Resoso v. Sandiganbayan
REITERATIONFacts
The Antecedents: Seven informations for falsification of public document under Article 171, paragraph 6 of the Revised Penal Code were filed against petitioner Bernardo B. Resoso, then Executive Officer of the National Meat Inspection Commission (NMIC). The charge alleged that he made alterations in Veterinary Quarantine Clearances to Import, changing the quality, quantity, and country of origin of imported items, thereby making the documents speak falsely to the prejudice of public interest. Procedural History: Petitioner pleaded not guilty. The prosecution presented four witnesses and offered exhibits, which were admitted. Petitioner filed a Demurrer to Evidence, arguing that the prosecution failed to establish his guilt beyond reasonable doubt. The Sandiganbayan denied the demurrer, stating that good faith was not yet apparent and that the alterations authorized acts not previously authorized, changing the meaning of the documents. Petitioner's Motion for Reconsideration was also denied. The Petition: Petitioner filed a petition for certiorari, prohibition, and mandamus, seeking to set aside the Sandiganbayan's resolutions denying his Demurrer to Evidence and Motion for Reconsideration. He argued that the prosecution's evidence clearly showed his good faith, as the alterations were authorized by then Undersecretary Conrado Gozon and made in accordance with prevailing practice. He contended that the prosecution failed to establish his guilt beyond reasonable doubt.
Issue(s)
Whether the Sandiganbayan committed grave abuse of discretion amounting to lack of jurisdiction in denying petitioner's Demurrer to Evidence. Whether the prosecution's evidence sufficiently established petitioner's guilt beyond reasonable doubt at the time the demurrer was filed.
Ruling
The petition is dismissed for lack of merit. The Sandiganbayan did not commit grave abuse of discretion in denying the demurrer to evidence. The assessment of the sufficiency of evidence at this stage is within the Sandiganbayan's jurisdiction, and a petition for certiorari is not the proper remedy to correct alleged errors of judgment in such assessment.
Ratio Decidendi
On the propriety of certiorari and the denial of the Demurrer to Evidence: The Supreme Court held that a petition for certiorari, prohibition, and mandamus is not available to correct mistakes in a judge's findings and conclusions or to cure erroneous conclusions of law and fact. The petitioner's claim that the Sandiganbayan erred in assessing the evidence presented by the prosecution is a matter of judgment, not grave abuse of discretion. The proper remedy for an adverse interlocutory order, such as the denial of a demurrer to evidence, is to continue with the case and, if an unfavorable verdict is rendered, to take an appeal. The Court reiterated that factual findings of the Sandiganbayan are conclusive unless exceptions like speculation, manifestly mistaken inferences, grave abuse of discretion, or misapprehension of facts are present. In this case, there was no showing that the Sandiganbayan's conclusions were manifestly mistaken or based on speculation. The denial of the demurrer was made in the due exercise of its jurisdiction. On the sufficiency of evidence and good faith: The Court found no merit in the petitioner's argument that his good faith was clearly established by the prosecution's evidence. The Sandiganbayan's assessment that good faith was not yet apparent and that the alterations authorized acts not previously authorized was a valid exercise of its discretion at the demurrer stage. The testimonies cited by the petitioner regarding authorization from Undersecretary Gozon and prevailing practices were subject to conflicting interpretations and were not definitively established as authorizing the specific alterations made. The Sandiganbayan correctly noted that Secretary Bacani denied authorizing the alterations, and the alleged authority from Undersecretary Gozon was unwritten. Therefore, it was premature to conclude good faith and acquit the petitioner at that stage.
Main Doctrine
A petition for certiorari is not the proper remedy to correct alleged errors in the assessment of evidence by the Sandiganbayan when denying a demurrer to evidence; such remedy lies in an appeal after a judgment on the merits. Grave abuse of discretion must be shown, not merely an error of judgment.