FACTS:

The People of the Philippines filed a petition for certiorari to annul and set aside the Sandiganbayan's resolution granting the respondents' joint demurrer to evidence in a criminal case for falsification of public documents. The respondents, including Mayor Saludaga, were charged for falsification of public documents in relation to the issuance of an official receipt and mayor's permit to De Luna, an accused non-licensed contractor. The prosecution presented witnesses who testified to the alleged conspiracy. The respondents filed a demurrer arguing that the prosecution failed to prove their criminal intent and conspiracy. The Sandiganbayan granted the demurrer and the People filed a petition to annul the resolution.

This case involves a petition by the People against the Sandiganbayan's decision to grant the respondents' demurrer. The People argue that the respondents' admission of antedating a receipt already constitutes falsification. They also argue that the Sandiganbayan erred in its requirement of absolute falsehood in the narration of facts, and that good faith does not apply since the accused should have known the act was illegal. The People assert that the respondent mayor cannot invoke the Arias doctrine as he may be a knowing participant in the conspiracy. The respondents maintain their arguments to support the demurrer, including the failure to prove conspiracy and taking advantage of their official positions. The main issue is whether the Sandiganbayan gravely abused its discretion in granting the demurrer.

ISSUES:

1. Whether the Sandiganbayan's grant of demurrer to evidence may be assailed through a certiorari petition.

2. Whether the Sandiganbayan gravely abused its discretion in granting the demurrer to evidence.

3. Whether the Sandiganbayan gravely abused its discretion in granting the respondents' demurrer to evidence.

4. Whether the prosecution failed to prove the elements of the crime charged.

5. Whether the petition should be dismissed due to double jeopardy;

6. Whether there is sufficient evidence to prove conspiracy among the respondents.

RULING:

1. The Sandiganbayan's grant of demurrer to evidence may be reviewed through certiorari under Rule 65. A petition for certiorari is intended to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. Its purpose is to keep the inferior court within its jurisdiction or prevent it from committing grave abuse of discretion.

2. The People failed to demonstrate that the Sandiganbayan gravely abused its discretion in granting the demurrer to evidence. The burden is on the petitioner to clearly demonstrate that the trial court blatantly abused its authority to a point so grave as to deprive it of its power to dispense justice. In this case, the People failed to overcome this burden.

3. No, the Sandiganbayan did not gravely abuse its discretion in granting the respondents' demurrer to evidence.

4. Yes, the prosecution failed to prove some elements of the crime, namely: (i) that the offenders took advantage of their official positions, and (ii) that they falsified a document by making untruthful statements in a narration of facts.

5. The petition should be dismissed. The Supreme Court finds no grave abuse of discretion on the part of the Sandiganbayan in granting the respondents' joint demurrer to evidence. The petition cannot be pursued as it would place the respondents in double jeopardy.

6. The charge of conspiracy does not hold water. There was no convincing evidence presented to show how the respondents conspired to commit the crime. The acts of the respondents, on their own and nothing more, do not support the allegation of conspiracy. Therefore, the Supreme Court concluded that the concurrence of wills and common intent or design to commit a crime is not clearly manifest in the present case.

PRINCIPLES:

• A petition for certiorari is intended to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction.

• Mere abuse of discretion is not enough; the abuse must be grave, defied positive duty or was a refusal to perform a duty enjoined by law.

• A demurrer to evidence challenges the sufficiency of the prosecution's evidence and may lead to the grant of acquittal in criminal cases.

• The dismissal order resulting from the grant of demurrer to evidence may be reviewed through certiorari under Rule 65.

• Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony, and it may be inferred from the acts of the accused. Conspiracy must be proved by clear and convincing evidence.

• In determining whether to grant a demurrer to evidence, the court must examine the prosecution's evidence vis-a-vis the elements of the crime.

• The court may dismiss the case if the prosecution fails to prove the elements of the crime by clear and convincing evidence.

• The court must thoroughly evaluate the testimonial and documentary evidence presented by the prosecution.

• The accused must be shown to have taken advantage of their official positions in order to be held liable for the crime.

• In cases of falsification, if the statements in a document are not altogether false and there is some colorable truth in them, the crime of falsification may not have been committed.

• The court must give weight to the evidence presented by the prosecution and make a determination based on the available evidence.

• Certiorari shall lie only when the respondent court gravely abuses its discretion, such as when it ignores facts or denies a party due process.

• Errors of judgment may occur in the court's evaluation of the sufficiency of evidence, but such errors do not amount to grave abuse of discretion.

• In order to prove conspiracy, the acts of the accused must clearly manifest a concurrence of wills, a common intent or design to commit a crime.

• Conspiracy may be inferred from the acts of the accused.

• Double jeopardy prevents a person from being tried again for a crime of which they have already been acquitted or convicted.

• The mere fact that an acquittal may be erroneous or predicated on a mistake of fact or law does not mean that the acquittal can be set aside.