G.R. No. 167710. June 05, 2009 (Case Brief / Digest)

### Title:
**People of the Philippines v. Joven de Grano, Armando de Grano, Domingo Landicho, and Estanislao Lacaba**

### Facts:
The case began with the filing of an Information for murder against Joven de Grano, Armando de Grano, and Estanislao Lacaba, among others, for the killing of Emmanuel Mendoza on April 21, 1991. They pleaded not guilty. Due to one accused’s status as Mayor of Laurel, Batangas, the case was transferred from the RTC in Tanauan, Batangas to Manila for fear of unfair trial, being re-docketed as Criminal Case No. 93-129988.

Despite the prosecution’s evidence on premeditation and treachery, bail was granted to the accused. This decision was initially upheld by the CA, but later reversed by the Supreme Court, ordering the accused’s arrest. The case was remanded to the RTC for decision, which, in April 2002, found the accused guilty of murder, qualified by treachery.

A motion for reconsideration led the RTC to modify its decision, acquitting two of the accused and reducing the charge for Lacaba and another to homicide. The prosecution sought reconsideration, arguing the motion’s invalidity since most accused were at large and lacked the Solicitor General’s sanction. The CA dismissed the prosecution’s subsequent certiorari petition based on procedural grounds, such as lack of OSG participation, leading to this Supreme Court review.

### Issues:
1. Whether the CA erred in dismissing the certiorari petition on double jeopardy grounds.
2. Whether the CA erred in dismissing the certiorari petition for lack of filing by the OSG or in the name of the offended party.
3. Whether the CA erred in dismissing the petition for improper verification and certification.

### Court’s Decision:
The Supreme Court granted the petition, reversing the CA’s resolutions and reinstating parts of the RTC’s decision convicting the accused of murder. The Court emphasized the RTC’s grave abuse of discretion for taking cognizance of the joint motion for reconsideration filed by the accused who failed to appear at the promulgation without justifiable cause, doing so without jurisdiction, thereby voiding related orders. The Court directed an investigation into the responsible judge for possible violations of the law or judicial conduct codes.

### Doctrine:
This case reiterates that a writ of certiorari under Rule 65 of the Rules of Court can challenge an erroneous acquittal when there’s a grave abuse of discretion amounting to lack or excess of jurisdiction by the lower court, thus not placing the accused in double jeopardy.

### Class Notes:
– **Key Elements for Certiorari Against Acquittal:**
– Grave abuse of discretion by the lower court;
– Lack or excess of jurisdiction leading to void judgment;
– Non-application of double jeopardy if due process is violated.

– **Verification and Certification Exceptions:**
– Liberal application of rules possible;
– Procedural non-compliance may be excused for substantial compliance under justifiable circumstances.

– **Double Jeopardy Essentials:**
– Charged under a valid complaint;
– Jurisdictionally competent court;
– Accused has pleaded;
– Convicted, acquitted, or the case was dismissed without the accused’s express consent.

### Historical Background:
This case highlights the judicial process and procedural nuances in criminal law within the Philippine legal system, particularly the safeguards against double jeopardy and the exceptional circumstances under which an acquittal can be challenged. It underscores the complexity of due process rights versus prosecutorial and judicial errors, reflecting the balance of ensuring fair trials and correcting grave abuses of discretion.


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