FACTS:

The Supreme Court held that the OSG's posture is contrary to the rules and established jurisprudence. The OSG's duty is to represent the State and safeguard the public interest. When the OSG disagrees with the private complainant's position, it should still actively participate in the proceedings to ensure that the court is properly informed and to protect the interests of the State.

II. The case does not fall under an exception to the rule on finality of acquittal and the doctrine of double jeopardy.

Chua argued that the case falls under the exception to the rule on finality of acquittal and the doctrine of double jeopardy because the CA's decision was tainted by grave abuse of discretion. However, the Supreme Court found no grave abuse of discretion committed by the CA. The Court pointed out that the private complainant's assertion that the CA merely relied on the weaknesses of the defense, instead of properly evaluating the prosecution's evidence, is not supported by the CA decision. The CA dismissed the case due to the failure of the prosecution to establish Chiok's guilt beyond reasonable doubt, not because of the weaknesses of the defense.

III. Chiok is not civilly liable to Chua.

The Supreme Court affirmed the CA's finding that Chua failed to prove her claim for civil liability against Chiok. The Court noted that the burden of proof lies with the prosecution to establish the guilt of the accused beyond reasonable doubt, including the civil liability arising from the offense. In this case, the prosecution failed to provide sufficient evidence to prove Chiok's misappropriation of the funds entrusted to him by Chua. Therefore, Chiok cannot be held civilly liable to Chua.

Based on the above, the Supreme Court dismissed Chua's petition and affirmed the CA's decision acquitting Chiok. The Court also denied Chiok's appeal on the civil liability imposed on him.

ISSUES:

1. Whether the private offended party or complainant can appeal the dismissal or acquittal of a criminal case.

2. Whether the appeal from the judgment of acquittal will place the accused in double jeopardy.

3. Whether the Court of Appeals had jurisdiction to entertain the appeal of the accused.

4. Whether the exceptions to the rule on finality of acquittal and double jeopardy doctrine apply.

5. Whether there are exceptions to the rule on double jeopardy.

6. Whether the State was deprived of due process in presenting its case.

7. Whether Chiok is civilly liable to Chua in the amount of P9,563,900.00.

8. Whether the amount admitted by Chiok for the estafa case is P9,500,000.00 or P9,563,900.00.

9. Whether Chiok's absolution from civil liability in the BP 22 case bars civil liability in the estafa case.

10. Whether res judicata bars the plaintiff from recovering any civil claims.

11. Whether the plaintiff is entitled to interest on the principal amount.

RULING:

1. The private offended party or complainant may not appeal the dismissal or acquittal of a criminal case. The appeal on the criminal aspect may only be undertaken by the State through the Solicitor General. The private offended party may only appeal as to the civil aspect of the case. However, there are instances when a liberal view is adopted and the petition filed by an offended party is given due course. In those cases, the Office of the Solicitor General's position in its comment on the petition will determine if the OSG ratifies and adopts the private complainant's petition as its own.

2. The appeal from the judgment of acquittal will place the accused in double jeopardy. The Constitution guarantees the right of the accused against double jeopardy. For double jeopardy to attach, the requirements of a valid information, court of competent jurisdiction, arraignment and plea, and conviction, acquittal, or dismissal without the accused's consent must be present. A judgment of acquittal, whether ordered by the trial or appellate court, is final, unappealable, and immediately executory upon its promulgation. This rule on finality of acquittal is based on the need for repose and to protect the innocent against wrongful conviction.

3. The Court of Appeals had jurisdiction to entertain the appeal of the accused. The accused filed his Notice of Appeal before the promulgation of judgment, and under the 1985 Rules on Criminal Procedure, the right to appeal is not automatically forfeited in such cases. The CA acquired jurisdiction over the appeal when it denied the prosecution's motion to deny due course to the notice of appeal.

4. The exceptions to the rule on finality of acquittal and double jeopardy doctrine do not apply. The dismissal of the accused's appeal due to his jumping bail was a discretionary act by the CA, and it exercised its discretion to reinstate the appeal. The SC bail decisions that set aside the CA resolutions enjoining the accused's arrest did not automatically revive the CA resolution dismissing the appeal. Therefore, the first jeopardy attached and the proceedings before the CA and the subsequent acquittal are valid.

5. There are no exceptions to the rule on double jeopardy in this case. The alleged irregularities in a separate case and the alleged tampering of evidence do not constitute the same intensity and gravity of pressure exerted in Galman v. Sandiganbayan, which resulted in a miscarriage of justice.

6. The State was not deprived of due process in presenting its case. Both parties had the opportunity to present their case and submit memoranda, and the Office of the Solicitor General actively participated in prosecuting the case before the appellate court.

7. Chiok is civilly liable to Chua in the amount of P9,563,900.00. While Chiok was acquitted of criminal liability, the acquittal based on reasonable doubt does not exempt him from civil liability. The monetary transaction between Chua and Chiok was proven by preponderance of evidence, including bank deposit slips and Chiok's admission of receiving the amount mentioned.

8. The amount admitted by Chiok for the estafa case is P9,563,900.00.

9. Chiok's absolution from civil liability in the BP 22 case does not bar civil liability in the estafa case.

10. Res judicata does not bar the plaintiff from recovering any civil claims.

11. The plaintiff is entitled to interest on the principal amount.

PRINCIPLES:

• The private offended party or complainant may not appeal the dismissal or acquittal of a criminal case but may only do so as to the civil aspect of the case.

• The appeal from the judgment of acquittal will place the accused in double jeopardy as guaranteed by the Constitution.

• The rule on finality of acquittal is based on the need for repose and to protect the innocent against wrongful conviction.

• The right to appeal is not automatically forfeited when an accused fails to appear during the promulgation of judgment.

• The appellate court has the authority to dismiss an appeal for abandonment if the accused escapes from prison or confinement or jumps bail or flees to a foreign country during the pendency of the appeal, but such dismissal is discretionary.

• Exceptions to the rule on finality of acquittal and double jeopardy doctrine include mistrial due to a partial court and biased prosecution, and grave abuse of discretion amounting to lack or excess of jurisdiction or a denial of due process.

• The doctrine of res judicata in the concept of conclusiveness of judgment bars the re-litigation of particular facts or issues in another litigation between the same parties on a different claim or cause of action. However, it presupposes that facts and issues were actually and directly resolved in a previous case.

• A civil action in a BP 22 case is not a bar to a civil action in an estafa case. Both remedies are simultaneously available to the offended party, and there may only be one recovery of the single civil liability.

• Res judicata does not apply when there are no findings of fact on the transaction giving rise to the civil liability.

• The amount awarded shall earn interest from the date of extrajudicial demand until finality of the judgment, and thereafter at the rate of 6% per annum until satisfaction.

• The ruling in Nacar v. Gallery Frames is applicable in computing the interest on the principal amount.