**People of the Philippines v. Sandiganbayan (Fourth Division), et al.**
### Facts:
#### Sequence of Events:
1. **Background:**
– Soledad Oppen Montilla owned a residential house and a prawn farm in Barangay Ubay, Pulupandan, Negros Occidental.
– Her grandsons were Magdaleno and Bonifacio Peña.
– Bonifacio initially managed the properties but was later ejected by Magdaleno, who took possession following a Special Power of Attorney executed by Soledad.
2. **Judicial Actions:**
– Magdaleno obtained control over the property, leading Bonifacio to threaten eviction.
– Magdaleno filed a petition for injunction with the Regional Trial Court, which ruled against him.
– The trial court issued a writ of execution to reinstate Bonifacio, mandating the involvement of military and police officers for enforcement.
3. **Attempted Eviction:**
– Despite Magdaleno securing a Temporary Restraining Order (TRO) from the Court of Appeals, respondents (military and police) enforced the trial court’s writ.
– Respondents forcibly entered Montilla’s residential property, ignoring the TRO, and allegedly stole valuables and took control of the premises.
4. **Continued Encroachments:**
– Respondents occupied the premises from November 24, 1990, to January 3, 1991, during which they also entered Montilla’s fishpond and took several tons of prawns.
5. **Court of Appeals Decision:**
– The Court of Appeals later ruled in favor of Magdaleno, declaring the trial court’s order null and void.
#### Procedural Posture:
1. **Informations Filed:**
– The Office of the Ombudsman filed multiple criminal charges against respondents for robbery, violation of the Anti-Graft and Corrupt Practices Act, and qualified theft.
2. **Arraignment:**
– All respondents, except Jesus Clavecilla and Manuel Malapitan, Sr., were arraigned and pleaded not guilty.
3. **Demurrer to Evidence:**
– After the prosecution rested, the defense filed a demurrer to evidence without leave of court.
– The Sandiganbayan granted the demurrer, acquitting the respondents due to insufficiency of evidence.
### Issues:
1. **Jurisdiction over Respondents Clavecilla and Malapitan:**
– Did the Sandiganbayan err in granting the demurrer to evidence for these two respondents who were never arraigned or arrested?
2. **Insufficiency of Evidence:**
– Did the Sandiganbayan commit grave abuse of discretion in acquitting the respondents on the grounds that the evidence presented by the prosecution was insufficient to prove their guilt beyond reasonable doubt?
### Court’s Decision:
#### Issue 1: Jurisdiction over Clavecilla and Malapitan
**Ruling:**
– The Supreme Court ruled that the Sandiganbayan committed grave abuse of discretion by acquitting Clavecilla and Malapitan without acquiring jurisdiction over their persons. Without arrest or voluntary submission, the court lacked jurisdiction, rendering the acquittal invalid.
#### Issue 2: Sufficiency of Evidence
**Ruling:**
– The Supreme Court upheld the Sandiganbayan’s decision for the rest of the respondents. It found no grave abuse of discretion as the Sandiganbayan properly exercised its judicial discretion. The prosecution’s evidence was deemed insufficient to overturn the presumption of innocence.
### Doctrine:
The doctrine reiterated that a judgment of acquittal cannot be appealed due to double jeopardy. Additionally, jurisdiction must be properly acquired over all accused, which did not occur for Clavecilla and Malapitan, making the acquittal for them invalid.
### Class Notes:
– **Criminal Procedure:**
– **Double Jeopardy:** A judgment of acquittal is final and cannot be appealed.
– **Jurisdiction over Person:** Jurisdiction is acquired via arrest or voluntary submission. Without it, any proceeding or judgment is null.
– **Evidence:**
– **Demurrer to Evidence:** Can be filed by the defense after the prosecution rests. If granted, it results in acquittal due to insufficient evidence unless leave was not obtained, in which case, the defendant’s right to present evidence is waived.
– **Relevant Statutory Provisions:**
– **Article 293 and 294, Revised Penal Code:** Robbery with force upon things.
– **Article 310, Revised Penal Code:** Theft from fishponds.
– **Section 3(e), RA 3019:** Anti-Graft and Corrupt Practices Act violation required showing undue injury through evident bad faith.
### Historical Background:
This case highlighted a common dispute scenario involving properties managed under family dynamics. It also underscored the clashes between military/police enforcement of judicial orders and higher judicial interventions (e.g., TROs) meant to forestall such enforcement. Further, it explores the legal brinkmanship between family members embroiled in property disputes, drawing a critical examination of judicial discretion and procedural compliance in Philippine courts during the 1990s.
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