People v. Uy
REITERATIONFacts
The Antecedents: On March 23, 2001, Rabel Campos was found dead with stab wounds. Teofilo Panangin was arrested on January 22, 2002, and subsequently executed a sworn statement-extrajudicial confession with the assistance of counsel. In his confession, Panangin implicated Louel Uy, stating that Uy instructed him to stab the victim and then Uy himself repeatedly stabbed the victim until she died. Procedural History: Following Panangin's confession, a murder case was filed against Panangin and Uy. After preliminary investigation, an Information for murder was filed. Both accused pleaded not guilty. The prosecution presented evidence, including Panangin's sworn statement. Subsequently, both accused filed separate demurrers to evidence. The Regional Trial Court granted the demurrers, acquitting both accused for insufficiency of evidence but ordering them to jointly and severally pay P35,000.00 for vigil and burial expenses. The trial court ruled that Panangin's confession was involuntary and inadmissible as a "fruit of a poisonous tree" due to alleged illegal arrest. The Petition: The People of the Philippines and Vilma Campos (mother of the victim) filed a petition for certiorari under Rule 65 of the Revised Rules of Court, assailing the trial court's decision. They argued that the trial court committed grave abuse of discretion in granting the demurrer to evidence, contending that Panangin's confession was voluntary and admissible, and that the issue of admissibility was rendered moot by its admission into evidence. They also argued that the trial court's ruling deprived the prosecution of due process.
Issue(s)
Whether or not the extra-judicial confession executed by accused Teofilo Panangin is admissible in evidence. Whether or not the prosecution was able to prove the guilt of the accused beyond reasonable doubt, considering the admissibility of the extra-judicial confession. Whether or not the Acting Judge committed grave abuse of discretion amounting to lack of jurisdiction when he granted the demurrer to evidence on the ground that the extra-judicial confession was inadmissible after admitting it as part of the prosecution's evidence-in-chief.
Ruling
The petition is GRANTED. The April 7, 2003 decision of the Regional Trial Court of Misamis Oriental, Branch 44, is SET ASIDE, and the case is REMANDED to said court for further proceedings. The acquittal was deemed void due to grave abuse of discretion and denial of due process, thus preventing double jeopardy from attaching.
Ratio Decidendi
On Issue 1: The Court found that the trial court committed grave abuse of discretion in holding Panangin's extra-judicial confession inadmissible. The trial court relied on an affidavit of retraction executed by Panangin over five months after his confession and without him being presented to identify and affirm it, rendering it hearsay. The Court reiterated that a confession is presumed voluntary until proven otherwise, and the burden of proof lies with the declarant, which Panangin failed to discharge. Furthermore, the testimony of Atty. Sarsaba, who assisted Panangin, indicated that Panangin was apprised of his constitutional rights and voluntarily proceeded with giving his statement, which was translated into the Visayan dialect. The claim that the confession was a "fruit of a poisonous tree" due to illegal arrest was also dismissed, as this doctrine primarily applies to object evidence obtained from illegal searches and seizures, not testimonial evidence. On Issue 2: The Court did not directly rule on whether the prosecution proved guilt beyond reasonable doubt, as the case was remanded for further proceedings. However, by setting aside the acquittal and remanding the case, the Supreme Court implicitly found that the trial court's premature dismissal based on the inadmissibility of the confession was erroneous and prevented a proper determination of guilt. The Court emphasized that the State, like the accused, is entitled to due process, and the prosecution should have been given the opportunity to present its case fully without the trial court prematurely declaring evidence inadmissible without proper procedure. On Issue 3: The Court held that the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction. By granting the demurrer to evidence based on the alleged inadmissibility of the extrajudicial confession, which was admitted as part of the prosecution's evidence-in-chief, the trial court effectively denied the prosecution due process. The Court stressed that the State's right to due process is a serious jurisdictional issue that cannot be disregarded. The precipitate action of the trial court in acquitting the accused based on a flawed assessment of evidence and procedure was deemed a "lawless thing" that could be ignored, thus allowing the case to be remanded without violating the prohibition against double jeopardy.
Main Doctrine
A judgment of acquittal, even if based on a demurrer to evidence, is generally final and unappealable due to the prohibition against double jeopardy. However, this rule is not absolute and may be assailed via a petition for certiorari under Rule 65 if the lower court, in acquitting the accused, committed grave abuse of discretion amounting to lack or excess of jurisdiction or a denial of due process. The State is also entitled to due process, and the admissibility of an extrajudicial confession must be determined following established rules, with the burden of proving involuntariness resting on the declarant.