Teodoro v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioner Amado B. Teodoro, vice-president and corporate secretary of DBT-Marbay Construction, Inc., slapped Carolina Tanco-Young, the corporation's treasurer, during a board meeting. The incident occurred after a verbal exchange where Tanco-Young questioned the propriety of a document Teodoro insisted be signed by the chairman. Tanco-Young allegedly called Teodoro a "falsifier," which allegedly provoked the slap. Tanco-Young, who was seven months pregnant, embraced her father to prevent him from confronting Teodoro. 2. Procedural History: The Metropolitan Trial Court (MeTC) found petitioner guilty of simple slander by deed and imposed a fine of P110.00. Petitioner appealed to the Regional Trial Court (RTC). While the appeal was pending and after being required to file a memorandum, petitioner moved to withdraw his appeal and paid the fine imposed by the MeTC. The RTC denied the motion to withdraw, citing that the appeal had already been perfected and the prosecution had submitted its memorandum. The RTC subsequently found petitioner guilty of grave slander by deed and sentenced him to three months of arresto mayor. The Court of Appeals affirmed the RTC decision, holding that the withdrawal of appeal was discretionary and that payment of the fine did not render the MeTC decision final, thus avoiding double jeopardy. The Court of Appeals also agreed that the slander was grave due to the offended party being a pregnant woman. 3. The Petition: Petitioner sought review of the Court of Appeals' decision, arguing he had an absolute right to withdraw his appeal and that his payment of the fine rendered the MeTC decision final, thus barring further proceedings on appeal and raising double jeopardy.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion in denying the petitioner's motion to withdraw his appeal. Whether the petitioner's payment of the fine imposed by the Metropolitan Trial Court, after perfecting an appeal, rendered the said judgment final and executory, thereby placing him in double jeopardy when the Regional Trial Court proceeded to render its decision on the appeal.
Ruling
The Supreme Court ruled that the withdrawal of an appeal is not a matter of right but lies within the sound discretion of the court. The Court affirmed the denial of the motion to withdraw the appeal, finding no grave abuse of discretion. The Court also held that payment of the fine imposed by the Metropolitan Trial Court after an appeal had been perfected does not render the decision final and executory, and therefore, the petitioner was not placed in double jeopardy by the Regional Trial Court's decision on his appeal. The Court modified the penalty imposed by the RTC.
Ratio Decidendi
On the denial of the motion to withdraw appeal: The Court held that the withdrawal of an appeal is a matter addressed to the sound discretion of the court, as provided for under Rule 122, Section 12 of the Rules of Court. In this case, the petitioner filed his motion to withdraw his appeal only after the records were with the Regional Trial Court, after he was required to file his memorandum, and after the prosecution had already submitted its memorandum. This timing indicated a potential attempt to avoid an adverse decision on appeal, particularly the possibility of a conviction for grave slander by deed, which carries a higher penalty than simple slander by deed. The RTC's denial was therefore a sound exercise of discretion to prevent an error from going uncorrected and to ensure justice for the State as well as the accused. Allowing withdrawal at that stage would have allowed an apparent error and injustice to go uncorrected. On the issue of double jeopardy: The Court reiterated that an appeal, even if it does not vacate the judgment appealed from, prevents the judgment from becoming final and executory. The perfection of an appeal stays the execution of the judgment of the lower court. Therefore, the petitioner's payment of the fine imposed by the Metropolitan Trial Court after his appeal had been perfected did not render the MeTC decision final. The appeal was still pending before the Regional Trial Court, and it was within the RTC's jurisdiction to proceed with the case and render its own judgment. Consequently, the subsequent decision of the RTC on the appeal did not constitute double jeopardy because the initial judgment had not yet become final and executory due to the pending appeal.
Main Doctrine
The withdrawal of an appeal is not a matter of right but lies within the sound discretion of the court. Payment of the fine imposed by the Metropolitan Trial Court after an appeal has been perfected does not render the decision final and executory, thus preventing double jeopardy when the Regional Trial Court proceeds with the appeal.