Primary Holding

The Supreme Court dismissed the petition for certiorari, holding that an acquittal based on appreciation of evidence cannot be appealed by the government, as it would violate the constitutional protection against double jeopardy.

Background

In San Ildefonso, Bulacan, a shooting incident resulted in the death of Alex Vinculado and serious injuries to his twin brother Levi and uncle Miguel Vinculado Jr. Honorato Galvez (town mayor) and Godofredo Diego (municipal employee) were charged with murder, frustrated murder, and illegal possession of firearms. After trial, Diego was found guilty while Galvez was acquitted. The government challenged the acquittal.

Facts

• 1. A shooting incident occurred in San Ildefonso, Bulacan
• 2. Alex Vinculado was killed
• 3. Levi Vinculado lost his left vision
• 4. Miguel Vinculado Jr. was shot in the arm and body
• 5. Three criminal informations were originally filed for homicide and frustrated homicide
• 6. Charges were upgraded to murder and frustrated murder
• 7. Additional charge of illegal possession of firearms against Mayor Galvez
• 8. Venue transferred from Malolos to Quezon City
• 9. Co-accused Godofredo Diego was convicted
• 10. Mayor Galvez was acquitted of all charges

Arguments of the Petitioners

• 1. The acquittal constitutes grave abuse of discretion
• 2. Judge deliberately disregarded facts and evidence
• 3. Review would not transgress double jeopardy
• 4. US doctrine permits review of acquittals where no retrial is required
• 5. Philippine double jeopardy concepts should follow new US jurisprudence

Arguments of the Respondents

• 1. Acquittal was based on evidence evaluation
• 2. Double jeopardy bars appeal
• 3. Certiorari cannot be used to review evidence
• 4. Judge exercised proper discretion

Issues

• 1. Whether certiorari can be used to reverse an acquittal
• 2. Whether review of acquittal violates double jeopardy
• 3. Whether American jurisprudential changes should alter Philippine double jeopardy doctrine

Ruling

• 1. The Court dismissed the petition
• 2. Acquittal based on evidence evaluation cannot be appealed
• 3. Double jeopardy attaches to acquittals after trial on merits
• 4. Certiorari cannot be used to review evidence appreciation
• 5. Philippine jurisprudence maintains finality of acquittals
• 6. American modifications to double jeopardy doctrine not applicable to Philippine context

Doctrines

• 1. Double Jeopardy - prohibits multiple prosecutions for same offense
• 2. Finality of Acquittal - verdict of acquittal is final and unappealable
• 3. Grave Abuse of Discretion - requires capricious exercise of judgment equivalent to lack of jurisdiction

Precedents Cited

• 1. Kepner v. United States (1904) - established finality of acquittals in Philippine jurisdiction
• 2. United States v. Ball (1896) - affirmed double jeopardy rule
• 3. United States v. Wilson (1975) - discussed limitations on government appeals
• 4. Galman v. Sandiganbayan - established mistrial exception

Statutory and Constitutional Provisions

• 1. 1935 Philippine Constitution, Article III, Section 20
• 2. 1973 Constitution, Article IV, Section 22
• 3. 1987 Constitution, Article III, Section 21
• 4. Rules of Court, Rule 117, Section 7
• 5. General Order No. 58
• 6. Act No. 194