In this regard, we reiterate that a judge’s failure to correctly interpret the law or to properly appreciate

the evidence presented does not necessarily incur administrative liability,[23] for to hold him
administratively accountable for every erroneous ruling or decision he renders, assuming he has erred,
will be nothing short of harassment and will make his position doubly unbearable. His judicial office will
then be rendered untenable, because no one called upon to try the facts or to interpret the law in the
process of administering justice can be infallible in his judgment.[24] Administrative sanction and
criminal liability should be visited on him only when the error is so gross, deliberate and malicious, or is
committed with evident bad faith,[25] or only in clear cases of violations by him of the standards and
norms of propriety and good behavior prescribed by law and the rules of procedure, or fixed and
defined by pertinent jurisprudence.[26]

([2012R74E] RE: VERIFIED COMPLAINT OF ENGR. OSCAR L. ONGJOCO, CHAIRMAN OF THE BOARD/CEO
OF FH-GYMN MULTI-PURPOSE AND TRANSPORT SERVICE COOPERATIVE, AGAINST HON. JUAN Q.
ENRIQUEZ, JR., HON. RAMON M. BATO, JR. AND HON. FLORITO S. MACALINO, ASSOCIATE JUSTICES,
COURT OF APPEALS, A.M. OCA IPI No. 11-184-CA-J, 2012 Jan 31, En Banc)

“In this regard, we reiterate that a judge’s failure to correctly interpret the law or to properly
appreciate the evidence presented does not necessarily incur administrative liability, for to hold
him administratively accountable for every erroneous ruling or decision he renders, assuming
he has erred, will be nothing short of harassment and will make his position doubly unbearable.
His judicial office will then be rendered untenable, because no one called upon to try the facts
or to interpret the law in the process of administering justice can be infallible in his judgment.
Administrative sanction and criminal liability should be visited on him only when the error is so
gross, deliberate and malicious, or is committed with evident bad faith, or only in clear cases of
violations by him of the standards and norms of propriety and good behavior prescribed by law
and the rules of procedure, or fixed and defined by pertinent jurisprudence.” (citation omitted)

“From a legal point of view, and in a very real sense, it is of no concern to the accused what is
the technical name of the crime of which he stands charged. It in no way aids him in a defense
on the merits. xxx. That to which his attention should be directed, and in which he, above all
things else, should be most interested, are the facts alleged. The real question is not did he
commit a crime given in the law some technical and specific name, but did he perform the acts
alleged in the body of the information in the manner therein set forth. If he did, it is of no
consequence to him, either as a matter of procedure or of substantive right, how the law
denominates the crime which those acts constitute. The designation of the crime by name in
the caption of the information from the facts alleged in the body of that pleading is a
conclusion of law made by the fiscal. In the designation of the crime the accused never has a
real interest until the trial has ended. For his full and complete defense he need not know the
name of the crime at all. It is of no consequence whatever for the protection of his substantial
rights. The real and important question to him is, “Did you perform the acts alleged in the
manner alleged?” not “Did you commit a crime named murder.” If he performed the acts
alleged, in the manner stated, the law determines what the name of the crime is and fixes the
penalty therefor. It is the province of the court alone to say what the crime is or what it is
named. xxx.” (citation omitted)

([2012V36] PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, versus PO2 EDUARDO VALDEZ and
EDWIN VALDEZ, Accused-Appellants, G.R. No. 175602, 2012 Jan 18, 1st Division)
“Article 8 of the Revised Penal Code provides that “[a] conspiracy exists when two or more
persons come to an agreement concerning the commission of a felony and decide to commit
it.” The ‘evidence of a chain of circumstances,’ to wit: that appellant went inside the house of
Romines to ascertain that the victim was there; that he fetched Dollendo to bring him to Ruiz;
that he gave the dipang to Dollendo to commit the crime; and that they both fled after the
stabbing, taken collectively, shows a community of criminal design to kill the victim. Evidently,
there was conspiracy in the commission of the crime. Thus:

“To be a conspirator, one need not participate in every detail of the execution; he need not
even take part in every act xxx. Each conspirator may be assigned separate and different tasks
which may appear unrelated to one another but, in fact, constitute a whole collective effort to
achieve their common criminal objective. Once conspiracy is shown, the act of one is the act of
all the conspirators. The precise extent or modality of participation of each of them becomes
secondary, since all the conspirators are principals.” (citation omitted)

([2012V28] PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, versus EDUARDO DOLLENDO AND

NESTOR MEDICE, Accused, NESTOR MEDICE, Appellant, G.R. No. 181701, 2012 Jan 18, 2nd
Division)

In People v. Carmen,[226] the accused members of the religious group known as the
Missionaries of Our Lady of Fatima – under the guise of a “ritual or treatment” – plunged the
head of the victim into a barrel of water, banged his head against a bench, pounded his chest
with fists, and stabbed him on the side with a kitchen knife, in order to cure him of “nervous
breakdown” by expelling through those means the bad spirits possessing him. The collective
acts of the group caused the death of the victim. Since malicious intent was not proven, we
reversed the trial court’s finding of liability for murder under Article 4 of the Revised Penal Code
and instead ruled that the accused should be held criminally liable for reckless imprudence
resulting in homicide under Article 365 thereof.

([2012V85] [3/4] ARTEMIO VILLAREAL, PETITIONER, VERSUS PEOPLE OF THE PHILIPPINES,

RESPONDENT., G.R. No. 151258, 2012 Feb 1, 2nd Division)

In a particular case, the accused members of the religious group known as the Missionaries of
Our Lady of Fatima – under the guise of a ‘ritual or treatment’ – plunged the head of the victim
into a barrel of water, banged his head against a bench, pounded his chest with fists, and
stabbed him on the side with a kitchen knife, in order to cure him of ‘nervous breakdown’ by
expelling through those means the bad spirits possessing him. The collective acts of the group
caused the death of the victim. Since malicious intent was not proven, the Supreme Court
reversed the trial court’s finding of liability for murder under Article 4 of the Revised Penal Code
and instead ruled that the accused should be held criminally liable for reckless imprudence
resulting in homicide under Article 365 thereof. (citation omitted)

“A judgment of acquittal sought to be reviewed on the basis of grave abuse of discretion

amounting to lack or excess of jurisdiction or on the ground of denial of due process implies an
invalid or otherwise void judgment. If either or both grounds are established, the judgment of
acquittal is considered void; as a void judgment, it is legally inexistent and does not have the
effect of an acquittal. Thus, the defense of double jeopardy will not lie in such a case.” (citation
omitted)

([2012V93E] PEOPLE OF THE PHILIPPINES, Petitioner, versus HON. SANDIGANBAYAN (FOURTH

DIVISION), IMELDA R. MARCOS, JOSE CONRADO BENITEZ and GILBERT C. DULAY,* Respondents,
G.R. No. 153304-05, 2012 Feb 7, En Banc)
“The requirements of due process of law mandate that every accused or respondent be
apprised of the nature and cause of the charge against him, and the evidence in support
thereof be shown or made available to him so that he can meet the charge x x x. COA’s failure
to furnish or show to the petitioner the inculpatory documents or records of purchases and
price levels constituted a denial of due process which is a valid defense against the accusation.
Absent any evidence documentary or testimonial to prove the same, the charge of COA against
the herein petitioner must fail for want of any leg to stand on.” (citation omitted)

([2012R92ED] [2/3] CANDELARIO L. VERZOSA, JR. (in his former capacity as Executive Director of
the Cooperative Development Authority), Petitioner, versus GUILLERMO N. CARAGUE (in his
official capacity as Chairman of the COMMISSION ON AUDIT), RAUL C. FLORES, CELSO D.
GANGAN, SOFRONIO B. URSAL and COMMISSION ON AUDIT, Respondents, G.R. No. 157838,
2012 Feb 7, En Banc)

“In rape cases, while denial and alibi are legitimate defenses, bare assertions thereof cannot
overcome the categorical testimony of the victim. In particular, the defense of alibi is weak if
wanting in material corroboration. In order to merit credibility, denial must be buttressed by
strong evidence of non-culpability. And in order for alibi to prosper, the accused-appellant
must prove not only that he was at some other place at the time of the commission of the
crime but also that it was physically impossible for him to be at the locus delicti or its
immediate vicinity.” (citation omitted)

([2012V83] PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, versus DIOSDADO TUBAT y

VERSOZA, Accused-Appellant, G.R. No. 183093, 2012 Feb 1, 2nd Division)