FACTS
Following the death of Murray Philip Williams, the Regional Trial Court appointed Denis Michael Stanley as administrator of his estate. Acting on behalf of the estate, Stanley filed criminal complaints for two counts of carnapping against William Victor Percy, alleging that Williams had entrusted two vehicles to Percy for safekeeping, but Percy refused to return them. The Office of the City Prosecutor found probable cause and filed two Informations for carnapping under the Anti-Carnapping Act. During trial, however, the RTC granted Percy's demurrer to evidence, ruling that the prosecution failed to establish all the elements of carnapping beyond reasonable doubt, thereby acquitting him.
Instead of filing a motion for reconsideration or coordinating with the Office of the Solicitor General (OSG), Stanley personally filed a Petition for Certiorari under Rule 65 before the Court of Appeals, alleging that the RTC committed grave abuse of discretion in granting the demurrer to evidence. The CA dismissed the petition for failure to acquire jurisdiction over Percy because Stanley served the petition only upon Percy's counsel and not upon Percy himself as required under Sections 3 and 4, Rule 46 of the Rules of Court, which mandate proof of service upon the respondent and require jurisdiction over the respondent's person before the court may proceed. Although Percy later filed a Comment, the CA denied reconsideration, prompting Stanley to elevate the case to the Supreme Court.
The Supreme Court likewise noted that Stanley's petition was, in substance, an attempt to overturn Percy's acquittal rather than merely question the civil aspect of the case. The petition focused entirely on proving the criminal elements of carnapping and challenged the RTC's appreciation of the prosecution's evidence. The Court emphasized that Stanley neither obtained the conformity of the OSG nor complied with the procedural requirements governing petitions for certiorari, rendering his recourse procedurally and substantively defective.
ISSUE
Whether the Court of Appeals erred in dismissing Stanley's Rule 65 petition for certiorari, and whether the acquittal of Percy may be challenged by the private complainant despite the constitutional protection against double jeopardy.
The case likewise raised the issues of whether the CA acquired jurisdiction over Percy despite service of the petition only upon his counsel, whether Stanley could directly question the RTC's order granting the demurrer to evidence without first filing a motion for reconsideration, and whether a private complainant may independently assail an acquittal without the participation of the OSG. These questions involved the application of Rules 46 and 65 of the Rules of Court, as well as the constitutional protection against double jeopardy under Section 21, Article III of the 1987 Constitution.
HELD
The Supreme Court denied the petition and affirmed the dismissal of the case. It held that the Court of Appeals correctly ruled that jurisdiction over Percy's person was not properly acquired because Stanley failed to comply with Sections 3 and 4, Rule 46 of the Rules of Court, which require service of the petition upon the respondent himself. Service solely upon the respondent's counsel was insufficient. Moreover, Stanley failed to first file a motion for reconsideration before resorting to a petition for certiorari under Rule 65, despite the well-settled rule that such motion is a condition precedent unless recognized exceptions exist, none of which were present in this case.
The Court further ruled that Stanley, as private complainant, had no authority to appeal or challenge Percy's acquittal without the participation of the Office of the Solicitor General, which exclusively represents the People in criminal appeals. The RTC's order granting the demurrer to evidence constituted an acquittal on the merits. Under Section 21, Article III of the Constitution, a judgment of acquittal is immediately final and unappealable, and any attempt to reverse it would violate the constitutional prohibition against double jeopardy. The Court stressed that a petition for certiorari cannot be used to circumvent this constitutional safeguard absent a clear showing that the trial court acted with grave abuse of discretion amounting to lack or excess of jurisdiction, which Stanley failed to establish.
Finally, the Supreme Court rejected Stanley's claim that he was merely protecting the civil aspect of the case. Examining the allegations of the petition, the Court found that it exclusively attacked the RTC's appreciation of the criminal evidence and sought the reversal of Percy's acquittal. Consequently, the petition was properly dismissed, and the acquittal remained final, immutable, and beyond judicial review in accordance with the constitutional guarantee against double jeopardy and the settled doctrine on the finality of acquittals.
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