People v. Terrado
REITERATIONFacts
The Antecedents: The accused, Joseph Terrado, was charged with Carnapping under Republic Act No. 6538. The Information alleged that on August 8, 1997, the accused, armed with a fan knife, threatened the tricycle driver, Leoncio Dalmacio, with force and intimidation, and then took the tricycle with intent to gain. The tricycle was owned by Spouses Marilyn and Francisco Garcia. Procedural History: The case went through several procedural hurdles, including a motion to dismiss based on an affidavit of desistance by the private complainant, a motion to revive the case, motions for reconsideration, and a petition for certiorari before the Court of Appeals (CA) filed by the accused. The case was eventually re-raffled to Judge Salvador P. Vedaña. After trial, the RTC, in its Decision dated April 6, 2001, acquitted the accused of carnapping for failure to prove intent to take the tricycle and intent to gain. However, the RTC ordered the accused to pay civil damages. The prosecution filed a motion for reconsideration, which was denied. The Petition: The People of the Philippines and Spouses Marilyn and Francisco Garcia filed a Petition for Certiorari with the Supreme Court, assailing the RTC's decision of acquittal. They alleged that the RTC acted with grave abuse of discretion amounting to lack of jurisdiction by rendering the decision on dubious factual and legal bases, specifically claiming misapprehension of facts and that the trial court's conclusion was based on speculation, surmises, and conjectures.
Issue(s)
Whether the accused is guilty of violation of R.A. 6538 otherwise known as the "Anti-Carnapping Act of 1972"; Whether the public respondent acted with grave abuse of discretion amounting to lack of jurisdiction in rendering the questioned Decision.
Ruling
The Supreme Court dismissed the Petition for Certiorari. It held that a petition for certiorari under Rule 65 is limited to correcting errors of jurisdiction or grave abuse of discretion, not errors of judgment. The Court emphasized that verdicts of acquittal are absolutely final and irreviewable, and converting a petition for certiorari into an appeal would violate the constitutional right against double jeopardy.
Ratio Decidendi
On the Issue of Carnapping Violation: The Court noted that the petition primarily alleged misapprehension of facts and that the trial court's conclusions were based on speculation, surmises, and conjectures. The petitioners argued that the accused forcibly took the vehicle and that the trial court erred in acquitting him for failure to prove intent to gain. However, the Supreme Court reiterated that a review of facts and evidence is not the province of a certiorari proceeding under Rule 65. The Court found that the alleged mistakes were errors of judgment, not errors of jurisdiction, which are correctible by a petition for review on certiorari under Rule 45. Therefore, the Court could not delve into the factual findings of the trial court. Furthermore, verdicts of acquittal are absolutely final and irreviewable to afford the accused final repose and protect them from government oppression. Allowing a certiorari petition to review an acquittal, when it merely calls for an ordinary review of findings, would convert the petition into an appeal, which is proscribed by the Constitution, the Rules of Court, and jurisprudence on double jeopardy. The fundamental philosophy behind this principle is to safeguard the acquitted individual from repeated attempts at conviction through the abuse of criminal processes. Therefore, the accused, having been acquitted, must be afforded protection against repeated attempts for conviction in faithful adherence to the constitutional rule against double jeopardy. On the Issue of Grave Abuse of Discretion: The Court explained that grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. It must be so patent and gross as to amount to an evasion of a positive duty. The Court found that the petitioners' imputation of grave abuse of discretion was premised on the assertion that the trial court reached its conclusions based on speculation, surmises, and conjectures, which essentially questions the correctness of the judgment, not the jurisdiction of the court. The Court stressed that even if the trial court committed a mistake in its judgment, such an error does not vitiate the decision if the court had jurisdiction over the case. The remedy for errors of judgment is an appeal, not a special civil action for certiorari.
Main Doctrine
A petition for certiorari under Rule 65 assailing an acquittal in a criminal case will be dismissed if it merely raises errors of judgment and not errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. Such a petition, if granted, would violate the constitutional right against double jeopardy.