Obugan v. People
REITERATIONFacts
The Antecedents: Petitioner Billy P. Obugan was charged in two criminal cases with violations of Republic Act No. 6425, as amended (Dangerous Drugs Act). In one case, he was accused of selling 200 grams of marijuana, and in the other, of possessing 800 grams of marijuana dried leaves, 15 grams of flowering tops, and 3 cigarette roaches. The trial court found him guilty in both cases. Procedural History: The trial court, presided over by respondent judge, initially found petitioner guilty and sentenced him to life imprisonment for the sale and imprisonment of six years and one day to seven years for possession. Petitioner filed a motion for reconsideration, which was denied, but a subsequent motion for a new trial based on newly discovered evidence (an affidavit alleging the drugs were planted) was granted. After a trial de novo, the trial court issued an order on June 3, 1994, affirming its original decision. Petitioner received this order on June 6, 1994. He filed a motion for reconsideration of this affirming order, but on June 20, 1994, he received a notice of entry of judgment stating the January 10, 1994 decision had become final and executory. The trial court denied his subsequent motion for reconsideration and a motion to set his manifestation for hearing. The Petition: Petitioner filed a petition for certiorari seeking to set aside the orders denying his motion for reconsideration and recalling the notice of entry of judgment. The core of his argument is that when a motion for new trial is granted, the original judgment is vacated, and the period for appeal should commence from the notice of the new judgment rendered after the de novo trial. He contends that the trial court erred in deeming the original decision final and executory before his motion for reconsideration of the affirming order could be properly addressed. Petitioner also sought to be temporarily detained at the Baguio City Jail and to be allowed bail.
Issue(s)
Whether the period for appeal should be counted from the promulgation of the original decision or from the notice of the judgment rendered after a new trial was granted and conducted. Whether the transfer of the petitioner to the Bureau of Corrections was premature. Whether the petitioner is entitled to bail.
Ruling
The petition is GRANTED. The Orders dated June 20, 1994 and June 27, 1994 are SET ASIDE. Respondent court is ORDERED to recall the transfer of petitioner to the National Penitentiary and direct his detention at the Baguio City Jail pending disposition of his motion for reconsideration.
Ratio Decidendi
On the period of appeal: The Court held that petitioner's contention was meritorious. Citing Rule 121, §6(c) of the 1985 Rules on Criminal Procedure, as amended, the Court explained that when a new trial is granted, the original judgment is automatically vacated. The nullification of the original judgment is not dependent on whether the new trial results in a new or modified judgment; the mere grant of the motion for new trial operates to vacate the original judgment. Therefore, the fifteen-day period for appealing should be counted from the receipt of the new judgment rendered after the new trial. In this case, the petitioner received the order affirming the original decision on June 6, 1994, giving him until June 21, 1994, to appeal. The trial court's assertion that the decision became final on June 7, 1994, was incorrect. On the premature transfer: The Court found that the transfer of the petitioner to the Bureau of Corrections was premature. Circular No. 4-92-A mandates the immediate issuance of orders of commitment for national prisoners only after conviction, and the transfer is ordered when cases are on appeal. Since the petitioner's motion for reconsideration was still pending, his transfer before the finality of the decision was not in accordance with the circular. On the application for bail: The Court ruled that since the decision of the trial court had not yet become final, the application for bail must be addressed to the trial court.
Main Doctrine
When a motion for new trial is granted, the original judgment is automatically vacated, and the period for appeal begins to run anew from the notice of the judgment rendered after the new trial.