People vs. Uy

A judgment of acquittal rendered with grave abuse of discretion amounting to lack of jurisdiction—such as relying on hearsay retraction affidavits or misapplying exclusionary rules—is void and may be annulled via certiorari without violating double jeopardy.

Rabel Campos was found dead with multiple stab wounds on March 23, 2001 along the National Highway of Maputi, Naawan, Misamis Oriental. Teofilo Panangin, arrested on January 22, 2002 for a separate offense, executed a sworn extrajudicial confession on January 23, 2002, implicating himself and his former employer, Louel Uy, in the murder. Panangin detailed how Uy instructed him to stab the victim, after which Uy dragged her and fatally stabbed her multiple times. The confession was assisted by Public Attorney's Office (PAO) lawyer Atty. Celso Sarsaba.

• The Crime and Confession: Rabel Campos was found dead on March 23, 2001. Panangin, arrested for another case, gave a sworn statement on January 23, 2002, with PAO assistance, confessing that Uy ordered him to stab Rabel; after Panangin stabbed her once, Uy took the knife and stabbed her repeatedly until she died. Panangin identified his and the victim's sandals recovered from the crime scene.
• The Retraction and Demurrer: After the prosecution rested its case, Panangin filed a demurrer to evidence attaching a July 1, 2002 affidavit retracting his confession, claiming he was handcuffed, manhandled, and not informed of his constitutional rights. Uy filed a separate demurrer echoing the same grounds.
• The Trial Court Ruling: The RTC granted the demurrers, acquitting the accused. It held that Panangin's confession was involuntary due to its subsequent retraction and, alternatively, inadmissible as "fruit of the poisonous tree" because it was obtained following an illegal arrest. The RTC also found the prosecution's testimonial evidence to be hearsay and speculative, yet ordered the accused to pay ₱35,000 for burial expenses.

• Grave Abuse of Discretion: Petitioners contended that the trial court gravely abused its discretion in granting the demurrer to evidence.
• Admissibility of Confession: Petitioners maintained that Panangin was fully apprised of his constitutional rights during the investigation and that the basic requirements of law were fully complied with.
• Mootness of Admissibility Issue: Petitioners argued that because the trial court had previously admitted Panangin's extrajudicial confession as part of the prosecution's evidence in chief, the issue of its admissibility had become moot and academic.

• Involuntariness of Confession: Respondents argued that Panangin's extrajudicial confession was not voluntary, as evidenced by his retraction affidavit claiming he was manhandled, handcuffed, and denied his constitutional rights during custodial investigation.
• Fruit of the Poisonous Tree: Respondents asserted that the confession was inadmissible because it was obtained as a direct result of Panangin's illegal arrest.
• Insufficiency of Evidence: Respondents contended that the prosecution's testimonial evidence was hearsay and speculative, failing to prove Uy was the last person seen with the victim or to establish guilt beyond reasonable doubt.

• Admissibility of Confession: Whether Panangin's extrajudicial confession is admissible in evidence despite his claim of involuntariness and illegal arrest.
• Grave Abuse of Discretion: Whether the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction in granting the demurrer to evidence based on the inadmissibility of the confession after it had been admitted as part of the prosecution's evidence.
• Double Jeopardy: Whether setting aside the judgment of acquittal and remanding the case for further proceedings violates the accused's right against double jeopardy.

• Admissibility of Confession: The extrajudicial confession was admissible and voluntary. A confession is presumed voluntary until the contrary is proved, and the declarant bears the burden of proving involuntariness. Panangin's retraction affidavit was hearsay because he did not testify to identify and affirm it at the witness stand; bare assertions of involuntariness cannot overturn the presumption. Furthermore, PAO counsel's unrefuted testimony established that Panangin was informed of his constitutional rights, including the effect of his confession, and that he gave his statement voluntarily.
• Grave Abuse of Discretion: The trial court committed grave abuse of discretion. By blindly accepting an unproven hearsay affidavit of retraction to invalidate a confession, the trial court deprived the prosecution of due process by denying it the opportunity to cross-examine the affiant. Moreover, the trial court misapplied the "fruit of the poisonous tree" doctrine; the exclusionary rule under Sections 2 and 3, Article III of the Constitution applies only to object (physical) evidence seized during an illegal search and seizure, not to testimonial evidence obtained following an illegal arrest.
• Double Jeopardy: Because the trial court committed grave abuse of discretion amounting to lack of jurisdiction—rendering the judgment void—no valid judgment was rendered and jeopardy did not attach. A void judgment may be assailed via certiorari without violating double jeopardy. Additionally, the trial court erred in ordering civil liability; an acquittal based on a finding that the accused is not the perpetrator of the act closes the door to civil liability.

• Finality of Acquittal / Double Jeopardy — A judgment of acquittal is final and unappealable, including acquittals via demurrer to evidence, to safeguard the accused from government oppression and double jeopardy. Exception: A judgment of acquittal may be assailed via certiorari under Rule 65 if the lower court committed grave abuse of discretion amounting to lack or excess of jurisdiction, rendering the judgment void.
• Fruit of the Poisonous Tree Doctrine — Applies exclusively to object (physical) evidence seized during an illegal search and seizure under Sections 2 and 3, Article III of the Constitution. It does not apply to testimonial evidence (confessions) obtained from a person during custodial investigation following an illegal arrest.
• Presumption of Voluntariness of Confessions — A confession is presumed voluntary until the contrary is proved, and the declarant bears the burden of proving involuntariness. Bare allegations of force or intimidation, without substantiation, are insufficient to overturn the presumption. Retraction affidavits not affirmed on the witness stand are hearsay and cannot overcome this presumption.
• Due Process of the State — The State is entitled to due process just like the accused. Where the denial of the State's fundamental right to due process is apparent, the decision rendered is void for lack of jurisdiction.

• "The inadmissible evidence termed as 'fruit of a poisonous tree' in jurisprudence is that contemplated in above-quoted constitutional provisions. It refers to object, not testimonial, evidence. And it refers to an object seized in the course of an illegal search and seizure."
• "A confession is presumed to be voluntary until the contrary is proved and the declarant bears the burden of proving that his confession is involuntary and untrue. x x x Bare assertions will certainly not suffice to overturn the presumption of voluntariness."
• "Where the denial of the fundamental right of due process is apparent, a decision rendered in disregard of that right is void for lack of jurisdiction. Any judgment or decision rendered notwithstanding such violation may be regarded as a 'lawless thing, which can be treated as an outlaw and slain at sight, or ignored wherever it exhibits its head.'"

• People v. Court of Appeals, 423 SCRA 605 (2004) — Cited for the rationale behind the finality-of-acquittal doctrine and the double jeopardy safeguard against government oppression.
• People v. Sandiganbayan, 447 SCRA 291 (2004) — Followed for the rule that granting a demurrer to evidence in criminal cases results in a dismissal on the merits tantamount to an acquittal.
• People v. Bocar, 138 SCRA 166 (1985) — Applied to establish that a violation of the State's right to due process raises a serious jurisdictional issue, rendering the decision void.
• People v. Porio, 376 SCRA 596 (2002) — Followed for the doctrine that a confession is presumed voluntary and the declarant bears the burden of proving involuntariness.
• Eusebio-Calderon v. People, 441 SCRA 137 (2004) — Cited for the principle that an acquittal based on a finding that the accused is not the perpetrator precludes the imposition of civil liability.

• Rule 65, Rules of Court — Governs the special civil action for certiorari used to annul the trial court's judgment on the ground of grave abuse of discretion amounting to lack or excess of jurisdiction.
• Section 2, Article III, 1987 Constitution — Guarantees the right against unreasonable searches and seizures; provides the constitutional basis for the "fruit of the poisonous tree" exclusionary rule regarding object evidence.
• Section 3, Article III, 1987 Constitution — Renders inadmissible any evidence obtained in violation of the right against unreasonable searches and seizures or the privacy of communication.
• Section 12, Article III, 1987 Constitution — Guarantees the rights of persons under custodial investigation, including the right to remain silent and to have competent and independent counsel.

Artemio V. Panganiban, Angelina Sandoval-Gutierrez, Renato C. Corona, Cancio C. Garcia