People v. Court of Appeals, Isidoro Concon and Inocencio Crisostomo
REITERATIONFacts
The Antecedents: Private respondents Isidoro Concon and Inocencio Crisostomo, along with eight co-accused, were convicted by the Circuit Criminal Court of Manila for violation of Section 3602 of Republic Act No. 1937, as amended by Republic Act No. 4712. They were sentenced to an indeterminate penalty and a fine. All convicted accused appealed to the Court of Appeals (CA). The CA, in a Decision dated July 13, 1978, affirmed the conviction of private respondents and others, while acquitting some. Procedural History: Private respondents filed several motions for reconsideration with the CA. Their first motion was denied on February 14, 1979. Their second motion was denied on June 27, 1979. They received this denial on July 11, 1979. The fifteenth day from receipt was July 26, 1979. On July 27, 1979, one day late and without prior leave, they filed a Third Motion for Reconsideration. This was denied on August 20, 1979. They received this denial on August 22, 1979. On September 5, 1979, they filed a Motion for Leave to file a Fourth Motion for Reconsideration. On November 12, 1979, the CA denied this motion, stating the judgment had become final on August 23, 1979. On March 14, 1980, the CA reconsidered its denial and set aside the denial of the Motion for Leave to File Fourth Motion for Reconsideration. On April 18, 1980, the CA admitted the Fourth Motion for Reconsideration. On July 3, 1980, the CA issued a Resolution acquitting private respondents. The Petition: The People of the Philippines, through the Solicitor General, filed a Petition for Certiorari with the Supreme Court, seeking to nullify the CA's Resolution of acquittal dated July 3, 1980, alleging that the CA acted without or in excess of jurisdiction or with grave abuse of discretion because the judgment of conviction had already become final on July 26, 1979.
Issue(s)
Whether the Court of Appeals acted without or in excess of its jurisdiction or with grave abuse of discretion when it entertained and granted the private respondents' Fourth Motion for Reconsideration; and whether the judgment of conviction dated July 13, 1978, had become final and executory prior to the filing of the Third and Fourth Motions for Reconsideration. Whether the arguments of election of remedies, simultaneous appeals, double jeopardy, timeliness of motions, and invocation of justice for the innocent are tenable in this case.
Ruling
The Supreme Court granted the Petition for Certiorari. The Resolution of acquittal dated July 3, 1980, of the Court of Appeals, as well as all proceedings and Resolutions issued subsequent to July 26, 1979, the date the judgment affirming conviction became final and executory, is declared null and void. The Court of Appeals is ordered to remand the records to the court of origin for execution of the final judgment of affirmance of conviction.
Ratio Decidendi
On the issue of jurisdiction, finality of judgment, and timeliness of motions: The Supreme Court held that the judgment of conviction affirming the trial court's decision had become final on July 26, 1979. Private respondents received the Resolution denying their Second Motion for Reconsideration on July 11, 1979, giving them until July 26, 1979, to appeal by certiorari to the Supreme Court. Their Third Motion for Reconsideration was filed on July 27, 1979, one day late and without prior leave of court, violating Section 15, Rule 124 of the Rules of Court. The Court emphasized that public policy demands that judgments become final at a definite date. The Court found that both the Third and Fourth Motions for Reconsideration were filed beyond the reglementary period. The extension granted by the Supreme Court for filing a Petition for Review was not a grant of a similar period for filing a Motion for Reconsideration with the Court of Appeals, nor could it confer jurisdiction upon the Court of Appeals when it had already lost it. On the arguments of election of remedies, simultaneous appeals, double jeopardy, and invocation of justice for the innocent: The Court rejected the argument that rights exercised in the Supreme Court could be exercised in the Court of Appeals simultaneously, clarifying that a party cannot pursue simultaneous remedies in two different forums. The filing of a Petition for Review with the Supreme Court and a Motion for Reconsideration with the Court of Appeals at the same time is not permissible. Since the Court of Appeals' Resolution of acquittal was void for having been issued without jurisdiction, it was legally considered no judgment at all; therefore, no double jeopardy attaches. The Court stated that while justice for the innocent is important, it must be dispensed with balanced scales, considering the interests of society which have been wronged.
Main Doctrine
A judgment of conviction that has become final and executory can no longer be altered or modified by the Court of Appeals. Any resolution issued after finality, particularly one that acquits the accused, is void for having been issued without jurisdiction and constitutes grave abuse of discretion.