Case Digest: People vs Webb and Lejano vs People

Lejano vs People
People vs Webb

GR Nos. 176389 and 176864                                        January 18, 2011

Facts:
The Supreme Court reversed the judgment of the CA and acquitted accused, namely: Hubert Webb, Antonio Lejano, Michael Atchalian, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Gerardo Biong on the ground of lack of proof of their guilt beyond reasonable doubt.

Thereafter, complaint Lauro Vizconde, asked the Court to reconsider its decision, claiming that it "denied the prosecution due process of law; seriously misappreciated the facts; unreasonably regarded Alfaro as lacking credibility; issued a tainted and erroneous decision; decided the case in a manner that resulted in the miscarriage of justice; or committed grave abuse in its treatment of the evidence and prosecution witnesses."

Issue:
Whether or not a judgment of acquittal may be reconsidered.

Ruling:
No, as a rule a judgment of acquittal cannot be reconsidered for it places the accused under double jeopardy. On occasions, a motion for reconsideration after an acquittal is possible, but the grounds are exceptional and narrow as when the court that absolved the accused gravely abused its discretion, resulting in loss of jurisdiction, or when a mistrial has occurred. In any of such cases, the State may assail the decision by special civil action of certiorari under Rule 65.

Althou complainant Vizconde invoked the exceptions, he has been unable to bring pleas for reconsideration under such exceptions. He did not specify that violations of due process and acts constituting grave abuse of discretion that the Court supposedly committed. Vizconde did not also alleged that the Court held a sham review of the decision of the CA. What the complainant actually questions is the Court's appreciation of the evidence and assessment of the prosecution witnesses' credibility. That the court committed grave error in finding Alfaro as not a credible witness. The complaint wants the court to review the evidence anew and render another judgment based on such evaluation which is not constitutionally allowed and therefore, the judgment of acquittal can no longer be disturbed.


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