Court of Appeals Revokes Muntinlupa RTC Acquittal
The Court of Appeals has declared null and void the Muntinlupa Regional Trial Court’s decision to acquit former Senator Leila De Lima and Ronnie Dayan of drug charges. This ruling directly challenges the previous verdict that cleared them of involvement in illegal drug activities.
The Office of the Solicitor General filed a petition for certiorari, which the Eighth Division of the Court of Appeals granted in a detailed 12-page decision. Consequently, the case has been sent back to Branch 204 of the Muntinlupa RTC for further proceedings.
Previously, on May 12, 2023, the Muntinlupa RTC acquitted De Lima and Dayan, citing the retraction of testimony by former Bureau of Corrections chief Rafael Ragos. The court found that Ragos’s withdrawal of his statements created reasonable doubt about their alleged involvement in the illegal drug trade inside the New Bilibid Prison.
Legal Grounds for Overturning Acquittal
Despite this, the Court of Appeals noted critical flaws in the Muntinlupa RTC’s decision. For instance, when the prosecution moved to reverse the acquittal on July 6, 2023, the trial court denied this motion, stating that “Every acquittal becomes final immediately upon promulgation and cannot be recalled for correction or amendment.” However, the appellate court disagreed, pointing out that the basis for acquittal was solely the retraction by witness Ragos.
The court emphasized that the trial court failed to explain which parts of Ragos’s testimony were retracted or how those retractions affected the proven facts. Moreover, it did not clearly identify which specific elements of the crime were left unproven.
Trial Court’s Oversights
- The Muntinlupa RTC did not specify the exact statements Ragos recanted.
- It failed to explain how these retractions impacted the evidence presented by the prosecution.
- The court neglected to point out which crime elements lacked proof.
Such omissions, the Court of Appeals said, violate the fundamental right to due process. “Indeed, elementary due process demands that the parties to a litigation be given information on how the case was decided, as well as an explanation of the factual and legal reasons that led to the conclusions of the court,” the appellate court stated.
Constitutional Mandate and Abuse of Discretion
The Court of Appeals further remarked that the case is not a mere issue of misappreciating evidence. Rather, it reflects a clear disregard for the constitutional duties the trial court must uphold in its rulings.
Failing to comply with these requirements amounts to a grave abuse of discretion, which in turn results in either lack or excess of jurisdiction. Because of this, the Court of Appeals found sufficient grounds to nullify the acquittal and remand the case for proper resolution.
While the legal battle continues, this decision reiterates the importance of thorough judicial reasoning, especially in cases with significant public interest and complex evidence.
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