G.R. No. 205275 . June 28, 2022
Mamerto Austria, Petitioner, vs. AAA and BBB, Respondents. (Concurring Opinion of Justice Caguioa)

FACTS

The Regional Trial Court (RTC) initially convicted Mamerto Austria of five counts of Acts of Lasciviousness. He timely filed a motion for reconsideration. Before the original judge could rule, he was appointed to the Court of Appeals. An executive judge took over and issued a Joint Order acquitting Austria. This Order merely summarized the arguments in Austria’s motion and memorandum, and contained a single-paragraph dispositive portion stating the prosecution failed to overcome the presumption of innocence.
The private complainants filed a petition for certiorari with the Court of Appeals, arguing the Joint Order violated Section 14, Article VIII of the Constitution , which mandates that decisions must state clearly and distinctly the facts and the law on which they are based. The CA granted the petition, annulled the void Joint Order, and reinstated the original conviction. Austria elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals correctly annulled the RTC’s Joint Order of acquittal for being constitutionally infirm.

RULING

Yes, the Court of Appeals is affirmed. The ponencia, with which Justice Caguioa concurs, correctly denies Austria’s petition. The core legal principle is that a judicial order or decision that fails to comply with the constitutional mandate under Section 14, Article VIII is void. This provision requires courts to state clearly and distinctly the facts and the law upon which a judgment is based. It is a fundamental component of due process, ensuring parties are informed of the rationale behind a ruling and serving as a check against arbitrary judicial action.
The RTC’s Joint Order was patently deficient. It did not contain any discussion of the prosecution’s case, an evaluation of the evidence, an application of law, or a reasoned explanation for reversing the conviction. It merely listed the defense’s arguments and abruptly concluded with an acquittal. This defect renders the order a nullity. Jurisprudence, such as People v. Lizada and Velarde v. Social Justice Society, consistently holds that such constitutionally infirm decisions are void ab initio—they are legally non-existent and cannot attain finality.
Consequently, the acquittal conveyed by the void order is itself invalid. Therefore, remanding the case to the RTC for a proper resolution of the still-pending motion for reconsideration does not violate the right against double jeopardy. Jeopardy attaches only upon a valid acquittal or conviction. Since the Joint Order was void from the beginning, no valid acquittal ever occurred to terminate the first jeopardy. The legal effect is that the motion for reconsideration remains unresolved, and the RTC must resolve it anew in a manner that complies with constitutional standards.