THE SUPREME Court’s recent ruling in Marilao Medical and Diagnostic, Inc. v. Dr. Jovith Royales (G.R. No. 265152, October 29, 2025) reinforces a long-standing doctrine in criminal law: an acquittal, once rendered, is final, unappealable, and immediately executory. At the core of this principle is the constitutional protection against double jeopardy, which ensures that no person shall be tried twice for the same offense.
The case stemmed from allegations of falsification of private documents filed against Dr. Royales. After the prosecution completed the presentation of its evidence, the accused filed a demurrer to evidence. A demurrer to evidence is a remedy available to the accused in a criminal case after the prosecution rests its case. It asserts that the evidence presented by the prosecution is insufficient to establish guilt beyond reasonable doubt. If the court grants the demurrer, the case is dismissed, and the accused is acquitted without having to present defense evidence.
In granting the demurrer, the Metropolitan Trial Court found that the prosecution failed to sufficiently prove Dr. Royales’ direct participation in the alleged falsification. While there may have been allegations of irregularities, the court observed that there was no clear evidence identifying the falsified documents or showing that the accused authored, possessed, or ordered their falsification. The ruling emphasized that mere ownership of a company or position within it does not automatically create criminal liability. Criminal responsibility must be established through competent proof, not presumption.
The complainant sought to question the acquittal through a petition for certiorari. However, the Supreme Court affirmed the fundamental rule that a judgment of acquittal cannot be appealed. Allowing an appeal would place the accused in jeopardy a second time for the same offense, which the Constitution expressly prohibits. The Court reiterated that the only recognized exception is when the acquittal is tainted with grave abuse of discretion. It means that the trial court acted in a capricious, arbitrary, or whimsical manner equivalent to lack of jurisdiction or denial of due process. In this case, the High Court found no such grave abuse.
The decision also clarified a procedural matter regarding who may represent the State in criminal proceedings before the Regional Trial Court. The Court explained that the provincial or city prosecutor may represent the State in petitions filed at that level, and that the absence of participation by the Office of the Solicitor General is not automatically fatal. This clarification provides important guidance for litigants and lower courts navigating post-acquittal remedies.
Beyond the technicalities, the ruling underscores a core tenet of criminal justice: the burden of proof rests entirely on the prosecution. The presumption of innocence is not a mere formality but a substantive right. Courts must acquit when evidence falls short of the constitutional threshold of proof beyond reasonable doubt.
By affirming the finality of acquittals via demurrer to evidence, the Supreme Court reinforces the balance between the State’s authority to prosecute and the individual’s right to liberty. The doctrine protects citizens from repeated litigation and preserves public confidence in the fairness and stability of judicial decisions./PN
