People v. Cogasi
REITERATIONFacts
The Antecedents: On July 16, 2012, private respondents Sonny Rufino, Juliet Arcita, Jay Arcita, Carlos Ticawa, and Mencio Amiten were allegedly threatened by petitioners, who were then police officers. The prosecution alleges that the petitioners, identifying themselves as police officers from Station 10 and the National Bureau of Investigation, attempted to arrest Sonny Rufino for illegal drug activities without presenting identification or a warrant. When the private respondents blocked the arrest, the petitioners allegedly drew their firearms, fired shots in the air, and one of them uttered a threat in Igorot, translated as "Why, you want that blood will flow in this place?" The petitioners, conversely, claim they were conducting a legitimate buy-bust operation for illegal drugs against Sonny Rufino, and that the private respondents resisted the arrest, leading to a confrontation where warning shots were fired. The petitioners further assert that the private respondents retaliated by filing this case for grave threats after the petitioners filed charges for violation of Republic Act No. 9165 and direct assault against them. Procedural History: The Municipal Circuit Trial Court (MCTC) of Tuba-Sablan, Benguet, initially convicted the petitioners of grave threats on April 30, 2014, imposing a penalty of two months imprisonment and a fine. The MCTC found all elements of the crime present and gave more credence to the prosecution's version of events. The petitioners' motion for reconsideration was denied, leading them to appeal to the Regional Trial Court (RTC) of La Trinidad, Benguet, Branch 62. On August 11, 2017, the RTC dismissed the appeal, concurring with the MCTC's findings. However, in an Order dated March 12, 2018, the RTC reversed its earlier decision, setting aside the conviction and acquitting the petitioners. This reversal was based on the testimony of a prosecution witness who stated the firearms were not pointed at the private respondents and the threatening words were not uttered, which the RTC deemed fatal to the prosecution's case. The private respondents then filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. On February 28, 2019, the CA reversed the RTC's acquittal, reinstating the conviction. The CA found the RTC's reliance on the neighbor's testimony to be a mistake and gave more weight to the MCTC's credibility assessment. The CA denied the petitioners' motion for reconsideration on August 13, 2019. The Petition: Before the Supreme Court, the petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They argue that the CA violated their constitutional right against double jeopardy by reversing the RTC's judgment of acquittal. The petitioners contend that the acquittal had already attained finality and that the CA erred in taking cognizance of the certiorari petition filed by the private respondents. They assert that the RTC did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in acquitting them, and that the CA's reversal constituted a mere error of judgment, not an error of jurisdiction. The petitioners further claim that the private respondents' motion for reconsideration before the CA was filed without the conformity of the public prosecutor, which they argue invalidates the CA's proceedings. The private respondents, in their comment, countered that their private prosecutor had the authority to prosecute the case and that the RTC indeed committed grave abuse of discretion by disregarding crucial testimonies.
Issue(s)
Whether the Court of Appeals violated the petitioners' constitutional right against double jeopardy when it reversed the Regional Trial Court's judgment of acquittal for grave threats. Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in acquitting the petitioners.
Ruling
The petition is meritorious. The Decision dated February 28, 2019 and the Resolution dated August 13, 2019 of the Court of Appeals in CA-G.R. SP No. 157140, finding Dino Wally Cogasi, Jerry Silawon, Reynaldo Badua, Geoffrey Bantule, and Ramon Christopher Bueno guilty beyond reasonable doubt of the crime of grave threats are hereby declared NULL and VOID for violation of their constitutional right against double jeopardy.
Ratio Decidendi
On the issue of double jeopardy and the CA's reversal of acquittal: The Court reiterated the established rule that a judgment of acquittal is final, unappealable, and immediately executory upon its promulgation. This rule is absolute and admits only one exception: grave abuse of discretion that is strictly limited to situations where there is a violation of the prosecution's right to due process, such as being denied the opportunity to present evidence, or where the trial was a sham or a mistrial, rendering the judgment of acquittal void. The Court emphasized that an error of judgment, such as a misappreciation of evidence, does not constitute an error of jurisdiction that would allow a writ of certiorari to set aside an acquittal. In this case, the CA reviewed the evidence and reversed the acquittal based on its disagreement with the RTC's appreciation of evidence, which is a mere error of judgment. The petition for certiorari before the CA lacked allegations or evidence of a violation of the prosecution's due process rights or that the proceedings were a mockery. Therefore, the CA's reversal of the acquittal violated the petitioners' right against double jeopardy. On the alleged grave abuse of discretion by the RTC: The Court found that the CA erred in concluding that the RTC committed grave abuse of discretion. The RTC, in its Order dated March 12, 2018, meticulously reviewed the records and found that the testimony of an impartial witness, Ramon Bulakit, contradicted the prosecution's theory that the firearms were pointed at the private respondents and that the threatening words were uttered. The RTC's reliance on this testimony to acquit the petitioners was a valid exercise of its judicial discretion in weighing the evidence. The RTC's finding that the warning shots were reasonably necessary for the police officers to perform their duty of arresting Sonny Rufino, despite resistance, was also a reasonable conclusion based on the evidence presented. The CA's disagreement with the RTC's factual findings and appreciation of evidence did not rise to the level of grave abuse of discretion.
Main Doctrine
A judgment of acquittal, whether ordered by the trial or the appellate court, is final, unappealable, and immediately executory upon its promulgation, with the sole exception of grave abuse of discretion amounting to a violation of the prosecution's right to due process or a mistrial.