ANTONIO LEJANO v. PEOPLE

FACTS:

The Court acquitted the accused, Hubert Jeffrey P. Webb et al., in a criminal case due to lack of proof beyond reasonable doubt on December 14, 2010. Subsequently, the complainant, Lauro G. Vizconde, filed a motion for reconsideration on December 28, 2010, arguing that the Court denied the prosecution due process, misappreciated the facts, and issued a tainted and erroneous decision. Vizconde contended that the Court committed grave abuse of discretion and filed for reconsideration of the acquittal.

ISSUES:

  1. Whether the Supreme Court erred in acquitting the accused, violating due process and committing grave abuse of discretion.

  2. Whether the motion for reconsideration of the acquittal places the accused under double jeopardy.

RULING:

  1. The Supreme Court ruled that the acquittal did not violate due process nor constitute grave abuse of discretion. Complainant failed to specify the alleged due process violations or acts constituting grave abuse of discretion by the Court.

  2. The Court held that reconsidering a judgment of acquittal would place the accused under double jeopardy, which is constitutionally prohibited. The judgment acquitting the accused is final and cannot be disturbed.

PRINCIPLES:

  1. Double Jeopardy - No person shall be twice put in jeopardy of punishment for the same offense, as enshrined in Section 21, Article III of the Constitution.

  2. Judgment of Acquittal - A judgment of acquittal is generally not subject to reconsideration because it would subject the accused to double jeopardy.

  3. Exceptions to Reconsideration of Acquittal - Acquittals can be reconsidered in exceptional and narrow situations, such as when there is grave abuse of discretion or a mistrial.

  4. Burden of Proof in Exceptional Cases - The party challenging the acquittal must specify the due process violations or acts constituting grave abuse of discretion with substantial evidence, which was not met in this case.