People v. Feliciano
REITERATIONFacts
The Antecedents: Francisco Feliciano alias Tarzan, along with Ernesto and Fidel Feliciano, were charged with murder. The case was forwarded to the Court of First Instance, where the Provincial Fiscal filed an information for murder against Francisco Feliciano only, moving for the dismissal of the charges against Ernesto and Fidel, which was granted. Procedural History: The trial was initially set for January 21, 1950, but was postponed. On March 30, 1950, the accused, through his counsel, offered to plead guilty to homicide with the mitigating circumstances of incomplete self-defense of a relative and lack of education. The Provincial Fiscal agreed that the facts tallied with the defense counsel's narration. The accused pleaded guilty to homicide, and the court, presided over by Judge Roman Campos, sentenced him to eight (8) months of prision correccional, P6,000 indemnity to the heirs of Enrique Espiloy, with subsidiary imprisonment, and costs. The accused was credited with preventive imprisonment. The order of commitment was issued, and the accused commenced serving his sentence on March 30, 1950. Subsequently, on April 10, 1950, the private prosecutor filed a motion for reconsideration, alleging he was not notified of the March 30 hearing and pointing out alleged mistakes by the fiscal. The motion was heard by Judge Jose P. Flores, who, in an order dated April 14, 1950 (promulgated April 15, 1950), set aside Judge Campos' decision and imposed an indeterminate penalty of eight (8) years, two (2) months and one (1) day of prision mayor to fifteen (15) years and four (4) months of reclusion temporal. A motion for reconsideration of this new sentence was denied. The Petition: The defendant appealed the order of Judge Flores.
Issue(s)
Whether the order of Judge Flores dated April 14, 1950, which modified the decision of Judge Campos dated March 30, 1950, was valid. Whether the court retained jurisdiction to modify its decision after the accused had commenced serving the sentence.
Ruling
The Supreme Court set aside and declared null and void the order of Judge Flores dated April 14, 1950, and declared in full force and effect the decision of Judge Campos dated March 30, 1950. The accused was sentenced to eight (8) months of prision correccional, to pay the heirs of Enrique Espiloy P6,000 indemnity, with subsidiary imprisonment in case of insolvency, and to pay one-third of the costs.
Ratio Decidendi
On the validity of Judge Flores' order: The Court ruled that Judge Flores' order dated April 14, 1950, promulgated on April 15, 1950, was issued beyond the fifteen-day period within which a court may modify its decision. This period commenced on March 30, 1950, the date of promulgation of Judge Campos' decision. The filing of a motion for reconsideration by the private prosecutor did not suspend this fifteen-day period, citing People vs. Tamayo. Therefore, the order of modification was issued after the judgment had become final. On the court's jurisdiction after commencement of sentence: The Court further held that the accused had already commenced serving the sentence imposed by Judge Campos on March 30, 1950, as evidenced by the order of commitment and the Provincial Warden's receipt. Once an accused begins to serve a sentence, the court loses its power to alter the decision, as it has become final. This principle was reinforced by the ruling in Gregorio vs. Director of Prisons. Consequently, Judge Flores could no longer alter the decision that had already become final and was being executed.
Main Doctrine
A court loses its power to modify its judgment after the lapse of the fifteen-day period from its promulgation, or once the accused has commenced to serve the sentence imposed by the original decision.