SC acquits cop in Maguindanao massacre case, cites double jeopardy



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A police officer accused as an accessory in the 57-count murder case stemming from the 2009 Maguindanao massacre has been acquitted by the Supreme Court, which ruled that the Court of Appeals (CA) violated his constitutional right against double jeopardy when it reversed his acquittal.
In a 5 February 2026 decision written by Associate Justice Alfredo Benjamin Caguioa, the Supreme Court's Third Division reinstated the ruling of the Quezon City Regional Trial Court (RTC) acquitting SPO2 Badawi Bakal, then chief of police of Ampatuan, Maguindanao.
Bakal had been accused of manning a checkpoint during the massacre and threatening witnesses.
The Court held that the CA's reversal of the acquittal placed Bakal in double jeopardy because the RTC had already acquitted him after finding reasonable doubt following a full trial.
The justices ruled that the prosecution was not denied due process and that there was no sham trial.
The Court noted that a valid information had been filed against Bakal before a court of competent jurisdiction, that he had been arraigned and entered a plea, and that he was subsequently acquitted.
The Supreme Court emphasized that it adheres to the "finality-of-acquittal" rule, which protects an accused from being prosecuted more than once for the same offense.
While exceptions exist, such as when the prosecution is denied the opportunity to present evidence or when the trial is a sham, the Court said neither circumstance was present in Bakal's case.
"On the contrary, what is extant from the facts of the case is that the People was given all the opportunity to present its evidence, to argue its case before the trial court, and to confront the witnesses of the defense," the ruling stated.
The Court also rejected the prosecution's argument that the RTC grossly misapprehended the evidence.
It ruled that such allegations do not establish caprice or arbitrariness that would amount to grave abuse of discretion.
"As such, there can be no grave abuse of discretion on the part of the RTC, which would warrant a reversal of the acquittal of SPO2 Bakal," the Court said.
"Just because the People disagree with how the RTC weighed the prosecution's evidence does not mean that it was deprived of due process. No party to a litigation has a vested right in a favorable decision," it added.
The Supreme Court further noted that the petition filed before the CA merely alleged that the RTC selectively appreciated the evidence and misapprehended incriminating facts.
However, it stressed that these claims do not satisfy the narrow scope of a Rule 65 petition, which is limited to determining whether a court committed grave abuse of discretion—not whether it erred in appreciating the evidence.
The Court said prosecutors could not simply claim that the RTC disregarded their evidence to justify overturning an acquittal.
"No matter how egregious the RTC may have been in disregarding the prosecution's evidence, this will only amount to an error in judgment and will not rise to the level of an error in jurisdiction, absent the element of caprice, whimsicality, arbitrariness, or despotism. To hold otherwise would dangerously throw open a Rule 65 review of acquittal for every assertion of gross misapprehension of facts," the Court said.
The Court added that allowing such challenges would undermine the constitutional protection against double jeopardy, whose primary purpose is to give an accused "repose" from the burdens of repeated prosecution.