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    People v. de Leon

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    MAC
    The Supreme Court ruled that the appellate court erred in violating Danilo's constitutional right against double jeopardy. The elements of double jeopardy were met since Danilo was charged, tried in a court of competent jurisdiction, and acquitted by the regional trial court of the crime of robbery due to insufficient evidence. By reversing the acquittal and convicting Danilo of robbery, the appellate court subjected him to double jeopardy which is prohibited by the Constitution. An acquittal, even if based on insufficient evidence, is immediately final and not subject to appeal due to the constitutional prohibition against double jeopardy.

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    People v. de Leon

    Uploaded by

    MAC
    1K views1 page
    The Supreme Court ruled that the appellate court erred in violating Danilo's constitutional right against double jeopardy. The elements of double jeopardy were met since Danilo was charged, tried in a court of competent jurisdiction, and acquitted by the regional trial court of the crime of robbery due to insufficient evidence. By reversing the acquittal and convicting Danilo of robbery, the appellate court subjected him to double jeopardy which is prohibited by the Constitution. An acquittal, even if based on insufficient evidence, is immediately final and not subject to appeal due to the constitutional prohibition against double jeopardy.

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    People v. De Leon

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    The Supreme Court ruled that the appellate court erred in violating Danilo's constitutional right against double jeopardy. The elements of double jeopardy were met since Danilo was charged, tried in a court of competent jurisdiction, and acquitted by the regional trial court of the crime of robbery due to insufficient evidence. By reversing the acquittal and convicting Danilo of robbery, the appellate court subjected him to double jeopardy which is prohibited by the Constitution. An acquittal, even if based on insufficient evidence, is immediately final and not subject to appeal due to the constitutional prohibition against double jeopardy.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    1K views1 page

    People v. de Leon

    Uploaded by

    MAC
    The Supreme Court ruled that the appellate court erred in violating Danilo's constitutional right against double jeopardy. The elements of double jeopardy were met since Danilo was charged, tried in a court of competent jurisdiction, and acquitted by the regional trial court of the crime of robbery due to insufficient evidence. By reversing the acquittal and convicting Danilo of robbery, the appellate court subjected him to double jeopardy which is prohibited by the Constitution. An acquittal, even if based on insufficient evidence, is immediately final and not subject to appeal due to the constitutional prohibition against double jeopardy.

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    © All Rights Reserved
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    People v.

    De Leon
    G.R. No. 197546 (March 23, 2015)

    Topic: Rule 117: Motion to Quash (double jeopardy)

    Facts: The RTC did not find the accused guilty of the crime of robbery with homicide as charged in the
    Information, but found all the accused guilty of the crime of murder. According to the RTC, contrary to the
    charge of robbery with homicide, the accused is guilty of the crime of murder because the prosecution
    failed to establish the crime of robbery. The RTC, citing People v. Nimo, ratiocinated that in order to
    sustain a conviction for robbery with homicide, robbery must be proven as conclusively as the killing itself.

    On the other hand, the Court of Appeals affirmed with modifications the ruling of the RTC and found all of
    the accused guilty of the crime of murder. However, contrary to the findings of the RTC with regard to the
    crime of robbery, the Court of Appeals reversed the ruling of the RTC and found accused Danilo guilty of
    the separate crime of robbery. We find that the appellate court erred for violating the constitutional right of
    Danilo against double jeopardy as enshrined in Section 21, Article III of the 1987 Constitution.

    Issue: Whether or not the appellate court erred for violating the constitutional right of Danilo against
    double jeopardy

    Held: Yes

    Ratio: Double jeopardy attaches if the following elements are present: (1) a valid complaint or information;
    (2) a court of competent jurisdiction; (3) the defendant had pleaded to the charge; and (4) the defendant
    was acquitted, or convicted or the case against him was dismissed or otherwise terminated without his
    express consent.

    In case at bar, it is undisputed the presence of all the elements of double jeopardy: (1) a valid Information
    for robbery with homicide was filed; (2) the Information was filed in the court of competent jurisdiction; (3)
    the accused pleaded not guilty to the charge; and (4) the RTC acquitted Danilo for the crime of robbery for
    lack of sufficient evidence, which amounted to an acquittal from which no appeal can be had. Indeed the
    conviction for murder was premised on the fact that robbery was not proven. The RTC Decision which
    found accused guilty of the crime of murder and not of robbery with homicide on the ground of
    insufficiency of evidence is a judgment of acquittal as to the crime of robbery alone.

    As the first jeopardy already attached, the appellate court is precluded from ruling on the innocence or
    guilt of Danilo of the crime of robbery. To once again rule on the innocence or guilt of the accused of the
    same crime transgresses the Constitutional prohibition not to put any person "twice x x x in jeopardy of
    punishment for the same offense." As it stands, the acquittal on the crime of robbery based on lack of
    sufficient evidence is immediately final and cannot be appealed on the ground of double jeopardy. A
    judgment of acquittal is final and unappealable. In fact, the Court cannot, even an appeal based on an
    alleged misappreciation of evidence, review the verdict of acquittal of the trial court due to the
    constitutional proscription, the purpose of which is to afford the defendant, who has been acquitted, final
    repose and safeguard from government oppression through the abuse of criminal processes. The crime of
    robbery was not proven during the trial. As we discussed, the acquittal of the accused-appellant, including
    Danilo, is not reversible.

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