Argel v. Pascua
Argel v. Pascua
Facts:
Argel alleged in his complaint that Judge Pascua rendered a decision convicting him of murder
notwithstanding the fact that he had already been previously acquitted by Pascua in her Decision.
Argel contends that respondent is guilty of gross ignorance of the law and of violation his constitutional
right against double jeopardy.
Pascua acquitted Argel of murder because she erroneously thought that there was no witness that could
have identified the accused. Her mistake was brought about by the fact that the testimony of the
eyewitness was not attached to the records at the time she wrote her decision. After reviewing, she
revised her decision finding Argel guilty of murder. Pascua ordered the police to bring Argel to court to
inform him of his liabilities arising from the crime.
Argel charged Pascua with gross negligence for not exercising extreme caution in the preparation of her
decision by making sure that all the transcripts of stenographic notes were attached to the records
before writing the decision.
Ruling: Yes.
Ratio: Except to correct errors which are clerical in nature, to clarify any ambiguity caused by an
omission or mistake in the dispositive portion, or to rectify a travesty of justice brought about by a
moro-moro or mock trial, a final decision is the law of the case and is immutable and unalterable
regardless of any claim of error or incorrectness. In criminal cases, a judgment of acquittal is
immediately final upon its promulgation. It cannot be recalled for correction or amendment except in
the cases already mentioned nor withdrawn by another order reconsidering the dismissal of the case
since the inherent power of a court to modify its order or decision does not extend to a judgment of
acquittal in a criminal case.