MACAPAGAL-ARROYO v. PEOPLE
MACAPAGAL-ARROYO v. PEOPLE
MACAPAGAL-ARROYO v. PEOPLE
PEOPLE
FACTS:
The Court resolves the consolidated petitions for certiorari separately filed by former President Gloria
Macapagal-Arroyo and Philippine Charity Sweepstakes Office (PCSO) Budget and Accounts Manager Benigno
B. Aguas. On July 10, 2012, the Ombudsman charged in the Sandiganbayan former President Gloria
Macapagal-Arroyo (GMA) and PCSO Budget and Accounts Manager Aguas (and some other officials of PCSO
and Commission on Audit) for conspiracy to commit plunder. Charges against Aguas and others were later
dismissed after their respective demurrers to evidence were granted, except for Uriarte and Valdes who were
at large.
Gloria Macapagal-Arroyo, the then President of the Philippines, and Benigno Aguas, then PCSO Budget and
Accounts Manager, all public officers committing the offense in relation to their respective offices. GMA and
Aguas separately filed their respective petitions for bail which were denied by the Sandiganbayan on the
ground that the evidence against them was strong.
GMA and Aguas' demurrers to plunder were denied by the Sandiganbayan after the Prosecution rested its
case against them. The duo then filed their respective petitions for certiorari, which were also denied. They had
alleged that there was sufficient evidence to show that they had conspired to commit plunder.
ISSUE:
Wheteher or not the consideration and granting of the motion for reconsideration of the State will amount to the
violation of the constitutional guarantee against double jeopardy.
HELD:
Yes. Granting the motion for reconsideration would violate the Constitutional prohibition against double
jeopardy.
Section 21, Article III (Bill of Rights) of the 1987 Constitution states:
No person shall be twice put in jeopardy of punishment for the same offense. If an act is punished by a law
and an ordinance, conviction or acquittal under either shall constitute a bar to another prosecution for the same
act.
The constitutional prohibition against placing a person under double jeopardy for the same offense bars not
only a new and independent prosecution but also an appeal in the same action after jeopardy had attached. As
such, every acquittal becomes final immediately upon promulgation and cannot be recalled for correction or
amendment. In the present case, the Court's consequential dismissal of Criminal Case No. SB-12-CRM-0174
as to the petitioners for insufficiency of evidence amounted to their acquittal of the crime of plunder charged
against them. With the acquittal being immediately final, granting the State's motion for reconsideration in this
case would violate the Constitutional prohibition.
It is cogent to remind in this regard that the Constitutional prohibition against double jeopardy provides to the
accused three related protections, specifically: protection against a second prosecution for the same offense
after acquittal; protection against a second prosecution for the same offense after conviction; and protection
against multiple punishments for the same offense.