GR L 26734; (September, 1967) (Digest)
G.R. No. L-26734 September 5, 1967
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. PANFILO PADERNAL, defendant-appellee.
FACTS
Panfilo Padernal was charged with homicide for the stabbing death of Brigido Rodila. On January 26, 1961, during arraignment, Padernal initially pleaded guilty. His counsel then invoked mitigating circumstances, including incomplete self-defense. The trial court directed the presentation of evidence to prove these circumstances. Defense presented Policeman Nemesio Ouano, and the prosecution presented Felicidad Rodila, the victim’s sister. Padernal then testified, describing facts that indicated complete self-defense (e.g., the victim hacked him first, he wrested the bolo, and used it in defense). On January 27, 1961, the trial court, upon realizing the testimony invoked complete self-defense, ordered that a plea of not guilty be entered and set the case for trial on the merits on January 31, 1961. On that date, both the prosecution and defense submitted the case, adopting the testimonies from the previous hearing as evidence for the trial on the merits. The trial court then acquitted Padernal on the ground of reasonable doubt. The prosecution moved for reconsideration, arguing the guilty plea should have sustained a conviction, but the trial court denied it, invoking double jeopardy. The prosecution appealed.
ISSUE
Whether the principle of double jeopardy bars the prosecution’s appeal from the decision of acquittal.
RULING
Yes, the appeal is barred by double jeopardy. The Court distinguished this case from People v. Balisacan. Here, after the accused’s exculpatory testimony, the trial court properly ordered the withdrawal of the guilty plea, entered a plea of not guilty, and reset the case for trial on the merits, giving both parties sufficient opportunity to prepare. During the trial on the merits, both parties voluntarily chose to adopt the previously taken testimonies as their evidence, thereby constituting a full trial on the merits. Due process was observed, as both parties had full and adequate opportunity to prove their case. Consequently, the acquittal after such a trial on the merits cannot be reviewed on appeal, as all requisites for double jeopardy (a valid plea, due process, and trial on the merits) are present. The appeal is dismissed.