of the lesser crime of illegal detention, having found the element of lewd designs unproven. Before this judgment became final, petitioners sought and were granted a new trial. After the new trial, the court convicted them of forcible abduction. On appeal, the Court of Appeals modified the conviction and found them guilty again only of illegal detention, imposing an indeterminate penalty. Petitioners filed this certiorari, arguing that being convicted of illegal detention after having been acquitted of it in the first instance (by the trial court’s initial judgment) violated their constitutional right against double jeopardy.
ISSUE
Whether the conviction for illegal detention after a new trial granted upon petitioners’ own motion constitutes double jeopardy.
RULING
No. The petition is without merit. The grant of a new trial sets aside the original judgment entirely, and the case reverts to its original status as if no trial had previously occurred. Both parties are placed back in their pre-trial positions and must present evidence anew for a final judgment. Therefore, a new trial does not acquit the accused of the crime in the initial judgment; it vacates that judgment. Consequently, petitioners were not placed in double jeopardy because the second trial was a continuation of the first prosecution, not a new one. This principle is supported by prior jurisprudence, including Trono vs. United States. The petition is dismissed.
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