Villareal vs People G.R. No.

151258 February 1, 2012 Facts: Seven Freshmen Law students of Ateneo de Manila University School of Law have been initiated by the Aquila Legis Juris Fraternity on February 1991. The neophytes were insulted and threatened even before they got off the van. Members of the fraternity delivered blows to the neophytes as they alighted from the van. Several initiation rites were experienced by the neophytes like the Indian run, Bicol express and rounds. Accused fraternity members, Dizon and Villareal, asked the head of the initiation rites Victorino to reopen the initiation. Fraternity members subjected neophytes to paddling and additional hours of physical pain. After the last session of beatings, Lenny Villa could not walk. Later that night, he was feeling cold and his condition worsened. He was brought to the hospital but was declared dead on arrival. Criminal case was filed against 26 fraternity members and was subsequently found guilty beyond reasonable doubt of the crime of homicide and penalized with reclusion perpetua. CA modified the criminal liability of each of the accused according to individual participation. Issue: Whether or not there was double jeopardy. Held: What the Petition seeks is to reexamine, reassess, and reweigh the probative value of the evidence presented by the parties. In People v. Maquiling, it was held that grave abuse of discretion cannot be attributed to a court simply because it allegedly misappreciated the facts and the evidence. Mere errors of judgment are correctible by an appeal or a petition for review under Rule 45 of the Rules of Court, and not by an application for a writ of certiorari. Therefore, pursuant to the rule on double jeopardy, the SC constrained to deny the Petition contra Victorino et al. the 19 acquitted fraternity members. It was however, modify the assailed judgment as regards Tecson, Ama, Almeda, and Bantug the four fraternity members convicted of slight physical injuries. Indeed, it ruled in a line of cases that the rule on double jeopardy similarly applies when the state seeks the imposition of a higher penalty against the accused. The SC also recognized, however, that certiorari may be used to correct an abusive judgment upon a clear demonstration that the lower court blatantly abused its authority to a point so grave as to deprive it of its very power to dispense justice. The present case is one of those instances of grave abuse of discretion.

Ysidoro vs De castro G.R. No. 190963 February 6, 2012 Facts: Ysidoro, a Municipal Mayor of Leyte, Leyte, was charged before the Sandiganbayan with Anti-Graft and Corrupt Practices. Ysidoro filed an omnibus motion to quash the information and, in the alternative, for judicial determination of probable cause, which were both denied by the Sandiganbayan. He was arraigned and pleaded not guilty. The Sandiganbayan preventively suspended Ysidoro for ninety days. Ysidoro filed a motion for reconsideration but the Sandiganbayan denied the motion. Later, the Sandiganbayan acquitted Ysidoro and held that the second element of the offense, that there be malice, ill-motive or bad faith was not present. The people then filed a petition for certiorari. Ysidoro insists that he can no longer be prosecuted for the same criminal charge without violating the rule against double jeopardy. Issue: Whether or not there was double joupardy. Held: The Supreme Court that the rule against double jeopardy cannot be properly invoked in a Rule 65 petition, predicated on two exceptional grounds, namely: in a judgment of acquittal rendered with grave abuse of discretion by the court; and where the prosecution had been deprived of due process. The rule against double jeopardy does not apply in these instances because a Rule 65 petition does not involve a review of facts and law on the merits in the manner done in an appeal. In certiorari proceedings, judicial review does not examine and assess the evidence of the parties nor weigh the probative value of the evidence. It does not include an inquiry on the correctness of the evaluation of the evidence. A review under Rule 65 only asks the question of whether there has been a validly rendered decision, not the question of whether the decision is legally correct. In other words, the focus of the review is to determine whether the judgment is per se void on jurisdictional grounds. Applying these legal concepts to this case, we find that while the People was procedurally correct in filing its petition for certiorari under Rule 65, the petition does not raise any jurisdictional error committed by the Sandiganbayan. On the contrary, what is clear is the obvious attempt by the People to have the evidence in the case reviewed by the Court under the guise of a Rule 65 petition. This much can be deduced by examining the petition itself which does not allege any bias, partiality or bad faith committed by the Sandiganbayan in its proceedings. The petition does not also raise any denial of the Peoples due process in the proceedings before the Sandiganbayan.

Ivler vs Judge Pedro G.R. No. 172716 November 17, 2010 Facts: Jason got involved in a vehicular collision and was charged with two separate offenses with the MTC of Pasig City, for reckless imprudence resulting to slight physical injuries of one victim, and reckless imprudence resulting to homicide of the other victim and damage to property. He pleaded guilty on the First Criminal Case and was penalized with public censure. By this conviction, he asked for the quashal of the Second Criminal Case on the ground of double jeopardy, but was refused by the lower court. He elevated this matter to the Regional Trial Court, and then sought suspension of the Second Criminal Case invoking the SCA Case as

a prejudicial question. The MeTC did not act on the suspension motion but proceeded with the arraignment of the Second Criminal Case, which Jason failed to attend. Because of his nonappearance his bail was cancelled and he was arrested. At the other side, the respondent victim filed a motion to dismiss the SCA Case on the ground that Jason lost his standing to maintain the suit. Because of this so-called forfeiture of standing due to non-appearance, the RTC dismissed Jasons SCA Case. After a motion for reconsideration became unsuccessful, Jason filed a petition for review on certiorari with the Supreme Court on questions of law, particularly on the issue of double jeopardy. Issue: If Jason did forfeit his standing, is his constitutional right under the Double Jeopardy Clause bars further proceedings in the Second Criminal Case? Held: Supreme Court held that the MeTC is mistaken in finding that the two cases of reckless imprudence are entirely separate offenses using the basis that the Second Criminal Case required proof of an additional fact which the First Criminal Case does not. The High Court reasoned that reckless imprudence is a single crime, its consequences on persons and property are material only to determine the penalty. The doctrine that reckless imprudence under Article 365 is a single quasi-offense by itself and not merely a means to commit other crimes such that conviction or acquittal of such quasi-offense bars subsequent prosecution for the same quasioffense, regardless of its various resulting acts.