People vs. Sandiganbayan

An acquittal rendered after a full trial on the merits is immediately final and cannot be reviewed via certiorari on double jeopardy grounds, the only exception being where there was a mistrial resulting in denial of due process; errors in the appreciation of evidence are errors of judgment, not errors of jurisdiction, and are not correctible by the extraordinary writ of certiorari.

Private respondents Abelardo P. Panlaqui, Renato B. Velasco, Angelito Pelayo, and Wilfredo Cunanan were public officials and a private contractor connected to the Municipality of Sasmuan, Pampanga. Panlaqui served as Municipal Mayor, Velasco as Municipal Planning and Development Coordinator, Pelayo as Municipal Treasurer, and Cunanan as representative of J.S. Lim Construction. They were charged under Section 3(e) of R.A. No. 3019, the Anti-Graft and Corrupt Practices Act, for allegedly causing undue injury to the government and granting unwarranted benefits to J.S. Lim Construction through a lease of equipment contract for dredging work on the Palto and Pakulayo Rivers. The case was filed before the Sandiganbayan, which has jurisdiction over public officials of the rank and category involved.

On September 1, 1991, or thereabouts, Municipal Mayor Abelardo P. Panlaqui of Sasmuan, Pampanga, without authorization from the Sangguniang Bayan, entered into a Contract of Lease of Equipment with J.S. Lim Construction, represented by Wilfredo Cunanan. The contract involved the lease of seven units of Crane on Barge with Clamshell and one unit of Back Hoe on Barge for an unstipulated consideration, for a period of thirty days, ostensibly for the deepening and dredging of the Palto and Pakulayo Rivers in Sasmuan. Renato B. Velasco, the Municipal Planning and Development Coordinator, and Angelito Pelayo, the Municipal Treasurer, were likewise impleaded as accused, together with Barangay Captain Victorino Maninang of Malusac, Sasmuan.

Thereafter, the accused allegedly caused it to appear that work on the project had been accomplished and 100% completed per the approved Program of Work and Specifications, and that the project had been turned over to Barangay Malusac. Based on the Accomplishment Report and Certificate of Project Completion and Turn-Over, payments of ₱511,612.20 and ₱616,314.60 were made to and received by Cunanan, totaling ₱1,127,926.80. The prosecution contended that no work had actually been done, pointing out that J.S. Lim Construction had no barge or any vessel registered with the First Coast Guard District and that no business license or permit had been granted to the company by the Municipal Treasurer's Office of Guagua, Pampanga.

An Information dated February 24, 1994 was filed before the Sandiganbayan charging the accused with violation of Section 3(e) of R.A. No. 3019 for causing undue injury to the government and granting unwarranted benefits to J.S. Lim Construction. The accused were arraigned on April 10, 1996 and pleaded not guilty. Trial on the merits followed, with both prosecution and defense presenting numerous witnesses and documentary exhibits.

On May 19, 2006, the Sandiganbayan acquitted all the accused, finding that the prosecution failed to prove guilt beyond reasonable doubt. The trial court concluded that dredging work was in fact performed along the Palto and Pakulayo Rivers and that the project was actually undertaken and accomplished by the contractor, justifying the payment made. The Sandiganbayan found that the prosecution had not established all the elements of the offense charged. The cash bonds posted by the accused were ordered returned, the Hold Departure Order lifted, and no civil liability was pronounced as the facts from which it might arise were not proven.

• Grave Abuse of Discretion — Disregard of P.D. No. 1594: Petitioner argued that the Sandiganbayan disregarded the mandatory provisions of Presidential Decree No. 1594, which require approved plans and specifications before bidding for construction contracts can proceed, and that the trial court supplied a defense not invoked by respondents and anchored its decision on possibilities, assumptions, or conjecture rather than on facts established by evidence on record, thereby violating the prosecution's fundamental right to due process.
• Grave Abuse of Discretion — Ignoring Prosecution Evidence: Petitioner argued that the Sandiganbayan ignored the evidence adduced by the prosecution and erroneously declared that the prosecution failed to present any evidence proving that respondents violated Section 3(e) of R.A. No. 3019. Petitioner pointed out that as of September 2 to October 2, 1991, when the dredging works were supposedly conducted, there was as yet no approved plan and specifications as required by P.D. No. 1594, the required plan being dated only November 18, 1991.

• Certiorari vs. Double Jeopardy: Whether the Sandiganbayan's acquittal of the private respondents, rendered after a full trial on the merits, may be reviewed via certiorari under Rule 65 without violating the constitutional right against double jeopardy.
• Error of Judgment vs. Error of Jurisdiction: Whether the alleged errors committed by the Sandiganbayan in its appreciation of evidence and application of P.D. No. 1594 constitute grave abuse of discretion amounting to lack or excess of jurisdiction, or merely errors of judgment not correctible by certiorari.
• Denial of Due Process: Whether the prosecution was denied due process of law during the trial before the Sandiganbayan.

• Certiorari vs. Double Jeopardy: No. The acquittal was rendered after a full trial on the merits and is immediately final; review thereof would violate the constitutional right against double jeopardy, the only exception being a mistrial resulting in denial of due process, which was not shown here.
• Error of Judgment vs. Error of Jurisdiction: No. The alleged errors in the appreciation of evidence and disregard of P.D. No. 1594 are errors of judgment, not errors of jurisdiction; certiorari does not extend to correcting errors in the evaluation of evidence or conclusions of law anchored on factual findings.
• Denial of Due Process: No. The prosecution was given ample opportunity to present its ten witnesses and all necessary documentary evidence; the case was submitted for decision only after the parties had rested their case, and the trial court stated which pieces of evidence led to its conclusion.

• Certiorari vs. Double Jeopardy: The Court reaffirmed the principle that after trial on the merits, an acquittal is immediately final and cannot be appealed on the ground of double jeopardy. The sole exception is where there is a finding of mistrial resulting in a denial of due process. Here, the Sandiganbayan rendered its decision only after all evidence had been considered, weighed, and passed upon by both parties. The prosecution presented ten witnesses and submitted all necessary documentary exhibits before the case was submitted for decision. There was no showing that the trial court hampered the prosecution's presentation of evidence in any way. Absent mistrial, the acquittal could no longer be reviewed, as doing so would constitute a violation of the constitutional right against double jeopardy.

• Error of Judgment vs. Error of Jurisdiction: The Court distinguished between errors of judgment and errors of jurisdiction. An error of judgment is one committed by a court in the exercise of its jurisdiction; an error of jurisdiction is one where the act complained of was issued without or in excess of jurisdiction, or with grave abuse of discretion tantamount to lack or excess of jurisdiction. Certiorari corrects only the latter. The petitioner's arguments — that the Sandiganbayan disregarded P.D. No. 1594, supplied a defense not invoked by respondents, and anchored its decision on conjecture — all relate to the trial court's appreciation and evaluation of evidence. A review of facts and evidence is not the province of certiorari. The Court cannot re-examine conflicting evidence, re-evaluate witness credibility, or substitute the findings of fact of the court a quo. The alleged errors were thus errors of judgment not remediable by the extraordinary writ.

• Denial of Due Process: The Court found no deprivation of due process. The prosecution was afforded full opportunity to present its case: ten witnesses testified and all necessary documentary evidence was submitted. The case was submitted for decision only after both parties had rested. The Sandiganbayan clearly stated in its decision which pieces of evidence led it to conclude that the project was actually undertaken and that payment was justified. Petitioner failed to show any mistrial or any act by the trial court that prevented the prosecution from fully presenting its case. The contention that the trial court supplied a defense not invoked by respondents did not amount to denial of due process, as it pertained to the court's evaluation of evidence rather than any procedural impediment to the prosecution's case.

• Finality of Acquittal and Double Jeopardy — After trial on the merits, an acquittal is immediately final and cannot be appealed on the ground of double jeopardy. The only exception is where there is a finding of mistrial resulting in a denial of due process. In this case, the Sandiganbayan's acquittal was rendered after full trial where both parties presented evidence and rested their case; absent mistrial, the acquittal was beyond review.
• Error of Judgment vs. Error of Jurisdiction in Certiorari — An error of judgment is one committed by a court in the exercise of its jurisdiction and is not correctible by certiorari. An error of jurisdiction is one where the act complained of was issued without or in excess of jurisdiction, or with grave abuse of discretion tantamount to lack or excess of jurisdiction, and is correctible only by the extraordinary writ of certiorari. Errors in the appreciation of evidence, evaluation of witness credibility, and conclusions of law anchored on factual findings are errors of judgment. The Court applied this distinction to hold that the petitioner's allegations concerned the Sandiganbayan's evaluation of evidence, not jurisdictional infirmity.
• Scope of Certiorari — No Review of Facts and Evidence — Certiorari is extra ordinem and does not extend to examining and assessing the evidence of the parties, weighing the probative value thereof, or inquiring into the correctness of the evaluation of evidence. The appellate court cannot re-examine conflicting evidence, re-evaluate the credibility of witnesses, or substitute the findings of fact of the court a quo.

• "it is clear in this jurisdiction that after trial on the merits, an acquittal is immediately final and cannot be appealed on the ground of double jeopardy. The only exception where double jeopardy cannot be invoked is where there is a finding of mistrial resulting in a denial of due process." — This passage states the controlling rule on the finality of acquittals and the narrow exception permitting review, forming the ratio decidendi of the case.
• "Certiorari will not be issued to cure errors by the trial court in its appreciation of the evidence of the parties, and its conclusions anchored on the said findings and its conclusions of law." — This formulation delineates the boundary between errors of judgment and errors of jurisdiction in certiorari proceedings, explaining why the prosecution's allegations did not warrant the extraordinary writ.
• "It is not for this Court to re-examine conflicting evidence, re-evaluate the credibility of the witnesses or substitute the findings of fact of the court a quo." — This statement defines the limits of judicial review in certiorari, emphasizing that factual findings of the trial court are beyond the scope of the extraordinary remedy.

• People vs. Tria-Tirona, G.R. No. 130106, July 15, 2005, 463 SCRA 462 — Controlling precedent followed. The Court reaffirmed its holding that an acquittal after trial on the merits is immediately final and cannot be appealed on double jeopardy grounds, the only exception being mistrial resulting in denial of due process. The Court also relied on this case for the principle that errors in the evaluation of evidence are errors of judgment not remediable by certiorari.
• First Corporation vs. Former Sixth Division of the Court of Appeals, G.R. No. 171989, July 4, 2007, 526 SCRA 564 — Followed for the distinction between errors of judgment and errors of jurisdiction, and for the principle that certiorari does not extend to a review of facts and evidence.

• Section 3(e), Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) — The provision under which the private respondents were charged, prohibiting public officers from causing undue injury to any party, including the government, or giving unwarranted benefits, advantage, or preference through manifest partiality, evident bad faith, or gross inexcusable negligence. The Sandiganbayan found that the prosecution failed to prove all the elements of this offense.
• Rule 65, Rules of Court — The procedural rule governing the petition for certiorari, which allows review of acts of lower courts issued without or in excess of jurisdiction, or with grave abuse of discretion tantamount to lack or excess of jurisdiction. The Court held that the remedy did not lie because the alleged errors were errors of judgment, not jurisdiction.
• Presidential Decree No. 1594 — The decree prescribing policies and guidelines for government infrastructure contracts, including the requirement of approved plans and specifications before bidding. Petitioner argued the Sandiganbayan disregarded this decree, but the Court treated the argument as going to the trial court's appreciation of evidence rather than to jurisdictional error.

Antonio T. Carpio (Chairperson), Presbitero J. Velasco, Jr., Lucas P. Bersamin, and Roberto A. Abad. No separate concurring opinions were written.